We acknowledge the requirement for Member States to rely on clear sustainability criteria in their production of both biofuels and bioliquids. This should include environmental and biodiversity criteria, such as land protection. We welcome the added consideration for the real greenhouse gas emissions (GHG) savings of biofuels and bioliquids, which includes a more detailed accounting methodology to calculate GHG savings. A key priority remains to ensure that sustainability criteria for bioenergy production are sufficiently robust and harmonised at EU level. They also need to be verifiable and enforced.
This is why ECOS regrets the predominant reliance on voluntary international and national certification schemes to verify compliance with requirements for bioenergy production, and to promote best practices. Such voluntary schemes cannot be used as a sole tool to guarantee compliance with sustainability and GHG saving criteria. More stringent compliance mechanisms should be set.
ECOS welcomes the EU’s long-awaited step towards phasing out the use of food-based biofuels. This is done by excluding those biofuels and bioliquids that do not fulfil the sustainability and GHG emissions saving criteria from counting towards the European renewable energy target. We believe this is essential to minimise overall indirect land use change impacts of bioenergy production, and to focus on the development of truly advanced biofuels. Still, we look forward to the Commission’s use of implementing acts, including adequate standards, to ensure that compliance with the sustainability and GHG emissions saving criteria is verified in a harmonised manner.