RCI Position on Sustainability Criteria

As Europe accelerates its transition to a climate-neutral economy, biomass is emerging as a crucial feedstock for the defossilisation of carbon-dependent sectors – in particular for bio-based chemicals and materials. Sustainability criteria provide assurance that the utilised biomass is sourced responsibly – but also need to be combined with incentives to facilitate a shift away from unsustainable fossil feedstocks. However, while sustainability criteria for biomass used for biofuels and bioenergy are well established through the Renewable Energy Directive (RED), there are no comparable criteria for biomass used in the chemical industry.

That’s why the Renewable Carbon Initiative (RCI) is calling on the European Commission to introduce horizontal sustainability criteria that also apply to biomass used in chemicals and derived materials. Without clear rules and incentives, this sector lacks the policy certainty needed to scale up and help deliver on the EU’s net-zero targets.

Key Messages of the Position Paper:

Biomass is essential for defossilising Europe’s industry and achieving climate neutrality, especially in sectors like chemicals and materials.

The EU must provide clear, long-term framework conditions to ensure biomass is used sustainably and competitively.

To ensure a level playing field, we propose to align the sustainability criteria for using biomass for chemicals and derived materials with the criteria already applied to bioenergy and biofuels.

While the RED criteria provide a solid foundation for agricultural biomass, further adaptations are recommended to ensure their effective application to forest biomass.

Sustainability criteria for biomass used in chemicals and derived materials can only be effective when linked to incentives (such as quotas), which are not granted/achieved if criteria are not met – as is the case in the biofuels and bioenergy sectors.

The most important criteria involve:

• Sustainable cultivation of biomass,
• Lifecycle GHG emissions, and
• Eligibility of different feedstock types (e.g. food crops, forest biomass).

We propose to adopt – with some adaptations – the RED criteria for cultivation of biomass and for GHG emissions. However, there should be no cap for producing chemicals and derived materials from primary agricultural biomass. For forest biomass, we propose clear adaptations to keep requirements realistic and implementable.

Conclusion: A Strategic Window for EU Action

With the EU already considering sustainability frameworks for bio-based packaging and product design, now is the time to close the regulatory gap for biomass in chemicals. By implementing harmonised sustainability criteria and linking them to meaningful incentives, the EU can foster a level playing field, unlock industrial innovation, and strengthen Europe’s bioeconomy — all while reducing its dependency on fossil carbon.

About the Position Paper

The position paper was conducted by the Working Group Policy of the Renewable Carbon Initiative (RCI). 

Please download the full position paper here: https://renewable-carbon.eu/publications/product/rcis-position-paper-there-is-an-urgent-need-for-horizontal-sustainability-criteria-for-biomass-in-bio-based-chemicals-and-derived-materials-in-the-framework-of-future-incentives

Disclaimer

RCI members are a diverse group of companies addressing the challenges of the transition to renewable carbon with different approaches. The opinions expressed in these publications may not reflect the exact individual policies and views of all RCI members. 

About RCI

The Renewable Carbon Initiative (RCI) is a global network of more than 70 prominent companies dedicated to supporting and accelerating the transition from fossil carbon to renewable carbon (bio-based, CO₂-based and recycled) for all organic chemicals and materials. Its work focuses on scientific background reports, position papers, advocacy and networking.

Source

Renewable Carbon Initiative, position paper, 2025-06-30.

Supplier

European Commission
Renewable Carbon Initiative (RCI)

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