Report from the Commission to the Council and the European Parliament on sustainability requirements for the use of solid and gaseous biomass sources in electricity, heating and cooling SEC(2010) 65 final SEC(2010) 66 final
Date: 2010-02-25
Institutions: European Commission
Subjects: bioenergy, electrical energy, energy efficiency, greenhouse gas, heating, management of resources, physical process, reduction of gas emissions, renewable energy, sustainable development

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EUROPEAN COMMISSION  

Brussels, 25.2.2010 
COM(2010)11 final 

REPORT FROM THE COMMISSION TO THE COUNCIL AND THE EUROPEAN 
PARLIAMENT 

on sustainability requirements for the use of solid and gaseous biomass sources in 
electricity, heating and cooling 

SEC(2010) 65 final 
SEC(2010) 66 final 

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REPORT FROM THE COMMISSION TO THE COUNCIL AND THE EUROPEAN 
PARLIAMENT 

on sustainability requirements for the use of solid and gaseous biomass sources in 
electricity, heating and cooling 

1. 

Introduction 

The  Renewable  Energy  Directive1  includes  a  sustainability  scheme  for  (a)  biofuels  for 
transport  and  (b)  bioliquids  used  in  other  sectors  (electricity,  heating  and  cooling).  Article 
17(9)  of  that  Directive  provides  that  the  Commission  should  report  by  December  2009  on 
requirements for a sustainability scheme for energy uses of biomass other than biofuels and 
bioliquids  (i.e.  solid  and  gaseous  fuels  in  electricity,  heating  and  cooling).  This  report  is 
intended to fulfil that obligation.  

In the EU, around 5% of final energy consumption is from bio-energy. The projections made 
for the Renewable Energy Road Map2 of January 2007 suggested that the use of biomass can 
be  expected  to  double,  to  contribute  around  half  of  the  total  effort  for  reaching  the  20% 
renewable energy target in 2020.  

The  growing  production  and  use  of  biomass  for  energy  purposes  already  gives  rise  to 
international trade, and this market is bound to expand in future. Most of the increased trade is 
expected  to  be  in  the  form  of  pellets,  a  type  of  solid  biomass,  generally  consisting  of 
processing  residues  from  forest  based  industries3.  Several  non-EU  countries  are  producing 
wood  pellets  specifically  for  the  European  market.  Member  States  that  are  dependent  on 
biomass imports increasingly turn to sources in other Member States or outside the EU4. 

For  biomass  produced  within  the  EU,  the  current  legal  framework  (notably  related  to 
agriculture and forest management) gives certain assurances for the sustainable management 
of forest and agriculture5. The same is true for some third countries – but others lack such a 
framework. For this reason, concerns have been expressed that an expansion of international 
trade  of  biomass  and  increasing  imports  from  third  countries  may  lead  to  the  unsustainable 
production of biomass. As a result, the main importing countries of biomass have started to 
develop  national  sustainability  requirements  for  bio-energy.  This  has  led  to  certification 

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Directive 2009/28/EC 
COM(2006)848  
The European Biomass Association (AEBIOM) estimates that by 2020 up to 80 million tons of pellets 
could be used in the EU (33 Mtoe) http://www.aebiom.org/IMG/pdf/Pellet_Roadmap_final.pdf  
The Netherlands for instance reported that approximately 30% of biomass consumed in the Netherlands 
originates  from  North  America  and  20%  from  Asia  Source:  Junginger,  Sikkema,  Faaij  "International 
bioenergy trade in the Netherlands", Special IEA Bioenergy Task 40 Issue of Biomass and Bioenergy, 
2008 
Environmental  rules  in  the  Common  Agriculture  Policy,  as  well  as  common  environmental  rules  on 
nitrates,  pesticides,  water  quality  and  protected  areas  provide  for  a  framework  for  sustainable 
agriculture  in  the  EU.  In forestry,  the  applicable  forest  laws  of  Member States  include either  specific 
regulation for obligatory reforestation after final cuttings or regulate the subject as part of sustainable 
forest management and forest management planning (source: UNECE European Forest Sector Outlook 
Studies) 

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schemes (voluntary and mandatory) in the agriculture, forestry and energy sectors which are 
not  necessarily  complementary  or  compatible6.  This  in  turn  has  led  to  calls  from  utilities, 
environmental  organisations  and  biomass  importing  countries  for  a  common  sustainability 
scheme for biomass in order to limit intra-EU cross-border barriers in setting up bio-energy 
projects.  

In  its  analysis  of  requirements  for  extending the EU sustainability scheme,  the Commission 
has considered three principles which a European-wide policy on biomass sustainability has 
to meet:  

– 

– 

– 

effectiveness in dealing with problems of sustainable biomass use,  

cost-efficiency in meeting the objectives and  

consistency with existing policies.  

The  Commission  has  also  further  reflected  on  whether  or  not  it  is  necessary  to  propose 
binding or voluntary policy measures at this stage, and this is outlined in this report. 

Section  2  of  the  report  will  cover  the  main  sustainability  issues,  and  section  3  will  make 
recommendations for actions to be taken. The accompanying impact assessment7 assesses all 
the issues in more detail.  

2. 

Sustainability  issues  for  solid  and  gaseous  biomass  in  electricity,  heating  and 
cooling 

This section evaluates the main sustainability issues identified during the public consultation 
carried  out  in  July-September  2008  and  in  the  accompanying  impact  assessment,  bearing  in 
mind  the  need  for  consistency  with  the  sustainability  scheme  adopted  for  biofuels  and 
bioliquids under the Renewable Energy Directive.  

