Increasing policy coherence between bioenergy and clean air policies and measures : final project report.
Date: 2024-06-06
Institutions: Directorate-General for Environment
Subjects: EU law, EU policy, air quality, bioenergy, biomass, fuel wood, health risk, public awareness campaign, reduction of gas emissions, report

Increasing policy coherence 
between bioenergy and clean air 
policies and measures 

Final Project Report 

Written by Logika Group, TNO and Ineris 
March – 2024 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
EUROPEAN COMMISSION 

Directorate-General for Environment 
Directorate C — Zero Pollution 
Unit C.3 — Clean Air & Urban Policy 

Contact: Bettina Kretschmer 

E-mail:  Bettina.KRETSCHMER@ec.europa.eu  

European Commission 
B-1049 Brussels 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
EUROPEAN COMMISSION 

Increasing policy coherence 
between bioenergy and clean air 
policies and measures  

Final Project Report 

2024 

EN 

Directorate-General for Environment  

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Manuscript completed in March 2024 

1st edition 

This document should not be considered as representative of the European Commission’s official position.  

Luxembourg: Publications Office of the European Union, 2024 

© European Union, 2024 
The reuse policy of European Commission documents is implemented by Commission Decision 2011/833/EU of 12 
December 2011 on the reuse of Commission documents (OJ L 330, 14.12.2011, p. 39). Unless otherwise noted, the reuse 
of this document is authorised under a Creative Commons Attribution 4.0 International (CC BY 4.0) licence 
(https://creativecommons.org/licenses/by/4.0/). This means that reuse is allowed provided appropriate credit is given and 
any changes are indicated. 

For any use or reproduction of elements that are not owned by the European Union, permission may need to be sought 
directly from the respective rightholders.  

PDF 

ISBN 978-92-68-14908-9 

doi:10.2779/94296   

KH-02-24-446-EN-N 

 
 
 
 
 
 
 
 
 
 
 
 
 
Increasing policy coherence between bioenergy and clean air policies and measures Final Project Report 

Contents 

1 

2 

Executive Summary 

Introduction 

2.1 

2.2 

2.3 

2.4 

Project drivers and needs 

Aims of the project 

Introducing the toolbox 

Layout of the report and annexes 

3 

Stakeholder outreach 

3.1 

3.2 

3.3 

Purpose of stakeholder outreach 

Approach and structure 

Key messages from stakeholder outreach 

4 

Bioenergy Impacts on Air Quality 

4.1 

4.2 

4.3 

4.4 

4.5 

Introduction 

Approach and data sources 

Evidence for environmental impacts of bioenergy 

Variability in bioenergy emissions and impacts 

Prospects for future bioenergy uptake and impacts 

5 

EU Level Bioenergy Drivers and Policy Framework 

5.1 

5.2 

5.3 

General policy on energy, climate and the environment 

Potential legislative/policy drivers for the uptake of bioenergy 

Potential legislative and policy restrictions on the uptake of bioenergy 

6  Member State policy responses 

6.1 

6.2 

6.3 

6.4 

6.5 

6.6 

6.7 

Approach 

Data sources 

Types of measures and strategies employed 

Policy development and evaluation 

Case studies 

Analysis of measures 

Principles for successful measures 

7 

Enabling action through policy development 

7.1 

7.2 

Ecodesign Directive 

Energy Performance of Buildings Directive 

8 

Conclusions 

8.1 

8.2 

Key emerging messages 

Recommendations 

9 

Bibliography 

5 

7 

7 
7 
8 
8 

10 

10 
10 
11 

13 

13 
13 
14 
22 
30 

36 

36 
37 
38 

41 

41 
41 
41 
43 
44 
59 
63 

65 

65 
65 

66 

66 
68 

70 

11/13788A/11 

3 of 104 

28 March 2024 

Increasing policy coherence between bioenergy and clean air policies and measures Final Project Report 

10  Annexes 

Tables 

Table 4-1: Main factors influencing the emissions of a small-scale combustion appliance 

Table 4-2: Emission factor (range) for most used appliances in residential wood combustion as measured by 
Kindbom & Mawdsley (2018) 

73 

25 

27 

Figures 

Figure 4-1: Bioenergy use in EU27 in 2021, main sectors and main fuel type. The figure includes the use of liquid 
biofuels in each sector, but excludes the use of biofuels in the transport sector (source: Eurostat energy 
balances) 

15 

Figure 4-2: Per capita use of primary solid biofuels (the definition used by Eurostat for bioenergy in solid form) in 
15 
each MS and the EU27 average (source: Eurostat8) 

Figure 4-3: Main sectors contributing to bioenergy emissions in the EU27 in 2020 (source: CAO3 emission data)

Figure 4-4: Main contributing sectors, differentiating between bioenergy and other fuels, for total PM2.5 
emissions in EU27 in 2020 (source: CAO3 emission data) 

16 

17 

Figure 4-5: Alternative emission inventory of PM2.5 emissions (“Ref2”) from small-scale combustion (GNFR C) for 
2019, with and without condensables, compared to the emissions used in CAO3. Black dots represent the 
share of solid biomass in the energy mix for this sector (based on Eurostat). 

19 

Figure 4-6: Origin of bioenergy in the EU (2015), figure taken from JRC report (European Commission, 2021) 

23 

Figure 4-7: Range of emission factors for residential wood combustion reported in literature per main type and 
environmental class. Blue dots represent individual measurements, green line represent median value per 
appliance type. Adapted from Kindbom and Mawdsley (2018) 

28 

Figure 4-8: Bioenergy products included in the PRIMES Energy System model 

31 

Figure 4-9: Consumption of solid bioenergy by sector in the stationary demand (source: PRIMES scenario that 
meets the Fit for 55 targets for 2030 and climate neutrality in 2050) 

32 

Figure 4-10: Emissions of PM2.5 and selected air pollutants from bioenergy use in residential and in other sectors 
combined in the EU27 as well as share of bioenergy related emissions in total anthropogenic emissions. Source: 
33 
GAINS model results from the third Clean Air Outlook (Klimont et al., 2022a, 2022b) 

Figure 4-11: Comparison of annual mean concentrations of PM2.5 in 2015 estimated in the GAINS model in the 
standard setup and using the harmonized set of PM2.5 emission factors including condensable fraction of PM 
from Simpson et al. (2022). Difference maps (GAINS standard Efs vs GAINS with harmonized/condensable Efs) 
showing absolute (left) and relative (right) difference for 2015. 

34 

Figure 4-12: Contribution of biomass use in residential, power, and industry sectors to total population weighted 
35 
annual mean PM2.5 concentrations in the EU27 countries for 2020 and 2030 Baseline and OPT10 scenarios 

Figure 10-1: “BeReal –Firewood” – test procedure and measurements (from BEREAL final report) 

Figure 10-2: Comparability of results obtained by existing methods in relation to concentrations emitted and 
measured in ambient air (source: after Nussbaumer, 2010) 

75 

77 

11/13788A/11 

4 of 104 

28 March 2024 

 
 
 
 
Increasing policy coherence between bioenergy and clean air policies and measures Final Project Report 

1 

Executive Summary 

This  project  was  commissioned  by  DG  Environment  under  the  Air  Quality  Support  Framework,  to  assess  the 
evidence on the impacts of bioenergy use (solid biomass for heat and electricity generation) on air quality, the 
responses  by  Member  States  to  such  impacts,  and  to  support  increased  policy  coherence  at  the  EU  level  in 
relation to this issue. The specific objectives were to: 

1)  Collate, analyse and summarise evidence on the air pollution effects of biomass combustion and related 
health impacts, to assess the size of the challenge and policy trade-offs arising from this. The project included 
an  assessment  of  the  impact  of  bioenergy  emissions  on  Member  States’  ability  to  meet  EU  air  quality 
standards and air pollutants emission reduction commitments  

2)  Draw together good practice and mitigation measures implemented or under consideration by Member 
States,  regions  and  local  authorities  across  the  EU  (and  other  European  countries  such  as  Norway, 
Switzerland and the UK) for dealing with the identified trade-offs  

3)  Provide support to the European Commission to help address trade-offs between bioenergy and clean air 
objectives  through  ecodesign  and  energy  labelling,  and  in  the  context  of  the  Energy  Performance  of 
Buildings Directive 

The  project  included  an  extensive  literature  review  to  help  provide  the  evidence  underpinning  the  first  and 
second objectives. This was supplemented by a stakeholder outreach programme which included both a survey 
and  targeted  interviews.  Key  stakeholders  included  NGOs,  trade  bodies  and  representatives  from  Member 
States, cities and regions (see section 3). 

The research showed that solid biomass used for heat and energy generation is the single largest source of fine 
particulate matter (PM2.5) emissions across the EU. This is largely as a result of domestic combustion, which makes 
up around half of total emissions, and which in turn is dominated by wood fuel combustion (see section 4). PM2.5 
is the main driver of the health effects of air pollution and is thus of primary concern for air quality policy. In the 
EU, the use of bioenergy increased rapidly between 2005 and 2020, although in recent years the growth has 
levelled out, potentially due to uncertainty in policies and debates about sustainability of bioenergy1. 

A  review  of  EU  legislation  and  policy  showed  that  while  there  are  drivers  to  facilitate  the  increased  use  of 
bioenergy, particularly within the energy and climate space, there is also a well-developed body of legislation 
and  policy  to  control  air  quality.  The  two  policy  areas  are,  largely,  separate  and  distinct,  and  stakeholder 
feedback suggested a perception of mixed messaging. Other than the requirements of the Ecodesign Directive, 
measures to specifically address the air quality impacts of small-scale bioenergy use largely rest at the Member 
State level (see section 5). During the lifetime of this project, two potential areas for better harmonisation of air 
quality and climate/energy  interests with regard to bioenergy were  available and have been studied. These 
were  the  revision  of  the  Ecodesign  Directive  (2009/125/EC),  and  the  revision  of  the  Energy  Performance  of 
Buildings Directive (EPBD, 2010/31/EU). Consequently, this project has formulated recommendations on how to 
put  in  practice  an  indicator  for  PM2.5  emissions  from  buildings  under  the  Energy  Performance  of  Buildings 
Directive (Annex 1)a)i)(1)(a)(i)A7). While this is an optional indicator, it does provide a small step towards greater 
integration  of  energy,  climate  and  air  quality  considerations,  in  relation  to  domestic  use  of  bioenergy  in 
particular, at a practical level. 

The project identified  around 130 measures implemented in EU and other European countries to address the 
adverse impacts of small-scale bioenergy use (e.g. log burners, wood stoves, fireplaces and boilers) on air quality 
(see section 6). These have been classified according to four broad categories  and analysed further for their 
key features. The categories are: 

1 https://publications.jrc.ec.europa.eu/repository/bitstream/JRC130730/2022.5470_kjna31283enn.pdf 

11/13788A/11 

5 of 104 

28 March 2024 

 
Increasing policy coherence between bioenergy and clean air policies and measures Final Project Report 

•  Operational measures, aimed at improving the emissions from existing appliances (including improved fuel 

quality) 

• 

Stack  replacement  measures,  aimed  at  improving  the  emission  performance  of  installed  appliances 
through replacement with lower or zero emission alternatives 

•  Use  restrictions,  which  prevent  the  use  of  all  or  certain  categories  of  bioenergy  appliances  under  given 

conditions 

• 

Information and training 

The  analysis  of  these  measures,  assisted  by  targeted  interviews  with  some  stakeholders,  has  allowed  the 
development of a set of principles for the development of measures at Member State, regional or city level. 
These are set out more fully in section 6.7 but in summary are: 

• 

The measures need to fit the issues, i.e. the nature of bioenergy use, the location where the measures are to 
be targeted and the availability of alternative sources of heating 

•  A  variety  of  measures  is  likely  to  be  required,  at  different  administrative  levels,  to  provide  an  overall 

framework within which measures can be adapted to local circumstances 

•  Measures need to be bound together in a coherent, publicly accessible strategy, in order to make clear 

the overall intention of the policy and how the measures contribute towards it 

•  Measures need to include both suppliers and consumers, especially as a large proportion of fuel wood is 

sourced through grey or non-market routes 

• 

Information is a key component, as is the way in which information is presented, including the routes through 
which  it  is  disseminated.  For  example,  chimney  sweeps  have  been  shown  to  be  an  effective  route  to 
informing appliance users about improved operational practice 

•  Measures need to take into account both fuel poverty and the access to alternatives, to avoid exchanging 

one set of issues for another 

•  Cultural drivers around the collection and use of wood as a heating fuel need to be taken into account 

The  emerging  messages  and  recommendations  from  the  work  are  set  out  in  section  8.  In  summary,  the  key 
massages are: 

• 

• 

• 

Bioenergy is also a significant part of the energy supply landscape in almost all EU Member States, small-
scale bioenergy use presents a significant barrier to meeting clean air ambitions in some areas in the EU, 
and controlling air pollutant emissions from domestic-scale bioenergy use is a key challenge for air quality 
policy 

There  are  drivers  to  both  increase  bioenergy  use  and  control  its  impacts  within  EU  policy,  and  greater 
coherence is needed especially around domestic heating 

There are measures to address the air quality impacts of bioenergy use in most, if not all, Member States, 
following a similar pattern. However, variations in the way in which bioenergy is used at the domestic scale 
e.g. as primary or secondary heating, the age and type of appliances, etc, means that precise nature of 
the  issues  vary  between  Member  States,  as  does  the  level  of  ambition  shown  in  controlling  air  pollution 
emissions 

• 

There  are  good  examples  of  measures  already  introduced  from  a  variety  of  Member  States,  at  local, 
regional and national scale, although more work is needed to fully evaluate their effectiveness 

•  National strategies to address domestic bioenergy (and other solid fuel) use are likely to be needed in order 

to meet EU air quality and climate ambitions, as well as to address social issues such as fuel poverty 

11/13788A/11 

6 of 104 

28 March 2024 

Increasing policy coherence between bioenergy and clean air policies and measures Final Project Report 

2 

Introduction 

This project was commissioned by DG ENV under the Air Quality Policy Support framework  contract FRA/C.3/ 
ENV/2021/OP/0017. It has been undertaken by Air Quality Consultants (part of the Logika Group) supported by 
TNO, Ineris, IIASA and E3Modelling. 

2.1 

Project drivers and needs 

Greenhouse gases and air pollutants share many of the same sources and source categories. Action to address 
either can be beneficial to the other, for example the electrification of the car fleet will also remove air pollutant 
emissions  (NOX,  etc.)  associated  with  internal  combustion  engines.  However,  they  can  also  be  antagonistic: 
measures to promote the shift from petrol cars to diesel had a beneficial impact on CO2 emissions but increased 
NOX and PM emissions (prior to the mandatory fitting of diesel particulate filters). 

The need to reduce European reliance on fossil fuels, especially natural gas, for space heating and power has 
been strongly highlighted by recent events. Russia’s unjustified and unprovoked invasion of Ukraine has shown 
the  risks  of  relying  on  energy  supplies  from  unstable  political  regimes,  while  the  record  high  temperatures 
experienced in many European countries in Summer 2022 and the impact of water scarcity and temperatures 
on energy supply has underlined the vulnerabilities of the whole economic system, and the need to address 
climate change. Bioenergy, in the form of woody biomass, remains a significant part of the energy mix for many 
EU Member States and the increased use of wood and other biomass fuels is seen as a renewable and relatively 
low  direct  cost  alternative  combustion  fuel.  However,  it  carries  with  it  the  risk  of  greatly  increased  pollutant 
emissions – the cleanest wood-fired domestic boilers emit around 300 times more PM2.5 than an equivalent gas 
fired  boiler2  –  and  also  the  potential  to  reintroduce  pollutant  emissions  in  cities,  as  large,  centralised  power 
stations are replaced with local biomass combined heat and power (CHP). 

However,  not  all  bioenergy  is  the  same  and  this  problem  is  not  a  new  one.  Potential  solutions  exist  to  help 
mitigate the negative effects of bioenergy on air quality, and to increase policy coherence between bioenergy 
and clean air policies in the EU.  

2.2 

Aims of the project 

The principal aims of the project are twofold: to review the impact, measured and potential, of bioenergy use 
in the EU on air quality; and to investigate the ways in which Member States have, or could, help mitigate those 
impacts while supporting their obligations to increase renewable energy use. 

In terms of outputs the project has:  

•  Collated,  analysed  and  summarised  evidence  on  the  air  pollution  effects  of  biomass  combustion  and 
related health impacts, so as to assess the size of the challenge and policy trade-offs arising from this. The 
project included an assessment of the impacts on Member States’ ability to meet EU air quality standards 
and air pollutants emission reduction commitments  

•  Drawn together good practice and mitigation measures implemented or under consideration by Member 
States, regions and local authorities across the EU (and neighbouring countries such as Norway, Switzerland 
and the UK) for dealing with the identified trade-offs  

• 

Provided support to the European Commission to help address trade-offs between bioenergy and clean air 
objectives through eco-design and eco-labelling, and in the context of the Energy Performance of Buildings 
Directive 

2 https://www.eea.europa.eu/publications/emep-eea-guidebook-2019 

11/13788A/11 

7 of 104 

28 March 2024 

 
Increasing policy coherence between bioenergy and clean air policies and measures Final Project Report 

The project itself was structured around three main tasks: 

• 

• 

• 

Task 1: Background analysis of air pollution associated with biomass combustion and its impacts: scientific 
evidence, regions more at risk, existing regulation, trade-offs between policies 

Task  2:  Analysis  of  measures  and  available  solutions  to  reduce  trade-offs  (based  on  best  practices 
developed at Member State national, regional or local levels) and how to incentivise their uptake 

Task 3: Analysis of how best to use the existing and planned policy frameworks to reduce trade-offs in relation 
to biomass combustion whilst supporting EU clean air policy objectives 

Tasks 1 and 2 both included a literature review element and so these were carried out in parallel. There was also 
a stakeholder outreach programme (see section 3) which mainly informed Task 2 but which also provided useful 
information on the drivers and impacts of bioenergy which helped inform Task 1. A key output of Task 2 was the 
development  of  a  toolbox  for  Member  States  to  help  the  design  and  implementation  of  measures  and 
approaches to mitigate the impacts of bioenergy (see below). 

The third task was more limited in scope. An initial discussion was held with the team helping to develop the 
impact assessment for the revision of the Ecodesign Directive, and while there was an exchange of information, 
the main focus and timing of the two projects precluded further interaction. The main focus under this task has 
been to develop a potential metric for an optional indicator on PM2.5 emissions, for use in Energy Performance 
Certificates  (EPCs),  mandated  under  the  Energy  Performance  of  Buildings  Directive  (2010/31/EU),  which  was 
also subject to revision during the course of the study3 (see section 7). 

2.3 

Introducing the toolbox 

As  mentioned  in  the  previous  section,  one  of  the  outputs  from  the  review  of  bioenergy  impact  mitigation 
measures being undertaken or planned by Member States (and their regions and cities), is a toolbox aimed at 
supporting the development of further actions. This is, in effect, a summary of the findings of this project, and 
has been developed as a stand-alone document, alongside this report. The aim of the toolbox is both to act as 
a guide itself but also to provide links to other available resources to assist in policy or measure development. 

Almost all Member States have some measures in place to help mitigate air pollutant emissions from the use of 
bioenergy, especially from domestic solid fuel use (the main focus of this project), and these break down into a 
few  distinct  types.  However,  there  are  also  some  novel  features  and  approaches  which  could  be  used  to 
supplement,  enhance  or  extend  measures  already  in  place.  Moreover,  the  project  team  has  struggled  to 
identify evidence showing the effectiveness of actions, largely because formal impact or process evaluation is 
still  something  of  a  rarity  for  these  kinds  of  measure.  Therefore,  the  toolbox  introduces  a  potentially  more 
systematic way of designing and implementing measures which will help support impact evaluation and ensure 
measures are targeted in a more cost-effective way. 

The toolbox is published here. 

2.4 

Layout of the report and annexes 

The remainder of this report addresses: 

• 

• 

• 

Stakeholder outreach: what has been undertaken, why, how it was done and the key outcomes 

The impacts of bioenergy use on air quality, based on a review of the available literature 

The drivers, positive and negative, for bioenergy use in the EU 

3 https://www.europarl.europa.eu/thinktank/en/document/EPRS_BRI(2022)698901  

11/13788A/11 

8 of 104 

28 March 2024 

 
Increasing policy coherence between bioenergy and clean air policies and measures Final Project Report 

•  How  EU  Member  States  have  responded  to  these  drivers,  including  case  studies  of  particularly  notable 

measures 

• 

Enabling action through policy development at the EU level 

•  Conclusions and key messages 

The annexes to this report are as follows: 

•  A1: Measurement standards 

•  A2: Literature review 

•  A3: Stakeholder Interview Guides 

•  A4: Stakeholder survey 

•  A5:  Summary  of  the  EU  policies,  legislation  and  other  regulatory  instruments  which  currently  impact  on 

bioenergy 

•  A6: Policies and Measures at Member State, regional or local level 

•  A7: Energy Performance of Buildings Directive (EPBD): potential metrics for PM2.5 

•  A8: Policy Evaluation 

11/13788A/11 

9 of 104 

28 March 2024 

Increasing policy coherence between bioenergy and clean air policies and measures Final Project Report 

3 

Stakeholder outreach 

Summary and outcomes: 

•  A  stakeholder  outreach  programme  was  developed  to  supplement  and  validate  the  findings  of  the 
project’s literature review, and in particular to provide further detail on Member State measures to control 
the impact of bioenergy use on air quality 

• 

• 

Targeted  interviews  were  undertaken  with  stakeholders,  with  a  small  online  survey  added  to  extend  the 
range of views accessed 

The interviews and survey showed a generally high awareness of the potential impacts of bioenergy use on 
air quality, with domestic combustion a key source of emissions. Some concerns were raised in relation to 
the  coherence  between  climate/energy  and  air  quality  policy  at  the  EU  and  Member  State  level. 
Specifically, this was between facilitating the uptake of bioenergy to support renewable energy and heat 
goals, and the need to protect air quality and public health 

3.1 

Purpose of stakeholder outreach 

A key aspect of this project has received input by stakeholders, from “umbrella” organisations (i.e. operating 
across Member States) and by representatives of Member States and/or their cities and regions. The purpose of 
this outreach work was to supplement the literature review elements of Tasks 1 and 2, and to gather information 
from stakeholders on: 

•  Measures to mitigate the impact of bioenergy use on air quality being developed or implemented at the 

Member State national, regional or local level 

• 

• 

• 

Supplementary information on the drivers for bioenergy use at the Member State national level 

Evidence for the effectiveness of measures to mitigate the air quality impact of bioenergy use 

Barriers  to  and  issues  around  the  successful  design  and/or  implementation  of  measures  to  mitigate  the 
impact of bioenergy use 

The information gained from stakeholders was used to inform the outcomes of Tasks 1 and 2 and, particularly, 
to support the development of the Toolbox for Member States described in section 2.3 above. 

3.2 

Approach and structure 

Stakeholder input was mainly gathered through a series of structured interviews, carried out between May and 
December 2023. A two-tiered approach was used, to ensure that the project resources were used effectively. 
The first tier of stakeholders were “umbrella” type organisations, operating at a European (i.e. supra-national) 
level  and,  usually,  representing  collectives  of  Member  State  level  organisations.  The  purpose  of  the  first-tier 
interviews was to gather knowledge on measures implemented at Member State level (or below) and which 
have been brought to the attention of the organisation (through its membership or other routes). Such measures 
are more likely to have had an impact on bioenergy uptake or use and thus be of greater interest for this project. 
The interviews were carefully structured to avoid, as far as possible, assessments as to the desirability of measures 
(which may be regarded positively or negatively, depending on the organisation concerned) and a key aim 
was to identify both available evidence on the impact of the measure and contacts at Member State, regional 
or city level who may be able to provide additional detail. 

The first tier of interviews followed the same process, using an interview guide (see Annex A2) which was shared 
with the interviewee prior to the interview. Consent forms were also provided and the interviews undertaken on 

11/13788A/11 

10 of 104 

28 March 2024 

Increasing policy coherence between bioenergy and clean air policies and measures Final Project Report 

a  non-attribution  basis,  i.e.  information  provided  was  reported  but  it  was  not  associated  with  particular 
individuals  or  organisations.    The  interviews  were  recorded,  and  the  recordings  deleted  once  the  written 
outcomes were agreed post-interview. Tier 1 interviews were undertaken with: 

• 

• 

• 

European Environment Bureau 

Bioenergy Europe 

IEA Bioenergy (Task 32) 

Due to the large number of contacts supplied by Bioenergy Europe, a short survey was conducted with those 
contacts, to gather initial information about measures being implemented at Member State level, and to help 
direct  the  next  stage  of  interviews.  The  survey  was  conducted  using  a  short  online  form,  shown  in  Annex 
1)a)i)(1)(a)(i)A4. Of the 29 invitations to complete the survey issued, 10 were completed. 

The  second  tier  of  interviews  was  with  Member  State  level  contacts.  The  purpose  of  these  interviews  was  to 
gather more detailed information on the measures identified, including: 

• 

• 

the aims, scope, timing and mode of implementation for the measure 

the availability of evidence on impact 

•  costs (and any monetised benefits) 

•  barriers to implementation and potential solutions 

•  any accompanying measures (e.g. publicity campaigns) 

•  any formal evaluation that has been undertaken 

• 

views on the success (or otherwise) of the measure and what contributed to this 

Any  available  documentary  support  for  the  measure  or  the  evidence  of  impact  was  also  requested.  The 
interviews were less formally structured than the Tier 1 interviews, reflecting differences in the information already 
held  by  the  project  team  and  the  nature  of  both  the  measures  concerned  and  the  organisations  involved, 
although they were still undertaken on a non-attribution basis. Tier 2 interviews were undertaken with: 

• 

• 

Environmental Protection Agency, Sweden 

Festbrennstoffe Technologie- und Förderzentrum (TFZ), Germany 

•  Ministry of Environment and Ineris, France 

• 

Za Zemiata, Bulgaria 

Correspondence  was  also  exchanged  with  UBA,  Germany;  the  Environmental  Protection  Agency,  Denmark; 
and the cities of Malmo (Sweden), Grenoble (France) and Sofia (Bulgaria). 

3.3 

Key messages from stakeholder outreach 

As mentioned above, the main purpose of the first round of interviews was to identify contacts and activities at 
Member State level (or below) which could merit a more detailed discussion/investigation. This aim was largely 
achieved, with around 30 additional contacts identified and some potential measures and information sources 
highlighted.  The  follow  up  survey  and  interviews  were  intended  to  supplement  information  gained  through 
literature  reviews  and  searches,  adding  detail  which  could  be  expanded  into  the  case  studies  presented  in 
section 6.5. 

11/13788A/11 

11 of 104 

28 March 2024 

Increasing policy coherence between bioenergy and clean air policies and measures Final Project Report 

From all three stages of outreach, several common outcomes were apparent: 

General awareness 

All  parties  contacted  were  aware  of  the  potential  impact  of  bioenergy  use  on  air  quality,  especially  at  the 
domestic  scale.  Views  differed  as  to  whether  this  was  an  issue  simply  of  older  appliances  being  used  or  an 
inevitable consequence of bioenergy use. However, there was a broad consensus that further action to reduce 
the  air  quality  impact  of  bioenergy  was  necessary  to  bring  an  equivalent  level  of  pollution  control  as  that 
developed in other emitting sectors, such as transport or industry, where available abatement technologies are 
more fully exploited. 

EU level 

Another  area  of  commonality  was  in  the  expression  of  frustration  that  policies  and  signals  at  the  EU  level 
appeared not to be well coordinated. There were perceptions of mixed messaging around the environmental 
benefits  and  disbenefits  of bioenergy,  and  views were  expressed  in  interviews  that  carbon  neutrality was  still 
being used to promote bioenergy (not necessarily by the Commission), despite evidence to the contrary. 

