Comment: Cornerstones for a National Biomass Strategy (NABIS)

From the UFOP's point of view, there is already an extensive regulatory framework in the area of energy use of the various types of biomass, but there is a need for action in the material use of renewable raw materials

In a joint press release, the Federal Ministry of Economics and Technology, the Federal Ministry for the Environment, Nature Conservation and Nuclear Safety and the Federal Ministry for Food, Agriculture and Consumer Protection have announced the key points of the “Biomass Strategy” announced in the coalition agreement.

The key points paper is the basis for further coordination between the above-mentioned ministries as well as business and environmental associations. The prioritisation announced in the coalition agreement – “food first, material use before energy use” – is the central guideline for the coordination processes carried out in the coming months to develop a biomass strategy. The participation of the business and environmental associations is envisaged, and the final biomass strategy is to be adopted by the Federal Government in spring 2023. 

The „key issues paper“ is therefore the basis not only for the above-mentioned federal ministries, but also for the agriculrure and forestry sector (bioenergy associations – BBE) concerned as a guideline for further discussion and internal coordination. Against this background, the UFOP had called for the development of a biomass strategy among the trade associations concerned in the BBE. This process has now begun. From the UFOP’s point of view, the issues listed in the key issues paper must be taken into account. With regard to the content of the key issues paper, it should be noted that some statements and observations are made without any connection to “material or energy” use, e.g. p. 2: “agricultural land and marine ecosystems are already being overexploited globally today”.

This fundamental statement is correct from a global perspective, but it is not appropriate to derive a cascade use from it. The key issues paper consistently fails to address the regulations already in place to limit the use of the biomass potential. These include, for example, the intensively discussed cap on biofuels from cultivated biomass, the existing technical legislation restricting cultivation at national and EU level, as well as the intensively discussed requirements resulting from the national implementation (strategy plans) of the CAP and the Renewable Energy Directive (RED II / III).

Against this backdrop, the overarching goal that the biomass strategy should contribute to the medium and long-term sustainable use of resources as well as to climate and biodiversity protection and that the appropriate framework conditions should be created for this purpose is expressly emphasised below. From the UFOP’s point of view, there is already an extensive regulatory framework in the area of energy use of the various types of biomass, but there is a need for action in the material use of renewable raw materials. This concerns the regulatory framework that needs to be adapted for market access (e.g. bio-hydraulic oils: application requirements and adaptation of tender conditions) and sustainability certification, which, in contrast to biofuels, is not yet regulated by law for material use, but is based on certification requirements developed and introduced voluntarily by industry (ISCC plus / REDcert2). Against this background, the efficiency effects of the national GHG quota regulation are not taken into account, which significantly determine the raw material composition of the biofuels counted and are the subject of an annual comprehensive report by the Federal Office for Agriculture and Nutrition

At the same time, the complexity becomes clear with regard to the guiding principles described in the key issues paper from p. 4 onwards. The basis should and must be an analysis of the sustainably available biomass potential. In the UFOP’s view, there are sufficient studies by the ministries of agricualture and economy that can serve as a basis for further coordination. However, the overall effect of cultivation and use must be classified and considered objectively and holistically, e.g. if the raw material production in crop rotation systems is considered holistically rather than the individual crop and its cultivation potential.

The 10 + 10 protein strategy of the UFOP is also a strategic approach in this context that should be taken into account in the development of the biomass strategy. In this context, the UFOP has repeatedly emphasised that the biomass strategy, against the background of the BMEL’s arable farming strategy, must be developed as a “cultivation strategy” in order to achieve the greatest possible synergy effects, e.g. with the production of plant protein for animal and human nutrition from oil and protein plants. This would also contribute to the overall ecological effect described in the key issues paper (reduction of import requirements). Consequently, the existing strategies (arable farming and protein crop strategy) must be developed together and the need for support must be identified.

Otherwise, developing a biomass strategy solely taking into account the end use and its prioritisation would miss the goal of achieving positive effects on the overall ecology, which is also outlined in the key issues paper. Against this background, the UFOP is eagerly awaiting the content and structure of the vote on a biomass strategy. Whether this can be achieved by the announced interministerial working group alone is questionable in view of the variety of factors to be taken into account. The planned involvement (see 5. Implementation, p. 10) of relevant actors is therefore necessary, especially since not only the requirements for cultivation, but especially for energy and above all material use (technical and regulatory non-technical obstacles) must be taken into account. 

The planned involvement of representatives of the Bioeconomy Council is fundamentally to be welcomed because, in the view of the UFOP, the bioeconomy and biomass strategy must be appropriately coordinated with regard to the raw material production and use areas to be discussed, on the one hand in order to promote the technical exchange on biomass use and, on the other hand, to avoid duplication of work.


UFOP, press release, 2022-10.


Bundesministerium für Ernährung und Landwirtschaft (BMEL)
Bundesministerium für Umwelt, Naturschutz und Nukleare Sicherheit (BMU)
Bundesverband BioEnergie e.V. (BBE)
International Sustainability & Carbon Certification (ISCC)
Union zur Förderung von Oel- und Proteinpflanzen e.V. (UFOP)


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