Solid and gaseous biomass originates from agricultural crops and residues (e.g. maize, wheat, 
straw,  animal  manure),  from  forestry  (e.g.  logs,  stumps,  leaves  and  branches)  wood-
processing  industries  (bark,  off-cuts,  wood  chips,  sawdust)  and  from  organic  waste  (e.g. 
municipal solid waste, post consumer recovered wood, refuse-derived fuels, sewage sludge). 
It  can  be  virtually  any  organic  material.  Many  of  these  feedstocks  can  also  be  used  for 
producing transport biofuels or bioliquids used in electricity, and heating and cooling.  

2.1. 

Sustainability in production (land management, cultivation and harvesting)  

Sustainability  related  to  biomass  production  concerns  inter  alia  the  protection  of  highly 
biodiverse ecosystems and of carbon stocks, such as those in forests. In Europe, sustainable 
agricultural production is regulated through the environmental cross-compliance requirements 

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7 

In  some  Italian  regions  for  instance,  financial  support  is  limited  to  power  plants  which  use  to  a 
significant  extent  (50  to  70%)  local  biomass,  defined  as  biomass  produced  within  a  radius  of  50  km 
from  the  power  generation  site,  whereas  in  the  Flanders  region  in  Belgium,  power  plants  are  not 
supported to use biomass coming from the region itself.  
The  impact  assessment  considered  the  need  for  sustainability  measures  in  biomass  production, 
greenhouse  gas  performance  and  energy  conversion  efficiency.  It  did  not  consider  whether  a  scheme 
should be binding or voluntary at EU level. 

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in the Common Agricultural Policy (CAP)8. Forest management is regulated at national level, 
with policy guidance through the EU Forestry Strategy and international processes such as the 
Ministerial Conference for the Protection of Forests in Europe (MCPFE). 

It is difficult to say exactly how much primary biomass directly from forestry or agriculture is 
used  for  energy  purposes.  According  to  estimations  of  an  ongoing  study  by  the  United 
Nations  Economic  Commission  for  Europe  (UNECE)9,  around  24%  of  woody  biomass  for 
energy comes from direct removals from forests and agriculture in Europe and a large share of 
biomass  comes  from  agricultural  crop  residues,  forestry  residues10,  processing  residues  and 
recovered wood11. 
Unlike  some  agricultural  crops,  including  short-rotation  coppice,  biomass  wastes  and 
processing residues are not produced specifically for use in the energy sector, but result from 
other  economic  activity  that  would  take  place  anyway12.  Saw  mills  sell  on  the  sawdust  to 
wood pellet manufacturers and manure is used to produce biogas through anaerobic digestion. 
This  is  one  of  the  reasons  why  the  use  of  biomass  for  energy  purposes  has  been  able  to 
increase in the EU, at the same time as European forests increase in area, growing stock and 
standing volume. There are also direct removals of forest and agricultural residues for energy 
purposes, such as the removal of stumps, branches and leaves or straw.  

Increased  demand  for  forestry  or  agricultural  residues  can  lead  to  reduction  of  land  carbon 
stock  in  the  soil,  for  instance,  if  too  few  residues  are  left  on  the  land.  There  are  large 
quantities of carbon in soil organic matter, which can increase or decrease depending on the 
crops or trees planted and the management regime, such as the application of fertiliser. 

At a global level, deforestation and forest degradation continue, whereas European and North 
American  forests  are  increasing.  Among  the  root  causes  for  deforestation  and  forest 
degradation  are  weak  governance  structures  for  forest  conservation  and  sustainable 
management  of  forest  resources,  in  particular  in  developing  countries13.  A  large  number  of 
countries  are  party  to  intergovernmental  initiatives  to  put  in  place  criteria  and  indicators  to 
monitor sustainable forest management, but they are not entirely based on common principles 
and criteria and do not have a mechanism for verifying compliance with the agreed principles. 
Instead,  voluntary  certification  schemes  have  been  set  up  to  verify  sustainable  forest 

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The  cross-compliance  rules  provide  for  inter-  alia  preservation  of  habitats,  biodiversity,  water 
management and use and mitigating climate change.  
UNECE/FAO Timber Section "Joint Wood Energy Enquiry (JWEE)", Presentation at the Joint Working 
Party  on  Forest  Economics 
and  Statistics,  Geneva,  31  March  –  1  April  2009, 
http://timber.unece.org/fileadmin/DAM/meetings/03-wood-energy-steierer.pdf  
Forest residues mean all raw materials collected directly from the forest whether or not as a result of 
thinning or logging activities, and they do not include residues from related industries or processing 
Recovered wood is the source with the biggest growth rate in the past two years (UNECE, FAO JWEE) 
However,  this  situation  has  changed  somewhat  during  the  economic  recession,  whereby  a  drop  in 
demand for sawnwood has resulted in whole sawlogs being converted directly to wood pellets. FAO's 
Forest 
2005: 
http://w3.unece.org/pxweb/DATABASE/STAT/Timber.stat.asp  
FAO (2009) "Small-scale bioenergy initiatives", ftp://ftp.fao.org/docrep/fao/011/aj991e/aj991e.pdf  

Assessment 

Resources 

(FRA) 

2000 

and 

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management14.  Only  8%  of  all  forests  are  certified  in  the  world  today,  compared  to  almost 
45% in the EU15. 

In  the  EU,  as  most  biomass  comes  from  European  forest  residues  and  by-products  of  other 
industries (processing residues), and as forest management governance structures are strong, 
the  current  sustainability  risks  are  considered  to  be  low.  However,  the  expected  increase  of 
demand  for  domestic  and  non-EU  biomass  feedstock  warrants  vigilance  in  how  far  and  in 
what way the expected expansion will impact on carbon stocks in forests and agricultural land 
and soils. 

2.2 

Land use, land use change and forestry accounting 

Deforestation,  forest  degradation  and  a  number  of  other  practices  can  result  in  a  significant 
loss of terrestrial carbon and/or significant changes in productivity (e.g. harvesting practices 
that result in excessive removal of litter or stumps from the forests).  