Another area of concern was that emissions control legislation at the EU level focussed on the performance of 
new equipment (e.g. eco-design requirements for new stoves), but did little about the stock of existing bioenergy 
equipment, including the use of open fires. It was suggested that the conversion of all, or the majority of, solid 
fuel appliances to modern, pellet fed versions could alleviate the air quality impacts of bioenergy. However, the 
practicality of doing so, in addition to the financial and political support required, was questioned. 

Member State level 

As reflected in the literature review, it is clear that all or almost all Member States have some measures in place 
aimed at mitigating the air quality impacts of solid fuel (including bioenergy) use. This includes the  domestic 
scale although the stringency and ambition of those measures differs considerably. Some Member States and 
regions were incentivising an upgrade to newer, less polluting equipment, although the picture is very mixed 
and schemes differed in detail. 

Drivers for the uptake  of  bioenergy,  or the  failure  to  reduce  bioenergy  air  pollution  emissions,  other than  the 
perceived climate benefits or achievement of renewable energy targets, were raised. These included energy 
security, the cost of electricity and gas for heating4, and the aesthetics of solid fuel use. Aesthetics and cultural 
drivers for bioenergy use, were identified as strong drivers in wealthier Member States, with the view expressed 
that coordinated messaging would be required to change attitudes around wood combustion in particular. 

Evaluation 

A  consistent  finding  was  the  lack  of  effectiveness  evaluation  for  national  or  local  scale  interventions  on 
bioenergy. While there were some references made to air quality measures (and trends therein), other than a 
few  examples  there  were  no  direct  assessments  found  of  the  effectiveness  of  measures.  Linking  individual 
measures to changes in air pollutant concentrations is notoriously difficult, especially for a pollutant such as PM2.5 
which has multiple sources and is complex to measure. It is therefore not surprising that the impacts of measures 
on  concentrations  have  generally  not  been  assessed.  However,  effectiveness  evaluation  can  also  look  at 
intermediate steps, such as changes in the appliance stock, quantity or quality of fuel, or rates of combustion. 
Unfortunately, there appears to be little information available on the impact on intermediates either. 

The outcomes of the stakeholder engagement work have been combined with the literature review to form the 
principles for successful measure and key messages in sections 6.7 and 8.1. 

4 Note that the relative cost of electricity, gas and wood pellet fuel is dynamic and the views expressed the 
pricing at the time of the interview. 

11/13788A/11 

12 of 104 

28 March 2024 

 
Increasing policy coherence between bioenergy and clean air policies and measures Final Project Report 

4 

Bioenergy Impacts on Air Quality 

Summary and outcomes: 

• 

• 

• 

• 

PM2.5  is the  main  driver  of the  health  effects  of  air  pollution  and  is thus  of  primary  concern  for  air  quality 
policy.  Solid  biomass  used  for  heat  and energy generation  is the  single  largest  source  of  fine  particulate 
matter (PM2.5) emissions across the EU 

This is largely as a result of domestic combustion, which makes up around half of total emissions, and which 
in turn is dominated by wood fuel combustion 

In  the  EU,  the  use  of  bioenergy  increased  rapidly  between  2005  and  2020,  although  in  recent  years  the 
growth  has  levelled  out,  potentially  due  to  uncertainty  in  policies  and  debates  about  sustainability  of 
bioenergy5 

Estimating emissions from bioenergy, especially small-scale bioenergy (i.e. domestic scale), is complex and 
challenging. Emissions vary significantly based on the quality of fuel, the type of appliance and the actions 
of the user. In addition, accurate information on fuel and appliance use is generally difficult to obtain. Finally, 
different  Member  States  calculate  emissions  differently,  particularly  in  the  inclusion  or  exclusion  of  the 
condensable fraction of particulate matter 

4.1 

Introduction 

This chapter reviews the evidence with regard to bioenergy use and air quality.  For the purposes of this study, 
biogas  production  and  biofuels  used  in  transport  are  excluded.  Moreover,  while  the  analysis  in  this  section 
touches on different types of non-transport bioenergy, the main focus is on the use of wood and woody biomass 
as a domestic space and water heating fuel. This is due to both the predominance of this use type within the 
sector,  and  the  association  of  small-scale  bioenergy  (mainly  wood  fuel)  combustion  with  the  majority  of  air 
quality  impacts.  Larger  combustion  plants,  such  as  that  used  in  power  generation,  are  subject  to  the  same 
legislative  emission  controls  as  plants  running  on  other  fuels.  However,  small-scale  combustion,  especially 
“traditional” stoves and fireplaces burning wood logs, emit far higher levels of PM2.5 (the principal driver of health 
effects  from  air  pollution)  than  gas  (including  biogas)  or  non-combustion  equivalents.  In  this  section,  little 
distinction is made between different types of solid biofuels used for domestic-scale heating – wood, wood ships 
and pellets, reconstituted wood or biological waste (e.g. coffee logs), etc. Each will have their own emission 
profile but the essential issue of controlling emissions from small-scale combustion applies to them all, accepting 
that such controls are more feasible for some (e.g. wood pellets) than others (e.g. log wood). 

4.2 

Approach and data sources 

Bioenergy is defined in this study as the use of biomass in a wide range of energy related applications (typically 
for producing electricity and heat). This includes solid biofuels (wood) but also liquid and gaseous biofuels, while 
peat is classified as a fossil fuel and therefore excluded from biofuels. Also the production of biogas as well as 
the use of liquid biofuels in transport are excluded from the definition of bioenergy for the purposes of this study. 
To  assess  the  impacts  of  bioenergy  on  air  quality  in  Europe,  a  literature  survey  has  been  conducted,  the  full 
document  list  for  which  is  shown  in  Annex  1)a)i)(1)(a)(i)A2.  A  long  list  of  data  sources  has  been  identified, 
collected and examined. These include policy documents and legislation, project reports and websites, as well 
as scientific and other sources of grey literature. This chapter summarizes the bioenergy impacts on air pollution, 
now and (potentially) in the future, based on this assessment of literature. 

5 https://publications.jrc.ec.europa.eu/repository/bitstream/JRC130730/2022.5470_kjna31283enn.pdf  

11/13788A/11 

13 of 104 

28 March 2024 

 
Increasing policy coherence between bioenergy and clean air policies and measures Final Project Report 

4.3 

Evidence for environmental impacts of bioenergy 

The  use  of  bioenergy  has  been  increasing  in  recent  years.  The  combustion  of  biomass  emits  CO2,  but  it  is 
considered “zero-rated” under the EU Emissions Trading System (ETS), because it is already counted under the 
Land Use, Land Use Change and Forestry (LULUCF) Regulation. Here it is accounted for in the form of reduction 
of  carbon  sinks,  which  implies  that  the  CO2  emissions  from  combusting  biomass  correspond  to  the  CO2 
absorbed by the biomass during the growth of the feedstock. The increased use of biomass for energy purposes 
can worsen local and regional air pollution levels, since pollutant emissions from the use of biomass are typically 
greater than those from other fuels, especially when solid biomass is replacing natural gas as the combustion 
fuel. 

This section explains the impacts of bioenergy on air pollutant emissions, air quality and human health. First a 
general overview of the bioenergy use and trends is given, then the focus is on air pollution impacts related to 
bioenergy. 

4.3.1 

Trends in the consumption of bioenergy in the EU 

Bioenergy is the main source of renewables in the EU in terms of gross final energy consumption, representing 
almost 60% of renewable energy sources6. Its main use is for heating and cooling (around 75%). In the EU, the 
use of solid bioenergy increased by 33.5% between 2008 and 2021, however in recent years the growth seems 
to be levelling out because of uncertainties in policies and debates about sustainability of bioenergy7. Germany, 
France,  Italy  and  Sweden  are  the  EU27  Member  States  with  the  highest  bioenergy  consumption  in  absolute 
terms. Figure 4-1 shows the bioenergy use in EU27 in 2021, illustrating that the largest part of bioenergy is used in 
transformation input (mostly for electricity and heat generation) as well as in other sectors (mostly for small-scale 
heat generation). The contribution of liquid bioenergy in the energy sector in the figure excludes biodiesel and 
biogasoline inputs into the energy sector since these are largely used in transport. However, small quantities of 
liquid  biofuels  are used  in  industry  and  other  sectors  as  illustrated  by the  Figure. Around 65%  of  this  solid  and 
gaseous bioenergy is used in combined heat and power (CHP) plants, whereas electricity and heat-only plants 
use 18% and 17% of the bioenergy in EU27 in 2021, respectively. Industry is a smaller but not negligible user of 
bioenergy, and within the industrial sector the main users are the pulp and paper industry and the wood and 
wood products industry (20%). In terms of the type of bioenergy used, industry and other sectors primarily use it 
in solid form (wood or similar), while the electricity and heat generation sector also utilises significant amounts of 
bioenergy in liquid and gaseous form. However, since the largest air pollution impacts are related to bioenergy 
in solid form, this study focuses on these. Figure 4-2 shows the per capita use of solid biomass in each MS and for 
the EU27 as a whole, illustrating that there are large variations between different Member States regarding the 
uptake of bioenergy. This mostly relates to the energy and industrial sectors, and is related to the presence of 
specific industries (e.g. pulp and paper production) in each Member State. 

6 https://energy.ec.europa.eu/document/download/68e51bbf-aa4f-4570-9497-
0af7c19c153c_en?filename=COM_2023_650_1_EN_annexe_autre_acte_part1_v7.pdf  
7 Ibid. 

11/13788A/11 

14 of 104 

28 March 2024 

 
Increasing policy coherence between bioenergy and clean air policies and measures Final Project Report 

Figure 4-1: Bioenergy use in EU27 in 2021, main sectors and main fuel type. The figure includes the use of liquid 
biofuels in each sector, but excludes the use of biofuels in the transport sector (source: Eurostat energy 
balances8)  

Figure 4-2: Per capita use of primary solid biofuels (the definition used by Eurostat for bioenergy in solid form) in 
each MS and the EU27 average (source: Eurostat8) 

4.3.2 

Current air pollutant emissions from bioenergy use 

Unfortunately  for  air  pollutants,  official  reported  emission  inventories  (reported  under  the  National  Emission 
reduction  Commitments  (NEC)  Directive  2284/2016/EU)  do  not  distinguish  between  fuels,  which  makes  it 
impossible to analyse these data regarding the use of bioenergy. For instance, for residential combustion only 
the total emissions per pollutant are provided which represent the sum of emissions from the combustion of fossil 

8 Eurostat complete energy balances, last updated 28/04/2023 

11/13788A/11 

15 of 104 

28 March 2024 

 
 
 
Increasing policy coherence between bioenergy and clean air policies and measures Final Project Report 

and  biomass  sources.  Therefore,  air  pollutant  emissions  data  from  the  IIASA  GAINS  model,  which  is  used  to 
underpin much of the EU and international policies on clean air, have been used. Emissions were extracted per 
key fuel/activity and sector for the year 2020 in the “baseline” scenario which is used to underpin the analyses 
in the 3rd Clean Air Outlook (CAO3)9. It should be noted that these numbers are derived from emissions modelling 
rather than the official inventories, although they are aligned as much as possible with Member States as part 
of the CAO3 consultation processes10.  

Figure 4-3 shows the main sectors contributing to bioenergy emissions in the EU27 in the year 2020, for the main 
air pollutants which have reduction commitments specified in the NEC Directive. It shows that, for all 5 pollutants, 
small combustion installations are the main contributor to emissions from bioenergy, with significant contributions 
from energy and manufacturing industry for NOX and SO2. With the stricter emission limits included in the updated 
LCP BAT conclusions which are in place from 2021, the pollutant emissions from the use of bioenergy in these 
sectors probably decrease in the near future. However, for NH3, NOX and SO2 the shares of bioenergy within the 
total emissions of the respective pollutants are between 2-8%. For NMVOC this share is 13%, while for PM2.5 the 
emissions from bioenergy represent more than 50% of the total emissions in EU27 in 2020. PM2.5 is also the pollutant 
that is typically associated with the most relevant health impacts.  

Figure 4-3: Main sectors contributing to bioenergy emissions in the EU27 in 2020 (source: CAO3 emission data) 

Figure 4-4 shows total PM2.5 emissions in EU27 distributed between the different sources, including both bioenergy 
and non-bioenergy. The figure shows that bioenergy use in small combustion is responsible for half the total PM2.5 
emissions in the EU27, and the use of bioenergy in other sectors only makes a small contribution. Hence, it can 
be concluded that when it comes to air pollution related to the use of bioenergy and its impacts, the main issue 
is the use of bioenergy in the small combustion sector, which mostly consists of wood used for heating purposes. 
Looking back at the last two to three decades, PM2.5 emissions have decreased in the EU27 by 37% between 
2000 and 202011. However, this decrease is mostly attributed to sectors other than small combustion, in particular 
transport and industry, because of the abatement measures that were implemented in these sectors. Hence, 

9 https://environment.ec.europa.eu/publications/third-clean-air-outlook_en  
10 When preparing the CAO3, IIASA ran individual meetings with Member States to consult them on the 
baseline assumptions and underlying data in the model relating to the respective Member State.  
11 https://www.eea.europa.eu/data-and-maps/dashboards/air-pollutant-emissions-data-viewer-4 

11/13788A/11 

16 of 104 

28 March 2024 

 
 
Increasing policy coherence between bioenergy and clean air policies and measures Final Project Report 

the  relative  importance  of  small  combustion  in  total  PM2.5  emissions  in  EU27,  which  are  primarily  related  to 
bioenergy use, has increased in the last decades. 

Figure 4-4: Main contributing sectors, differentiating between bioenergy and other fuels, for total PM2.5 
emissions in EU27 in 2020 (source: CAO3 emission data) 

It should be noted that emissions from bioenergy use are particularly important in winter time, when European 
citizens use biomass for domestic heating. The actual emissions however depend strongly on the specific stove 
or boiler used – old stoves and especially open fireplaces have high emissions, the devices with latest technology 
that meet the latest European standards are significantly cleaner – but also on the quality of the feedstock as 
well as on the way the combustion device is operated by the user (Bioenergy Europe, 2021). 

4.3.3 

PM emissions and condensables 

In  recent  years,  it  has  become  clear  that,  within  Europe,  there  are  different  ways  in  which  PM  emissions  are 
measured and reported (Simpson et al., 2020). The lack of a uniform standard and agreed upon way to quantify 
PM  emissions  in  inventories  causes  significant  differences  in  the  comparability  of  reported  PM  emissions  in 
emission inventories from different EU Member States, especially in the residential sector. 

One common way to measure PM emissions is using a heated filter approach, where fine particulate matter is 
collected  on  a  filter  which  is  typically  placed  in  the  chimney.  This  way,  only  the  particles  which  are  already 
present in the hot flue gases are measured. However, upon leaving the chimney, the hot flue gases cool down 
and additional particles may be formed through condensation. Depending on the circumstances, this process 
takes place within seconds to minutes after the flue gases leave the stack, and may generate up to five times 
more  particles  than  originally  present  in  the  exhaust  gases.  These  additionally  formed  particles  are  typically 
referred  to  as  “condensables”.  Alternative  methods  to  the  heated  filter,  such  as  the  use  of  a  dilution  tunnel 
based  measurement  approach,  allow  for  condensation  before  the  particle  mass  is  collected  and  therefore 
include  the  condensable  particles  in  the  total  PM  mass,  thus  giving  a  more  complete  picture  of  particulate 
matter related pollution. 

For practical reasons, different methods have been adopted in different sectors: 

11/13788A/11 

17 of 104 

28 March 2024 

 
Increasing policy coherence between bioenergy and clean air policies and measures Final Project Report 

• 

• 

In  large  stationary  combustion  installations  (power  plants,  industry),  the  heated  filter  approach  is  used 
throughout  Europe  and  therefore  the  condensables  are  excluded  from  the  emissions  in  (practically)  all 
cases  

In  quantifying  transport  exhaust  PM  emissions,  condensables  are  largely  included  when  following  the 
established  measurement  protocols  in  this  sector.  These  include  a  cooling  of  the  exhaust  gases  to  51°C 
which allows most of the condensables to be formed. However, further cooling could generate additional 
particles, although their contribution is likely to be limited 

• 

For small stationary combustion processes, methods which include and exclude condensables are used in 
the absence of a common European measurement standard  

More details regarding the different measurement and sampling methodologies are provided in general terms 
in Section 4.4.3 and in detail in Annex 1)a)i)(1)(a)(i)A1 

When  it  became  clear  that  this  reporting  inconsistency  led  to  underestimated  PM  concentration  levels  by 
excluding  condensable  particles,  most  European  countries  updated  their  official  inventories  to  include 
condensables for small combustion. However, as of the 2023 inventory submissions some Member States such 
as Austria and Germany still do not, or only partially, include condensables in their PM emission inventories for 
stationary small combustion, as was concluded by the 2022 CLRTAP Stage 3 emission inventory review12. 

It is important to note that a simple statement stating that condensables are included or excluded oversimplifies 
the real-world situation. The 2022 CLRTAP Stage 3 review, which focussed on the inclusion of condensables in 
small  combustion  and  road  transport, concluded  that for  road transport  the  situation  is  clear,  as  all  emission 
factors used include condensables in a similar way. For small combustion however, in many countries a mix of 
emission  factors  is  used.  For  one  specific  appliance  an  emission  factor  may  be  used  that  (partly)  includes 
condensables (e.g. determined using a dilution tunnel approach), while for another appliance, this may not be 
the case. Also, it was found that in numerous cases the inclusion of condensables in the emission factor could 
not be determined. 

To overcome this uncertainty in country reporting and examine the possible impacts on European emissions and 
air quality, an alternative and independent emission inventory (“Ref2”) has been developed for PM emissions 
from the small combustion sector for all of Europe, in support of the review of the UNECE Gothenburg Protocol 
(Simpson et al., 2022). The Ref2 inventory includes specifically the filterable part of PM as well as the condensable 
part. This inventory includes all PM emissions from small combustion, not only from bioenergy. In the majority of 
countries however, bioenergy is responsible for more than 90% of PM2.5 emissions from small combustion units. 
This is indicated by the black dots in Figure 4-5. The countries with a lower bioenergy share in their PM2.5 emissions 
from  small  combustion  have  significant  contributions  from  coal  (e.g.  Czech  Republic,  Poland)  or  from  peat 
(Ireland). Apart from the bioenergy share, Figure  4-5 also shows CAO3 emissions as well as the Ref2 inventory 
emissions with and without condensables. The Ref2 inventory with condensables included results with 19% higher 
PM2.5 emissions for the EU27 in 2019 compared to the CAO3 emissions. However, when a similar comparison is 
made between the Ref2 inventory and the official inventories reported by each MS under the NEC Directive in 
2023 the two are found to be very similar. This can be attributed largely to recalculations in 2023, submitted by 
France and Poland, both adding around 80 kt (thousand tonnes) additional emissions compared to their earlier 
submissions. For both of them, it implies their official submitted emission is now higher than the Ref2 inventory. 
Therefore, the fact that for EU27 as a whole the two inventories match does not mean that all MS now account 
for condensables in their PM emissions from small combustion. The fact that in some cases the official inventories 
are substantially higher than the Ref2 inventory compensates for missing condensables in other inventories. The 
methodological differences between Member States in the way they estimate PM emissions contributes to the 
high uncertainty in reported PM emissions from the domestic sector, in particular for the use of bioenergy. 

12 https://www.ceip.at/status-of-reporting-and-review-results/2022-submission  

11/13788A/11 

18 of 104 

28 March 2024 

 
Increasing policy coherence between bioenergy and clean air policies and measures Final Project Report 

The results also show that condensables make up around two thirds of the total PM2.5 emissions from small-scale 
combustion in the EU27 in 2019, which underlines the importance of including them to assess the real impact of 
(bioenergy) emissions on air quality, human health and the environment. 

Figure 4-5: Alternative emission inventory of PM2.5 emissions (“Ref2”) from small-scale combustion (GNFR C) for 
2019, with and without condensables, compared to the emissions used in CAO3. Black dots represent the 
share of solid biomass in the energy mix for this sector (based on Eurostat). 

Finally, it should be noted that condensables may also be emitted from larger scale stationary combustion (in 
energy and manufacturing industries). While the PM2.5 emissions from these sectors are significantly smaller, these 
should  not  be  overlooked.  There  are  indications  that,  especially  for  modern  plants  with  low  (filterable)  PM 
emissions,  the  contribution  of  condensables  may  exceed  the  filterable  PM  emissions  (Liu  et  al.,  2022).  More 
research  is  needed,  however, to  see  how  this  applies to  the  European  situation  and  how the  importance  of 
condensables  fluctuates  with  technology  and  abatement  levels.  To  better  understand  this,  measurements 
aiming at quantifying the condensable contribution are needed, distinguishing between fuel types as well as 
between older and modern state-of-the-art plants that are being used throughout Europe. 

4.3.4 

Ambient air pollution impacts 

The impact of emissions from bioenergy alone on outdoor air pollution is difficult to quantify, given the range of 
other sources of the same pollutants. Once released, the particles originating from bioenergy combustion mix 
with other particles and gases and undergo transformations and/or chemical reactions. During these processes, 
additional so-called “secondary particles” are formed through chemical reactions of its precursors: mainly NOx, 
NH3  and  SO2.  This  secondary  PM  is,  in  most  cases,  responsible  for  a  significant  share  of  the  overall  PM2.5 
concentrations. This – in combination with other local circumstances – makes the impacts of air pollution from 
bioenergy strongly location dependent. In addition, there is still not a full understanding of the role of ultrafine 
particles  (UFPs),  which  are defined  as  those  particles with  a  diameter  below  100  nm13.  UFP  is  in  the  spotlight 
because of some evidence that smaller particles may be more harmful to human health than larger particles, 
since the smaller the particle the more deeply it could penetrate into the lungs (Schraufnagel, 2020; Ohlwein et 
al., 2019). There is little information about emissions of UFPs. To address UFP, the Commission proposal for a revised 
Ambient  Air  Quality  Directive  (AAQD)14  introduces  monitoring  of  UFP  at  sites  which  are  likely  to  have  high 
concentrations.  First  indications  at  European  scale  suggest  that  transport  (exhaust)  emissions  dominate  UFP 

13 Since at this size the mass of the particles becomes very small, UFPs are typically expressed as the number of 
particles. 
14 https://environment.ec.europa.eu/publications/revision-eu-ambient-air-quality-legislation_en  

11/13788A/11 

19 of 104 

28 March 2024 

 
 
Increasing policy coherence between bioenergy and clean air policies and measures Final Project Report 

emissions, but bioenergy use in residential combustion cannot be neglected15. However, the uncertainty around 
these initial estimates is high (and hence their contribution to ambient concentrations) and further research is 
needed  to  better  understand  the  emissions  and  transformations,  and  especially  how  the  smallest  particles 
behave in their initial seconds to minutes after emission. 

The above implies that for quantifying the impacts of PM2.5 emissions from bioenergy in terms of ambient air 
quality concentrations and impacts thereof, specific information is needed on many other pollutants, not only 
from  bioenergy  use  but  from  all  relevant  sources  of  emissions.  Using  modelling  tools,  the  relation  between 
emission and concentrations, and the contribution of different sources to concentrations can be estimated for 
different regions or cities. The variation of the contribution from bioenergy use (and residential wood combustion 
in particular) is further elaborated upon for specific cities/regions in Section 4.4.4. 

4.3.5 

Indoor air pollution 

The use of heating devices inside homes also affects the indoor air quality. A UK study looking specifically at 
wood-fired stoves has measured PM levels during use of these stoves in 20 different situations and concluded 
that PM emission levels were 2-3 times higher when the stove was in use (Chakraborty et al., 2020). On top of 
that, higher peak concentrations were clearly identified, showing that part of the PM emissions “leak” to the 
indoor environment. The peaks were mostly found to be associated with number of wood logs used and the 
length of the burn period. This points to the opening of the stove door as a primary mechanism for introducing 
PM into the home. A study in Norway (Wyss et al. 2016) found that residential homes with a wood stove showed 
typically higher PM2.5 concentrations than those without, and in addition lower PM2.5 levels were measured when 
newer wood stoves were installed. 

4.3.6 

Health effects 

Wood or bioenergy combustion is known to emit particulate matter (PM2.5, PM10, ultrafine particles), NMVOCs, 
but also NOx, SOx and NH3, as well as polycyclic aromatic hydrocarbons (PAHs) and dioxins. PM emissions from 
combustion sources contain a large fraction of carbonaceous aerosol, predominantly present in the sub-micron 
size fraction (<1µm). Amongst these pollutants, PM2.5 (primary and secondary), as well as PAHs and dioxins are 
of specific health concern (Denier van der Gon et al., 2015; UK Air Quality Expert Group, 2017). 

PM2.5  has  long  been  linked to  mortality, to  inflammation  and  oxidative  stress,  which  compromises  pulmonary 
immunity and increases the susceptibility to infection. The illnesses associated with the presence of PM2.5 range 
from  lung  cancer,  bronchitis  and  other  respiratory  infections  to  cardiovascular  diseases,  strokes,  dementia, 
Parkinson’s  disease  and  low  birth weight.  Effects  are particularly  pronounced for  children,  pregnant women, 
and  the  elderly  (Chakraborty  et  al., 2020;  Sigsgaard  et  al.,  2015;  WHO,  2015).  PAHs  can  reduce  the  immune 
function and are known for their carcinogenic and mutagenic effects (Tsiodra et al., 2021), and dioxins are also 
carcinogenic  (Coolproducts  &  ECOS,  2022).  Both  families  of  substances  are  known  to  be  persistent  and  to 
accumulate. PAHs emitted to the atmosphere can be deposited onto soil, water and vegetation. In water they 
can accumulate in aquatic organisms, in soil they can enter the groundwater and be transported within an 
aquifer  (EFSA,  2008).  When accumulated  in  soil  and  water, they  can  enter the food  chain  also through their 
uptake by vegetation and plant materials, and through the use of contaminated vegetation to feed livestock 
(Sampaio et al., 2021). Dioxins bind to sediment and organic matter in the environment, they  are absorbed in 
animal and human fatty tissue and bio-accumulate in the food chain (MEMO/01/270, 2001).  

Epidemiological studies document that short- and long-term exposure to smoke from biomass combustion are 
responsible  for  chronic  obstructive  pulmonary  disease  (COPD)  (Salvi  &  Barnes,  2009),  acute  respiratory  and 
cardiovascular disease (Sigsgaard et al., 2015), pneumonia, tuberculosis, asthma and cancer (Patel et al., 2013). 
A  strong  relationship  between  PM  from  biomass  combustion  and  health  impacts  such  as  hospitalisations, 

15 https://riurbans.eu/wp-content/uploads/2022/11/RI-URBANS_M13_.pdf  

11/13788A/11 

20 of 104 

28 March 2024 

 
Increasing policy coherence between bioenergy and clean air policies and measures Final Project Report 

cardiovascular  and  respiratory  problems  and  premature  mortality  has  been  found  (Pope  &  Dockery,  2006, 
Kukkonen et al., 2020). 

The  World  Health  Organisation  (WHO)  notes  that  short-term  exposure  to  particles  from  wood  combustion 
appears  to  be  as  harmful to  health  as  exposure  to  particles  from  the combustion  of  fossil  fuels  (WHO,  2015). 
Other  studies  indicate  that  emissions  from  wood  burning  might  be  specifically  dangerous  for  health:  Danish 
Ecological Council (2016) suggests that soot particles, emitted amongst others from wood burning, might be 
more harmful than inorganic particles formed from the precursors NOx, NH3 and sulphates. And a study in Athens 
found that the fraction of PAHs associated with biomass burning was linked to increased health risk compared 
to other sources, accounting for 43% of the annual PAH carcinogenic potential (Tsiodra et al., 2021). 

