The European Commission recently published its proposal for guidance on the sustainability criteria for forest biomass used in energy production. The guidance should respect the sustainability criteria agreed among the European Parliament and the Council in 2018.

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Finnish Forest Industries emphasizes following viewpoints:

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Wood-based products and sustainable forest management play an important role in the European Green Deal, especially in achieving 2030 climate targets and climate neutrality by 2050. The Commission demonstrated the climate benefits of our sector already in the 2050 vision A Clean Planet for All, where the Commission communicated that products from renewable resources are much needed. Our industry delivers these products such as construction materials, pulp, packaging materials, textiles, composites, tissue papers, baking and cooking papers, bioplastics, paper and bioenergy.

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Proposed REDII implementing act does not bring climate benefits nor stable operating environment for businesses.

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Proposed REDII implementing act does not bring climate benefits nor stable operating environment for businesses. Operational guidance should not go beyond REDII mandate. Instead of guidance, the draft creates substantive forest legislation that should be under Member State competence. Forestry has its own set of legislation on national level taking into account national circumstances. Forestry should not be regulated by EU’s energy legislation. Publicizing the Navigant study would be especially useful for understanding the factual basis of the current proposal.

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Delaying investments is bad news for the climate as it hinders the renewing of the industry.

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The sustainability criteria should be implemented as agreed in the REDII since for wood processing industry the last 15 years have been time of instability due to unclarity about the sustainability rules. Now with the recently agreed and soon implemented REDII rules, both forest owners and the industry should be given an opportunity to make investments without a risk that rules will suddenly change. Delaying investments is bad news for the climate as it hinders the renewing of the industry.

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While the Commission proposal comes late of original timetable, there is still time to adjust the guidance to better match the needs of the forest sector. The FFIF encourages the Commission and the Member States to do their best in finding solutions that are useful for operators and the MS authorities.

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