Emissions  related  to  land  use,  land  use  change  and  forestry  (LULUCF),  are  reported  by  all 
Annex  1  countries  under  the  United  Nations  Framework  Convention  on  Climate  Change 
(UNFCCC),  including  EU  Member  States,  Russia,  Canada  and  the  USA,  but  accounting 
methods  as  applied  under  the  Kyoto  Protocol  need  to  be  improved.  International  climate 
change  negotiations  are  ongoing  to  decide  accounting  methods  for  LULUCF  under  a  new 
international  agreement.  A  UN  programme  for  reducing  emissions  from  deforestation  and 
forest degradation in developing countries (REDD) is also being discussed under UNFCCC.  

LULUCF emissions can best be addressed through a general framework that accounts for both 
removals and emissions of all land uses (production of food, feed, and fibre etc.). This would 
reward  increasing  carbon  stocks,  which  is  important  to  secure  sufficient  biomass  resources 
over  time.  Proper  global  LULUCF  accounting  can  make  an  important  contribution  in  the 
context of the sustainable production of biomass.  

2.3 

Life cycle greenhouse gas (GHG) performance 

The potential environmental benefits, including in terms of GHG savings that can be obtained 
from replacing  fossil fuels with biomass sources,  are  one  of  the  main  driving  forces  for  the 
promotion of bio-energy. 

Life  Cycle  Assessment  (LCA)  is  considered  to  be  the  appropriate  method  to  evaluate  the 
GHG performance of bio-energy compared to that of fossil alternatives. The GHG balance of 
bio-energy systems differs depending on the type of feedstock, carbon stock changes due to 
land  use  change,  transport,  processing  of  the  feedstocks  and  the  conversion  technologies  to 
produce heat or electricity.  

There is no single LCA methodology. Methodological choices for LCA will have an effect on 
the measurement of the GHG performance of bio-energy. The LCA methodology for biofuels 
and bioliquids laid down in the Renewable Energy Directive was based on a careful analysis 

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Such as the Programme for the Endorsement of Forest Certification (PEFC) or the Forest Stewardship 
Council (FSC) 
COWI Consortium (2009) "Technical Assistance for an evaluation of international schemes to promote 
biomass sustainability" 

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and has been endorsed by the legislator. For consistency, it would make sense to use the same 
methodology for all types of bio-energy.  

The LCA method in the Renewable Energy Directive follows the energy chain from source to 
final  energy,  i.e.  in  the  case  of  transport  the  final  fuel.  In  the  case  of  solid  and  gaseous 
biomass  used  for  electricity,  heating  and  cooling,  the  final  energy  is  not  the  final  fuel;  it  is 
electricity,  heat  and  cooling.  To  assess  the  GHG  performance  of  biomass,  the  LCA 
methodology should be extended so that conversion of the biomass fuel to electricity, heating 
or cooling is included in the GHG emissions calculations. 

In addition, the methodology should be capable of allocating appropriate respective fractions 
of  the  GHG  emissions  coming  from  cogeneration  of  heat  and  electricity,  to  the  amount  of 
electricity  and  heat  produced.  Life  cycle  emissions  for  solid  and  gaseous  biomass  used  in 
electricity, heating and cooling can then be compared to the average EU fossil electricity, heat 
and cooling.16 

Taking these methodological points into account, figure 1 shows the typical greenhouse gas 
performance  values  of bio-energy produced from different solid biomass feedstocks. Losses 
for  energy  conversion  are  included,  based  on  assumptions  of  25%  electrical  conversion 
efficiency, and 85% thermal conversion efficiency.  

Figure 1 – Typical greenhouse gas performance of solid biomass17 

GHG savings from solid biomass used in electricity and heating

Electricity

Heat

%
s
g
n
i
v
a
s
G
H
G

)
l
e
u
f

l
i
s
s
o
f

U
E
o
t
d
e
r
a
p
m
o
c
(

100%

90%

80%

70%

60%

50%

40%

30%

20%

10%

0%

FR pellets (EU NG process fuel) 
FR pellets (EU/wood process fuel) 
FR pellets (tropical/NG process fuel)
FR charcoal (EU)
FR chips (EU)
FR charcoal (tropical)
FR chips (tropical)
FR pellets (tropical/wood process fuel)
Bagasse briquettes (NG process fuel)
wheat straw (EU)
Bagasse briquettes (wood process fuel)

Bagasse bales

Palm kernel shells

SRC pellets (EU/ NG as process fuel)
SRC chips (EU)
SRC pellets (tropical/ NG as process fuel)
SRC pellets (EU/ wood process fuel)
SRC chips (tropical)
Miscanthus
SRC pellets (tropical/ wood process fuel)

solid biomass feedstocks

Source: JRC 200918  

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For consistency, it would be desirable for similar extensions to be made to the method for bioliquids, 
since  these  are  also  used  for  the  production  of  electricity  and  heat/cooling.  Such  an  extension  would 
however require amendment to Annex V of the Renewable Energy Directive. 
FR means forest residues and SRC means short rotation coppicing 

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Where  forest  or  agricultural  residues  are  used,  the  greenhouse  gas  savings  of  European 
feedstocks are high, generally above 80% savings compared to the fossil alternative. The risk 
of not achieving high GHG savings is thus lower than the risks identified for biofuels used in 
transport,  because  the  typical  processing  steps  (e.g.  pelletisation)  generally  consume  less 
energy than the processes required to make transport biofuels. Higher emissions can occur for 
agricultural  crops  and  to  some  extent  for  short-rotation  coppice  due  to  fertiliser  use  in 
agriculture, which is not normally used in forestry.  

Where  tropical  or  subtropical  feedstocks  are  used,  in  particular  for  products  which  require 
more energy input (as in the case of charcoal), greenhouse gas emissions are typically higher 
because  processing  is  often  carried  out  using  fossil  energy  input  and  (to  a  lesser  extent) 
because of emissions from transport to the EU.  