Wood combustion is an important source of air pollution in Europe. In some countries it is even the dominating 
source. In Finland, for example, residential wood combustion is the largest domestic source of PM2.5 (Savolathi 
et al., 2019). This said, levels of ambient PM2.5 concentrations are generally very low in Finland16.. 

A few studies have estimated the burden of disease due to exposure to PM2.5 from wood or biomass combustion. 
Sigsgaard  et  al.  (2015)  estimated  a  contribution  of  biomass  smoke  to  premature  mortality  in  Europe  at 
approximately  40,000  deaths  per  year.  The  authors  derived  this  number  from  the  estimation  that  premature 
deaths  due to  PM exposure  in the  EU  amounted  to  around  400,000  annually  in 2010  and  2012,  and that  the 
contribution of biomass smoke to population exposure is about 10%. Disease burden related to residential wood 
combustion in Finland, in 2015, was estimated to correspond to 204 deaths (Savolathi et al., 2019). In a study 
from 2016, fine particles from wood burning emitted in Denmark were estimated to account for 550 premature 
deaths in Denmark, and for 1000 premature deaths in Europe (Danish Ecological Council, 2016).The year this 
estimate corresponds to is not specified. In the 2022 update of the study the numbers are 300 premature deaths 
for Denmark and 600 for Europe (Green Transition Denmark, 2022). 

Frequently, estimates are made for residential heating with wood and coal together. WHO (2015), for example, 
estimate the following numbers for premature deaths that can be  attributed to residential heating with wood and 
coal in different  European  regions  in  2010:  20,000  for  Western  Europe,  20,000  for  Central  Europe  and  21,000  for 
Eastern Europe. 

Looking  at  trends,  the  increase  in  residential wood  burning  between  2005  and  2016, was  estimated  to  have 
been responsible for an increase of around 10,700 premature deaths in the EU27 & UK in 2016 relative to 2005. 
This  is  due  particularly  to the  high emissions  of  fine  particulate  matter from  domestic  stoves  (Couvidat  et  al., 
2021). 

In terms of socio-economic costs, it was estimated that in the EU27 & UK, in 2018, 31% of the health costs from 
ambient air pollution due to residential heating and cooking come from the use of wood burners (Kortekand et 
al.,  2022;  EPHA,  2022).  The  authors  also  calculated  that  health  costs  associated  to  using  a  wood  stove,  on 
average  across  the  region,  amount  to  756  €/year/household,  and  those  associated  with  using  a  non-
condensing boiler for wood amount to 159 €/year/household. These costs are higher than those estimated for 
all  other  energy  sources  for  heating,  with  the  sole  exception  of  non-condensing  coal  boilers  (1233 
€/year/household).  Similar  results  are  found  for  Denmark,  where  domestic  wood  burning  in  small  stoves  and 
boilers is the most expensive heat source in terms of estimated average health costs, amounting to  15.6 €/GJ 
house  heating  in  Denmark.  The  health  costs  occurring  outside  Denmark  are  estimated  at  18.9  €/GJ  house 
heating  (EEB,  2021).  For  Denmark,  it  was  estimated  in  2016  that  fine  particles  emitted  from  wood  burning 
contributed with about 50% to overall health damage from Danish pollution sources17, and that pollution from 
wood  burning  was  the  most  expensive  environmental  problem  (Danish  Ecological  Council,  2016).  The  latter 
statement remains valid in the 2022 update of the study (Green Transition Denmark, 2022), while the share of 
costs  associated  with  pollution  from  wood  burning  in  total  costs  from  air  pollution  from  polluting  sources  in 

16 https://www.eea.europa.eu/themes/air/urban-air-quality/european-city-air-quality-viewer  
17 Note that the impact of secondary particles and the fact that different sources have a different particle 
composition and particle size range were not considered in this estimate. 

11/13788A/11 

21 of 104 

28 March 2024 

 
Increasing policy coherence between bioenergy and clean air policies and measures Final Project Report 

Denmark is down to 40 %. These socio-economic costs of wood burning in Denmark amount to €750 million in 
Denmark and to €1.225 million in Europe due to the transboundary nature of air pollution (costs in Europe include 
costs in Denmark) according to the two sources.  

From the range of results reported above, it is clear that estimates of health impacts from air pollution bear some 
uncertainty. The physicochemical properties of particulate matter from biomass combustion vary with specific 
combustion  conditions,  and  hence  make  the  evaluation  of  the  respiratory  and  cardiovascular  toxicity  of 
biomass  emission  complex  (Sigsgaard  et  al.,  2015).  Uncertainty  also  remains  about  the  relative  toxicity  of 
different  particle types  (Green  Transition  Denmark,  2022).  These  authors  assume  that  air  pollution  from  wood 
burning might be more damaging than estimated in current studies, also because some adverse health effects 
for which the epidemiological literature has been growing more recently (e.g., low birth weight, IQ loss), are not 
yet included in the studies for which results are summarised here. 

4.4 

Variability in bioenergy emissions and impacts  

4.4.1 

Fuel types and biomass amounts used 

Bioenergy  emissions  per  unit  of  energy  generated  vary  significantly  between  the  different  regions  in  Europe, 
both in terms of bioenergy amounts and bioenergy types. The demand for bioenergy is largely related to the 
structure  of  the  energy  system  in  each  Member  State,  especially  when  considering  the  residential  sector. 
Member States with a low share of bioenergy in the final energy consumption in the residential sector in the EU27 
in 2021 are Ireland (0.9%), Malta (1.3%), Luxembourg (3.3%) and Netherlands (3.8%)18. On the other hand, high 
bioenergy  shares  are  reported  for  Croatia  (46%),  Estonia  (40%),  Slovenia  (39%)  and  Latvia  (38%)  (European 
Commission, 2021). 

Bioenergy is not a single type of fuel but a group of energy carriers derived from the conversion of natural or 
biological sources. In the EU overall, the use of bioenergy shows an increasing trend. However, the growth rate 
has slowed down in recent years. In the year 2015, primary wood contributed to 37% of the total wood used for 
energy, from which about 47% is stemwood while the remaining 53% are other wood components (treetops, 
branches, etc.). Secondary woody biomass (sawdust, chips, etc.) accounted for 49%, while the remaining part 
accounts for the woody biomass use for which the origin is unknown (14%) (European Commission, 2021). The 
Figure also shows that 75% of the biomass is used for heating purposes, other uses being electricity and fuel for 
transport. Woody biomass however may still consist of different tree species, wood types and can be used in 
different forms (large or small wood logs, wood chips, etc.), which may have an impact on emissions when the 
biomass is combusted. 

18 Based on Eurostat energy balances for the year 2021 (accessed 10 October 2023) 

11/13788A/11 

22 of 104 

28 March 2024 

 
 
Increasing policy coherence between bioenergy and clean air policies and measures Final Project Report 

Figure 4-6: Origin of bioenergy in the EU (2015), figure taken from JRC report (European Commission, 2021)  

One  of  the  reasons  for  variability  and  associated  uncertainty  in  bioenergy  emissions  and  impacts  is  the 
uncertainty around the amounts that are used. Official statistics of biomass use often only contain the amount 
of  biomass  that  is  recorded  in  the  sales  statistics.  In  fact,  a  gap  exists  between  reported  use  and  sources  of 
woody  biomass  at  EU  level,  which  can  be  largely  attributed  to  bioenergy  use  (European  Commission,  2021) 
Especially in rural areas which are not (well) connected to power or gas networks, local inhabitants may harvest 
wood  directly  from  the  forest  e.g.  for  heating  and  cooking  purposes.  Estimating  the  additional  wood 
consumption  (and  associated  emissions)  resulting  from  this  is  a  challenging  task  as  typically  no  data  are 
available. 

4.4.2 

Variation in appliances 

There is a wide range in bioenergy appliances. In the larger combustion sectors (energy and manufacturing 
industries) biomass is often used in combination with other solid fuels (co-firing), although larger new biomass-
only  electricity  plants  have  been  built  in  recent  years  as  well  as  CHP  (combined  heat  and  power)  plants. 
However,  these  larger  and  new  plants  typically  have  lower  emissions  of  hazardous  air  pollutants  per  unit  of 
energy produced compared to smaller installations because their operating temperature is higher, which means 
most air pollutants are largely burned before they can be released, and larger installations typically have more 
advanced abatement equipment installed so that remaining air pollutants can be largely removed from the 
exhaust gases. The latter is also related to the regulation of these large installations under the Industrial Emissions 
Directive. 

Hence, the largest share of emissions from the use of bioenergy comes from residential combustion (see also 
Section 4.3.2). Also, within this sector, a wide range of different equipment types are used. Distinctions can be 
made between boilers and stoves, between larger and smaller appliances and between different technology 
types  (traditional  appliances  versus  new  appliances).  More  details  on  these  different  appliances  used  in 
residential combustion of bioenergy and their typical emission levels is provided in Section 4.4.3. 

4.4.3 

Emission factors 

An  emission  factor  specifies  the  amount  of  a  certain  air  pollutant  that  will  be  released  per  unit  of  a  certain 
activity,  for  instance  the  amount  of  a  given  fuel  used.  As  such  it  is  an  important  indicative  number  of  how 
environmentally damaging the combustion of a specific fuel or a type of appliance can be considered. This 
should also be put into perspective with the output (heat or electricity produced) of this given input. According 
to the latest EEA Emission Inventory Guidebook19 for instance, PM2.5 emission factors for residential combustion 
vary between 0.12 and 2.2 g/GJ for natural gas, 0.75 and 6 g/GJ for distillate heating fuel and 72 and 480 g/GJ 
for bituminous coal, with the range primarily determined by the type of combustor.  

For  fuel  wood  the  Guidebook  PM2.5  emission  factors  for  residential  combustion  range  from  37  to  1680  g/GJ 
(including the lower and upper ranges), so with a factor of 50 between the lowest and highest number. This 
particularly  high  range  is  the  result  of  the  wide  range  of  combustor  types  in  use  in  Europe,  but  also  of  the 
operator’s significant influence on combustion efficiency and fuel quality (particularly its moisture content). To 
be  able  to  estimate  pollutant  emissions  from  residential  combustion  of  biomass  with  a  sufficient  degree  of 
accuracy,  it  is  evident that  an  inventory  of  combustion  technologies  used  is  a  prerequisite.  Furthermore,  the 
actual range in operator behaviour should be characterised, as well the actual range in fuel quality. 

During the last decade in particular, many emission measurements have been taken on wood-fired residential 
heating  appliances  throughout  the  world.  Two  publications  are  of  particular  interest  to  Europe  and  further 
discussed here.  

19 EMEP/EEA Air Pollutant Emission Inventory Guidebook, 2019 edition, 
https://www.eea.europa.eu/publications/emep-eea-guidebook-2019  

11/13788A/11 

23 of 104 

28 March 2024 

 
Increasing policy coherence between bioenergy and clean air policies and measures Final Project Report 

Kindbom  &  Mawdsley  (2018)  presented  and  discussed  new  pollutant  emission  measurements  on 20  different 
stoves  and  single  house  boilers,  typical  for  Scandinavia.  Measurements  were  taken  under  various  appliance 
load  factors,  varying  fuel  quality  (standard,  moist  and  dry),  and  various  other  user-determined  parameters, 
which  will  be  further  discussed  in  the  remainder  of  this  section.  The  report  compares  the  measured  emission 
factors for PM in particular to literature data and discusses the differences. Furthermore, it includes instructions 
on how to go from emission factors measured under standard conditions, to (much higher) real-world emission 
factors that include a certain amount of ‘bad combustion’ due to for instance part load instead of nominal 
load  and  moist  fuel.  The  report  confirmed  what  has  been  observed  before,  that  emissions  vary  widely  with 
appliance technology and user operation. In comparison to the emission factors from the EMEP/EEA Guidebook, 
Kindbom  &  Mawdsley  (2018)  generally  measured  somewhat  lower  emissions  under  standard  conditions. 
Accounting for a certain amount of bad combustion brought the emission factors more in line however. 

Klimont  et  al.  (2017) collected  and  compared  literature  emission  factors  for wood-fired  stoves  and  boilers  to 
support a global emission inventory undertaking. On average, the data they collected show somewhat higher 
emission factors than Kindbom et al., being more in line with the EEA Guidebook recommended emission factors. 

Impact of fuel quality 

Both Kindbom & Mawdsley (2018) and Wohler et al. (2016) looked at the influence of fuel quality on emissions. 
Measurements taken by Kindbom & Mawdsley (2018) indicated that using wood with a higher (25-30%) or lower 
(5-15%) moisture content than standard fuel (16-20%) generally increased the emission factors by a factor of 1.5 
– 2. Modern stoves appeared more sensitive to moist fuel, where emissions of PM2.5 increased in the order of 5 – 
8 times compared to when fired with standard fuel. Older technologies  appeared less affected by moist fuel, 
and the emission levels were comparable to the standard fuel. Using extra dry fuel wood also increased emission 
factors, but not to the same extent as moist fuel. Wohler et al. (2016) surveyed behaviour of individual residential 
stove operators in Europe and found that 25% of the used fuel wood was not properly dried. A study for the 
Netherlands20 suggested 20%. 

Most emission measurements like those discussed here are taken with firewood or wood pellets as a fuel. Besides 
firewood and wood pellets, alternative types of solid biofuels may also be used for residential heating. These 
bioenergy carriers can be forest-derived (e.g. forest slash, bark or wood chips) or industrial waste from the wood 
industry (e.g. sawdust, splinter), or agricultural by-products (e.g. straw, olive bone and other herbaceous waste). 
The  use  of  these  or  other  lower  quality  bioenergy  carriers  or  waste-like  fuels  is  often  associated  with  energy 
poverty. Also wood products other than pellets (e.g. densified pressed wood briquettes, or charcoal) may be 
used. 

Often these alternative biofuels have a somewhat lower energy-content than dry firewood. Moreover, they may 
also have a large volume to weight ratio, which makes them impractical to handle by households. They may 
also require modified combustion equipment to burn efficiently. When these fuels are used for residential heating 
this tends to be in higher capacity equipment (>50 kW), for heating multiple homes, rather than in single house 
equipment (e.g. Musule et al. (2021)). This type of higher capacity boiler typically has much lower particulate 
matter emission factors than smaller single house equipment (as explained in the next section). Charcoal is used 
by households directly but mostly used outdoors for grilling foods. Wood briquettes are used by households for 
space  heating  but  there  are  currently  no  indications  that  these  would  cause  higher  emissions  compared  to 
firewood logs (rather the contrary, see e.g. Mitchell et al. (2020)).  

Impact of installation size/type and age 

During  the  last  decades  much  progress  has  been  made  in  optimising  combustion  technology  for  domestic 
combustion of fuel wood. There are basically four types of appliances distinguished in international literature 
with each a different typical capacity range: log wood-fired stoves (5  – 10 kW), log wood fired single house 

20 Van Middelkoop M., R. Segers, Wood use by households – WoON 2018 (in Dutch), CBS report The Hague 
(2019). 

11/13788A/11 

24 of 104 

28 March 2024 

 
Increasing policy coherence between bioenergy and clean air policies and measures Final Project Report 

boilers (10 – 50 kW), medium sized log-fired boilers for heating multiple houses (50 -1000 kW) and wood pellet-
fired stoves and boilers (5 – 1000 kW). For single house appliances, various forms of technology are used for each 
basic  type,  ranging from  traditional  cast  iron  and  masonry  stoves to  advanced  Ecodesign  stoves  and  single 
house boilers, i.e. those stoves and boilers which are meeting the Ecodesign emission limit values.  

Over  the  whole  range  of  equipment  used  to  generate  heat  from  wood-firing,  there  are  three  main  factors 
affecting the emissions from a small-scale combustion appliance. These are explained in Table 4-1. 

Table 4-1: Main factors influencing the emissions of a small-scale combustion appliance 

Size of the 
combustor 

In general, particulate matter emission factors decrease with increasing capacity, 
mainly because of the increasing operating temperature that leads to more efficient 
and more complete combustion. There is also less disturbance of the fire when fresh fuel 
is added. For medium size boilers (50 – 1000 kW), Kindbom and Mawdsley (2018) 
measured emission factors roughly comparable to only the best in class among the 
smaller appliances. This is confirmed by literature emission factors collected and 
reported by Klimont et al. (2017). 

Type of fuel feed 

Fuel feeding in single house equipment is traditionally done manually, by periodically 
adding fresh chunks of wood to the fire. Directly after adding fuel, a period of high 
particulate matter emission may occur when the added fuel starts pyrolyzing under 
heat, but not yet fully burns. Volatile decomposition products are then released as 
particulate matter. When fuel is added continuously in small measured amounts this 
does not happen. Automatic pellet-firing has therefore far lower emission factors than 
(manual) log wood firing, because the precise metering of the fuel leads to a more 
complete combustion. In a higher capacity appliance (>50 kW) this is less of a factor 
because the added amount of fuel is much smaller compared to the amount already 
present, so complete combustion of the added fuel is achieved much quicker. 

Type and 
technical 
sophistication of 
the combustor 

In emission literature, combustion appliances of similar type are usually roughly ranked 
by their level of technical sophistication (which typically follows their environmental 
performance). Three categories are often distinguished: traditional/conventional, 
improved (having a basic form of emission optimisation) and modern/advanced, with 
the latter including the Ecodesign labelled installations. 

For  stoves  and  single  house  boilers  using  wood  in  the  small  combustion  sector,  the  EEA  Guidebook  emission 
factors for PM2.5 range from under 100 g/GJ for modern appliances to 5  – 10 times higher for traditional ones, 
with the improved appliances in between, around 200  – 300 g/GJ (for stoves as well as single house boilers)). 
Kindbom and Mawdsley (2018) measured up to 2 times higher emission factors in traditional stoves compared 
to modern stoves. The pellet-fired automated variants performed by far the best across all appliance types, with 
emission factors being at least a factor 2 below those of the most advanced log wood-fired stoves and boilers. 
For medium sized boilers (50 kW – 1000 kW) emission factors comparable to pellet stoves are reported.  

Impact of behaviour 

It  has  been  shown  many  times  that  user  behaviour  has  a  big  influence  on  the  emissions  of  small  wood 
combustors. User behaviour affects fuel quality, as well as load factor. A smouldering fire for instance (a very low 
load factor) emits relatively large amounts of PM whereas the actual amount of wood combusted is at the same 
time low. This condition then results in particularly high emissions compared to emission factors for nominal load 
operation (i.e. operating the appliance at the designed load).  

Kindbom  and Mawdsley (2018) found that part load combustion conditions (30% of the nominal load) in the 
measured  boilers  increased  the  emission  factors  between  2  –  6  times  compared  to  nominal  load.  For  the 
measured stoves, part load conditions generally increased the emission factors 1.5 – 3.5 times.  

11/13788A/11 

25 of 104 

28 March 2024 

 
 
 
Increasing policy coherence between bioenergy and clean air policies and measures Final Project Report 

Both Kindbom and Mawdsley (2018) and Wohler et al. (2016) recommend that for emission inventories where 
“real life” emissions are estimated, the large sensitivity to operational conditions (moist fuel and part load) needs 
to be taken into consideration, and a certain percentage of incomplete combustion needs to be assumed. 
Relying  on  emission  factors  derived  strictly  for nominal  load  and  standard  fuel  quality  may  give  a  significant 
underestimation of real-world emissions. Wohler et al. surveyed actual user operation of wood-fired appliances 
in Europe, and give guidelines to what degree operator-induced sub-optimal combustion conditions may be 
taken into account. 

One  way  to  reduce  emissions  is  to  provide  the  user  with  guidance  on  how  to  operate  the  device.  A 
presentation21 by the UNECE Task Force on Techno-Economic Issues (TFTEI) provides information on a code of 
good practice for solid fuel burning and small combustion installations based on Best Available Techniques (BAT) 
with the aim of reducing combustion pollutant emissions and the related impact on the environment and human 
health22.  

Influence of prescribed measurement standard 

When  emission  inventories  are  compared  between  countries,  emission  factors  used  for  residential  biomass 
combustion often have a very different basis from country to country. They may vary widely as a result, even for 
comparable appliances. As has been discussed above emission factors are highly dependent on what exactly 
was measured in the underlying experimental evidence, and under what circumstances.  

The  two  prime  reasons  for  emission  factor  inconsistency  is  whether  or  not  an  emission  factor  includes 
condensables (see 4.2.3), and secondly, what user behaviour/fuel quality/combustion cycle is assumed, as is 
explained above. Ideally, condensables are fully accounted for in emission inventories and the assumed  user 
behaviour/fuel quality/combustion cycle represents real-world conditions.  

There  are  several  reasons  why  this  is  sometimes  not  the  case.  Some  countries  require  for  legal  reasons  that 
emission factors used in inventories have to be based on emission factors measured in type testing, for instance 
to check whether a certain appliance meets an applicable emission limit value. Typically measurements which 
are intended intended to check whether a certain appliance meets legal emission limit values, such as those 
adopted  under  the  Ecodesign  Directive, use  a  dedicated  measurement  standard  in  which  usually  only  solid 
particles  are  measured  for consistency reasons.  Such a  dedicated  standard  may  be  very  specific  regarding 
equipment to use, procedures to be followed, fuel specification, load factors etc., which is necessary to get 
reproducible  results.  However,  when  these  standards  do  not  represent  the  real-world  practice,  they  are 
unsuitable to assess real-world emissions. These specific type testing standards are therefore not discussed here 
in relation to emission factors. 

Another reason to use domestic emission factor measurements exclusively are country-specific appliance types 
and available biomass types, for which there is little information available in literature. 

In countries that do not have such obligations, inventory compilers can select any scientific source for emission 
factors that they deem appropriate. Usually, condensables are included in such cases and often a partly sub-
optimal combustion cycle is assumed, which may include a certain amount of part load and moist fuel.  

As discussed earlier, whether or not a used measurement standard includes condensables or not, will lead to 
very different results. Indicatively a relative increase of a factor 2 is often observed for modern appliance types, 
whereas for older appliance types this could be a factor of 3 to 4, and in some cases even higher (see e.g. 
EMEP/EEA Guidebook). A measurement standard may also prescribe a certain combustion cycle (prescribing 
the manner of ignition, fuel batch sizes, load factors, duration of the cycle, fuel quality etc.). Similar to the choice 
whether to include condensables, different combustion cycles can lead to very different results. An extreme 
case was described by Kindbom & Mawdsley (2018). They compared emission factors determined according 

21 https://unece.org/fileadmin/DAM/env/documents/2019/AIR/WGSR/item_3_Tiziano_Pignatelli.pdf  
22 Other examples of measures to reduce emissions or environmental impacts thereof are available from the 
case studies (see chapter 6). 

11/13788A/11 

26 of 104 

28 March 2024 

 
Increasing policy coherence between bioenergy and clean air policies and measures Final Project Report 

to  the  European  EN 16510 standard  to  the Norwegian  NS3058  standard  on  the  same  two  improved/modern 
stoves.  The  difference  between  the  two  standards  is  mainly  the  prescribed  combustion  cycle,  as  the  firing 
scheme of the NS3058 standard included much more part load operation than EN 16510, and in fact adopted 
the majority of the operation at part load. The results showed that the Norwegian standard resulted in a factor 
of 5 higher PM2.5 emission factor compared to nominal load and standard fuel quality as prescribed by EN 16510. 

Annex A1 provides more technical background on the different measurement methods, and also describes how 
the appliance type test operating procedures fit in there. Annex A1 elaborates on the following two specific 
elements: 

• 

• 

The pollutant sampling method (with or without condensables for particulate emissions) used to determine 
the emissions 

Procedures  for  appliance  tests  (i.e.  concerning  combustion  phases  tested,  types  of  nominal  or  reduced 
combustion speed, fuel quality) and how these relate to real-life emissions 

Conclusion on emission factors 

The PM2.5 emission factors for nominal load and standard fuel quality, including ignition, as measured by Kindbom 
&  Mawdsley  (2018)  and  aggregated  to  rough  environmental  standard  (‘modern’,  ‘old’,  ‘pellet’  boiler/stove) 
are provided in Table 4-2. All emission factors are based on measurements using a dilution tunnel approach at 
ambient temperature, thus fully including condensables. 

Table 4-2: Emission factor (range) for most used appliances in residential wood combustion as measured by 
Kindbom & Mawdsley (2018) 

Type 

Stove (g/GJ) 

Single house boiler 
(SHB) (g/GJ) 

Modern 

50-100 

Old 

Pellet 

100-200 

~ 50 

50-100 

~ 300 

~ 30 

Emission factors for boilers were found to be highly sensitive to part load operation, whereas modern stoves were 
very sensitive to fuel moisture content. A particular state-of-the-art stove measured by Kindbom & Mawdsley 
(2018) appeared only moderately sensitive to fuel moisture and almost insensitive to part load operation. As a 
result of these sensitivities, assuming a certain amount of part load operation, or moist fuel could easily double 
the emission factors in Table 4-2.  

In Kindbom & Mawdsley (2018) an extensive comparison between their measured emission factors and literature 
data was made. All measured appliances in this study, including their range as a result of partial incomplete 
combustion, plus all literature values quoted in there (such as by Klimont et al. 2017, including range) have been 
plotted  in  Figure  4-7.  Appliances  are  aggregated  and  sorted  according  to  main  type  and  environmental 
standard (X-axis categories). Blue dots represent the reported central values while the error bars represent their 
range. The green line shows the median values for stoves, boilers and pellet-fired appliances, by environmental 
standard. It is obvious from the figure that literature data vary widely. Even within comparable appliance classes 
the variation is typically around one order of magnitude. Note in this  respect the logarithmic Y-axis. In spite of 
the  large  scatter,  the  median  values  do  show  a  decreasing  trend  with  technological  sophistication,  as 
expected. 

11/13788A/11 

27 of 104 

28 March 2024 

Increasing policy coherence between bioenergy and clean air policies and measures Final Project Report 

Note: SHB = single-house boiler. 

Figure 4-7: Range of emission factors for residential wood combustion reported in literature per main type and 
environmental class. Blue dots represent individual measurements, green line represent median value per 
appliance type. Adapted from Kindbom and Mawdsley (2018) 

4.4.4 

Regional impacts of bioenergy use 

The impacts of bioenergy on air quality and associated impact on human health and the environment varies 
between different regions in Europe. This does not only depend on the actual emissions of bioenergy use, but 
also on emissions of other substances in the region, emissions from the neighbouring regions, local topography, 
climatological conditions, etc. The health impacts or possible exceedances of limit values are always due to the 
combination  of  all  these  factors.  Hence,  the  areas  with  relatively  high  emissions  from  bioenergy  are  not 
necessarily the regions with the highest impacts. 

In recent years, some tools have been built to assess the impact of specific sources on air quality in cities, mostly 
to provide policy makers at local level with information on the origin of the sources responsible for the pollution 
in  their  cities.  This  knowledge  helps  to  define  policy  measures  that  are  most  effective  given  the  local 
circumstances. One example is the Urban PM2.5 Atlas from JRC23. It provides the annual average concentrations 
of PM2.5 and PM10 for 150 cities in Europe, as well as a high-level breakdown of the main sources contributing to 
the  concentrations,  based  on  the  SHERPA  model  approach.  In  addition  to  the  sources,  there  is  also  a  split 
between contributions from the local area, the rest of the country and of transboundary origin. While the sources 
do not specifically include emissions from the use of bioenergy, as pointed out previously, the PM2.5 emissions 
from the residential sector largely originate from the use of bioenergy, while the PM2.5 emissions from bioenergy 
use  in  large  combustion  plants  (energy  and  manufacturing  industry)  are  relatively  small.  The  contribution  of 
residential  combustion  is  therefore  a  suitable  approximation  for  the  contribution  of  bioenergy  use  in  most 

23 https://publications.jrc.ec.europa.eu/repository/handle/JRC134950  

11/13788A/11 

28 of 104 

28 March 2024 

 
 
Increasing policy coherence between bioenergy and clean air policies and measures Final Project Report 

Member States, only in those that have a significant share of coal use in the residential sector this approximation 
is not valid (cf. Figure 1-5).  

