Bioenergia ry – the Bioenergy Association of Finland – supports consistent progress towards the 2050 climate neutrality target in setting the EU’s 2040 climate target. Despite the energy crisis and war, the EU cannot afford to jeopardize its long-term net-zero target but must proceed decisively towards it in the medium term as well. The EU’s already agreed target is a 100% emission reduction by 2050, and we note that in the impact assessment of the 2040 climate target continuing current EU actions will already lead to an approximately 88% emission reduction by 2040. However, the assessment involves many underlying assumptions and significant uncertainties. 

Bioenergia ry believes that in the 2030s, limited international trading of emission units should also be allowed in accordance with Article 6 of the Paris Agreement, and qualified units could be utilized for internal EU obligations. Enabling does not necessarily mean use, but it is an option. Therefore, we support the Commission’s proposal, which clearly allows a limited number of high-quality emission units as part of the 2040 target. In this context, we underline that that the amount of units allowed must be determined in a clear and unambiguous way, e.g. by expressing the amount in MtCO2-equivalent. As a minimum requirement, the units must meet the guidelines and quality requirements set by the parties to the Paris Climate Agreement. The proposal to limit the use of emission units to sectors outside the emissions trading system is acceptable. Enabling cooperation related to emission reductions expands the EU’s influence outside its borders and promotes the competitiveness of European business and improves the cost-effectiveness of EU climate policy by reducing the risk of very high emission reduction costs. 

Bioenergia ry supports the inclusion of permanent carbon removal solutions (BECCS, DACCS, and biochar, BCR) produced under the Carbon Removals and Carbon Farming (CRCF) certification framework in the emissions trading system. Emissions trading allows for the leveraging of private capital, and the system is familiar to market participants. There is also an already functioning and liquid secondary market in emissions trading. Additionally, integration would create incentives for promoting permanent carbon removals at the EU level, rather than building large-scale operations based on different national mechanisms. Permanent carbon removal solutions are also inherently close to the operations of the emissions trading sector. There are several mechanisms for managing the risks of delayed emission reductions, mainly by regulating supply and demand. Such mechanisms include quantitative limits on the total amount of removals included in the system or qualitative restrictions on removal methods. The inclusion of removal units should be done gradually, with limits set on the number of units, and only permanent carbon removals should be accepted into the system. 

We believe that climate and energy policy regulation for the 2030s should primarily focus on greenhouse gas emissions (compared to renewable energy, energy efficiency, sector-specific or technology-specific regulation). The functionality of emission trading mechanisms must be ensured, and their coverage should be expanded. In the 2030s, it is worth examining the conditions and possibilities for merging the EU Emissions Trading System (EU ETS) with the new emissions trading system (ETS2) starting in 2027. The possibilities of phasing out the remaining effort-sharing sector as a separate pillar of EU climate policy should be investigated and evaluated. Similarly, the functionality of the EU’s new carbon border adjustment mechanism should be monitored, and checkpoints should be set for the 2030s to ensure that EU regulation in the 2030s is fit-for-purpose, promotes global climate action, and does not jeopardize the EU’s competitiveness.