2.4 Energy conversion efficiency 

Reducing energy consumption and increasing the efficiency of energy production are among 
the  main  energy  goals  of  the  Community.  The  energy  conversion  efficiencies  of  household 
biomass  stoves  and  boilers  vary  from  around  10-95%.  Cogeneration  (producing  electricity 
and heat) and district heating plants can achieve between 80-90% efficiency, while large scale 
power  and  waste  incineration  with  energy  recovery  achieve  between  10-35%  efficiency. 
There  is  therefore  significant  potential  for  reducing  energy  consumption  through  increasing 
efficiency.  

Considerations for energy efficiency criteria for bio-energy installations have to take account 
of the wide range of energy conversion efficiencies which are significantly influenced by size, 
feedstocks,  technology  and  end-use.  For  feedstock  where  different  conversion  processes  are 
available,  it  is  particularly  important  to  encourage  the  more  efficient  conversion  processes. 
For household boilers, policy development for common energy efficiency and environmental 
performance standards (including related to air quality) is under way under the eco-design for 
energy-using  products  directive19.  Measures  are  also  introduced  in  the  energy  labelling 
directive20, and the recast of the energy performance of buildings directive21.  

These  policy  instruments  cover  the  energy  conversion  of  (mainly)  household  stoves  and 
boilers whether they are using fossil or renewable energy feedstocks. In principle, a common 
energy efficiency policy approach for both fossil and biomass fuels is preferable, in order to 
avoid the risk of switching to fossil energy if the same standards do not also apply to fossil 
fuel  applications.  Minimum  efficiency  requirements  solely  for  bio-energy  installations  may 
lead to disincentivising the energy use of biomass waste streams which have no other use (e.g. 
sewage sludge). 

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21 

The values in figure 1 do not take into account the positive or negative greenhouse gas effects of land 
use change, but these effects should be included in assessing biomass policies. 
Directive 2005/32/EC 
Directive 92/75/EEC 
COM(2008)780,  in  particular  Article  8  related  to  minimum  energy  performance  requirements  of 
technical building systems 

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3. 

Recommendations for appropriate action to address sustainability issues 

The  sustainability  concerns  identified  in  section  2  raise  the  issue  of  (1)  at  what  level  is  it 
appropriate for action to be taken and (2) what should the content of the action be? 

3.1. 

At what level should the action be taken? 

The wide variety of biomass feedstocks make it difficult to put forward a harmonised scheme 
at  this  stage.  Different  feedstocks  present  different  challenges  to  sustainable  production, 
greenhouse  gas  performance  or  efficient  energy  conversion.  It  is  also  considered  that  the 
sustainability  risks  relating  to  domestic  biomass  production  originating  from  wastes  and 
agricultural and forestry residues, where no land use change occurs, are currently low. 

For these reasons, the Commission does not at this stage propose binding criteria at EU level. 
However, to minimise the risk of the development of varied and possibly incompatible criteria 
at  national  level,  leading  to  varying  degrees  of  mitigation,  barriers  to  trade  and  stifling  the 
growth of the bio-energy sector (and imposing increased costs on Member States for meeting 
their national targets), the Commission hereby makes recommendations to Member States on 
the development of their sustainability schemes.  

3.2 

Recommended sustainability criteria 

The Commission recommends that Member States that either have, or who introduce, national 
sustainability schemes for solid and gaseous biomass used in electricity, heating and cooling, 
ensure  that  these  in  almost  all  respects  are  the  same  as  those  laid  down  in  the  Renewable 
Energy  Directive22.  This  would  ensure  greater  consistency  and  avoid  unwarranted 
discrimination in the use of raw materials.  

Due  to  the  characteristics  of  the  production  and  use  of  solid  and  gaseous  biomass  used  in 
electricity, heating and cooling, the following differences are appropriate: 

1. 

22 

According  to  Article  17(1)  of  the  Renewable  Energy  Directive,  wastes  and  certain 
residues  should only  be  required  to fulfil the requirements of  Article  17(2), i.e.  the 
greenhouse gas performance criteria. It is challenging to set greenhouse gas default 

For ease of reference, it is recalled that the sustainability criteria of the renewable Energy Directive are 
as follows: Article 17(2) establishes minimum greenhouse gas saving values of 35%, rising to 50% on 1 
January 2017 and to 60% from 1 January 2018 for biofuels and bioliquids produced in installations in 
which  production  started  on  or  after  1  January  2017.  According  to  Article  17(1)  wastes  and  residues 
only need to fulfil the minimum greenhouse gas requirements, not the other criteria. Article 17(3), 17(4) 
and  17(5)  require  that  raw  material  should  not  come  from  high  biodiversity  value  areas,  from  the 
conversion of high-carbon stock areas, or from undrained peatland, respectively. Article 17(6) requires 
that  agricultural  raw  materials  cultivated  in  the  Community  are  obtained  in  accordance  with  specific 
agricultural regulations of the EU. Article 18(1) requires that economic operators show compliance with 
the  criteria  using  the  'mass  balance'  method  for verifying the  chain of  custody.  [Compliance  with  the 
criteria  can  be  proven  in  one  of  three  ways:  (1)  EU-level  recognition  of  voluntary  schemes  which 
address one or  more of the sustainability criteria (2) through bilateral or  multilateral agreements with 
third  countries  and  (3)  by  Member  States'  national  verification  methods.]  The  consequences  of  not 
meeting  the  requirements  of  the  sustainability  scheme  are  contained  in  Article  17(1),  detailing  that 
biofuels and bioliquids which do not meet the criteria cannot be counted towards the EU's renewable 
energy  targets  or  the  targets  of  the  Fuel  Quality  Directive  (Directive  2009/30/EC)  and  national 
renewable energy obligations or benefit from financial support.  