The JRC Urban Atlas builds on emissions as reported and taken up by the CAMS-REG-v6.1 inventory (Kuenen et 
al.  2022).  In  contrast  to  the  earlier  Urban  Atlas  (2021)  a  CAMS-REG  version  is  used  where  reported  small 
combustion  PM  emissions  are  replaced  with  a  dataset  that  consistently  includes  condensables  (the  “Ref2” 
dataset described in Section 4.3.3), to avoid the inconsistency between different countries and to be able to 
consistently assess the contribution of different sources across cities in Europe. 

Apart from the estimation of bioenergy emissions at country level, also the spatial variability of the bioenergy 
emissions (from country to grid level) is a key source of uncertainty. A generic method was used over Europe for 
this purpose, where based on population density and degree of urbanisation, a hypothetical wood demand 
function was derived. Given that urban areas are typically connected to gas networks or other means of heating 
possibility, the use of bioenergy is less common compared to rural areas which are not connected to a network. 
However, some use of bioenergy, also in relation to recreational use in outdoor environments, is allowed to take 
place. In addition to this, a fuel supply function is derived estimating how much fuel wood is being produced 
based  on  land  cover.  These  two  functions  are  overlaid  spatially  assuming  that  locally  produced  fuelwood  is 
mainly supplied to neighbouring area.  This method implies most wood is used in rural areas and in urban areas 
a  limited  amount  of  wood  burning  is  assumed  to  take  place.  In  practice,  however,  some  cities  have  put 
restrictions or even bans on wood burning, while in others it may be more widespread, which means that in some 
countries  bioenergy  use  emissions  in  urban  areas  are  likely  to  be  overestimated  while  in  others  it  may  be 
underestimated.  While  the  knowledge  on  where  wood  is  used  is  clearly  an  uncertainty,  the  currently  used 
methodology for spatially distributing wood combustion emissions is the state-of-the-art for Europe as a whole. 
Further improvements should focus on representing local regulatory and cultural aspects in the representation 
of wood burning emissions. 

The  JRC  Urban  Atlas  finds  that  the  residential  sector  is  responsible  for  more  than  35%  of  the  PM2.5  urban 
background concentrations in a number of cities, for instance in northern and central Italy but also in Poland, 
Czechia, Slovenia, Croatia, Hungary, Romania and Bulgaria. There is a wide range of cities across Europe which 
are largely affected by emissions from the residential sector which, given the large contribution of bioenergy to 
residential PM2.5 emissions, in most cases also implies that they are largely affected by bioenergy combustion. In 
comparison to the earlier 2021 JRC Urban Atlas, the contribution of residential emissions to urban background 
PM2.5 concentrations increased, which is partly related to higher emissions which include the condensable part 
of PM2.5 across Europe. 

The  EEA  annually  publishes  maps  of  the  measured  air  pollutant  concentrations  in  relation  to  the  limit  values 
currently in the EU legislation24. For PM2.5 in 2021, in northern Italy, southern Poland and northern Czechia as well 
as in Croatia  the reported annual mean concentrations  exceed the annual mean concentration limit value. 
These regions  are also regions where a high share of the residential sector is reported in the aforementioned 
Urban PM2.5 Atlas, which implies that bioenergy use is likely an important contributor to the exceedances.  

• 

• 

• 

For Croatia, the Urban Atlas only considers the city of Zagreb. The contribution of residential emissions in the 
PM2.5 mass is modelled to be above 45% 

In Italy, it is typically the Po Valley which shows exceedances. Looking specifically at the cities in this area, 
typically 35-45% contribution from the residential emissions is modelled, with for Turin and Florence higher 
contributions around 50% 

For the cities in southern Poland, typical contributions of the residential sector are modelled to be above 
50% (for instance in Krakow and Warsaw). Important especially for Poland is that in contrast to most other 

24 https://www.eea.europa.eu/publications/europes-air-quality-status-2023 

11/13788A/11 

29 of 104 

28 March 2024 

 
Increasing policy coherence between bioenergy and clean air policies and measures Final Project Report 

Member States the residential PM2.5 emissions contain an important share of coal combustion, which implies 
that the bioenergy contribution is significantly lower than this share 

• 

For Czechia, six different cities are considered, with a residential contribution to the modelled PM2.5 mass 
typically above 35% in all of them. Although less than in Poland, also in Czechia the use of coal for residential 
heating plays a role, which reduces the contribution from bioenergy alone 

All in all, from the available information it can be concluded that especially in Croatia and northern Italy (Po 
Valley), the contribution of bioenergy use to the PM2.5 exceedances is significant. For Poland on the other hand, 
the impact of the residential sector is a combination of the combustion of wood and coal, so the contribution 
of bioenergy use alone to the exceedances is not possible to quantify.  

In addition to the JRC study, the CAMS policy service25 provides similar information, but more focused on the 
short term (predicted PM2.5 concentrations and responsible sectors in a set of cities in the next 4 days) to support 
short-term actions. However, given the temperature dependency of bioenergy use in the residential sector, such 
a short-term forecast cannot be used to assess the impact of bioenergy on average annual PM2.5 concentration 
levels. 

Furthermore, Kukkonen et al. (2020) aimed to quantify the importance of residential wood combustion on PM2.5 
concentration  levels  in four  Nordic cities,  and  concluded  that  in three  out  of four  cities,  the  predicted  levels 
reached up to ~20%. For Oslo however, contributions up to 60% in specific areas of the cities were found.  

4.5 

Prospects for future bioenergy uptake and impacts 

This section discusses the possible development of bioenergy uptake in the future and its impacts on air quality 
in the EU, building on the scenario modelling that has been performed at EU level underpinning the 3 rd Clean 
Air Outlook (CAO3). 

4.5.1 

Future bioenergy uptake under various scenarios 

The CAO3 baseline scenario has been derived from the PRIMES energy system model. The PRIMES energy system 
modelling  suite  includes  different  bioenergy  products  in  all  sectors  of  the  economy.  An  overview  of  the 
bioenergy products included in the PRIMES model is available in Figure 4-8. The liquid bioenergy products are 
mainly used in the transport sector as biofuels, while gaseous products are used either for direct heat and power 
generation locally or are blended in the natural gas grid. Solid bioenergy is used for power generation and heat 
either  in  large-scale  installations  for  power  generation  as  well  as  CHPs  for  industry  or  district  heating,  or  at  a 
smaller scale for heating in the domestic sector (e.g. pellet burners). The PRIMES model also includes the use of 
waste (both renewable and non-renewable waste).  

25 https://policy.atmosphere.copernicus.eu 

11/13788A/11 

30 of 104 

28 March 2024 

 
Increasing policy coherence between bioenergy and clean air policies and measures Final Project Report 

Figure 4-8: Bioenergy products included in the PRIMES Energy System model26 

All bioenergy products used in PRIMES are considered sustainable, i.e. compliant with the sustainability criteria 
of the Renewable Energy Directive. The production of the quantities of bioenergy products is calculated through 
the PRIMES biomass model which computes the feedstock requirements for bioenergy and the potentials for 
bioenergy products are in turn derived from agricultural models such as CAPRI and Land Use Models such as 
GLOBIOM.  

For  the  purpose  of  this  study,  we  show  the  evolution  of  the  consumption  of  solid  bioenergy  in  the  stationary 
demand. Currently solid bioenergy is used primarily (45%) in the small combustion sector which comprises the 
residential,  commercial/institutional  and  agricultural  stationary  combustion.  Combustion  of  biomass  in  the 
energy transformation sector27 and in industry comprises 22% and 20%, respectively. The consumption in industry 
includes both consumption in onsite boilers or combined heat and power (CHP) units, as well as in furnaces. In 
future  projections  derived  using  the  PRIMES  model,  when  considering  a  net-zero  scenario  (e.g.  the  CAO3 
scenario), the amount of bioenergy use increases and the split between sectors changes: 

• 

• 

• 

Solid bioenergy use in the small combustion sector is projected to reduce and then almost stabilise. This is 
the result of renovation in European buildings incl. change of equipment to higher efficiency, as well as a 
shift towards electrification through heat pumps 

Similarly in the industrial sector: the solid bioenergy consumption reduces and then almost stabilises. This is 
also due to efficiency in equipment and processes (incl. heat recovery), electrification and the shift to new 
process types using e.g. hydrogen  

The energy transformation sector is the sector where the use of solid bioenergy consumption is increasing, 
which is due to a shift towards biomass in power and steam/heat generation, which represents a form of 
dispatchable power generation in a system otherwise dominated by variable renewable energy sources   

Figure 4-9 shows these changes for the CAO3 baseline projection of bioenergy consumption in EU27 until 2050. 

26 PRIMES model description 2022, available at https://e3modelling.com/modelling-tools/primes/ 
27 The energy transformation sector includes power, steam/heat generation as well as other elements of the 
transformation sector such as Blast Furnaces (based on the EUROSTAT energy balance split). 

11/13788A/11 

31 of 104 

28 March 2024 

 
 
Increasing policy coherence between bioenergy and clean air policies and measures Final Project Report 

Figure 4-9: Consumption of solid bioenergy by sector in the stationary demand (source: PRIMES scenario that 
meets the Fit for 55 targets for 2030 and climate neutrality in 2050) 

Finally, it should be mentioned that bioenergy consumption in EU27 in future years is dependent on the choices 
made  for  the  scenario,  for  instance  regarding  assumptions  about  the  potential  of  available  biomass  (and 
related products), biomass prices (and subsidies) and also regarding the (level of) deployment of the specific 
CO2 reduction options like Carbon Capture and Storage (CCS). The actual development of these factors in 
future years will also impact the bioenergy use and hence its environmental impact. 

4.5.2 

How bioenergy related emissions and their impacts are expected to evolve in the 
future 

Current (2020) EU27 emissions of PM2.5 from solid biomass use were estimated at 580 to 650 kt (Figure 4-12), where 
upper  value  includes  harmonized  set  of  emission  factors  including  condensable  PM  from  residential  heating 
sector (Klimont et al., 2022a; Simpson et al., 2022), and over 97% of these emissions originated from residential 
heating sector (as shown also in Figure 4-4). Overall, bioenergy related emissions represented over 50% of total 
anthropogenic  PM2.5  emissions  in  the  EU27  (Figure  4-10).  While  the  increment  in  total  PM2.5  emissions  due  to 
inclusion of condensable PM seems rather small (about 10-20% at the EU27 level) this is variable across regions 
and the Baseline calculation in GAINS partially already includes the condensable fraction (comparable to the 
mixed reporting by countries as described in Section 4.3.3, see more detailed discussions in the reports supporting 
the 3rd Clean Air Outlook28; Klimont et al., 2022b). The Baseline scenario that includes assumptions consistent with 
the Green Deal objectives, which result in declining use of bioenergy in residential sector (see previous section) 
and  assume  implementation  of  Ecodesign,  results  in  steady  decline  of  emissions  from  bioenergy  as  well  as 
declining share in total emissions. However, despite the overall reduction in emissions by over 50% by 2030 and 
nearly 80% by 2050, compared to 2020, bioenergy continues to represent over a third of total PM2.5 emissions 
even by 2050 with residential sector contributing well over 90% out of all bioenergy emissions. The scenario which 
reflects  the  proposal  for the  revision  of the Ambient  Air  Quality  Directive,  i.e.,  aiming  at reducing  the  annual 
mean PM2.5 concentrations to levels below 10 µg/m3 – ‘Baseline-OPT10’, brings additional 40% reduction of PM2.5 
emissions in 2030 resulting in over 70% reduction of bioenergy related emissions compared to 2020.  

28 https://environment.ec.europa.eu/topics/air/clean-air-outlook_en  

11/13788A/11 

32 of 104 

28 March 2024 

 
 
Increasing policy coherence between bioenergy and clean air policies and measures Final Project Report 

Figure 4-10: Emissions of PM2.5 and selected air pollutants from bioenergy use in residential and in other sectors 
combined in the EU27 as well as share of bioenergy related emissions in total anthropogenic emissions. 
Source: GAINS model results from the third Clean Air Outlook (Klimont et al., 2022a, 2022b) 

Figure 4-10 also shows emissions of selected air pollutants from bioenergy use. NMVOC emissions decline similarly 
to PM2.5, largely because residential sector dominates these emissions (80-95%) and declining fuel use as well as 
improvement  in  efficiency  of  residential  installations  bring  strong  reductions.  The  share  of  bioenergy  related 
emissions in total NMVOC drops from over 10% to below 5% in the long term. The picture looks different for Nox 
and NH3, where for the latter the decline is driven by fuel use reduction and the overall share of bioenergy is 
very small, about 2-3%. For Nox, the emission trajectory is not alike for other species because overall contribution 
of the residential sector to all bioenergy related emissions is only about half while power generation and industrial 
uses represent the other half. Their fuel use trends are different, including in the longer term a slight decrease of 
bioenergy use in industry and an increase in the power and transformation sector. In the Baseline, the share of 
emissions from bioenergy in total NOx emissions increases over time from about 6-7% in 2020 to about 15% in 
2050,  which  is  mostly  driven  by  more  significant  reductions  of  Nox  emissions  in  other  sectors,  including 
transportation and use of fossil fuels in stationary combustion. The share of bioenergy emissions in the OPT10 case 
increases slightly for both NH3 and NOx because reductions in other sectors are much stronger. 

As  indicated  earlier,  consistent  consideration  of  condensable  fraction  of  PM  (Simpson  et  al.,  2022)  in  used 
emission factors (Efs) results in increased emissions from biomass combustion (Figure 4-11). This has implications 
on  concentrations  of  ambient  PM2.5  which  were  analysed  in  the  study  supporting  the  3rd  Clean  Air  Outlook 
(Klimont  et  al.,  2022a).  Here  we  show  a  summary  figure  illustrating  the  PM2.5  increment  across  the  EU  from 
including condensables in a consistent way, shown as increase/decrease in absolute terms (µg/m3) and relative 
(%) change when compared to the Baseline case concentrations (Figure 4-11). Most significant increases are 
seen in central Europe including Austria, Czechia, and parts of Germany and Italy while small decreases (the 
original GAINS emission factors appear to be higher than the harmonized set of emission factors proposed in 
Simpson  et  al.  (2022))  are  shown  for  Poland  and  Norway.  The  relative  changes  (Figure  4-11,  right)  highlight 
importance  of  inclusion  of  condensable  in  Austria,  Germany,  France  which  is  consistent  with  the  reporting 
practice in these countries, i.e., reported PM2.5 from residential sectors do not include condensable fraction of 
PM (based on the 2021 reporting cycle, in some countries this may have been updated since then). Overall, 
across the EU27, harmonization of condensable emission factors results in estimated higher number of premature 

11/13788A/11 

33 of 104 

28 March 2024 

 
Increasing policy coherence between bioenergy and clean air policies and measures Final Project Report 

deaths by about 2-3%, i.e., 7-8 thousand per year, compared to the Baseline case and similarly 2-3% in YOLLs29, 
i.e., by about 6-7 million (more detailed results presented in Klimont et al. (2022b). 

Figure 4-11: Comparison of annual mean concentrations of PM2.5 in 2015 estimated in the GAINS model in the 
standard setup and using the harmonized set of PM2.5 emission factors including condensable fraction of PM 
from Simpson et al. (2022). Difference maps (GAINS standard Efs vs GAINS with harmonized/condensable Efs) 
showing absolute (left) and relative (right) difference for 2015. 

While primary PM2.5 emissions from bioenergy play a very important role in contributing to total concentrations 
of PM2.5, there are also significant sources (not bioenergy related) of other ambient PM precursors including SO2, 
Nox and NH3. Consequently, the contribution of bioenergy to the concentrations of PM2.5 is smaller than its share 
in  emissions  of  primary  PM2.5.  This  is  illustrated  in  Figure  4-12.  In  general,  residential  combustion  dominates 
contribution  from  bioenergy  with  power  sector  and  industrial  uses  contributing  only  1-2%  to  concentrations. 
Overall,  for  few  countries,  i.e.,  Croatia,  Hungary,  Latvia,  Romania  and  Slovenia  residential  combustion  of 
bioenergy contributes between 40 and 50% of total PM2.5 annual mean concentrations in 2020, with few more 
counties  (Bulgaria,  Italy,  Lithuania,  Slovakia)  where  that  contribution  is  about  30%.  Overall,  the  PM2.5 
concentrations decline across EU27 in the Baseline and a significant part of the reduction in concentrations can 
be  attributed  to  reduced  emissions  from  bioenergy  use,  therefore  its  contribution  to  concentrations  (also 
relative) declines (Figure 4-12). In the OPT10 case further decline of concentrations as well as share of bioenergy 
is  expected  with  only  few  countries  showing  about  30%  share  of  bioenergy  in  total  concentrations  of  PM2.5, 
including Croatia, Latvia, and Slovenia.

29 Years of Life Lost 

11/13788A/11 

34 of 104 

28 March 2024 

 
 
Increasing policy coherence between bioenergy and clean air policies and measures Final Project Report 

Figure 4-12: Contribution of biomass use in residential, power, and industry sectors to total population weighted annual mean PM2.5 concentrations in the 
EU27 countries for 2020 and 2030 Baseline and OPT10 scenarios 

11/13788A/11 

35 of 104 

28 March 2024 

 
 
Increasing policy coherence between bioenergy and clean air policies and measures Final Project Report 

5 

EU Level Bioenergy Drivers and Policy Framework 

Summary and outcomes: 

•  Within the overarching framework of European Union energy, environmental and public health policy, there 
are  both  drivers  for  the  increased  uptake  of  renewable  energy  and  heat  (including  bioenergy),  and  for 
improving air quality (and thus public and environmental health) 

• 

• 

The legislative and policy measures for energy and climate on one hand and air quality on the other are, in 
general, separate and distinct. The only main point of cross-over is the Ecodesign Directive, which seeks to 
control emissions from new small bioenergy appliances (amongst many other product controls) 

Specific policies to either encourage the use of bioenergy or seek to control the air pollution emissions from 
small-scale bioenergy largely rest at the Member State level. EU policies provide broad scale drivers and 
targets  for  energy,  climate  and  air  quality.  The  separation  of  policy  instruments,  e.g.  Renewable  Energy 
Directive and Ambient Air Quality Directive, potentially adds to the perception that they are not cohesive 
and could be seen as driving in different directions 

This chapter assesses EU policy and legislation, identifying those areas which act as drivers for the increased use 
of bioenergy, and those which are aimed at protecting air quality. The latter may have a suppressing effect on 
bioenergy use, but could also act as a driver for the uptake of cleaner bioenergy, e.g. at the domestic scale 
through the incentivisation of more efficient appliances. This largely depends on implementation  by Member 
States, but some legislation will have a more direct impact, such as through the Ecodesign Directive emission 
limits for new stoves and boilers. 

Annex 1)a)i)(1)(a)(i)A5 summarises the EU policies, legislation and other regulatory instruments which currently 
impact on bioenergy use within the  EU. It shows both increasing and decreasing pressures on bioenergy use 
from policy instruments, including within the same instrument. This is tied to the fact that bioenergy is a key source 
of renewable energy and, in particular, renewable heat. However, it is not the only source of renewable heat 
and so increases in renewable energy/heat use need not necessarily result in an increase in bioenergy. By the 
same token, initiatives such as ecodesign, energy labelling and the Medium Combustion Plants Directive  can 
be used to reduce the impact of bioenergy on air pollutant emissions and thus offer the potential to increase 
renewable heat without degrading air quality, depending however on the scale of this development. 

5.1 

General policy on energy, climate and the environment  

The trade-off between increasing bioenergy use and reducing air pollutant emissions is already well recognised 
by  environmental,  health  and  energy  communities  alike30  as  well  as  in  European  Commission  working 
documents.31 This trade-off calls for a more integrated approach to meeting renewable energy and air quality 
targets  in the  EU  as  the 2030  Climate  Target  Plan  impact  assessment forecasts that the  use  of  bioenergy will 
increase to 2050.32 The increase in bioenergy to meet renewable energy targets needs to be considered in the 

30 See for instance: https://www.eionet.europa.eu/etcs/etc-cme/products/etc-cme-reports/renewable-
energy-in-europe-2019-recent-growth-and-knock-on-effects and https://www.iea.org/articles/does-
household-use-of-solid-biomass-based-heating-affect-air-quality. The scientific evidence on pollutant emissions 
from biomass combustion and related health is summarised in a report by the UK Air Quality Expert Group for 
Defra (2017) report on ‘The Potential Air Quality Impacts from Biomass Combustion’, chapter 3 [ https://uk-
air.defra.gov.uk/assets/documents/reports/cat11/1708081027_170807_AQEG_Biomass_report.pdf ]. In a global 
context, WHO on household air pollution and health summarises the health hazards related to indoor air 
pollution from biomass burning [ https://www.who.int/news-room/fact-sheets/detail/household-air-pollution-
and-health ]. 
31 See the impact assessments underlying the Commission’s proposals for a revised Renewable Energy 
Directive (SWD(2021) 621 final) and for a recast of the Energy Taxation Directive (SWD(2021) 641) 
32 SWD(2020) 176 final 

11/13788A/11 

36 of 104 

28 March 2024 

 
Increasing policy coherence between bioenergy and clean air policies and measures Final Project Report 

wider context of the European Green Deal, in particular the Zero Pollution Action Plan and the proposed  revision 
of  the  Ambient  Air  Quality  Directives  (AAQD)33  and  their  planned  closer  alignment  to  the  updated  WHO  air 
quality guidelines34 (and on which a provisional political agreement was reached between the Council and the 
Parliament in early 202435) 

The European Green Deal36 (COM/2019/640) offers an overall framework for EU environment policy. It provides 
a set of policy initiatives to deliver the overarching goal of climate neutrality to the EU by 2050, supported by 
initiatives across all sectors of society. The goals included in the deal relate to circular economy, construction, 
biodiversity,  energy,  transport,  industry,  and  food.  It  includes,  inter  alia,  a  proposal  for  a  Carbon  Border 
Adjustment Mechanism, a new circular economy action plan, a review of all relevant climate-related policy 
instruments, a Farm to Fork strategy, a revision of the Energy Taxation Directive, a sustainable and smart mobility 
strategy, a Biodiversity Strategy and an EU forest strategy. 

5.2 

Potential legislative/policy drivers for the uptake of bioenergy 

5.2.1 

Policy and legislation 

By  the  end  of  2019,  EU  Member  States  were  required  to  submit  a  ten-year  integrated  national  energy  and 
climate plan (NECP) for the period 2021 to 2030, under the regulation on the governance of the energy union 
and climate action (EU/2018/199), with an update required by 30 June 2024. These plans contain information 
on the action of the Member State related to the five dimensions of the energy union: decarbonization, energy 
efficiency, security of supply, market integration and research, development and competitiveness. PaMs that 
directly or indirectly impact these dimensions should be reported and the review reports contain an assessment 
of  the  adequacy  of  these  policies.  As  an  increase  in  the  use  of  bioenergy  is  being  used  to  support 
decarbonization in the EU, relevant PaMs to increase the use of bioenergy are included in Member State NECPs.  

Renewable Energy Directive (RED) 

Demand for renewable energy in the EU is increasing as Member States look to meet renewable energy targets 
as  set  under  the  Renewable  Energy  Directive  (RED)  in  the  effort  to  reach  the  EU’s  target  of  reducing  net 
greenhouse gas emissions by at least 55% by 2030 and achieve climate neutrality by 2050. The recast RED (“RED 
II”)37 sets a common target for Member States (currently 32% by 2030) for the percentage of energy consumption 
sourced from renewable energy. Under the Fit for 55 package of proposals adopted in July 2021, the European 
Commission proposed an increase in the RED target to 40% by 2030, which will directly transpose to national 
targets. To accelerate this transition, the REPowerEU plan has proposed further increasing the RED target to 45% 
by 2030. There is now even greater incentive to reduce the EU’s dependence on fossil fuels, particularly those 
sourced from Russia, as a result of their unprovoked aggression against Ukraine.  On 30 March 2023, the European 
Parliament and the Council reached an agreement and set a binding renewable energy target of a minimum 
42.5%,  but  aiming  for  45%,  for  203038.  The  amended  REDII39  entered  into  force  on  20  November  2023  with  a 
transposition deadline by 21 May 2025 (1st of July 2024 for the permitting-related provisions). The amended RED 
II,  among  other  elements,  includes  a  reinforcement  of  the  sustainability  criteria  for  bioenergy,  as  well  as  an 

33 https://environment.ec.europa.eu/topics/air/air-quality/revision-ambient-air-quality-directives_en  
34 https://www.who.int/publications/i/item/9789240034228  
35 https://www.consilium.europa.eu/en/press/press-releases/2024/02/20/air-quality-council-and-parliament-
strike-deal-to-strengthen-standards-in-the-
eu/#:~:text=Today%20the%20Council%20presidency%20and,in%20the%20EU%20by%202050  
36 https://commission.europa.eu/strategy-and-policy/priorities-2019-2024/european-green-deal_en  
37 Directive (EU) 2018/2001 of the European Parliament and of the Council of 11 December 2018 on the 
promotion of the use of energy from renewable sources (recast), OJ L 328, 21.12.2018, p. 82–209 
38 https://energy.ec.europa.eu/topics/renewable-energy/renewable-energy-directive-targets-and-
rules/renewable-energy-directive_en  
39 DIRECTIVE (EU) 2023/2413 of the European Parliament and of the Council of 18 October 2023 amending 
Directive (EU) 2018/2001, Regulation (EU) 2018/1999 and Directive 98/70/EC as regards the promotion of 
energy from renewable sources, and repealing Council Directive (EU) 2015/652 

11/13788A/11 

37 of 104 

28 March 2024 

 
Increasing policy coherence between bioenergy and clean air policies and measures Final Project Report 

obligation to Member States to apply the cascading principle in their financial support schemes.  This is likely to 
have impacts on the availability, price and use of biomass for energy. 

5.2.2  Other factors 

IEA  Bioenergy’s  Annual  Report  202140  provides  information  of  the  trends  of  bioenergy  in  the  IEA  Bioenergy 
member  countries  up to 2019,  looking  at the  role  of  bioenergy  in total energy  supply,  in  electricity  use,  total 
fuel/heat consumption, and in transport energy consumption. This includes Austria, Belgium, Croatia, Denmark, 
Estonia, France, Germany, Ireland, Italy, Netherlands, Sweden and EU as a whole. Individual country reports are 
also available alongside the main report.  

The relative cost of different energy options will be a major driver in their uptake and use. Reporting from the 
International  Renewable  Energy  Agency  (IRENA)  shows  that,  relative  to  fossil  fuelled  energy  generation,  the 
costs of renewable energy, including bioenergy, have fallen globally41. However, the report also notes the wide 
variation in costs and that, for small-scale use (e.g. domestic), consistent information on feedstock costs is very 
difficult to identify. In addition, relative costs of different fuels are highly variable and can differ considerably 
over time. Anecdotal evidence indicates a shift towards bioenergy, especially during times of economic stress, 
for example, the use of open fires during the economic crash in Greece or a significant rise in the use of wood 
fuel in the UK during the winter of 2022/23 in response to significant rises in gas and electricity prices. In the latter 
case, this increased demand also meant an increase in the cost of fuel logs and it is not clear the extent to 
which shifting to bioenergy was an actual energy saving or a perceived one42. This is further complicated by the 
fact  that  wood  fuel  is  often  acquired  for  domestic  use  through  informal  routes,  e.g.  foraging,  community 
supplies, local agricultural suppliers, etc. 

