As previously communicated, on 14 July 2021 the European Commission published a Fit for 55 package, aiming to strengthen the increased overall climate ambition for 2030 of cutting emissions by 55% and ultimately reaching net zero emissions by 2050. The package consists of several legislative proposals, including the amendment to the renewable energy directive (RED).

As noted in EUSTAFOR’s initial comments, the new proposal, the so-called RED III, includes the following important changes:

  • Extension of agricultural biomass criteria for “no-go areas” to forest biomass (including primary, highly biodiverse forests and peatlands)
  • Introduction of the “biomass cascading use principle.”

Establishing no-go areas has, until now, only applied to agricultural biomass. The proposal now intends to ban forest biomass from all so-called “highly biodiverse” forests, that will, as explained by the Impact Assessment, include all types of protected forests.


Following its publication, the Commission was asking for feedback on the new proposal via a public consultation. As explained in EUSTAFOR’s input to the consultation, applying the existing no-go areas to forest biomass is conceptually wrong. It ignores the fact that almost every tending or harvest operation results in biomass removal from forests, entailing a certain amount of wood suitable only for bioenergy use. This includes management of protected forests as well. Furthermore, the cascading principles could be troublesome for many reasons. Namely, any rigid application of the biomass cascading principle that neglects other important dynamics, such as local demand, risks undermining the efficiency of forest-based value chains and ultimately risks the suboptimization of the value of biomass. To reach the targets for the reduction of waste set out in the EU’s Circular Economy Package, EU policies should aim to improve the flow of materials and residues within and between different industries and users, allow for a more efficient use of available biomass resources, and to “close the loop” of product lifecycles. Compulsory rules that limit market access or impose a cap on the use of biomass in certain industry sectors risk reducing the competitiveness of the whole sector and might well hinder technological advances.


The proposal follows the ordinary legislative procedure set out under the Lisbon Treaty. Therefore, it was sent to the European Parliament and the Council for examination.

European Parliament

Rule 57 (“Associated Committee”) of the European Parliament’s Rules of Procedure applies to this proposal. Under Rule 57, the European Parliament’s ITRE Committee (Lead) and ENVI Committee (Associated) work in close cooperation.

ITRE Committee (Lead): MEP Markus Pieper (Germany, EPP) is the rapporteur who will begin preparing the draft Report, containing proposed amendments to the proposal. The draft report will then be discussed by the Committee, following which MEPs may submit amendments to the report. The Committee will subsequently vote on the draft report and amendments with a view to adopt the Parliament’s negotiating position.

ENVI Committee (Associated): ENVI will focus on provisions relating to the sustainability and GHG emissions saving criteria of biofuels. MEP Nils Torvalds (Finland, Renew) was appointed as rapporteur and will begin preparing the draft opinion, containing amendments to the proposal in the Associated Committee’s area of competence. The draft opinion would then be discussed by the Committee, following which MEPs may submit amendments.


The Slovenian Presidency’s first revised text of the for a Directive amending Directive (EU) 2018/2001 (Renewable Energy Directive) was made available on 9 December 2021.

According to the document, the proposed changes made in the text reflect discussions held in the Council to this point. However, text not changed in this revision does not equate to acceptance of the text as is. Rather, the Presidency decided not to address some provisions at this time. The Working Party on Energy discussed the proposal on 13 December 2021. Council experts are expected to continue to meet over the coming months and examine the proposal, in order to prepare the Council’s internal position (General Approach).

Once both the European Parliament Committees and the Council have finalized their position on the proposal, informal negotiations with the aim of reaching a first reading agreement on the proposal are then expected to begin. Any resulting compromise would need to be approved by the European Parliament and by the Council.


EUSTAFOR will continue following and analyzing both processes and inform its membership about any necessary next steps. All relevant documents related to this topic, including EUSTAFOR’s previous contributions, are available on  EUSTAFOR’s Intranet.

Published 17/12/2021

Ms. Amila Meškin

Senior Policy Advisor

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