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values for the wide range of possible feedstocks such as wastes, or common default 
values  to  cover  a  range  of  similar  feedstocks  or  a  mixture  of  feedstocks.  It  is  also 
difficult to justify imposing obligations and additional costs for proving compliance 
with  greenhouse  gas  performance  criteria,  for  sectors  which  routinely  achieve  high 
greenhouse  gas  savings  such  as  by  using  wastes.  It  is  recommended  that  the 
greenhouse gas performance criterion is not applied to wastes, but to the products for 
which  default  greenhouse  gas  emission  values  have  been  calculated  as  listed  in 
Annex II. 

The methodology for the calculation of greenhouse gas emissions should be extended 
as described in section 2.2, resulting in the methodological rules described in Annex 
I.  Default  and  typical  greenhouse  gas  performance  values  calculated  using  this 
methodology are presented for primary solid and gaseous biomass fuels in Annex II. 
The  recommended  methodology  in  Annex  I  would  require  that  the  default  value  is 
divided by the actual energy conversion efficiency value of the electricity or heating/ 
cooling installation to obtain a value for total greenhouse gas emissions.  

To  stimulate  higher  energy  conversion  efficiency,  Member  States  should  in  their 
support  schemes  for  electricity,  heating  and  cooling  installations  differentiate  in 
favour of installations that achieve high energy conversion efficiencies, such as high-
efficiency  cogeneration  plants  as  defined  under  the  Cogeneration  Directive23.  For 
small-scale  solid-fuel  boilers24,  the  Commission  is  expected  to  propose  minimum 
efficiency and environmental requirements related to air quality in 2010. 

2. 

3. 

LULUCF accounting and provisions related to REDD could help addressing land use related 
sustainability issues in third countries. As such rules are not yet in place at international level, 
and  because  of  the  relatively  higher  sustainability  risks  related  to  forestry,  the  Commission 
will closely monitor progress in this field and, by 31 December 2011, reassess the situation. In 
case  LULUCF  and  REDD  issues  are  insufficiently  addressed  at  international  level,  or  if 
countries  are  not  engaging  sufficiently  to  implement  such  rules,  the  Commission  may 
consider to introduce a procedure to address potential sustainability problems. 

3.3 

Scope of application of the criteria 

The biomass sector is fragmented and there are numerous small-scale users of biomass. It is 
recommended  that  sustainability  schemes  apply  only  to  larger  energy  producers  of  1  MW 
thermal or 1MW electrical capacity or above. Placing requirements on small-scale producers 
to  prove  sustainability  would  create  undue  administrative  burden,  although  higher 
performance and efficiency should be encouraged.  

3.4. 

Requirements for reporting and monitoring  

Biomass trade in the EU plays an important role in the development of the bio-energy sector. 
National  and  European  statistics  have  large  knowledge  gaps  concerning  the  amount  of 
biomass  used  for  energy  purposes.  In  order  to  improve  data  on  biomass  use,  it  is 

23 
24 

Directive 2004/08/EC  
All solid fuels (e.g. coal, biomass) have to be covered by energy efficiency policy in order to ensure a 
level playing field. 

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recommended  that  Member  States  keep  records  of  the  origin  of  primary  biomass  used  in 
electricity, heating and cooling installations of 1 MW or above, helping to improve statistics 
on  biomass  use  and  to  monitor  the  effects  of  biomass  use  on  the  areas  of  origin.  Member 
States  are  also  encouraged  to  monitor  small-scale  (mainly  household)  biomass  use  through 
surveys and strive to improve the availability and quality of data.  

It is recommended that the information collected by Member States is communicated to the 
Commission  so  that  the  Commission  may  take  this  into  account  in  monitoring  potentially 
vulnerable  areas.  Further  development  on  the  emergence  of  wider  sustainability  regimes 
affecting forests (e.g. sustainable forest management schemes) or other agricultural or forest 
products will be monitored, to assess whether sustainability requirements for only the energy 
uses  of  forest  and  agricultural  biomass  help  to  deliver  on  sustainable  development  for  the 
forest  and  agricultural  sectors.  The  Commission  will  also  examine  efforts  to  account  for 
global  emissions  from  land  use,  land  use  change  and  forests  under  the  United  Nations 
Framework Convention on Climate Change.  

4. 

Conclusions 

Member States are invited to take into account the above recommendations for sustainability 
criteria  and  for  reporting  and  monitoring.  These  recommendations  aim  to  promote  the 
sustainable  production  and  use  of  biomass,  a  well  functioning  internal  market  in  biomass 
trade and to lift barriers to bio-energy development. It is therefore recommended in particular 
to those Member States that have already developed sustainability criteria which differ from 
the above recommendations, to duly integrate these recommendations. In any event, Member 
States must ensure that national sustainability schemes do not constitute a means of arbitrary 
discrimination or a disguised restriction on trade.  

The  Commission  will  report  by  31  December  2011  on  whether  national  schemes  have 
sufficiently and appropriately addressed the sustainability related to the use of biomass from 
inside and outside the EU, whether these schemes have led to barriers to trade and barriers to 
the development of the bio-energy sector. It will, inter alia, consider if additional measures 
such  as  common  sustainability  criteria  at  EU  level  would  be  appropriate.  The  Commission 
will  also  report  on  how  international  climate  change  negotiations  and  other  policy 
developments including LULUCF accounting and REDD relate to the sustainable production 
of biomass, whether used for energy, food, feed or fibre.  

EN 

10 

   EN 

 
ANNEX I – Methodology for calculating greenhouse gas performance of solid and 
gaseous biomass used in electricity, heating and cooling 

1a. 