5.3 

Potential legislative and policy restrictions on the uptake of 
bioenergy 

Supporting the European Green Deal, the Zero Pollution Action Plan: "Towards a Zero Pollution for Air, Water and 
Soil" (COM/2021/400)43 was adopted on 12th May 2021. It sets out a zero-pollution vision for 2050 and aims to 
reduce pollution levels in air, water and soil so that they are no longer harmful to human health and natural 
ecosystems. This is to be achieved through a number of key targets to 2030, including a reduction in premature 
deaths from poor air quality by 55% compared to 2005 levels. 

EU air pollutant emission reduction commitments  

Increasing the production of renewable energy in the EU is considered key to meeting the EU’s target of a 55% 
reduction in GHG emissions by 2030 (compared to 1990 levels). However, the conflicting environmental impacts 
of renewable energy sources need to be considered. Whilst renewable, increasing the use of bioenergy raises 
concerns  for  air  pollution  (amongst  other  environmental  problems),  conflicting  with  emission  reduction 
commitments for air pollutants. In the EU, Member State emission reduction commitments are set out under the 
National Emission reduction Commitment Directive (NEC Directive44) for five key air pollutants: Nitrogen oxides 
(NOx), non-methane volatile organic compounds (NMVOCs), sulphur dioxide (SO2), ammonia (NH3), and fine 

40 IEA Bioenergy (2021). Annual Report 2021. https://www.ieabioenergy.com/wp-
content/uploads/2022/04/IEA-Bioenergy-Annual-Report-2021.pdf  
41 Report: https://www.irena.org/Publications/2023/Aug/Renewable-Power-Generation-Costs-in-2022, 
infographic: https://www.irena.org/News/articles/2023/Aug/Infographic-Renewable-Power-Generation-Costs-
in-2022  
42 Evidence on the level of domestic burning in the UK is being developed but had not been published at the 
completion of this report (March 2024). 
43 https://environment.ec.europa.eu/strategy/zero-pollution-action-plan_en  
44 Directive (EU) 2016/2284 of the European Parliament and of the Council of 14 December 2016 on the 
reduction of national emissions of certain atmospheric pollutants, amending Directive 2003/35/EC and 
repealing Directive 2001/81/EC 

11/13788A/11 

38 of 104 

28 March 2024 

 
Increasing policy coherence between bioenergy and clean air policies and measures Final Project Report 

particulate matter (PM2.5). There has been an identified increase in PM2.5 and NOx emissions since 2005 because 
of the increase in the use of biomass.45 

By April 1, 2019, all EU Member States were required to submit a national air pollution control program (NAPCP) 
report.  These  reports contain  information  on the  policies  and  measures  (PaMs)  that  each  Member  State  has 
implemented to fulfil their commitments to reduce air pollutant emissions from 2020-2029 and beyond 2030. The 
pollutants in scope under the NAPCP include the five primary air pollutants, NOx, NMVOCs, SO2, NH3, and PM2.5, 
as  well  as  PM10  and  black carbon.  Policies targeting bioenergy  are  likely  to  be  included,  as  it  is  a  significant 
source of PM2.5, VOCs, and NOx emissions. Whilst most NAPCP reports give sector-specific PaM details, some do 
not provide sufficient information for a detailed analysis. 

Ambient Air Quality Directives 

Directives  2008/50/EC  and  2004/107/EC  specify  air  quality  standards  for  the  concentration  of  pollutants  in 
ambient air to be achieved by the  Member States for a range of pollutants, of which PM10, PM2.5 and PAH are 
most  affected  by  bioenergy.  The  Directives  also  set  requirements  for  assessing  and  reporting  air  pollutant 
concentrations, and for acting on exceedances of the air quality standards. Alongside the NEC Directive and 
relevant source policies, the Ambient Air Quality Directives are the mainstay of air quality policy across the EU, 
and a central part of achieving the clean air goals set out in the Green Deal and Zero Pollution Action Plan. In 
early 2024, a provisional political agreement was achieved on a revised Ambient Air Quality Directive, which will 
bring EU air quality standards closer in line with the World Health Organization (WHO) Air Quality Guidelines. 

According to the provisional agreement, the limit and target values of the revised Directive are to be achieved 
by  2030,  and  there  is  a  commitment  for regular  review  of  air  quality  standards  by  2030  and  every  five  years 
thereafter.  For the pollutants with the highest well-documented impact on human health, i.e. particulate matter 
and nitrogen dioxide, the standards have been tightened inter alia for the annual mean limit values of   fine 
particulate matter (PM2.5; from 25 µg/m3 to 10 µg/m3), and for nitrogen dioxide (from 40 µg/m3 to 20 µg/m3).   

Under the revised Directive, Member States will be permitted to apply for postponement of attaining some of 
the limit values for a period of up to 10 years (up until 2040), if they can demonstrate that compliance would not 
be achievable due to specific conditions, for instance climatic conditions or where the required reduction in 
emissions could only be achieved with “significant impact on domestic heating systems”.  For the postponement 
to be approved, the Member State will need to demonstrate, inter alia, that  they will take appropriate measures 
to ensure they respect air quality standards as soon as possible. 

Ecodesign and Energy Performance of Buildings 

Some policies have been implemented which begin to address the trade-off and mitigate the amount of air 
pollution from bioenergy. The Ecodesign regulation for solid fuel boilers and space heaters46 sets requirements 
for energy efficiency and air pollutant emissions for solid fuel boilers with a rated heat output of 500kW or less, 
reducing the emissions produced per unit of energy produced. Alongside this, the energy labelling regulation 
for solid fuel boilers47 requires new solid fuel boilers (with a rated heat output of 70kW or less) to be labelled on 
an energy efficiency scale ranging from A+++ to G. The Energy Performance of Buildings Directive (EPBD) looks 
to  achieve  a  “highly  energy  efficient  and  decarbonized  building  stock  by  2050”  through  improved  building 
standards,  higher  efficiency  building  services  and  greater  information  sharing  about  building  energy 
performance. This will also enable reductions of emissions associated with biomass as residential, commercial 
and institutional energy consumption is the principal source of PM2.5 emissions.48 The Commission’s proposal for 

45 European Environment Agency (2023) Briefing on ‘Renewable energy in Europe: key for climate objectives, 
but air pollution needs attention’. Available at: https://www.eea.europa.eu/publications/renewable-energy-
in-europe-key 
46 Regulation (EU) 2015/1189 and 2015/1185 
47 Regulation (EU) 2015/1187 
48  https://www.eea.europa.eu/data-and-maps/dashboards/necd-directive-data-viewer-7  

11/13788A/11 

39 of 104 

28 March 2024 

 
Increasing policy coherence between bioenergy and clean air policies and measures Final Project Report 

a recast of the Directive49 includes operational PM2.5 emissions as an optional indicator on Energy Performance 
Certificates, which could guide building owners to make renovation choices which will result in reduced PM 2.5 
emissions (see section 7).  Political agreement has been reached on the revised Directive50, although it has not 
been formally adopted at the time of writing (March 2024). 

Land, Land Use Change and Forestry (LULUCF) 

Furthermore, the Regulation on Land, Land Use Change and Forestry (LULUCF)51 provides incentives for Member 
States to harvest less forest and protect these as carbon sinks. This regulation was updated in 2023 to account 
for the period up until 2030 and introduces a novel land-based net carbon removals target of 310 million tonnes 
CO2eq by 2030 for the sector. To enforce this, the regulation’s phase 2 (to be implemented 2026-2030) simplifies 
the reporting standard from accounting benchmarks and towards reliance on actual reported emissions and 
removals. With this simplification, the regulation prioritises the development of more precise data monitoring, 
and the utilisation of geographical data and remote sensing.  

49 COM/2021/802 final 
50 https://ec.europa.eu/commission/presscorner/detail/en/ip_23_6423  
51 Regulation (EU) 2018/841: https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=uriserv:OJ.L_.2018.156.01.0001.01.ENG  

11/13788A/11 

40 of 104 

28 March 2024 

 
Increasing policy coherence between bioenergy and clean air policies and measures Final Project Report 

6  Member State policy responses 

Summary and outcomes: 

• 

• 

• 

• 

The majority of Member States, and other European countries, have put in place measures to control the air 
pollution impacts of small-scale bioenergy 

These  fall  into  four  broad  categories:  operational  measures  (including  fuel  quality),  stock  replacement 
measures,  use  restriction  measures  and  information  campaigns.  Of  the  measures  assessed  through  this 
project, stock replacement measures are the most numerous 

The precise nature of the measures, and the level of ambition shown, varies across Member States, although 
some  general  principles  can  be  identified,  alongside  the  key  considerations  for  the  development  of 
measures 

Six case studies are presented, to exemplify the range of measures and their application, and a database 
of arounds 130 measures is presented as Annex A6 to this report 

6.1 

Approach 

The chapter examines how Member States (and their regions and cities) have responded to the challenge of 
increasing bioenergy use while trying to address concerns relating to air quality. It provides an overview across 
the EU of measures identified and draws out a series of case studies to illustrate both the potential for action and 
the features which help achieve successful implementation, as well as highlighting some common barriers. It is 
based on firstly a literature review and secondly a series of targeted interviews with key stakeholders (see Section 
3). 

Note that this section deals mainly with the impact of domestic bioenergy use on air quality, rather than the 
industrial or commercial scale. This approach has been taken for three, interrelated reasons: the domestic sector 
is  by  far  the  largest  source  of  air  pollution  emissions  from  bioenergy  use;  industrial  and  commercial  units  are 
larger,  generally  more  efficient  and  thus  emissions  are  more  easily  controlled,  allied  to  the  need  for  regular 
maintenance to avoid breakdown; and larger commercial and industrial units are subject to EU-wide regulation, 
through the Medium Combustion Plan Directive and industrial emission control legislation. That said, some of the 
measures identified in this section do relate to commercial scale units. 

6.2 

Data sources 

To gain an overview of the measures in place and in development in Member States, a literature review was 
conducted, based on the sources listed in Annex A2. In addition, the submitted National Air Pollution  Control 
Programmes  (NAPCPs)  and  National  Energy  and  Climate  Plans  (NECPs)  for  each  Member  States  were  also 
reviewed.  A  standard  data  extraction  template  was  used  and  measures  were  classified  as  legislative  (e.g. 
regulations),  financial  or  voluntary.  The  latter  can  be  defined  through  legislation  but  their  adoption  is  non-
mandatory.  Awareness  raising  measures,  e.g.  publicity  campaigns,  were  also  included  under  voluntary 
measures, although they tend not to be reported on through formal literature; there was very little information 
regarding these in the documents reviewed. 

6.3 

Types of measures and strategies employed 

Previous  sections  of  this  report  have  detailed  both  the  impacts  of  bioenergy  on  air  quality  and  the  specific 
circumstances in which these impacts vary, including the types of fuel used, the types and ages of appliances, 
and how they are used, as well as the gross quantity of fuel being burnt. The different aspects of the problem 
have given rise to different types of solutions. These can be divided in a number of different ways but the key is 

11/13788A/11 

41 of 104 

28 March 2024 

Increasing policy coherence between bioenergy and clean air policies and measures Final Project Report 

how they fit together to form a strategic whole. Different countries have slightly different types of issue, including 
the age and size of the appliance stock, availability of other heat sources and the broader socio-economic 
circumstances. This means that different types of measures will have differing levels of relevance for different 
countries  and will  thus  be more  or  less  prominent.  However,  a comprehensive  strategy  for  addressing the  air 
quality impacts of bioenergy use is likely to have the following four elements: 

•  Operational measures: these focus on how appliances are used and other operational elements, such as 
the quality of the fuel used or the maintenance regimes employed. Such measures can include operational 
training for users (mandatory or voluntary), maintenance requirements (such as the need to use registered 
chimney sweeps, and the frequency of inspections), and the regulation of fuel either sold or used, such as 
a requirement to only sell seasoned wood. Such measures are aimed at ensuring equipment currently in use 
is operated so as to minimise air pollutant emissions where possible. 

• 

Stock improvement measures: These measures focus on the equipment and appliances in use and attempt 
to  shift  these  towards  cleaner  combustion  or  more  modern  versions,  or  to  remove  stock  entirely,  e.g.  by 
switching to other heating sources. Such measures include imposing emission standards on new appliances 
or  incentivising  the  sale  of  cleaner  operating  stock  (e.g.  beyond  eco-design  standards),  stove  or  boiler 
swap-out schemes (voluntary or mandatory), or incentives for other heating technologies, such as air-source 
heat pumps or solar PV. 

•  Use restriction measures: This type of measure aims to prevent the use of bioenergy appliances all together. 
Such restrictions have been used for many years, such as the Smoke Control Areas set up in the UK in the 
1950s and 60s, which heavily restricted the use of solid fuels within such areas. However, their application 
tends to be local and subject to exceptions and exemptions, either for the type of equipment or the times 
at which restrictions apply. 

• 

Information,  awareness  raising  and  behavioural  measures:  Each  of  the  three  previous  types  of  measure 
have a strong behavioural element, be it decisions on how and when appliances are operated, the types 
of equipment used or compliance with restrictions. Each will thus be improved in terms of their effectiveness 
if  they  are  underpinned  by  information  and  awareness  raising  campaigns,  with  a  view  to  encouraging 
beneficial  behaviours.  Campaigns  could  be  aimed  at  the  general  public  but  they  could  also  be  sector 
specific,  such  as  the  hospitality  trade  or  fuel  retailers.  Such  campaigns  may  not,  in  themselves,  reduce 
emissions but they can increase the emission reductions from other measures, if run and targeted effectively. 

The following sections of this report provide examples of each type of measure either in place or planned by 
Member States, regions or cities. They vary considerably in ambition and, inevitably, are tailored towards the 
prevalent situation in the country and its legislative and governance structures. However, there are common 
features which could potentially be transferred to other jurisdictions, and these are drawn out in section 6.7. One 
essential  aspect  is the  development  of  a  strategic  approach which  addresses  several,  ideally  all four,  of the 
types of measures described above. 

While the taxonomy described above is useful in identifying the focus and intent of different types of measures, 
they are in many ways interdependent. For example, a training programme on how to operate a stove more 
efficiently, and thus with lower pollutant emissions, would be more effective if the stock of appliances is modern 
and high quality. Likewise, uptake of an appliance replacement scheme might be higher if awareness of the 
issues (air pollution and the higher cost associated with running a lower efficiency appliance) is raised among 
stove owners. Restrictions on use of stove might also be more effective if there is a scheme available for stove 
owners to swap out to alternative heating technologies. 

While  the  key  drivers  of  air  pollution  impacts  from  bioenergy  will  vary  between  countries  (fuel  availability, 
appliance stock, patterns of use, etc), and so strategies will need to have a different emphasis, the four elements 
of operational improvements, improved stock, restrictions in sensitive areas and information provision are likely 
to  be  common  to  all.  However,  the  project  team  found  very  few  examples  of  coherent,  published  national 

11/13788A/11 

42 of 104 

28 March 2024 

Increasing policy coherence between bioenergy and clean air policies and measures Final Project Report 

strategies to address bioenergy, with that for France52 being one exception. More common is for measures in 
bioenergy  to  be  included  in  a  broader  air  quality  plan  or  strategy  although  there  is  a  risk  that  the  overall 
coherence of the approach to bioenergy is lost, especially if links to energy policy are missing. 

6.4 

Policy development and evaluation 

6.4.1 

Considerations for developing policies and measures on bioenergy 

A key initial consideration in developing an approach to mitigating the air quality impacts of bioenergy use is 
the nature of the problem to be addressed. In particular, whether the primary issue is local concentrations of air 
pollutants, including PM2.5, or the national or regional emissions of pollutants as a source of regional background 
concentrations.  This  balance  will  be  informed  by  local  concentration  measurements,  emissions  inventories, 
trends in both, compliance with targets or obligations, and the priority which both issues are afforded. A second 
consideration  is  the  available  energy  infrastructure,  such  as  connections  to  electricity  or  gas  grids,  district 
heating, etc. i.e. the extent to which households are dependent on solid fuel or other “delivered” heating fuels, 
such as oil or bottled gas. 

These two issues, namely the nature of the air quality impacts and the available energy infrastructure, will largely 
drive the balance between restricting the use of solid fuel – and by extension bioenergy – heating and improving 
the  performance  of  installed  appliances.  As  a  broad  characterisation,  it  may  be  considered  that  solid  fuel 
heating  in  urban  areas  is  inappropriate,  given  the  alternative  heating  methods  generally  available  and  the 
higher concentration of air pollutants locally. However, in more rural areas where the energy infrastructure is less 
extensive  and  lower  population  densities  make  air  pollution  concentrations  less  of  a  local  issue,  reducing 
emissions through improvements to the installed appliance stock, fuel quality or operational practice might be 
the preferred option. This is, of course, a highly simplified description but it is intended to illustrate the idea that 
different  approaches  are  required  for  different  circumstances  and  so  a  package  of  measures  is  likely  to  be 
required within a Member State, with implementation driven by local circumstances. 

Many further issues will inform the design of measures, including: 

• 

socio-economic factors such as the relative wealth of bioenergy users and consideration of fuel poverty 

•  cultural issues around the use of solid fuels 

• 

• 

• 

resources available for incentives and replacement schemes 

the degree to which the fuel market is formal or informal (e.g. purchased fuel versus own sourced), and 

the relative economic importance of the fuel or appliance manufacturing and supply sector  

Further  considerations  will  include  the  risk  of  bioenergy  users  switching  to  higher carbon  fuels  (such  as  oil)  or 
unregulated fuels, such as waste, with the latter carrying the potential to worsen the air pollution impacts. 

As following sections of this report make clear, a large number of measures are already being implemented by 
EU Member States and other European countries. Drawing from the experiences of others is encouraged, as is 
the use of policy evaluation processes to help steer policies towards greater effectiveness. A brief introduction 
to policy evaluation, its main elements, and resources for further support, can be found in Annex 1)a)i)(1)(a)(i)A8. 

52 Ministry of Energy Transition (2021) ‘The Government presents an action plan to develop more efficient 
domestic wood heating and reduce PM emissions by 50%’, Press Release, Online. Available at: 
https://www.ecologie.gouv.fr/gouvernement-presente-plan-daction-developper-chauffage-au-bois-
domestique-plus-performant-et 

11/13788A/11 

43 of 104 

28 March 2024 

 
Increasing policy coherence between bioenergy and clean air policies and measures Final Project Report 

In particular, a strategic approach is needed, with measures aimed at both restriction and improvement and 
implemented at the correct administrative level (national, regional or local). This will help to mitigate some of 
the unintended consequences of implementing isolated actions at a national scale. 

6.5 

Case studies 

This section presents a series of case studies to help illustrate the different types of measures implemented by 
Member States and how they can work as an overall strategy. These examples are not the only instances of 
such  measures  being  applied,  nor  are  they  necessarily  the  most  or  least  stringent.  They  do,  however, 
demonstrate  that  such  measures  are  being  implemented  at  both  the  national  and  local  scale  and  that  an 
integrated approach is likely to be more effective than single action approaches. 

6.5.1 

Case study 1: Denmark 

Context: what is the position of bioenergy in Denmark? 

Three quarters of Denmark’s renewable energy comes from bioenergy53. Whilst its predominant application is in 
district  heating,  it  is  estimated  that there  are  approximately  700,000  wood fuelled  appliances  in  operation  in 
Denmark, although this is a reduction from previous years54. Furthermore, as of 2021, it has been estimated that 
there are approximately 130,000 biomass-fuelled boilers, typically in regions with no or limited access to district 
heating55.  

In terms of reliance on bioenergy for energy consumption, the gross energy consumption of Denmark in 2022 
was at a historically high level56. Furthermore, Danish households consume one fifth of biomass directly (meaning 
for heat or for fuel, not including through electricity or district heating). Consumption of wood pellets has been 
increasing since 1995, while consumption of firewood has fallen sharply since 201857. 

What are the measures? 

In Denmark, there is no energy or CO2 taxation applied to biomass fuels58. According to stakeholders consulted 
for  the  purposes  of  this  study,  this  makes  up  for  the  higher  Capital  Expenditure  needed  to  use  biomass  fuels 
instead of fossil alternatives. The predominant pieces of legislation are the Wood Stove Order59 which first entered 
into force in 2008, and the Danish Change of Ownership Order of 202160. The Nordic Swan Eco Label is a voluntary 

53 IEA Bioenergy. (2021) Implementation of bioenergy in Denmark – 2021 update. Report (10 2021). Online. 
Available at: https://www.ieabioenergy.com/wp-
content/uploads/2021/11/CountryReport2021_Denmark_final.pdf. [Accessed: 28/11/2023]. 
54 Danish Energy Agency (2022). “Firewood Consumption in Denmark 2021,” The Danish Energy Agency, 
Energistyrelsen, Miljoministeriat and Wilke. Available at: 
https://ens.dk/sites/ens.dk/files/Statistik/braendeundersoegelsen_endelig_rapport.pdf. [Accessed: 
08/02/2024]. 
55 The Danish Technological Institute (2021). The boiler of the future emits almost no particles. [online] State of 
Green. Available at: https://stateofgreen.com/en/news/the-boiler-of-the-future-emits-almost-no-particles/. 
[Accessed 8 Dec. 2023]. 
56 Schultz, K. (2023) “Denmark’s consumption of biomass for energy maintains historically high level,” 
Danmarks Statistik. Available at: https://www.dst.dk/da/Statistik/nyheder-analyser-publ/bagtal/2023/2023-08-
23-Danmarks-forbrug-af-biomasse. [Accessed: 08/02/2024]. 
57 Ibid. 
58 IEA Bioenergy. (2021) Implementation of bioenergy in Denmark – 2021 update. Report (10 2021). Online. 
Available at: https://www.ieabioenergy.com/wp-
content/uploads/2021/11/CountryReport2021_Denmark_final.pdf. [Accessed: 28/11/2023]. 
59 The Wood Stove Order (2022). Denmark. Available at: https://www.retsinformation.dk/eli/lta/2022/199. 
[Accessed 8 Dec. 2023].  
60 The Danish Change Of Ownership Order (2021). Denmark. Order on the replacement or decommissioning 
of certain solid fuel combustion plants under 1 MW in the event of a change of ownership of real estate. 
Online. Available at: https://www.retsinformation.dk/eli/lta/2021/1449. [Accessed 08/12/2023].  

11/13788A/11 

44 of 104 

28 March 2024 

 
Increasing policy coherence between bioenergy and clean air policies and measures Final Project Report 

label which can also be applied to woodstoves of an appropriate operating standard61. A scrapping scheme 
for  old wood  stoves was  launched  in 201562.  Several  web-based  information campaigns  designed for  public 
education are currently in operation63.  

What will they do? 

Denmark’s Wood Stove Order empowers municipalities to increase restrictions and enforcements on the use of 
wood  for  heating  and  impose  additional  regulations on  wood  use  in  their  jurisdiction, under  §17.  The  Danish 
Environmental Protection Agency has published a list of municipalities implementing the restriction, which shows 
the  Municipality  of  Rebild  is  the  latest  adopter64.    The  Order  also  empowers  citizens  file  complaints with their 
municipal representatives about smoke from wood fuel used for heating.  Furthermore, its annexes specify limit 
values and test methods for appliances which implement the quality standards outlined in the EU Ecodesign 
Directive.   

Executive order No. 64 from 24 May 2023 allows municipalities to place a ban on the use of wood-burning stoves 
and fireplaces produced before June 2008 in areas with district heating or natural gas from 1 January 2023. On 
the 17th of June 2022, the Decree on the replacement or decommissioning of certain solid fuel combustion plants 
below 1 MW in the event of a change of ownership of immovable property came into force under the Danish 
Change of Ownership Order65. It stipulates that all wood stoves and fireplace inserts produced before 2003 must 
be  replaced  or  discontinued  when  selling  a  house.  If  the  appliance  was  produced  after  2003,  it  must  be 
documented  with  a  test  certificate  showing  compliance  with  the  Nordic  Swan  Ecolabel,  a  conformity 
assessment, or a signed statement from a verifier. This information is held by the Danish EPA. Due to shortages in 
supply of new stoves and inserts, the Danish EPA had issued a dispensation order. In November 2023, the EPA 
announced that the dispensation option would terminate on 1st January 202466. Other exemptions are listed 
under §2 of the order and include antique appliances, appliances in listed buidlings, built-in fireplace inserts and 
more.   

The Nordic Swan Ecolabel is a voluntary certification applicable to fireplaces, stoves, etc. and solid fuels. For 
stoves, etc. it prohibits the use of hazardous production chemicals when manufacturing the appliance, requires 
strict pressure testing of appliances labelled to monitor leakages and inefficiencies, and sets emission limits for 
organic gaseous carbon (OGC) and carbon monoxide (CO) and particulate matter67. For solid fuels (pellets, 
wood briquettes, wood chips, firewood), there are stringent requirements for quality properties to ensure efficient 
combustion including compliance with the EN ISO 17225 part 1-5:2014 standard. Wood fuels must be made from 
100% renewable sources. For pellets and wood briquettes, a minimum of 95% of raw wood materials must be 

61 Nordic Ecolabelling (2022) Nordic Ecolabelling for Stoves version 4.6 until 31 December 2025. Online. 
Available at: https://www.nordic-swan-
ecolabel.org/495e7f/contentassets/df55b91410e5472480635a54b10c7aa2/criteria-document_078_stoves-
078_english.pdf. [Accessed 08/12/2023].  
62 The Danish Environmental Protection Agency. (n.d.). Air pollution from stoves. [online] Available at: 
https://eng.mst.dk/industry/air/air-polluton-from-stoves. [Accessed: 08/12/2023]. 
63 Danish Ministry of Environment (2022): Fire correctly: Smoking cessation guide for wood-burning stoves. 
Online. Available at: https://braendefyringsportalen.dk/borger/rygestop-guide-for-braendeovne/. [Accessed 
08/12/2023]. 
64 See https://braendefyringsportalen.dk/kommuner/udvalgte-eksempler/eksempler-paa-kommunale-
forskrifter-om-brug-af-braendeovne   
65 The Danish Change of Ownership Order (2021). Denmark. Order on the replacement or decommissioning of 
certain solid fuel combustion plants under 1 MW in the event of a change of ownership of real estate. Online. 
Available at: https://www.retsinformation.dk/eli/lta/2021/1449. [Accessed 08/12/2023].  
66 https://mst.dk/nyheder/2023/november/ophoer-af-midlertidig-dispensationspraksis-for-braendeovne-og-
pejseindsatse?utm_medium=nyhedsmail&utm_source=20231106_Oph%C3%B8r%20af%20midlertidig%20dispens
ationspraksis%20for%20br%C3%A6ndeovne%20og%20pejseindsatse&utm_campaign=Oph%C3%B8r%20af%20m
idlertidig%20dispensationspraksis%20for%20br%C3%A6ndeovne%20og%20pejseindsatse 
67 Nordic Ecolabelling (2022) Nordic Ecolabelling for Stoves version 4.7 until 31 December 2026. Online. 
Available at: https://joutsenmerkki.fi/wp-content/uploads/2022/06/078e_4_7_CD.pdf. [Accessed 08/12/2023]. 

11/13788A/11 

45 of 104 

28 March 2024 

 
Increasing policy coherence between bioenergy and clean air policies and measures Final Project Report 

residues from the wood processing industry. For wood chips, firewood and firelighting products, a minimum of 
70% of wood raw materials must be certified as sustainably forested under the FSC or PEFC schemes68.  

