According to the European Commission’s Joint Research Centre1, in the EU only 45% of EU biomass goes to material use, with 55% used for bioenergy. At EPF we believe that at least 60% of this in-demand resource should be preferred for material applications, such as wood-based panels. In this respect, EPF believes it is of the utmost importance to reinforce the implementation of principles for cascading use of biomass, circularity, and resource efficiency.
The current energy crisis has critically underlined the necessity of scaling up the roll out of renewable energies. Indeed, the negative effects the energy crisis has on the energy prices and market disruptions caused by Russia’s invasion of Ukraine further increases the pressure on woody biomass. It is of greatest importance that policy makers realise that burning wood is not the solution to Europe’s energy shortages. Providing state aid to support to further biomass energy developments distorts commercial markets and deprives material markets such as wood-based panels, paper industries and others of valuable material. As well as adding value to the wood material uses keep the carbon locked up in wood in some cases for many decades, after which it can either be recycled for another use phase or if not possible the energy can then be recovered. Wood is too valuable to squander by burning in the first instance.
In this respect, EPF calls for the necessity to maintain all references to the cascading principle and the waste hierarchy under Art.3 of the Directive. Enshrining the cascading principle is especially important given current supply chain difficulties and material shortages. The retention of the cascading use of wood in RED III, in line with the EC guiding principles of sustainability, resource efficiency, circularity, new products or markets, and subsidiarity is vital to avoid market distortions and ensure the security of supply of raw materials for the industry.
Furthermore, to meet the objectives of climate neutrality, it is important to enhance the sustainability criteria under Art.29 of the Directive to reduce early energy recovery, restore sustainable carbon cycles and increase carbon removals in circular and climate positive harvested wood products. It is essential that subsidies for bioenergy should not create market distortions for raw materials especially for woody biomass and prevent that high quality wood is diverted to energy markets, with associated negative impacts on resource efficiency, biodiversity and sustainable carbon sinks.
Therefore, EPF calls upon the negotiators to bear in mind the above when finalising trilogue negotiations. In the words of Professor Hans Joachim Schellnhuber, founding director of the Potsdam Institute for Climate Impact Research and keynote speaker at the recent NEB Into The Woods conference held in the presence of EC President Mrs Ursula von der Leyen: “Currently in Europe we are burning 50% of the wood that is harvested. Wood is too precious to be burned. We are burning the book of life before we have studied it”.
7 December 2022
European Panel Federation
Rue Montoyer 24, 1000 Brussels, Belgium
EU Transparency Register: 572064811767-22 – IBAN: BE33 4268 1660 1346 – VAT: BE 0464.722.149