Greenhouse  gas  emissions  from the production of solid and gaseous biomass fuels, 
before conversion into electricity, heating and cooling, shall be calculated as: 

E = eec + el + ep + etd + eu - esca- eccs - eccr, 

where 

E = total emissions from the production of the fuel before energy conversion; 

eec = emissions from the extraction or cultivation of raw materials; 

el = annualised emissions from carbon stock changes caused by land use change; 

ep = emissions from processing; 

etd = emissions from transport and distribution; 

eu  =  emissions  from  the  fuel  in  use,  that  is  greenhouse  gases  emitted  during  the 
combustion of solid and gaseous biomass; 

esca  =  emission  savings  from  soil  carbon  accumulation  via  improved  agricultural 
management; 

eccs = emission savings from carbon capture and geological storage, and; 

eccr = emission savings from carbon capture and replacement. 

Emissions from the manufacture of machinery and equipment shall not be taken into 
account. 

1b. 

Greenhouse  gas  emissions  from  the  use  of solid and gaseous biomass  in  producing 
electricity, heating or cooling including the energy conversion to electricity and/ or 
heat or cooling produced shall be calculated as follows: 

For energy installations delivering only useful heat: 

EC

h

=

E
η
h

For energy installations delivering only electricity: 

EC

el

=

E
η
el

For energy installations delivering only useful cooling: 

EN 

11 

   EN 

 
 
 
 
EC

c

=

E
η
c

Where: 

ECh  = 
is heating. 

Total greenhouse gas emissions from the final energy commodity, that 

ECel  = 
is electricity. 

Total greenhouse gas emissions from the final energy commodity, that 

ECc  = 
is cooling 

Total greenhouse gas emissions from the final energy commodity, that 

= 

ηel 
divided by the annual fuel input. 

The  electrical  efficiency,  defined  as  the  annual  electricity  produced 

= 

ηh 
The thermal efficiency, defined as the annual useful heat output, that is 
heat generated to satisfy an economically justifiable demand for heat, divided by the 
annual fuel input. 

= 

ηc 
The thermal efficiency, defined as the annual useful cooling output, that 
cooling generated to satisfy an economically justifiable demand for cooling, divided 
by the annual fuel input. 

Economically  justifiable  demand  shall  mean  the  demand  that  does  not  exceed  the 
needs  of  heat  or  cooling  and  which  would  otherwise  be  satisfied  at  market 
conditions. 

For the electricity coming from energy installations delivering useful heat: 

EC

el

=

E
η
el

⎛
⎜⎜
⎝

C

el

C
η
⋅
el

η
⋅
el
el
C
+

η
⋅
h

h

⎞
⎟⎟
⎠

For the useful heat coming from energy installations delivering electricity: 

EC

h

=

E
η
h

⎛
⎜⎜
⎝

C
⋅
η
el

⋅
η
h
h
C
+

C

el

⋅
η
h

h

⎞
⎟⎟
⎠

Where: 

Cel  = 
than heat, set to 100 % (Cel = 1). 

Fraction  of  exergy  in  the  electricity,  or  any  other  energy  carrier  other 

Ch 

= 

Carnot efficiency (fraction of exergy in the useful heat).  

Carnot efficiency, Ch, for useful heat at different temperatures: 

EN 

12 

   EN 

 
 
 
 
C

h

=

T
h

T
0−
T
h

Where: 

= 

Th 
heat at point of delivery as final energy 

Temperature,  measured  in  absolute  temperature  (kelvin)  of  the  useful 

2. 

3. 

4. 

5. 

T0 

= 

Temperature of surroundings, set at 273 kelvin (equal to 0 °C) 

For Th < 150 °C (423 kelvin), Ch is defined as follows: 

Ch 

= 

Carnot efficiency in heat at 150 °C (423 kelvin), which is: 0.3546 

Greenhouse  gas  emissions  from  solid  and  gaseous  biomass  fuels  for  electricity, 
heating  and  cooling  purposes,  EC,  shall  be  expressed  in  terms  of  grams  of  CO2 
equivalent  per  MJ  of  final  energy  commodity  (heat,  cooling  or  electricity), 
gCO2eq/MJ. 

Greenhouse  gas  emission  savings  from  heat,  cold  and  electricity  being  generated 
from solid and gaseous biomass shall be calculated as: 

SAVING 

= (ECF (h,el,c) – ECh,el,c)/ECF (h,el,c), 

where 

ECh,el ,c = total emissions from the heat, cooling or the electricity; and 

ECF (h,el,c) 
electricity. 

=  total  emissions  from  the  fossil  fuel  comparator  for  heat,  cooling  or 

The  greenhouse  gases  taken  into  account  for  the  purposes  of  point  1  shall  be  CO2, 
N2O and CH4. For the purpose of calculating CO2 equivalence, those gases shall be 
valued as follows: 

CO2: 1 

N2O: 296 

CH4: 23 

Emissions  from  the  extraction,  harvesting  or  cultivation  of  raw  materials,  eec,  shall 
include emissions from the extraction, harvesting or cultivation process itself; from 
the collection of raw materials; from waste and leakages; and from the production of 
chemicals  or  products  used  in  extraction  or  cultivation.  Capture  of  CO2  in  the 
cultivation of raw materials shall be excluded. Certified reductions of greenhouse gas 
emissions  from  flaring  at  oil  production  sites  anywhere  in  the  world  shall  be 
deducted. Estimates of emissions from cultivation or harvesting may be derived from 
the use of averages calculated for smaller geographical areas than those used in the 
calculation of the default values, as an alternative to using actual values. 

EN 

13 

   EN 

 
 
6. 