Who is implementing them? 

At the municipal level, some authorities have implemented measures on wood combustion. For example, Lejre 
Municipality set regulations for the use of wood-burning stoves, pellet stoves and other stoves for solid fuel. The 
regulation  details  what  can  be  burnt,  chimney  height  and  design  requirements  and  implements  the  Danish 
Wood  Stove  Order.  A  list  of  municipalities  implementing  this  order  can  be  found  online69.  According  to 
stakeholders, during the development of Wood Stove Order 2023, Copenhagen has taken steps to move closer 
to a ban on wood combustion, and at time of writing, four municipalities in the capital region are developing a 
ban70. Public information campaigns have been run at national levels by both public authorities and industry. 
For an example of the latter, the Danish Association of suppliers of fireplaces and woodstoves (DAPO) provides 
information regarding the choice and operation of stoves71. 

What issues and obstacles have had to be overcome? 

Much of Denmark’s air pollution is transboundary, which means that any national measures will have a relatively 
small mitigation effect on air quality in much of Denmark (Green Transition Denmark, 2022)72. There may be less 
motivation  to  reduce  emissions  domestically  if  this  ambition  is  not  matched  at  the  international  level. 
Furthermore, through stakeholder engagement activities conducted for the purpose of this study, a common 
theme noted amongst multiple respondents has been that political incentive to introduce restrictive legislation 
in Scandinavian countries could be particularly low due to the popularity of ‘cosy’ heating. This may mean that 
industry, in turn, faces fewer incentives to invest in innovative appliance design. 

Is there an estimate of effectiveness? 

Denmark committed to, and achieved, a 33% reduction of fine particulate matter emissions by 2020 based on 
2005  levels  according  to  the  NEC  Directive.  This  has  been  attributed  predominantly  to  a  reduction  in  wood 
combustion and replacement of inefficient wood stoves.  However, the opposite trend was observed for soot 
(black carbon) particle emissions, which increased73 over the same period.  

Since the 2023 usage ban is an optional policy, its environmental impact cannot yet be determined.  

There is a risk of a lack of public transparency associated with industry-led information campaigns, such as some 
led by DAPO, on appliance use. For example, if the requirements for the design of an environmentally sound 
appliance  do  not  coincide  with  popular,  aesthetic  design  priorities  (such  as  the  use  of  glass  for  burners,  for 

68 Nordic Ecolabelling (2021) Nordic Ecolabelling for Solid fuels and firelighting products version 3.4 until 30 
June 2025. Online. Available at: https://joutsenmerkki.fi/wp-content/uploads/2022/05/087e_3_4_CD.pdf  . 
[Accessed 08/12/2023]. 
69 https://braendefyringsportalen.dk/kommuner/udvalgte-eksempler/eksempler-paa-kommunale-forskrifter-
om-brug-af-braendeovne 
70 Holst, N and Raarup, M. (2024) ”Hans wonders How can wood stoves be allowed in cities?” Kosmopol. 
Online. Available at: https://www.tv2kosmopol.dk/spoerg-os/hans-undrer-sig-hvordan-kan-braendeovne-
vaere-tilladt-i-byerne. [Accessed: 13/02/2024].  
71 The Association of Danish Suppliers of Fireplaces and Wood-burning Stoves (DAPO) (n.d.). Choosing a 
Woodburning Stove. [online] DAPO. Available at: https://dapo.dk/braendeovnen/  [Accessed 8 Dec. 2023]. 
72 Green Transition Denmark (2022). Pollution from Residential Burning: Danish experience in an International 
perspective. Green Transition Denmark, Clean Heat and Deutsche Umwelthilfe. Online. Available at: 
https://rgo.dk/wp-content/uploads/GTD_Pollution-from-wood-burning_2022-1.pdf. [Accessed: 08/11/2023]. 
73 Green Transition Denmark (2022). Pollution from Residential Burning: Danish experience in an International 
perspective. Green Transition Denmark, Clean Heat and Deutsche Umwelthilfe. Online. Available at: 
https://rgo.dk/wp-content/uploads/GTD_Pollution-from-wood-burning_2022-1.pdf. [Accessed: 08/11/2023]. 

11/13788A/11 

46 of 104 

28 March 2024 

 
Increasing policy coherence between bioenergy and clean air policies and measures Final Project Report 

example), public information surrounding the improvement seen with environmentally sound appliances may 
not be found on these websites.  

Comparing  the  Nordic  Swan  Eco  Label  with  the  EU  Ecodesign  Directive  requirements,  the  European 
Environmental Bureau concludes that both fail to reduce new stove PM emissions to an acceptable level.74 It is 
important to note that stakeholders contacted for the purpose of this case study question the methodology of 
this conclusion, so it should be noted that a full comparative evaluation of these standards is not available. 

What are the lessons which could be applied elsewhere? 

Denmark  is  unusual  among  EU  Member  States  in  that  its  predominant  heat  supply  is  district-based,  which 
removes a lot of the user impact when it comes to air quality concerns from biomass heating. This is allied with 
high home insulation standards, with a similar energy context seen in Sweden. This places small-scale domestic 
bioenergy  very  much  in  the  secondary  heating  category,  with  usage  for  “cosy”  purposes  rather  than  as  a 
necessary  supplementary  heat  source.  Conversations  with  key  stakeholders  in  both  Sweden  and  Denmark 
indicated that  there is an issue in terms of the public perception of  small-scale wood-fired heating, with little 
recognition of the potential impact on air quality. This lack of recognition of the problem, and a perceived lack 
of issue associated with it, as well as the cultural significance of ‘cosy’ firing,  addressing air pollutant emissions 
from  bioenergy  combustion  is  not  a  perceived  environmental  policy  priority  in  Scandinavia,  according  to 
stakeholders. Raising awareness of the issues, as well as the potential solutions, is necessary for the successful 
implementation of a programme of measures to mitigate the air quality impacts of domestic biomass burning. 

6.5.2 

Case study 2: Germany (national) 

Context: what is the position of bioenergy in Germany? 

Bioenergy  is highly  regarded  as  a  sustainable  source of  energy  in  Germany,  and  dependence  on the  fuel  is 
quite high with over half (55%) of renewable energy across all uses in the country being biomass75. Germany is 
the  largest  consumer  of  solid  biomass  in  the  EU  and  second  largest  consumer  of  solid  biomass  used  in  the 
residential sector, second to France76 

The  German  Environment  Agency  estimates  that  there  are  currently  more  than  11  million  wood  stoves  in 
Germany77.  Furthermore,  it  is  estimated  that  over  27%  of  households  in  Germany  have  a  stove  as  a 
supplementary heating appliance78.  

74 European Environmental Bureau and Green Transition Denmark (2021). Where there’s fire, there’s smoke: 
Emissions from domestic heating with wood. [online] Brussels: European Environmental Bureau, pp.1–13. 
Available at: https://eeb.org/wp-content/uploads/2021/09/Where-theres-fire-theres-smoke_domestic-heating-
study_2021.pdf [Accessed 8 Dec. 2023]. 
75 IEA Bioenergy (2021) ‘Implementation of bioenergy in Germany – 2021 update’, IEA, Pelkmans, L. Report no. 
102021. Online. Available at: https://www.ieabioenergy.com/wp-
content/uploads/2021/11/CountryReport2021_Germany_final.pdf. [Accessed: 19/12/2023]. 
76 European Commission (2024). ”Union Bioenergy Sustainability Report Study to support reporting under 
Article 35 of Regulation (EU) 2018/1999,” Luxembourg: Publications Office of the European Union. Available at: 
https://op.europa.eu/en/publication-detail/-/publication/96d671c9-c719-11ee-95d9-
01aa75ed71a1/language-en/format-PDF/source-305260384. [Accessed: 14/02/2024].  
77 Thieringer, J. R. D., et al., (2022). Impact of residential real-world wood stove operation on air quality 
concerning PM2.5 imission’, Karlsruhe Institute of Technology, 10:545. Online. Available at: 
https://doi.org/10.3390/pr10030545. [Accessed: 19/12/2023].  
78 Umwelt Bundesamt (2019). “Emissions from wood and coal burning stoves in residential areas”, online. 
Available at: https://www.umweltbundesamt.de/en/topics/health/environmental-impact-on-people/special-
exposure-situations/emissions-from-wood-coal-burning-stoves-in#use-of-wood-and-coal-stoves-in-residential-
areas. [Accessed: 19/12/2023].  

11/13788A/11 

47 of 104 

28 March 2024 

 
Increasing policy coherence between bioenergy and clean air policies and measures Final Project Report 

What are the measures? 

The German Ordinance on Small and Medium Firing Installations (1. BImSchV) is the main piece of operational 
legislation in Germany79. It first entered into force in 2010 and sets out the quality conditions for small and medium 
sized firing installations.  

The  German  Energy  Act  for  Buildings80  and  the  VDI-Standard  4207-281  implement  the  requirements  of  the  1. 
BImSchV. There are also regional financial support schemes82 to promote compliance with 1. BImSchV and there 
are further incentives to encourage technological improvements and innovation for ultra-low emission stoves 
which are better than the legal minimum83.  

There is user training program designed to raise public awareness of efficient wood combustion practices84.  

Germany is one Member State with an above-average number of policies and/or schemes in place to address 
air quality concerns related to domestic wood-burning. This is shown not least through their use of four different 
voluntary eco-labels; Blue Angel, ENplus, DINplus, and a TÜV-Süd-certificate for stoves.  

What will they do? 

The German Ordinance on Small and Medium Firing Installations governs the installation and operation of such 
appliances,  covering  both  installations  for  solid  fuels  and  oil  and  gas.  It  sets  out  permissible  fuels,  monitoring 
requirements and the standards to which these should be met. For solid fuel installations, it also sets out emission 
limit  values  for  particulate matter  and  carbon  monoxide  (Section 5)85.  The  monitoring  requirements  of the 1. 
BImSchV  are  then  operationalised  under  the  VDI  4207  series  of  standards.  Part  2  lays  out  how  to  measure 
emissions from small firing installations burning solid fuels and primarily addresses chimney sweeps who undertake 
these monitoring activities, also implementing the  German Chimney Sweeping and Inspection Code (KÜO)86. 
For  these  appliances,  any  wood  pellets  must  be  of  A1  quality  according  to  ISO  17225-2  and  an  emission 
measurement of CO and PM must be undertaken. If an appliance fails an inspection, a second measurement 
will be taken 6 months later following a service, repair, or procurement of more suitable fuel. There is one more 

79 The German Ordinance on Small and Medium Firing Installations (2010). BMUV. Online. Available at: 
https://www.bmuv.de/fileadmin/Daten_BMU/Download_PDF/Gesetze/1_bimschv_en_bf.pdf. [Accessed: 
19/12/2023].  
80 Gebäudeenergiegesetz (2020). Federal Ministry of Economic Affairs and Energy and the Federal Ministry of 
the Interior and Community. Online. Available at: https://www.bmi.bund.de/EN/topics/building-
housing/building/energy-efficient-construction-renovation/buildings-energy-act/buildings-energy-act-
node.html. [Accessed: 19/12/2023]. 
81 Technical Division Environmental Measurement Technologies (2016). VDI 4207 Blatt 2. Emission 
measurements at small firing installations – Measurements at installations for solid fuel.  
https://www.vdi.de/en/home/vdi-standards/details/vdi-4207-blatt-2-emission-measurements-at-small-firing-
installations-measurements-at-installations-for-solid-fuel. [Accessed: 19/12/2023]. 
82 See, for example: https://sdg21.eu/en/blog/scrapping-pay-for-old-wood-stoves; 
https://www.rundumwarm.de/Downloads/Infolinks/FBStVO_foerderrichtlinie_2011-01-26.pdf. 
83 Bundesministerium für Wirtschaft und Energie (2021). Richtlinie für die Bundesförderung für effiziente 
Gebäude – Einzelmaßnahmen (BEG EM). Bundesanzeiger. Online. Available at: 
https://www.bundesanzeiger.de/pub/publication/WvQ8k3f3hl7npi5nNo9/content/WvQ8k3f3hl7npi5nNo9/BAn
z%20AT%2007.06.2021%20B2.pdf?inline. [Accessed: 19/12/2023]. 
84 Shared in email contact with stakeholder. 
85 The German Ordinance on Small and Medium Firing Installations, Division 2, section 5. (2010). BMUV. Online. 
Available at: https://www.bmuv.de/fileadmin/Daten_BMU/Download_PDF/Gesetze/1_bimschv_en_bf.pdf. 
[Accessed: 19/12/2023]. 
86 Technical Division Environmental Measurement Technologies (2016). VDI 4207 Blatt 2. Emission 
measurements at small firing installations – Measurements at installations for solid fuel.  
https://www.vdi.de/en/home/vdi-standards/details/vdi-4207-blatt-2-emission-measurements-at-small-firing-
installations-measurements-at-installations-for-solid-fuel. [Accessed: 19/12/2023]. 

11/13788A/11 

48 of 104 

28 March 2024 

 
Increasing policy coherence between bioenergy and clean air policies and measures Final Project Report 

inspection chance after this, but if the boiler fails three times, a replacement or shut down of the appliance may 
be decreed.  

Furthermore, chimney sweeps in Germany must go through an intensive, three-year training program to become 
qualified. They are obliged to test fuels, something which is not within the scope of chimney sweeps in other 
Member States, such as France. The chimney sweep in Germany is regarded with high authority, and citizens 
cannot opt out of appliance or fuel inspections. Furthermore, all data kept by the chimney sweep is entered 
into a harmonised database of chimney sweeps nationwide, which works to generate  data on national fuel 
statistics and numbers of appliances. On top of this ambitious inspection and reporting system, emission testing 
equipment is required to be inspected annually, to maintain the accuracy of emissions values.  

There are numerous national information campaigns aimed specifically at promoting household shift towards 
more efficient appliances. The HKI quality label can be awarded to room heaters, inset appliances and slow 
heat release appliances. The emissions limits detailed by the HKI quality label for CO and PM are the same as 
those specified in 1. BImSchV, and for NOx and OGC, the limits applied in the EU Ecodesign Directive apply87. 
The HKI certification goes beyond efficiency requirements mandated by national legislation, with the stated aim 
of increasing the market share of lower-emission heating appliances for solid fuels. The HKI, in partnership with 
the Federal Association of Chimney Sweeps have developed a traffic light classification system for estimating 
appliance emissions, which are communicated to households with the aim of promoting a replacement of old 
appliances.  The  user  training  program  is  an  initiative  of  the  German  Environment  Agency  and  comprises  a 
course  focusing  on  the  correct  lighting  procedure  for  wood  combustion  appliances.  The  EU-funded  BEREAL 
project  (2013-2016)  sought  to  investigate  the  difference  in  performance  between  firewood  and  pellet  room 
heaters under test type conditions and real-life conditions. It found a significant difference between the test and 
practical operating conditions88.  

The most widely used ecolabel in Germany is the Blauer Engel (Blue Angel), having been the ecolabel of the 
German  Federal  Government  for  almost  half  a  century.  To  be  certified  with  the  Blue  Angel,  appliances  are 
subject to a stricter testing procedure than is the case in the current type testing process89. Whilst the statutory 
limit for PM emissions under the 1. BImSchV is 40 mg/m3, heating appliances holding the Blue Angel must comply 
with a limit of 15 mg/m3, which is predominantly achieved using innovative technology. Germany also has the 
TÜV-Süd-certificate  for  stoves,  which  is  a  new  label  being  promoted  by  the  German  Stove  Association  that 
applies  to  space  heaters90.  This  certificate  applies  to  appliances  in  compliance  with  improved  emission 
performance in real-life installations. It requires that the appliance has proof of conformity with the requirements 
of regulation EU 2015/1185 and Regulation EU 2015/1186, which detail energy labelling and the requirements of 
the EU Ecodesign Directive for solid fuel local space heaters.  

87 IEA Bioenergy (2022) ‘Inventory of national strategies for reducing the impact on air quality from residential 
wood combustion’, Technology Collaboration Programme. (eds) Hans Hartmann. Online. Available at: 
https://task32.ieabioenergy.com/wp-content/uploads/sites/24/2022/10/NationalStrategies_Report-final.pdf. 
[Accessed: 19/12/2023].  
88 Hartmann et al (2017). Advanced Testing Methods for Better Real Life Performance of Biomass Room 
Heating Appliances. Project Summary. European Union. Online. Available at: 
https://cordis.europa.eu/article/id/207390-new-real-life-test-method-for-biomass-heating-appliances. 
[Accessed: 19/12/2023]. 
89 Blue Angel (2020). ‘Stoves for Wood: Basic Award Criteria – Version 7’, DE-UZ 212. Online. Available at: 
https://www.blauer-engel.de/en/productworld/stoves-for-
wood#:~:text=Heating%20appliances%20holding%20the%20Blue,limit%20of%2015%20mg%2Fm3. [Accessed: 
19/12/2023].  
90 TÜV SÜD Industrie Service GmbH (2021). ‘Certification scheme for heating appliances fired by wood logs’, 
Certification document. Online. Available at: https://www.tuvsud.com/de-de/-/media/de/industry-
service/pdf/broschueren-und-flyer/is/real-estate/technische-gebaeudeausruestung-und-
aufzuege/feuerungstechnik-waermetechnik-abgastechnik/is-taf-certification-procedure-for-heating-
appliances-fired-by-wood-logs.pdf. [Accessed: 19/12/2023]. 

11/13788A/11 

49 of 104 

28 March 2024 

 
Increasing policy coherence between bioenergy and clean air policies and measures Final Project Report 

Who is implementing them? 

Whilst  the  1.  BImSchV  is  a  national  level,  it  is  the  federal  states  (Lander)  that  implement  and  enforce  it. 
Stakeholders indicated that Bavaria (Munich), Aachen and Stuttgart are implementing usage restrictions (see 
below), allowed for under the legislation. The Blauer Engel certificate is a label used and dispersed by the Federal 
Government (federal environment ministry), with different actors involved in the development of criteria and 
actual award of the label to products.  

What issues and obstacles have had to be overcome? 

It is important to note the cultural significance associated with wood combustion in Germany, and its overall 
positive image.  One problem identified through conversations with stakeholders, is that it is hard to regulate 
what individuals are entitled to do with the forest reserves they own (in the case of private or community owned 
forests).  Other  challenges  relate  to  enforcing fuel  quality  standards  and  making  sure  individuals  do  not  burn 
wood with a high moisture content, for example.  

Furthermore,  concerns  relating to  air  quality tend  to  be  focussed  on urban  areas  and  far  less  on  rural  areas, 
despite wood combustion having a proportionately higher impact in rural areas (both in terms of the number of 
users and the reduced presence of other sources). This is exacerbated by the small number of monitoring points 
located in rural areas, sited to capture regional background concentrations rather than local conditions. As a 
result of this, many, especially rural, citizens do not associate the use of wood fuel for home heating with impacts 
on  air quality, and there is often a higher level of acceptance of the practice as there are more users (more 
“normalised”  behaviour).  According  to  a  survey  on  wood  burning  and  perceived  nuisance,  80%  of  all 
respondents indicated that they typically did not feel affected by nuisance caused by smoke and the smell of 
wood-burning stoves in the neighbourhood. In these results also, there was a split picture between perceptions 
of impaired air quality because of heating with wood, between those in semi-urban areas (41% of the opinion 
that this was the case) compared to only 29% of those from rural areas91. 

Is there an estimate of effectiveness? 

The user training program mentioned above has been evaluated in terms of reduced emissions before and after 
training.  After  training,  results  indicated  an  estimated  11%  carbon  monoxide  (CO)  and  36%  total  particulate 
matter  (TPM)92  emission  decrease  during  ignition  and  an  average  57%  CO  and  82%  TPM  emission  reduction 
during reloading93. 

Furthermore, following findings from the EU funded BEREAL project, researchers have developed new testing 
methods  for  biomass  room  heating  appliances  reflecting  real-life  operation,  rather  than  optimistic  type-test 
conditions94.  Because  of  this,  real-life  operating  conditions  can  now  be  used  as  the  baseline  level  of  fuel  or 
appliance  efficiency  when displaying  quality  standards  associated with  different  ecolabels  meaning  there  is 
less room for over-reporting on efficiency standards of these.  

In relation to Germany’s advanced inspection procedures and the authoritative role of the chimney sweep, 
broadening the chimney sweep’s remit beyond fire safety to include an inspection of the quality of fuel has 
resulted in a much more efficient use of wood in Germany. Whilst the 1. BImSchV states that moisture content 
for wood fuels must not exceed 25%, recent study results show that the average moisture content was around 

91 Umwelt Bundesamt. (2023) ”Environmental Awareness in Germany 2020: Results of an additional survey on 
the topic of ’heating with wood stoves’”. Online. Available at: 
https://www.umweltbundesamt.de/sites/default/files/medien/11850/publikationen/auswertungsbericht_heize
n_mit_holzoefen.pdf. [Accessed: 14/02/2024].  
92 Total Particulate Matter, equivalent to Total Suspended Particulate (TSP) or total mass of particulate matter. 
93 Shared in email contact with stakeholder.  
94 Hartmann et al (2017). Advanced Testing Methods for Better Real Life Performance of Biomass Room 
Heating Appliances. Project Summary. European Union. Online. Available at: 
https://cordis.europa.eu/article/id/207390-new-real-life-test-method-for-biomass-heating-appliances  
[Accessed: 19/12/2023]. 

11/13788A/11 

50 of 104 

28 March 2024 

 
Increasing policy coherence between bioenergy and clean air policies and measures Final Project Report 

13%, with  some recorded  fuels  having  only  an 8%  moisture  content.  The  study  concludes that  problems with 
moisture content are scarcely relevant in Germany anymore, since the implementation of the legislation (UBA, 
2022/2023)95. 

Are there any other measures being implemented? 

There are no other national measures being implemented, but for a detailed overview of measures in Bavaria 
specifically, see section 6.5.3.  

What are the lessons which could be applied elsewhere? 

There are two key messages from the measures described above: firstly that “on the ground” operators make 
an effective means of spreading good practice, and that user training can make a measurable difference to 
emissions, especially in those areas heavily reliant on bioenergy. While few countries have in place mandatory 
training for chimney sweeps to the depth shown in Germany, many Member States have specific requirements 
for  mandatory  chimney  sweeping  or  maintenance.  Even  where  these  are  not  in  place,  regular  chimney 
sweeping  is  required  by  users  to  maintain  the  effective  operation  of  their  heating  appliances  and  for  fire 
prevention.  Chimney  sweeps  are  thus  very  well  placed  to  deliver  messages  on  good  practice  regarding 
appliance maintenance and fuel used. 

In addition, while Germany’s user training program has been criticised by stakeholders contacted for this study 
as  being  too  detailed  (and  thus  too  long),  it  has  been  shown  to  be  effective  at  reducing  emissions  from 
bioenergy  through  improved  operation.  Such  courses  may  be  most  effective  when  conducted  online,  to 
decrease the burden of attending sessions. This could be implemented in Member States who do not have the 
capacity nor resources to conduct user training programs in person.  

6.5.3 

Case study 3: Bavaria 

Context: what is the position of bioenergy in Bavaria? 

As shown in section 6.5.2, Germany is one of the main consumers of woody biomass for heating in the residential 
sector. Whilst the project group have identified no information on state-level bioenergy reliance for heating in 
the  residential  sector,  according  to  key  informants  interviewed  for  the  purposes  of  this  study,  Bavaria  is  the 
leading state in Germany in terms of wood stove usage and is where the greatest share of these appliances are 
located. 

What are the measures? 

There  was  a  utilisation  ban  on  appliances  non-compliant  with  emissions  limits  in  Munich  as  of  the  31st  of 
December  2018,  which  implements  the  Federal  Emission  Control  Act  of  1974.  The  State  Capital  Munich 
Department  for  Climate  and  Environmental  Protection  implements  the  1.  BImSchV  through  requiring  the 
declaration  on  the  decommissioning  of  a  single-room  combustion  system  for  solid  fuels  in  the  state  capital 
Munich96.  Between  2014  and  2017,  a  timebound  subsidy  scheme  was  implemented  to  shorten  the  transition 
period from older to new stoves97. 

95 UBA (2022/2023). “Staub- und CO-Messungen an Einzelraumfeuerungen im Realbetrieb“, Unpublished 
report. Project number: 170766. Eds. Kristina Juhrich. Shared in email contact with key stakeholder. 
96 Municipality of Munich (2021) “Merkblatt und Erklärung zur Stilllegung einer Einzelraumfeuerungsanlage für 
feste Brennstoffe auf dem Gebiet der Landeshauptstadt München”. Online. Available at: 
https://www.muenchen.de/rathaus/dam/jcr:fa244625-fd16-41a1-a9b2ec2d101bf5ea/merkbl_stillegung.pdf. 
[Accessed: 19/12/2023].  
97 Municipality of Munich (2017) Incentive program of the city of Munich for log wood stove replacement. 
Online. Available at: https://docplayer.org/59137101-Richtlinie-staedtisches-foerderprogramm-2017-fuer-den-
austausch-alterfestbrennstoffbefeuerter-oefen.html. [Accessed: 19/12/2023]. 

11/13788A/11 

51 of 104 

28 March 2024 

 
Increasing policy coherence between bioenergy and clean air policies and measures Final Project Report 

There is also a Bavarian-specific version of the wood stove operation training course, which has been shortened 
and streamlined to better reflect the local desires of users.  

What will they do? 

The local utilisation ban of appliances stipulates that combustion appliances installed before October 30, 1999, 
that do not meet the emission limits for PM at 40 mg/m3 and CO at 1250 mg/m3 can no longer be used, as of 
December 31st 201898. In addition, all older appliances in the city had to be retrofitted with a dust precipitator99. 
The  subsidy  scheme  granted  30%  of  eligible  costs  for  appliance  replacement  (or  max.  300€  for  each 
replacement of an older log wood stove). It lasted until 2017, when the total budget of 100,000 euros was utilised. 
New appliances had to comply with the limit values in the BIm.SchV.1, and a letter of commitment was needed 
declaring that the owner would not resell the new stove100. 

What issues and obstacles have had to be overcome? 

As mentioned in section 6.5.2, stakeholders interviewed for the purposes of these German case studies have 
mentioned the cultural significance of wood combustion (and forestry) and thus the difficulty in regulating the 
quality  of  fuels used  for  burning. There  are  some  2  million  private  and  community  forest  owners  in  Germany, 
700,000  of which  are  Bavarian.  Bavaria  is  the  most  densely  wooded  federal  areas,  with  2.56  million hectares 
which equates to around a third of the whole state101, which has the potential to exacerbate the difficulties 
associated with implementation of policies, particularly around the restriction of inefficient fuel usage outside of 
the city.  

Is there an estimate of effectiveness? 

There are no publicly available evaluations of any of the measures detailed in this case study.  

What are the lessons which could be applied elsewhere? 

The measures in Munich to aid in the implementation of 1. BIm.SchV, added to localised support for the national 
information  and  training  programme,  show  an  apparently  rare  example  of  a  Member  State  locality 
implementing all four types of policy (operational, changing stock, restriction of use and support from national 
information  campaigns)  together  to  achieve  transition.  Bavaria  exemplifies  how  national  measures  can  be 
adapted to the regional scale; reflecting the priorities and perceptions of wood usage in localities, compared 
to on a broader, national level.  

6.5.4 

Case study 4: Sweden  

Context: what is the position of bioenergy in Sweden? 

In Sweden, there is not a strong dependency on bioenergy at the household level since most homes are either 
connected to district heating or have changed to alternative sources such as electric boilers and heat pumps. 

