Bioenergia ry – the Bioenergy Association of Finland – believes that the EU’s bio- and circular economy plans should promote development of EU’s productivity, where the Union faces significant challenges compared to competitor countries. Ideally, new bio- and circular products will increase the added value and employment of the European economy and reduce its environmental footprint. Alongside new products, which may also be partly related to energy use, sustainable bioenergy should be promoted in the EU and have a recognized role in the plans. The circular economy act must consider the objectives and needs for the rapid increase of renewable energy share and supply as well as energy security in the EU.
Bioenergia ry supports the introduction of minimum bio-based content targets for selected products. For biochar applications, such as use in construction products, growing media, and as a substitute for industrial coke, minimum content targets could be appropriate. Generally, minimum content targets for all products are not appropriate if, for example, they reduce product quality, restrict innovation, and decrease competition. The association is open to considering extended producer responsibility to promote the circular economy in the EU and its advantages and disadvantages.
The EU should not define a policy for biomass use based on priority or hierarchy with regulatory instruments. The principle of cascading use is already widely accepted, but it should not be implemented with regulation that stiffens markets. We also believe that any extensions to sustainability requirements for biomass should be based on the existing sustainability criteria in the RED3 Directive.
Circular Economy Act Consultation