Annualised emissions from carbon stock changes caused by land-use change, el, shall 
be calculated by dividing total emissions equally over 20 years. For the calculation of 
those emissions the following rule shall be applied: 

el = (CSR – CSA) × 3,664 × 1/20 × 1/P – eB, 

where 

el = annualised greenhouse gas emissions from carbon stock change due to land-use 
change  (measured  as  mass  of  CO2-equivalent  per  unit  solid  and  gaseous  biomass 
energy); 

CSR = the carbon stock per unit area associated with the reference land use (measured 
as  mass  of  carbon  per  unit  area,  including  both  soil  and  vegetation).  The  reference 
land  use  shall  be  the  land  use  in  January  2008  or  20  years  before  the  raw  material 
was obtained, whichever was the later; 

CSA = the carbon stock per unit area associated with the actual land use (measured as 
mass of carbon per unit area, including both soil and vegetation). In cases where the 
carbon stock accumulates over more than one year, the value attributed to CSA shall 
be the estimated stock per unit area after 20 years or when the crop reaches maturity, 
whichever the earlier; 

P = the productivity of the crop (measured as solid and gaseous biomass energy per 
unit area per year); and 

eB = bonus of 29 g CO2eq/MJ solid and gaseous biomass if biomass is obtained from 
restored degraded land under the conditions provided for in point 7. 

7. 

The bonus of 29 g CO2eq/MJ shall be attributed if evidence is provided that the land: 

(a) was not in use for agriculture or any other activity in January 2008; and 

(b) falls into one of the following categories: 

(i) severely degraded land, including such land that was formerly in agricultural use; 

(ii) heavily contaminated land. 

The bonus of 29 g CO2eq/MJ shall apply for a period of up to 10 years from the date 
of  conversion  of  the  land  to  agricultural  use,  provided  that  a  steady  increase  in 
carbon  stocks  as  well  as  a  sizable  reduction  in  erosion  phenomena  for  land  falling 
under (i) are ensured and that soil contamination for land falling under (ii) is reduced. 

8. 

The categories referred to in point 7(b) are defined as follows: 

(a)  "severely  degraded  land"  means  land  that,  for  a  significant  period  of  time,  has 
either  been  significantly  salinated  or  presented  significantly  low  organic  matter 
content and has been severely eroded; 

EN 

14 

   EN 

 
9. 

10. 

11. 

12. 

13. 

14. 

15. 

(b) "heavily contaminated land"  means land that is  unfit for the  cultivation of  food 
and feed due to soil contamination. 

Such land shall include land that has been the subject of a Commission decision in 
accordance with the fourth subparagraph of Article 18(4) of Directive 2009/28/EC. 

In  accordance  with  Annex  V.C  point  10  of  Directive  2009/28/EC,  the  Commission 
guidelines  for  the  calculation  of  land  carbon  stocks  adopted  in  relation  to  that 
Directive,  drawing  on  the  2006  IPCC  Guidelines  for  National  Greenhouse  Gas 
Inventories —  volume 4, shall serve as the basis for the calculation of  land  carbon 
stocks. 

Emissions  from  processing,  ep,  shall  include  emissions  from  the  processing  itself; 
from waste and leakages; and from the production of chemicals or products used in 
processing. 

In  accounting  for  the  consumption  of  electricity  not  produced  within  the  fuel 
production  plant,  the  greenhouse  gas  emission  intensity  of  the  production  and 
distribution of that electricity shall be assumed to be equal to the average emission 
intensity  of  the  production  and  distribution  of  electricity  in  a  defined  region.  By 
derogation  from  this  rule,  producers  may  use  an  average  value  for  an  individual 
electricity production plant for electricity produced by that plant, if that plant is not 
connected to the electricity grid. 

Emissions  from  transport  and  distribution,  etd,  shall  include  emissions  from  the 
transport  and  storage  of  raw  and  semi-finished  materials  and  from  the  storage  and 
distribution  of  finished  materials.  Emissions  from  transport  and  distribution  to  be 
taken into account under point 5 shall not be covered by this point. 

Emissions  from  the  fuel  in  use,  eu,  shall  be  taken  to  be  zero  for  solid  and  gaseous 
biomass. 

Emission  saving  from  carbon  capture  and  sequestration,  eccs,  that  have  not  already 
been accounted for in ep, shall be limited to emissions avoided through  the capture 
and  sequestration  of  emitted  CO2  directly  related  to  the  extraction,  transport, 
processing and distribution of fuel. 

Emission  saving  from  carbon  capture  and  replacement,  eccr,  shall  be  limited  to 
emissions  avoided through the capture of CO2  of  which  the  carbon  originates  from 
biomass  and  which  is  used  to  replace  fossil-derived  CO2  used  in  commercial 
products and services. 

Where  a  fuel  production  process  produces,  in  combination,  the  energy  carrier  for 
which  emissions  are  being  calculated  and  one  or  more  other  products  ("co-
products"), greenhouse gas emissions shall be divided between the energy carrier or 
its  intermediate  product  and  the  co-products  in  proportion  to  their  energy  content. 
For  the  accounting  of  useful  heat  as  co-product,  the  allocation  between  the  useful 
heat and other co-products shall be made using the Carnot efficiency (C), where all 
other co-products than heat has a C equal to 1.  

EN 

15 

   EN 

 
A
i

=

E
η
i

⎛
⎜⎜
⎝

C
i
+⋅
η
i

⋅
η
i
C

C

i

⋅
η
h

h

⎞
⎟⎟
⎠

Where: 

Ai 

E 

= 

= 

Allocated GHG emissions at allocation point to (co-)product i 

Total GHG emissions up to allocation point 

= 

ηi 
The  fraction  of  co-product  or  product,  measured  in  energy  content, 
defined  as  the  annual  amount  of  co-product  or  product  produced  divided  by  the 
annual energy input. 

= 

The  fraction  of  heat  produced  together  with  other  co-products  or 
ηh 
products, defined as the annual useful heat output divided by the annual energy input. 

Ci 

Ch 

= 

= 

Fraction of exergy in the energy carrier (else than heat), equal to 1 

Carnot efficiency (fraction of exergy in the useful heat). 