98 Ramboll (2023). ‘EU Clean Air Technology Hub Final Clean Air Tech Report on Development And Greater 
Uptake Of Cleaner Solid Fuel Household Heating Solutions’, European Commission. Luxembourg: Publications 
Office of the European Union. DOI: 10.2779/6522. [Accessed: 19/12/2023].  
99 IEA Bioenergy (2022) ‘Inventory of national strategies for reducing the impact on air quality from residential 
wood combustion’, Technology Collaboration Programme. (eds) Hans Hartmann. Online. Available at: 
https://task32.ieabioenergy.com/wp-content/uploads/sites/24/2022/10/NationalStrategies_Report-final.pdf. 
[Accessed: 19/12/2023]. 
100 IEA Bioenergy (2022) ‘Inventory of national strategies for reducing the impact on air quality from residential 
wood combustion’, Technology Collaboration Programme. (eds) Hans Hartmann. Online. Available at: 
https://task32.ieabioenergy.com/wp-content/uploads/sites/24/2022/10/NationalStrategies_Report-final.pdf. 
[Accessed: 19/12/2023]. 
101 Bayerische Landesanstalt für Wald und Forstwirtschaft (n.d.). Forest ownership, counselling and forest 
policy. [online] Bayerische Landesanstalt für Wald und Forstwirtschaft. Available at: 
https://www.lwf.bayern.de/en/221952/index.php [Accessed: 19/12/2023]. 

11/13788A/11 

52 of 104 

28 March 2024 

 
Increasing policy coherence between bioenergy and clean air policies and measures Final Project Report 

The  small-scale  market  of  bioenergy  use  for  heating  in  single-family  houses  reached  historically  low  levels  of 
around 8 TWh in 2020102. However, when it comes to using wood as a secondary heating source, as a “cosy” 
fireplace  for  aesthetic  and  comfort  purposes  for  example,  there  has  been  an  increase  in  the  last  15  years. 
According to data from a yearly survey made by the Swedish Civil Contingencies Agency (MSB), all biomass 
appliance quantities have reduced between a 2012 and a 2021 stock take, apart from local fireplaces which 
increased by almost 260,000 units in the 9-year period103. In addition, due to recent shocks in energy prices, these 
secondary  heating  appliances  are  expected  to  sell  even  more  than  usual,  based  on  the  perceptions  of 
stakeholders interviewed for this case study104.  

In Sweden, wood combustion is the largest source of emissions of Black Carbon (BC) and accounts for ca. 30% 
of PM2.5 emissions105. The extent of the problem regarding the air quality impact of using wood- is not well-known 
in Sweden. Work is ongoing to investigate how information on the location, type and use of wood stoves can 
be collected and made available, to facilitate more effective assessments of air quality and identify areas with 
the highest concentrations of the most problematic woodstoves. As in most, if not all, Member States, there are 
significant shortcomings in the currently available data, resulting in PM emissions estimates relating to bioenergy 
which carry a high level of uncertainty. 

What are the measures? 

There  are  many  municipalities  that  do  not  have  restrictions  on  wood  combustion,  but  do  have 
recommendations  to  limit  usage106.  In  Sweden,  the  regulation  (1998:899)  on  environmentally  hazardous 
activities and health protection empowers municipalities to issue a temporary ban on small-scale combustion 
with certain solid fuels within specially defined areas. The strictest measure is related to the city of Malmö, where 
there are some restrictions on biomass combustion under the City of Malmö's local environmental regulations, 
paragraphs  10  to  12107.  There  is  also  the  regulation  by  the  Swedish  National  Board  of  Housing  Building  and 
Planning  that  limits  the  boilers  and  stoves  that  can  be  installed  for  residential  heating  in  new  buildings108. 
Information  campaigns  are  relatively  infrequent,  with  the  last  national  campaign  occurring  in  2019,  with  no 
follow up besides annual social media information campaigns.  

What will they do? 

Since the scale of the problem is relatively unknown in Sweden, and more than half of the domestic heating  is 
district-based,  there  are  only  a  handful  of  national  or  local  measures  in  Sweden.  Most  of  these  are  used  to 
implement EU policy to adhere to Ecodesign regulations. The usage ban in Malmö under the local environmental 
regulations, which is the most prescriptive of the local policies, however, only allows ‘cosy’ firing to take place 
during the coldest months (October to March), and on top of this, they recommend that fires in tiled chimneys 
are also lit no more than twice per week109.  

102 The Swedish Energy Agency (2023) ‘An Overall Picture of the Energy Situation in Sweden,’ ET 2023:01. 
Available at: ISBN (pdf) 978-91-7993-103-2. [Accessed: 19/12/2023].  
103 Information provided via email with key stakeholders. 
104 Information provided via email with key stakeholders. 
105 Bodin, S. (2017) “Evaluation of the Swedish Communication Campaign “Lighting in the Top,” 2017-18 
Woodburning Season Summary and Conclusions,” International Cryosphere Climate Initiative. Online. Provided 
through Email contact with stakeholder. 
106 International Cryosphere Climate Initiative (2013) “Legislation and Regulations in Nordic Countries to 
Control Emissions from Residential Wood Burning: An Examination of Past Experience,” Report to the Nordic 
Council of Ministers. Online. Available at: https://iccinet.org/wp-content/uploads/2012/03/Nordic-
Woodburning-Review-Draft-130911.doc. [Accessed: 19/12/2023]. 
107 Malmö stad (2023) ‘Elda med ved’, online. Available at: https://malmo.se/Bo-och-leva/Bygga-och-
bo/Inomhusmiljo/Elda-med-ved.html. [Accessed: 19/12/2023]. 
108 Boverket (2019). Boverkets föreskrifter om ändring i Boverkets byggregler (2011:6) - föreskrifter och 
allmänna råd. Available at: https://rinfo.boverket.se/BFS2011-6/pdf/BFS2019-2.pdf. [Accessed: 19/12/2023]. 
109 Malmö stad (2023) ‘Elda med ved’, online. Available at: https://malmo.se/Bo-och-leva/Bygga-och-
bo/Inomhusmiljo/Elda-med-ved.html. [Accessed: 19/12/2023]. 

11/13788A/11 

53 of 104 

28 March 2024 

 
Increasing policy coherence between bioenergy and clean air policies and measures Final Project Report 

Who is implementing them? 

As  abovementioned,  municipalities  can  impose  general  or  temporary  bans  on  small-scale  combustion  with 
certain  fuels  within  certain  areas.  The  most  prescriptive,  general  ban  is  shown  in  the  example  of  Malmö. 
According to stakeholders consulted, this is the only general ban in the country. However, the recommendation 
to limit biomass combustion for recreational purposes (not as a primary heating source) to twice per week, four 
hours  at  the  time,  has  become  practice  and  is  recommended  by  many  municipalities.  The  Swedish 
Environmental  Protection  Agency  (SEPA)  has  developed  information  on  best  practice  fire-lighting  and  this  is 
disseminated annually to the public.  There are information videos on boilers110, fireplaces111 and a “Light at the 
Top” best practice tutorial112. The latter is the second-most viewed video that the Swedish EPA posted between 
November 2022 and November 2023, according to interviewees. 

What issues and obstacles have had to be overcome? 

Homes that use solid fuel for heating, and typically the homes with the old inefficient stoves, are mainly in rural 
areas, outside of the city. As a result of this, where there is capacity and resource to measure air quality impacts 
of  wood  combustion  (typically  in  cities),  there  is  less  of  a  need  to  do  so,  since  homes  in  these  areas  are 
predominantly reliant on district heating or electricity. There is also a hint that there is a general lack of political 
incentive to reduce wood firing, due to the cultural significance of wood combustion and previous resistance 
from  the  public,  which  led  to  a  cancellation  of  an  old  wood  stove  regulation  in  2019113.  According  to 
interviewees, there have been attempts to set a target for the exchange of boilers, with some financial backing 
to do so, but it was never put in place, and remains on the government’s list of potential actions. Stakeholders 
indicate also that there is less of an incentive to tackle wood combustion since there is no pending risk of EU 
infringement proceedings and fines due to exceedances of the EU air quality standards. 

Is there an estimate of effectiveness? 

Where there is an estimate of effectiveness available for any action on air quality, it comes from the information 
campaigns disseminated by the Swedish Environmental Protection Agency. The evaluation report of the “Light 
it from the top” campaign in 2017 concludes that it was the most comprehensive campaign to change attitudes 
and behaviour. As a result, two-thirds of people interviewed who received the campaign brochure said they 
paid attention to it, and of these, almost three-quarters (73%) said they applied the guidelines stipulated in the 
brochure. However, only 79 out of 290 municipalities in Sweden participated in the campaign114. 

There have been no other evaluations of measures on wood combustion. 

Are there any other measures being implemented? 

One program which ended in 2008 in Sweden, provided financial incentive for people who undertook training 
on how best to light a wood-fuelled boiler, when they exchanged for an old fossil-fuel burner. There is an estimate 
of  effectiveness  with  this  scheme,  outlined  by  the  International  Cryosphere  Climate  Initiative.  The  scheme  is 
estimated to have reduced PM emissions by 6% in a 10-year period up to 2008, however it is likely that this is due 
to the transition away from fossil fuels rather than the training provided on proper lighting115.  

110 See https://youtu.be/FCjJbcVXVII 
111 See https://youtu.be/MwSWkZX-xOw 
112 See https://www.youtube.com/watch?v=am3495wKa_E 
113 Sahlberg, A., et al., (2022) ‘Don't extinguish my fire – Understanding public resistance to a Swedish policy 
aimed at reducing particle emissions by phasing out old wood stoves,’ Energy Policy, 167, 113017. Available 
at: https://doi.org/10.1016/j.enpol.2022.113017 . [Accessed: 19/12/2023].  
114 Bodin, S. (2017) “Evaluation of the Swedish Communication Campaign “Lighting in the Top,” 2017-18 
Woodburning Season Summary and Conclusions,” International Cryosphere Climate Initiative. Online. Provided 
through Email contact with stakeholder.  
115 International Cryosphere Climate Initiative (2013) “Legislation and Regulations in Nordic Countries to 
Control Emissions from Residential Wood Burning: An Examination of Past Experience,” Report to the Nordic 

11/13788A/11 

54 of 104 

28 March 2024 

 
Increasing policy coherence between bioenergy and clean air policies and measures Final Project Report 

What are the lessons which could be applied elsewhere? 

There is a similar landscape in Sweden as seen in Denmark, related to the fact that most of the country relies on 
district  heating,  and  there  is  a  similar  cultural  significance  of  wood  combustion,  which  to  many  people  is 
considered ‘cosy’ and an important right.  

The Regulation (1998:899) on environmentally hazardous activities and health protection and its implementation 
by  municipalities  allows  neighbourly  complaints  to  spark  an  inspection  could  be  a  useful  device  for  other 
Member States where restrictive policy is currently not possible. For example, this does not exist in Sofia, and has 
been suggested by interviewees as a reason why a total ban on wood combustion in the city’s jurisdiction would 
not be enforceable.   

6.5.5 

Case study 5: Sofia 

Context: what is the position of bioenergy in Sofia?  

Woody biomass makes up a large proportion of home heating across Bulgaria. A survey in 2018 indicated that 
electrical heating was the most used (38% of households), with wood fuel, in the form of wood logs, making up 
33%  of  household  heating;  wood  pellet  heating  added  a  further  3%.  Coal  and  manufactured  solid  fuels 
contributed 7.5% and district heating just over 14%. Heating with gas made up only 2-3% of households.  

While the use of wood fuel in Sofia is lower than the national average, it still accounts for a very large proportion 
of heating. The national census in 2011 indicated that around 50,000 households across the city are reliant on 
solid fuel heating, with wood logs being the most common fuel. In addition, it has been indicated that domestic 
solid fuel (though this also includes coal) use for heating make up around 56% of all PM10 emissions116. 

What are the measures?  

Sofia  Municipality  has  an  ambient  air  quality  program  which  is  implemented  by  the  project  “Bulgarian 
Municipalities  Working  Together  to  Improve  Ambient  Air  Quality"  under  the  LIFE  Programme  of  the  European 
Union - LIFE17 IPE/BG/000012 - LIFE IP CLEAN AIR. The main project under the program is the development of an 
appliance replacement scheme.  

Additionally in the municipality of Sofia, there is a Low Emission Zone (LEZ) for transport and household heating. 

What will they do?  

The LEZ for household heating is expected to be in action as of 1st January 2023117. This will not span the entirety 
of the city but will cover mostly central areas. There will be a ban on solid fuel heating (wood and coal, but not 
wood pellets). The European Commission contributes 60% of the EUR 16.7 million budget, which is set to expire in 
2024. The scheme aims to transition from heating with wood and coal towards pellets, gas or use of the central 
heating network. 

Council of Ministers. Online. Available at: https://iccinet.org/wp-content/uploads/2012/03/Nordic-
Woodburning-Review-Draft-130911.doc. [Accessed: 19/12/2023].  
116 Tcolova, K and Vladimirov, M. (2023) ‘Reversing the Trend Smart Enforcement of the Low-Emission Zone in 
Sofia, Bulgaria’, Center for the Study of Democracy. Online. Available at: 
https://csd.bg/fileadmin/user_upload/publications_library/files/2023_03/Reversing_the_trend_Smart_Enforcem
ent_of_the_LEZ_in_Sofia_WEB.pdf. [Accessed: 19/12/2023].  
117 Tcolova, K and Vladimirov, M. (2023) ‘Reversing the Trend Smart Enforcement of the Low-Emission Zone in 
Sofia, Bulgaria’, Center for the Study of Democracy. Online. Available at: 
https://csd.bg/fileadmin/user_upload/publications_library/files/2023_03/Reversing_the_trend_Smart_Enforcem
ent_of_the_LEZ_in_Sofia_WEB.pdf. [Accessed: 19/12/2023]. 

11/13788A/11 

55 of 104 

28 March 2024 

 
Increasing policy coherence between bioenergy and clean air policies and measures Final Project Report 

Who is implementing them?  

Municipalities are responsible for developing air quality plans in Bulgaria, the support of which is a priority of the 
LIFE-IP  Clean  Air  program.  In  Sofia,  a  combination  of  funds  channelled  through  the  Life  IP  program  and  the 
Operational  Program  for the  Environment  in  Sofia (2007-2013,  2014-2020  and currently 2021-2027)  have  been 
enabling the exchange of inefficient appliances.  

What issues and obstacles have had to be overcome?  

There are control issues associated with the informal collection of wood for heating. For example, whilst it may 
be possible to control the quality of fuels imported or sold formally, this might not be the same for those living in 
rural areas outside of the city. This makes the enforcement of fuel restrictions very difficult to oversee, and due 
to this, fuel restriction has largely remained outside of Bulgarian bioenergy policy landscape.  

Is there an estimate of effectiveness?  

The rate of exchange for boilers has been extremely slow. Since the start of the exchange program, there have 
been  ca.  7000  appliances  exchanged.  Whilst  all  new  appliances  must  follow  the  general  EU  Ecodesign 
regulations,  there  is  no  control  over  the  circulation  of  substandard  stoves  on  the  market  since  there  are  no 
restrictions on this in Bulgaria. The LEZ, though not yet implemented, has had criticisms that it may not be an 
effective measure since the majority who use wood for heating do not live in the central parts of the city, where 
the ban will be applicable118.  

Bulgaria’s NAPCP (dating from 2019)  described policies which  aimed to develop standards for the quality of 
wood  and  coal,  however  these  were  only  developed  for  the  latter  at  the  time  of  writing  (March  2024).  The 
program  has  thus  far  only  led  to  recommendations  being  made  for  use  of  wood  heating,  and  these 
recommendations are tailored towards the end-user, which makes them harder to enforce.  

Are there any other measures being implemented?  

It is expected that a total ban on wood heating from the 1st January 2029 will enter into force, however this 
remains to be seen since there are some enforceability issues which are not covered in existing legislation. For 
example,  one  stakeholder  mentioned  the  lack  of  structure  in  place  to  report  a  neighbour’s  property  if 
reasonably suspicious, as happens in Denmark and Germany, as a barrier towards more ambitious legislation 
detailing widespread usage bans.  

What are the lessons which could be applied elsewhere?  

The  landscape  for  domestic  use  of  wood  in  Eastern  Europe  is  very  different  than  in  Western  Europe  or 
Scandinavia.  In  Eastern  Europe,  there  is  demand  for  the  fuels  as  a  primary  source  of  heat,  as  opposed  to  a 
supplementary source or use of wood for ‘cosy’ firing. The inclusion of wood heating within an LEZ is a relatively 
new  initiative;  and  Sofia  is  among  the  first  of  any  city  in  Central  and  Eastern  Europe  to  introduce  a  LEZ119. 
However,  there  have  been  no  lessons-learnt  analysis  conducted  here  because  it  is  yet  to  be  implemented. 
Learning from the difficulties in developing the policy, and its subsequent push back, however, ex-post findings 
argue for the importance of engaging with the public through formal, in-person consultations which should be 
an approach taken when developing an LEZ in any city120. 

118 Tcolova, K and Vladimirov, M. (2023) ‘Reversing the Trend Smart Enforcement of the Low-Emission Zone in 
Sofia, Bulgaria’, Center for the Study of Democracy. Online. Available at: 
https://csd.bg/fileadmin/user_upload/publications_library/files/2023_03/Reversing_the_trend_Smart_Enforcem
ent_of_the_LEZ_in_Sofia_WEB.pdf. [Accessed: 19/12/2023]. 
119 Ibid.  
120 Ibid.  

11/13788A/11 

56 of 104 

28 March 2024 

 
Increasing policy coherence between bioenergy and clean air policies and measures Final Project Report 

6.5.6 

Case study 6: France  

Context: what is the position of bioenergy in France?  

According  to  the  IEA121,  around  60%  of  renewable  energy  in  France  is  from  biomass.  In  domestic  heating, 
6,725,000 domestic wood appliances produced 75,700 GWh of renewable heat in 2020122. According to one 
study conducted by IFOP and Cheminées Poujoulat, 75% of wood heater owners use another source of energy 
alongside  wood,  and  wood-based  domestic  energy  covers  24%  of  the  population’s  heating  needs  in  the 
residential sector123. 

What are the measures?  

There are two restriction of use policies operating in France: The Ministerial Decree of 7 April 2016124, and the 
Atmosphere Protection Plan125. In April 2021, Deputies to the National Council voted on a commitment to reduce 
fine particle emissions by 50% in highly polluted areas in France between 2020 and 2030 and developed and 
agreed to implement this in areas covered by an Atmosphere Protection Plan126. 

What will they do?  

The Ministerial Decree of 2 April 2016 authorises prefectures to temporarily suspend the use of inefficient biomass 
combustion devices. There are further geographical bans under the Atmosphere Protection Plan applicable in 
agglomerations < 250000 inhabitants where air quality standards are not respected.  

The efficient domestic wood heating action plan127 is a systematic approach to reducing particulate matter 
across the country, by speeding up the replacement of old stoves and fireplaces with efficient equipment. It 
covers  six  integrated  approaches  to  abating  air  quality  impacts  of  residential  wood  combustion.  These  are 
raising public awareness of the impact on air quality of using inefficient appliances and fuels, strengthening, 
and simplifying support schemes to speed up the replacement of inefficient appliances, extension of the Green 
Flame label beyond a 7-star threshold to showcase best available technology and appliances, and to develop 
a label indicating high quality fuels regarding their moisture content and origin. The approach will be tailored to 
each region to reflect public awareness and potential reception of air quality measures.  

Additionally, mandatory chimney sweeping has recently entered into force by decree (Decree No. 2023-641)128. 
These inspections cover not only sweeping, but also the maintenance of appliances. The chimney sweep acts 

121 IEA Bioenergy (2021). Implementation of bioenergy in France. Country Report No. 10 2021. Online. 
Available at: https://www.ieabioenergy.com/wp-
content/uploads/2021/11/CountryReport2021_France_final.pdf. [Accessed: 19/12/2023].  
122 Ibid. 
123 Cheminees Poujoulat (2022) ‘Study Report: The Place of Wood Heating in the Home’, study summary 
Online. Available at: https://www.ifop.com/wp-content/uploads/2022/12/25605-Rapport-Cheminees-
Poujoulat-diffusion-site-internet-IFOP.pdf. [Accessed: 19/12/2023].  
124 Order relating to the triggering of prefectural procedures in the event of episodes of ambient air pollution 
(7 April 2016). Available at: https://www.legifrance.gouv.fr/loda/id/JORFTEXT000032376671/. [Accessed: 
19/12/2023].  
125 Direction Regionale et Interdepartementale de l'Environnement et de l'Energie (2017). Atmosphere 
protection plan for Ile-de-France 2018-2025. Paris: France. Online. Available at: 
https://inis.iaea.org/search/search.aspx?orig_q=RN:51070016. [Accessed: 19/12/2023].  
126 Ministry of Energy Transition (2021) ‘The Government presents an action plan to develop more efficient 
domestic wood heating and reduce PM emissions by 50%’, Press Release, Online. Available at: 
https://www.ecologie.gouv.fr/gouvernement-presente-plan-daction-developper-chauffage-au-bois-
domestique-plus-performant-et. [Accessed: 19/12/2023].  
127 Ibid. 
128 Decree No. 2023-641 on the Maintenance of Fireplaces and Appliances for Heating, Cooking, 
Combustion, hot water production and the chimney sweeping of Flues (2023). Available at: 
https://www.legifrance.gouv.fr/jorf/id/JORFTEXT000047867286?fbclid=IwAR3b0G4sPQAvT5723ZB8NxxPmAwxrM
Ve7kL71EpJ1O_RfDNbwdLVCqaEU6E. [Accessed: 19/12/2023].  

11/13788A/11 

57 of 104 

28 March 2024 

 
Increasing policy coherence between bioenergy and clean air policies and measures Final Project Report 

as a consultant and is required to advise their customers about operational aspects related to best practice 
wood  combustion,  advise on  the need to replace  or update  appliances,  as well  as  inform  customers  about 
subsidies available for replacing their appliances.  

Who is implementing them?  

France’s action plan, whilst a national initiative, is enacted at the regional level. Having local plans (in addition 
to  the  overarching  national  plan)  is  designed  to  better  reflect  the  consensus  and  understanding  of  wood 
combustion and its impacts amongst a diverse population. These will reflect the general level of understanding 
of the negative air quality impacts from wood combustion in the region. The benefit of the regional APPs also, 
considering Grenoble as an example, mean that regional emissions limits can be developed based on ground 
research of the most important pollutants in the area. For example, in Grenoble, the most recent update to the 
plan  notes  that  PM  emissions  have  not  exceeded  regulatory  thresholds  for  half  a  decade,  however  these 
thresholds are still much higher than those recommended by the WHO. This, including the overarching aim of 
the plans detailed in the 2021 vote to reduce fine particulate matter emissions, provides a strong evidence base 
for justifying the newly introduced plan for post-2025 (Regional Directorate for the Environment, Planning and 
Housing, 2023)129. 

Whilst there is a national government level funding pot, it is up to state authorities to define the amount of funding 
available for households to access to upgrade their appliances. In states where there are usage bans (such as 
in  Grenoble  and  Auvergne-Rhône-Alpes,  for  example)  there  are  usually  subsidies  available  for  appliance 
replacement.  

What issues and obstacles have had to be overcome?  

Key interviewees informed us that the current log market only accounts for approximately 20% of logs being 
used in France for domestic heating, which means that there is a large portion of wood fuel that is not regulated, 
nor  can  its  moisture  content  be  enforced.  Fuel  restrictions  also  stipulate  that  moisture  of  wood  fuel  must  be 
known, for whatever quantity it is sold in. However, only wood sold in small quantities (i.e., where it is assumed 
that none will be stored before use), has a requirement of a moisture content <23%, according to conversations 
with stakeholders.  

Is there an estimate of effectiveness?  

The local plans required under the Atmosphere Protection Plan must be evaluated every two years, meaning 
the first will take place in 2025. Therefore, there will be estimates of effectiveness going forward, which can be 
regarded as best practice given the widespread lack of evaluation for such measures.  

The  Green  Flame  Label  is  only  slightly  more  stringent  than  the  requirements  laid  out  by  the  EU  Ecodesign 
Directive. There are plans for a revision of the label in 2025, however. It is important to note that the label does 
not require the use of catalysts, nor installation of particle filters. The predominant difference between the Green 
Flame  Label  and  the  EU  Ecodesign  requirements  is  that  Green  Flame  requires  emissions  certification  to  be 
confirmed at two separate laboratories. While this will be more burdensome for manufacturers, it will provide 
additional assurance that emissions levels can be replicated in real-world use.  

Are there any other measures being implemented?  

France Bois Bûche is a fuel quality mark. It also acts as an advice column and a public information source for 
details  regarding  upcoming  subsidy  schemes  and  changes  to  legislation.  For  example,  whilst  not  a  measure 
specifically, there is an upcoming reform of the main government subsidy scheme for replacing fossil fuel-based 

129 Regional Directorate for the Environment, Planning and Housing (2023). Plan de Protection de 
l’Atmosphère de Grenoble Alpes Dauphiné 2022-2027. Préfet De L’Isère. Online. Available at: 
https://www.auvergne-rhone-alpes.developpement-durable.gouv.fr/le-plan-de-protection-de-l-atmosphere-
de-l-a22941.html?lang=fr. [Accessed: 19/12/2023].  

11/13788A/11 

58 of 104 

28 March 2024 

 
Increasing policy coherence between bioenergy and clean air policies and measures Final Project Report 

appliances with wood-based ones. The reform will be implemented as of April 2024, and will cut the available 
funds for households looking to switch to wood-fuelled appliances. This will have implications for the uptake of 
wood-burning appliances130. This decision has allegedly been due to the necessity to preserve France’s forests.  

What are the lessons which could be applied elsewhere?  

The case study of France showcases a potential policy option which  accommodates regional differences of 
public perception and understanding of air pollution issues related to wood combustion. For example, through 
tailored  Atmosphere  Protection  Plans,  stringent  measures  are  introduced  only  in  areas  with  particularly  high 
exposure to poor air quality. France’s Atmosphere Protection Plan model also promotes the equitable division 
of financial resources amongst regions. 

6.6 

Analysis of measures 

Annex A6 (spreadsheet) provides a reference table for the policies and measures aimed at reducing the air 
pollution impact of bioenergy at national, regional or local/city level. It has been drawn together from a number 
of  different  sources,  as  well  as  primary  research.  The  measures  listed  cover  18  different  countries  (mainly  EU 
Member States), and while the search for measures has been extensive, it was not necessarily exhaustive: where 
Member States are not listed, it does not necessarily mean that no measures are being undertaken, simply that 
they did not feature in the information sources the project was able to access. In particular, information and 
awareness campaigns are likely to be far more numerous than those listed. For example, only two campaigns 
sponsored  by  local  authorities  in  the  UK  are  listed,  whereas  there  are  in  reality  many  more.  Adding  further 
examples to the list would not necessarily add value to the overall database given that many draw on the same 
sources of information. Moreover, in terms of policy interventions, they all refer to the same two or three policy 
measures available nationally in the UK. 

6.6.1 

Prevalence of measures across Member States 

Around  120  measures  are  listed  in  Annex  A6,  split  between  operational,  stock  change,  restriction,  and 
information. 

Operational measures  

As noted above, these measures are aimed at improving the operation of bioenergy appliances, by improving 
the quality of fuel used or improving maintenance regimes. Of the 17 listed, 7 are related to inspections, whereby 
mandatory inspection of units is required, usually on a one-to-three-year basis, and often by chimney sweeps. 
Note that “chimney sweep” is the English term for the function but it captures a wide variety of professionalisation 
and training. In some countries, chimney sweeps simply clean chimneys, whereas in others (such as Germany) 
they are appliance technicians, trained in solid, liquid and gaseous fuel appliances and equipped to undertake 
detailed technical inspections. 

