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Not all bioenergy will be sustainable: which activities comply with the EU taxonomy?

April 17, 2023
 min read

Electricity generation from bioenergy is one of the eligible activities identified by the EU in the taxonomy technical screening criteria. This covers construction and operation of electricity generation installations that produce electricity and/or heat exclusively from biomass, biogas or bioliquids. Biomass is plant or animal material that is used as a fuel to produce heat or energy. Activities that blend renewable fuels with biogas or bioliquids are also included under different criteria.

The inclusion of bioenergy is particularly relevant for Nordic countries like Finland and Sweden, where bioenergy meets more than a third of energy needs. In Finland, a country with huge forest resources, biomass is widely used to fuel electricity production, CHP plants and district heating.

What are the key things to know about the taxonomy criteria for bioenergy?:

·       Electricity production from bioenergy can make a substantial contribution to climate change mitigation, adaptation, and the protection and restoration of biodiversity and ecosystems.

·       Any agricultural or forest biomass used in the generation of electricity will need to comply with existing EU law on the sourcing of biomass.

·       To qualify as making a substantial contribution to the protection of biodiversity and restoration of ecosystems, there are additional requirements for biomass sourcing – including that it should not be sourced from whole trees or food or feed crops. There must also be a biomass sourcing plan in place.

·       Greenhouse gas emissions savings from the bioenergy activity will need to be at least 80% compared to a relative fossil fuel comparator.

·       An Environmental Impact Assessment must be carried out for the activity to identify potential risks along with possible mitigation or compensation measures required to protect the environment.

·       Emissions will need to be lower than the emission levels associated with the EU’s best available techniques ranges for large combustion plants.

·       If bioenergy plants are located in zones that fall below national air quality limits, measures must be in place to reduce emissions levels.


There has been some controversy over the proposed technical screening criteria for forestry, biomass, and bioenergy related activities. Some opponents have criticised the technical screening criteria as being too strict or being unclear and potentially confusing to investors. 

Finland has been a vocal critic of the EU’s forestry and biomass rules, suggesting that the rules go against the country’s national interests. Finland highlighted that “some aspects of the technical criteria for forest management are difficult to understand and open to interpretation” and that this might direct investment away from forestry and biomass, a critical part of their national energy policies. Sweden has also spoken out against the technical screening criteria, suggesting they disadvantage countries with large forest resources. 

The rules on biomass continue to be developed, and with the expected release of the updated Environmental Delegated Act this year, it remains to be seen if the criteria will be changed. 



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