Carnot efficiency, Ch, for useful heat at different temperatures: 

C

h

=

T
h

T
0−
T
h

Where: 

= 

Th 
heat at point of delivery. 

Temperature,  measured  in  absolute  temperature  (kelvin)  of  the  useful 

T0 

= 

Temperature of surroundings, set at 273 kelvin (equal to 0 °C) 

For Th < 150 °C (423 kelvin), Ch is defined as follows: 

Ch 

= 

Carnot efficiency for heat at 150 °C (423 kelvin), which is: 0.3546 

16. 

For the purposes of the calculation referred  to in paragraph 15, the emissions to be 
divided shall be eec + el, + those fractions of ep, etd and eee that take place up to and 
including the process step at which a co-product is produced. If any allocation to co-
products  has  taken  place  at  an  earlier  process  step  in  the  life-cycle,  the  fraction  of 
those emissions assigned in the last such process step to the intermediate fuel product 
shall be used for this purpose instead of the total of those emissions. 

In  the  case  of  solid  and  gaseous  biomass,  all  co-products,  including  electricity  that 
does  not  fall  under  the  scope  of  paragraph  14,  shall  be  taken  into  account  for  the 
purposes  of  this  calculation,  except  for  agricultural  crop  residues,  including  straw, 
bagasse,  husks,  cobs  and  nut  shells.  Co-products  that  have  negative  energy  content 
shall  be  considered  to  have  an  energy  content  of  zero  for  the  purpose  of  the 
calculation.  

EN 

16 

   EN 

 
 
 
Wastes,  secondary  biomass  and  primary  forest  and  agricultural  crop  residues, 
including  tree  tops  and  branches,  straw,  bagasse,  husks,  cobs  and  nut  shells,  and 
residues  from  processing,  including  crude  glycerine  (glycerine  that  is  not  refined), 
shall  be  considered  to  have  zero  life-cycle  greenhouse  gas  emissions  up  to  the 
process of collection of those materials. 

In the case of fuels produced in refineries, the unit of analysis for the purposes of the 
calculation referred to in paragraph 15 shall be the refinery. 

17. 

For  solid  and  gaseous  biomass,  for  electricity  production,  for  the  purposes  of  the 
calculation  referred  to  in  point  4,  the  fossil  fuel  comparator  ECF(el)  shall  be  198 
gCO2eq/MJ electricity. 

For solid  and gaseous  biomass used for  heating production,  for the purposes  of the 
calculation  referred  to  in  point  4,  the  fossil  fuel  comparator  ECF(h)  shall  be  87 
gCO2eq/MJ heat. 

For solid and gaseous biomass used for cooling through absorption heat pumps, for 
the purposes of the calculation referred to in point 4, the fossil fuel comparator ECF(c) 
shall be 57 gCO2eq/MJ cooling. 

EN 

17 

   EN 

 
ANNEX II – Typical and default values for solid and gaseous biomass if produced with 
no net carbon emissions from land use change 

Primary solid and gaseous biomass pathways 

Typical 
greenhouse 
gas emissions 

Default 
greenhouse 
emissions  

gas 

(gCO2eq/MJ) 

(gCO2eq/MJ) 

Wood  chips  from  forest  residues  (European  temperate 
continental forest) 

1 

Wood  chips 
subtropical forest) 

from 

forest 

residues 

(tropical  and 

21 

Wood  chips  from  short  rotation  forestry  (European 
temperate continental forest) 

3 

Wood  chips  short  rotation  forestry  (tropical  and  sub-
tropical e.g. eucalyptus) 

24 

Wood  briquettes  or  pellets 
residues 
(European temperate continental forest) – using wood as 
process fuel 

forest 

from 

2 

Wood briquettes or pellets from forest residues (tropical 
or subtropical forest) – using natural gas as process fuel 

17 

Wood briquettes or pellets from forest residues (tropical 
or subtropical forest) – using wood as process fuel 

15 

Wood  briquettes  or  pellets 
residues 
(European  temperate  continental  forest)  –  using  natural 
gas as process fuel 

forest 

from 

30 

Wood  briquettes  or  pellets  from  short  rotation  forestry 
(European temperate continental forest) – using wood as 
process fuel 

4 

Wood  briquettes  or  pellets  from  short  rotation  forestry 
(European  temperate  continental  forest)  –  using  natural 
gas as process fuel 

Wood  briquettes  or  pellets  from  short  rotation  forestry 
(tropical  and  sub-tropical  e.g.  eucalyptus)  –  wood  as 
process fuel 

19 

18 

1 

25 

4 

28 

2 

20 

17 

35 

4 

22 

22 

EN 

18 

   EN 

 
Wood  briquettes  or  pellets  from  short  rotation  forestry 
(tropical  and  sub-tropical  e.g.  eucalyptus)  –  natural  gas 
as process fuel 

33 

Charcoal  from  forest  residues  (European  temperate 
continental forest) 

34 

Charcoal  from  forest  residues  (tropical  and  sub-tropical 
forest) 

41 

Charcoal 
temperate continental forest)  

from  short 

rotation 

forestry 

(European 

38 

Charcoal  from  short  rotation  forestry  (tropical  and  sub-
tropical e.g. eucalyptus) 

Wheat straw 

Bagasse briquettes – wood as process fuel 

Bagasse briquettes – natural gas as process fuel 

Bagasse bales 

Palm kernel 

Rice husk briquettes 

Miscanthus bales 

Biogas from wet manure  

Biogas from dry manure  

47 

2 

14 

29 

17 

22 

24 

6 

7 

6 

Biogas from wheat and straw (wheat whole plant) 

18 

Biogas from maize as whole plant (maize as main crop) 

28 

Biogas from maize as whole plant (maize as main crop) – 
organic agriculture 

16 

40 

41 

50 

46 

57 

2 

17 

35 

20 

27 

28 

7 

8 

7 

21 

34 

19 

EN 

19 

   EN