However, mandatory chimney cleaning/inspection is in place in several countries, although usually for fire safety 
reasons. This not only provides a potentially useful source of information on installed appliances, but chimney 
sweeps have also been shown to be a very useful way of advising users on good combustion practice. Their 
advice and guidance is often more effective than generalised advice from either regulators (i.e. government 
or municipal sources) or manufacturers/suppliers. As the case study from Germany shows, they can be effective 
in changing consumer behaviour to the extent that burning unseasoned, or “wet”, wood is no longer seen as a 
significant issue. 

130 France Bois Buche (2024) ” 2024 subsidies for the purchase of a wood-burning appliance.” Online. 
Available at: https://www.franceboisbuche.fr/choisir-mon-appareil/les-aides-2024-pour-lachat-dun-appareil-
de-chauffage-au-bois/. [Accessed: 15/02/2024]. 

11/13788A/11 

59 of 104 

28 March 2024 

 
Increasing policy coherence between bioenergy and clean air policies and measures Final Project Report 

The remainder of the measures are focussed on fuel quality. They generally seek to limit the supply or use of wet 
wood,  with  the  maximum  moisture  content  of  20-25%  (where  specified).  Where  these  are  legislative 
requirements, there are some exemptions in terms of the volume of wood supplied or the locations they apply 
to.  However,  most  of  the  measures  listed  are  related  to  labelling  schemes  and  are  not  mandatory.  The  key 
weakness of almost all of the fuel quality measures is that they only apply to fuel sold, whereas in many areas 
wood fuel is either own sourced or supplied through the grey market, e.g. a local tree surgeon supplying friends 
and family. This emphasises the importance of user behaviour and knowledge, such as the importance of using 
seasoned wood, how to recognise seasoned wood and how to season at home, if necessary. 

Stock change measures  

This is the most numerous category among those identified through this project; it is also the most diverse. Over 
half  of those  identified  are  schemes  aimed  at  replacing  old  appliances  with  newer,  less  polluting versions  or 
even  with  non-combustion  heating  systems,  including  two  scrappage  schemes  (i.e.  aimed  at  fully  removing 
appliances from the stock, not just replacing them) such as in the Netherlands or Aachen, Germany. They all 
involve some form of subsidy, either as a direct payment or through subsequent tax relief. They vary in the level 
of subsidy, including some which cover 100% of purchase and fitting costs for new appliances, although this 
level of subsidy is rare (it was also criticized by one stakeholder for limiting the coverage available to the scheme 
as a whole). In some countries, e.g. Denmark, the subsidy scheme was linked to a time expiry for older stoves, 
and in fact a similar scheme ran in the UK following the Clean Air Act 1956 and the introduction of Smoke Control 
Areas,  which  directly  supported  the  uptake  of  gas  heating  systems  in  the  1950s  and  60s.  Thus,  subsidised 
replacement schemes are an effective way to facilitate both stock renewal and restriction programmes. 

A further 21 measures are product standards, applying emission limits to new appliances. In many cases, they 
have been superseded by the requirements of the Ecodesign Directive (2009/125/EC), but many are still more 
stringent.  This  includes  the  testing  regime  required  for  certification,  such  as  the  requirement  to  have  results 
certified by a second testing laboratory (France) or to include start up emissions as part of the test (Germany). 
The standards which are more stringent than the Ecodesign Directives tend to be voluntary labelling schemes, 
and  while  they  are  not  mandatory,  they  do  provide  some  leverage  for  local  authorities  to  specify  higher 
minimum standards in building codes, etc. 

The remaining three measures are building standards. Two restrict the types of appliances which can be installed 
in new buildings, with one, in Denmark, also specifying a maximum age for stoves to be included in house sales. 
The  third  measure,  in  Germany,  includes  the  listing  of  biomass  heating  as  part  of  the  Energy  Performance 
Certificate (EPC) which potentially paves the way for the inclusion of a PM2.5 metric in EPCs (see section 7). 

Restriction of use  

This  is  also  a  varied  category  of  measures,  with  9  identified  schemes  applied  at  a  national  level  and  the 
remainder at a regional or local level. Of the national measures, five are enabling (i.e. allowing municipalities to 
take certain actions but not mandating such action), while the others mandate either a product or building 
standard, and are thus very similar to equivalent stock change measures. 

The regional or local measures vary quite considerably in their specification and include: 

•  Absolute bans on solid fuel heating in some cities (e.g. Krakow and Sofia) although these are very locally 

focussed 

• 

• 

Temporary bans on wood or solid fuel heating depending on conditions, including high air pollution episodes 
(e.g. in Graz, Austria or the Po Valley region in Italy) 

Bans on the installation of appliances, either based on emission performance or location, or both (such as 
in Riga, Latvia) 

• 

Fuel quality requirements (such as the Domestic Solid Fuel Regulations in the UK), and 

11/13788A/11 

60 of 104 

28 March 2024 

Increasing policy coherence between bioenergy and clean air policies and measures Final Project Report 

• 

1 instance, from Denmark, of a ban on chimneys for new buildings, to restrict the uptake of bioenergy 

The  limited  geographical  extent  of  these  measures  will  mean  that  they  also  have  a  limited  impact  on  total 
regional or national emissions. However, their intent is to reduce local concentrations, especially of PM10 and 
PM2.5. The project team was unable to identify any evidence of their effectiveness in this, although the future (at 
the  time  of  writing)  evaluation  of  regional  plans  under  the  French  strategy  should  be  an  opportunity  to 
demonstrate this. 

Information campaigns  

As noted above, the extent of information campaigns is very likely much higher than those listed in this project. 
However, the broad themes are likely to be the same. Of the 32 measures listed, 22 are aimed at stove (and 
other  wood  fuel  appliance)  users,  mostly  to  provide  advice  and  information  on  how  to  operate  a  solid  fuel 
appliance correctly. This advice ranges from the type of appliance to choose, the type of fuel, how to light it 
and  how  to  operate  the  appliance  most  efficiently.  The  approaches  vary  from  simple  website  campaigns 
through to television advertisements and ultimately to full training and certification courses (non-mandatory). 
While these approaches will assist in reducing emissions from existing appliances, stakeholders have commented 
that they could legitimise solid fuel (or bioenergy) use where the local aim is to reduce it, e.g. in more urbanised 
settings. 

A further 10 campaigns are more general awareness raising, highlighting the impact of solid fuel/woody biomass 
use on air quality, as well as the themes mentioned above. They tend to be either leaflet or website campaigns 
and have been used in conjunction with more direct intervention. 

Once again, it has not been possible to identify evidence on the  effectiveness of such campaigns, at either 
reducing  bioenergy  use  or  improving  practice,  although  they  are  seen  as  a  necessary  facilitating  action 
alongside other, more direct, interventions. 

6.6.2 

Effectiveness of measures and barriers to uptake 

One of the main gaps in the information gathered for this project is the quantified effectiveness of measures. 
This  is  largely  because  policy  evaluation,  either  ex  ante  or  ex  post  appears  to  be  undertaken  rarely  and 
published even more rarely. This is especially the case for measures undertaken at local level, but national level 
policy evaluation is also still in its infancy in many Member States. Formal evaluations are either underway or 
planned  in  several  countries,  and  evaluation  of  the  impacts  of  the  regional  plans  is  mandated  through  the 
French Atmosphere Protection Plan131, although this won’t be undertaken until 2025. There is some evidence 
that the programme of inspections undertaken by chimney sweeps in Germany has resulted in improvements 
in the quality of fuel being burnt (i.e. lower moisture content).  A reduction in the use of wood logs has been 
reported in Denmark, with users switching to wood pellets or non-combustion heating.  

Barriers to the uptake of measures to control the impact of woody biomass used for heating on air quality, and 
which limit the effectiveness of those that are implemented, are multiple and overlapping. From the research 
undertaken  for  this  project,  they  tend  to  be  political,  cultural  and  socio-economic,  rather  than  technical  in 
nature:  applying  emission  limits  on  appliances,  for  example,  appears  to  be  relatively  straightforward  and, 
indeed, they already apply across the EU in the form of the Ecodesign Directive requirements. There are also 
technical controls applied to both medium and large bioenergy units, through the MCPD and IED, receptively. 
The  key  issue,  as  highlighted  throughout  this  report,  is  the  application  of  controls  on  the  domestic  use  of 
bioenergy, generally in the form of wood combustion. 

131 Direction Regionale et Interdepartementale de l'Environnement et de l'Energie (2017). Atmosphere 
protection plan for Ile-de-France 2018-2025. Paris: France. Online. Available at: 
https://inis.iaea.org/search/search.aspx?orig_q=RN:51070016 

11/13788A/11 

61 of 104 

28 March 2024 

 
Increasing policy coherence between bioenergy and clean air policies and measures Final Project Report 

Political barriers 

The reluctance to impose controls on people’s activities in their homes – the key political barrier – is not unique 
to bioenergy/woody biomass used in households for heating purposes, and extends to a number of potentially 
“polluting”  activities,  such  as  the  use  of  high  solvent  products.  These  are  usually  controlled  through  product 
standards, making the polluting product or material less available (or by banning it). However, such controls are 
far less effective where the product is sourced either outside the normal market, e.g. through local suppliers with 
extremely short supply chains, through grey markets or even self-sourced (e.g. foraged). Controls can be applied 
within the more formal retail settings, such as the labelling of wood logs sold in supermarkets, DIY stores or garden 
centres, but that only addresses a part of the supply: estimates in France, for example, are that only 20% of the 
wood logs used for heating come from such formal sources. There is therefore a strong reliance on consumer 
behaviour, such as the proper storage and seasoning of fuel or correct lighting procedure, which is politically 
and socially unattractive to regulate. 

Product control processes can, of course, be used to specify emission standards for new appliances, hence the 
approach used in the Ecodesign Directive. However, this only addresses new appliances and not appliances 
already installed. While replacement of old appliances with new will, eventually, reduce air pollution emissions, 
stock  turnover  is  often  very  slow  due  to  both  the  longevity  of  combustion  units  and  the  costs  (and 
inconvenience)  often  associated  with replacement.  The  application  of  emission controls  to  already  installed 
appliances is usually associated with an expectation of financial support or compensation to address either the 
cost of the new appliance, or its installation, or both. This brings, in turn, further potential issues, depending on 
the local circumstances. For example, in some countries, especially where bioenergy is not a principal source 
of space or water heating, the use of log burning stoves is associated with relatively wealthy households. Thus, 
any subsidies could be seen as subsidising the already well off. Moreover, securing significant funding for any 
compensation  scheme  will  be  at  the  detriment  of  other  public  funding  areas.  Finally,  the  effectiveness  of 
emission controls on appliances is still dependent on user behaviour, including the operation of the appliance 
and the quality of the fuel used. 

Socio-economic barriers 

Socio-economic factors which limit either the uptake or effectiveness of measures to reduce air pollution from 
domestic use of woody biomass for heating will depend on both the wider socio-economy of the Member State 
(or region) and the prevailing energy infrastructure. Where the predominant issue is the use of appliances using 
wood  (and/or  other  solid  fuels  such  as coal  or  MSF)  as  a  supplementary  space  heating  source,  a  significant 
proportion  is  likely  to  be  “aesthetic”  or  “cosy”  burning.  This  means  that  householders  decide  to  use  a 
supplementary heating source when it is neither necessary nor economical to do so; a recent analysis in the UK 
suggested that the use of wood fuel is significantly more expensive than relying on natural gas132 (by far the most 
common  heating  fuel  in  the  UK).  This  in  turn  means  that  household  value  the  “cosy”  atmosphere  and  the 
aesthetics of a wood fire above the additional cost of running such an appliance, voluntarily incurring additional 
costs. This makes it very difficult to use economic signals or market mechanisms to influence their behaviour. 

By  contrast,  reliance  on  solid  fuels,  including  the  use  of  woody  biomass/fuelwood  in  households,  is  also 
associated  with  more  economically  deprived  households,  with  the  proportion  varying  in  different  Member 
States.  Such  households  may  also  have  more  limited  access  to  alternative  energy  sources.  Thus,  the  use  of 
economic drivers to change behaviour may be viewed as regressive, penalising those who are least able to 
afford alternatives. 

Cultural barriers 

The  impact  of  cultural  influences  on  the  use  of  woody  biomass/fuelwood  in  households  is  more  difficult  to 
quantify, and evidence is limited. However, anecdotal evidence from interviews conducted as part of this study 

132 https://urbanhealth.org.uk/wp-content/uploads/2023/11/Relight-my-fire-investigating-the-true-cost-of-
woodburning-stoves-impact-on-urban-health.pdf  

11/13788A/11 

62 of 104 

28 March 2024 

 
Increasing policy coherence between bioenergy and clean air policies and measures Final Project Report 

has indicated that, in some countries and regions, there are strong cultural and traditional associations with the 
use  of  bioenergy,  especially  locally  sourced  wood  fuel.  In  parts  of  Germany,  for  example,  private  and 
community ownership of forests is common, and the expectation is that wood from such forests can (and should) 
be used as a heating fuel. Links between the use of wood-fuel and “traditional” lifestyles in some countries may 
make  political  decision  makers  reluctant  to  intervene,  particularly  in  the  current  political  climate,  where 
environmental issues are being employed as a “wedge” issue. 

All of these issues overlap to present a significant challenge to the successful implementation of measures to 
reduce the air pollution impact of fuelwood use for heating in households. They emphasise the need to be clear 
about the nature of the issue to be addressed (e.g. patterns and location of woody biomass use for energy) 
and the intended outcome of a measure (e.g. reduction in use or change in behaviour), and the use of multiple 
measures within a wider strategic framework. 

6.7 

Principles for successful measures 

Reviewing  the  measures  that  have  been  implemented  by  Member  States,  their  regions  and  cities  highlights 
some broad principles which could aid the successful development of new measures: 

The measures need to fit the issues 

It is clear that there is not a “one size fits all” solution to addressing the air quality impacts of biomass use for 
energy.  In  some  circumstances,  biomass  may  be  the  most  effective  source  of  renewable  heat,  and  the  air 
quality  impacts  may  be  of  lower  importance,  such  as  in  low  population  density,  rural  areas.  In  such  cases, 
ensuring equipment and fuels are of high quality is likely to be the main aim of local interventions. However, in 
high density, urban areas, where there are multiple alternative energy sources, encouraging users to use less or 
move  to  non-combustion  heating  systems  is  likely  to  be  a  more  preferable  policy  aim.  These  are  simply  two 
examples  and  there  are  many  other  circumstances,  each  requiring  a  slightly  different  policy  approach.  The 
main point is that the measures should be developed and implemented with the specific issue to be addressed, 
and the outcome desired, as the key guiding principle. 

A variety of measures is likely to be required, at different administrative levels 

Following on from the previous point, reliance on centrally implemented solutions is likely to be less successful 
than  locally  implemented  solutions  which  meet  local  needs  and  circumstances.  However,  a  national  level 
framework will be required, to ensure consistency and avoid confusion among suppliers and consumers alike. 
This could include fuel quality standards, appliance emission limits or labelling, the provision of powers to local 
enforcement  authorities  or  funding  for  appliance  replacement  schemes.  This  will  then  enable  the 
implementation of local measures ranging across the types described in this report, i.e. operational changes, 
stock changes, use restrictions, and information campaigns. 

Measures need to be bound together in a coherent, publicly accessible strategy 

A  coherent  strategy,  which  sets  out  the  national  framework  and  the  roles  and  responsibilities  of  local 
enforcement or planning authorities is required to ensure maximum visibility of the overall policy aims. A publicly 
available  strategy  will  provide  a  focal  point  for  action  and  allow  local  authorities,  producers,  suppliers  and 
consumers to understand what is expected of them. 

Measures need to include both suppliers and consumers 

The importance of the informal market, and non-market supply of fuel, means that measures which only address 
the formal market are unlikely to be effective, or at least unlikely to be effective on their own. Changing the 
level of understanding of air quality impacts among consumers, as well as upskilling in the use of woody biomass-
using  appliances,  will  help  create  upward  pressures  on  suppliers,  changing  the  market.  The  example  from 
Germany, where the combustion of unseasoned wood is no longer considered an issue, came as a result of 

11/13788A/11 

63 of 104 

28 March 2024 

Increasing policy coherence between bioenergy and clean air policies and measures Final Project Report 

directly changing consumer behaviour which in turn has changed the demands those consumers make on fuel 
suppliers. 

Information is a key component, as is the way in which information is presented 

The provision of information, both on the potential impact that the use of biomass for energy has on air quality 
and on the correct use of it (including appliance choices) is crucial for the successful implementation of other 
measures, e.g. on use restriction or fuel quality. There have been successful national and local information and 
training campaigns, implemented by national and local authorities. However, consideration also needs to be 
given  to  other  information  sources.  Specifically,  chimney  sweeps  have  been  shown  to  be  a  crucial  link  in 
providing  information  to  consumers,  being  both  more  personal  and,  potentially,  more  trusted  than  either 
authorities or manufacturers/suppliers. In countries where chimney sweep services are mandatory, they have 
also been shown to be an excellent source of information on the domestic appliance stock, thereby helping to 
improve air quality emissions estimates. 

Measures need to take into account both fuel poverty and the access to alternatives 

Every Member State, to a greater or lesser degree, will have households dependent on non-grid energy. Care 
is needed in the design and implementation of measures to avoid extending or exacerbating fuel poverty, for 
example by increasing fuel costs where no alternatives exist, given that fuel poverty is also linked to significant 
public health impacts. Other unintended consequences, such as forcing people to switch from regulated fuels 
to unregulated fuels, such as waste construction timber (which could in turn make air pollutant emissions worse), 
must also be considered within the measure design. 

Cultural drivers need to be taken into account 

Potential cultural drivers for the use of bioenergy need to be understood and sensitively handled in the design 
of measures. Not to do so risks popular backlash and a distrust of those implementing the measures, undermining 
their  effectiveness.  Popular  and  stakeholder  engagement  are  therefore  important  in  the  measure  design 
process, as is the provision of clear, unbiased information on both the issues to be addressed (e.g. air pollution 
or fuel poverty) and the aims of the policies being developed. 

11/13788A/11 

64 of 104 

28 March 2024 

Increasing policy coherence between bioenergy and clean air policies and measures Final Project Report 

7 

Enabling action through policy development 

One of the initial components of this study was the provision of support to the European Commission in securing 
policy coherence around the issue of bioenergy and air quality. In particular, measures in development which 
could, potentially, promote or enable the use of bioenergy needed to be aligned with the goals of improving 
air pollution and thus public health. During the project, two measures in particular were under development, 
namely the revision of the Regulations relating to  solid fuel boilers and  local space heaters, made under the 
Ecodesign  Directive  (2009/125/EC),  and  the  revision  of  the  Energy  Performance  of  Buildings  Directive  (EPBD, 
2010/31/EU).  

7.1 

Ecodesign Directive 

The Ecodesign Directive has provided a significant driver for the improvement in the energy performance, and 
other environmental metrics, of a wide range of consumer products.  Of relevance for this study, this includes 
space heaters and boilers, and the setting of mandatory air pollution emission limits for bioenergy appliances. 
However, these standards have lagged behind those set in some Member States and so a tightening of the 
standards has been proposed. 

An  initial  information  exchange  between  this  project  team  and  the  team  supporting  the  revision  of  the 
Ecodesign criteria for solid fuel boilers and local space heaters has been undertaken. However, other than a 
broad alignment of objectives (i.e. the minimisation of air quality impacts from bioenergy use), there was little 
commonality found between the specific aims of the projects. This project sought to summarise the air quality 
impacts of bioenergy and analyse the range of measures being developed in this space by Member States. It 
does not address the specifics of emission standards or testing procedures to the level of detail required by the 
Ecodesign Directive revision team. Therefore, no more work was undertaken under this sub-task, but the results 
generated here on the air quality impacts of bioenergy will be available to inform the preparation of the revision 
of Ecodesign criteria for solid fuel boilers and local space heaters. 

7.2 

Energy Performance of Buildings Directive 

The EPBD is the main EU instrument targeted at improving the overall energy performance of buildings in Europe. 
It  includes  requirements  for  Member  States  to  improve  the  energy  performance  standards  for  new  and 
renovated buildings and mandates the issuing of Energy Performance Certificates (EPCs). EPCs must include a 
standard set of performance metrics, with additional, optional indicators listed in Annex V of the Directive. One 
of these optional indicators relates to operational emissions of fine particulate matter (PM2.5), although this is not 
further defined in the Directive. 

Given that bioenergy, and solid fuel use more broadly, is the principal source of domestic PM2.5 emissions, the 
development of an initial format for the PM2.5 indicator for potential inclusion in EPCs was undertaken as part of 
this  project.  The  resulting  proposal  is  based  on  EMEP  Guidebook133  emission  factors  for  different  heating 
appliance types and uses an A-F scale similar to that already used for the energy performance indicators in 
EPCs. It is explained further in Annex 1)a)i)(1)(a)(i)A7 to this report. The proposal is the preferred option of three 
initially considered, and would need further refinement and testing using real-life examples before it is ready to 
roll out. 

133 https://www.eea.europa.eu//publications/emep-eea-guidebook-2023  

11/13788A/11 

65 of 104 

28 March 2024 

 
Increasing policy coherence between bioenergy and clean air policies and measures Final Project Report 

8 

Conclusions 

8.1 

Key emerging messages 

Small-scale bioenergy use presents a significant barrier to meeting clean air ambitions in the EU 

Bioenergy  use  in  small  combustion  appliances  makes  up  around  half  of  the  PM2.5  emissions  in  the  EU27  (see 
Figure 4-4). This presents a risk to the EU’s ability to meet both air pollutant emission reduction commitments and 
concentration  targets.  Given  the  scale  of  emission  reductions  from  all  sectors  required  to  meet  the  recently 
agreed  air  quality  standards  under the  revised  Ambient  Air  Quality  Directive134  significant reductions  in  PM2.5 
emissions from bioenergy use will be necessary for full compliance. 

Bioenergy is also a significant part of the energy supply landscape in almost all EU Member 
States 

Bioenergy is the main source of renewables in the EU in terms of gross final energy consumption, representing 
almost 60% of renewable energy sources135. Its main use is for heating and cooling (around 75%). In the EU, the 
use  of  bioenergy  increased  very  rapidly  between  2005  and  2020,  although  in  recent  years  the  growth  has 
levelled  out,  potentially  due  to  uncertainty  in  policies  and  debates  about  sustainability  of  bioenergy136. 
Germany, France, Italy and Sweden are the EU27 Member States with the highest bioenergy consumption in 
absolute terms,  although  it makes  a  significant contribution  to energy consumption  in  all  but  a  few  Member 
States. At the EU collective level in 2021, the industry sector consumed 21.1 Mtoe of solid biomass (8.8% of final 
energy consumed in the industry sector), the residential sector 45.2 Mtoe (17.3%) of final energy consumed in 
the residential sector), and the energy sector 33.0 Mtoe (2.6% of transformation input in the energy sector)137. 

Controlling air pollutant emissions from domestic-scale bioenergy use is a key challenge for 
clean air policy 

Small-scale biomass combustion, using solid fuel, makes up the great majority of bioenergy emissions for the five 
pollutants covered by the NEC Directive. There are  significant contributions from bioenergy use in the energy 
and manufacturing industry sectors for NOX and SO2. However, the stricter emission limits included in the updated 
LCP BAT conclusions, in place from 2021, will likely result in bioenergy emissions from these sectors decreasing in 
the near future. Moreover, bioenergy is a minority contributor (2-8%) to EU emissions of NOX, SO2 and NH3. This is 
not  the  case  for  PM2.5  where,  as  noted  above,  emissions  from  small-scale  bioenergy  combustion  make  up 
around 50% of the total. 

There are drivers to both increase bioenergy use and control its impacts within EU policy, and 
greater coherence is needed especially around domestic heating 

Policy  and  legislation  to  control  air  pollution  have  been  in  place  at  EU  and  Member  State  levels  for  a 
considerable  time  and  the  area  is  relatively  mature.  Such  legislation  should  act  to  control  the  air  pollution 
impacts of bioenergy use. However, climate  policies (and associated messaging) in general, and renewable 
heat policies in particular, have tended to promote an image of bioenergy as “green energy”. The attendant 
potential  negative  impacts  on  air  quality  have  not  had  much  prominence.  This  was  born  out  by  comments 
made by some of the stakeholders interviewed for this project. 

134 https://environment.ec.europa.eu/topics/air/air-quality/revision-ambient-air-quality-directives_en, see in 
particular the impact assessment underpinning the proposal for more details on the required reductions of 
emissions  
135 https://publications.jrc.ec.europa.eu/repository/bitstream/JRC130730/2022.5470_kjna31283enn.pdf 
136 Ibid. 
137 https://op.europa.eu/en/publication-detail/-/publication/96d671c9-c719-11ee-95d9-
01aa75ed71a1/language-en/format-PDF/source-305260384 

11/13788A/11 

66 of 104 

28 March 2024 

 
Increasing policy coherence between bioenergy and clean air policies and measures Final Project Report 

There are measures to address the air quality impacts of bioenergy use in most, if not all, 
Member States, following a similar pattern 

The potential air pollution impacts of domestic solid fuel use, be that bioenergy (wood) or coal, have been well 
known for many decades. As such, most Member States have some measures in place, and are also covered 
by EU scale legislation through, for example, the Ecodesign Directive. However, as other sources of air pollution, 
notably  industry  and  transport,  have  been  subject  to  increasingly  stringent  emission  controls,  the  impact  of 
bioenergy use in particular has come to the fore. Moreover, the focus on non-domestic and mobile sources has 
coincided with the uptake of domestic fuelwood use, often for “aesthetic” purposes, in many countries. This has 
changed the nature of the issue and has meant that many measures are overdue for update and revision. 

The precise nature of the primary issues vary between Member States, as does the level of 
ambition shown 

As noted above, the status of domestic woody biomass/fuelwood use varies between different Member States. 
In some, solid fuel use, including bioenergy, is still a staple component of domestic space and water heating. 
Of  those,  some  have  transitioned  strongly  towards  cleaner,  pellet  fuelled  boilers  (if  not  necessarily  stoves) 
whereas others, notably in Central and Eastern Europe, still retain a strong reliance on older log wood and coal 
fired appliances. In other countries, where gas and other energy networks are more extensive, the use of wood 
stoves as a supplementary heating source, often for aesthetic reasons, has increased over recent years. Added 
to this is the difference between rural and urban populations, both in terms of heating behaviour and access to 
alternative heating sources. This means that measures need to be carefully designed and complementary, in 
order to address the different circumstances, drivers and solutions each variant requires. 

What is certainly the case is that the level of ambition shown by different Member States also varies significantly. 
Germany, Denmark and France appear to be the most active in this space, although many other countries and 
cities are taking progressive action, such as Sofia’s low emission zone for both transport and domestic heating. 

There are good examples of measures already introduced from a variety of Member States, at 
local, regional and national scale, although more work is needed to evaluate their 
effectiveness 

In broad terms, the measures to address the air quality impacts of bioenergy undertaken by Member States, 
regions  and  cities  fall  into  four  categories:  operational  (addressing  things  like  maintenance  regimes  or  fuel 
quality),  stock  changes  (upgrading  the  stock  of  appliances  to  cleaner  burning  versions),  use  restrictions 
(restricting the  areas  or  times  in  which  bioenergy  can be  used)  or  information and  training  (mainly  aimed  at 
users,  although  not  exclusively).  In  addition  to  Sofia’s  low  emission  zone,  mentioned  above,  Denmark’s 
requirement  to  upgrade  stoves  before  a  house  can  be  sold,  Germany’s  work  with  information  provision  by 
chimney sweeps and France’s strategic approach to the control of domestic bioenergy emissions stand out as 
innovative (and replicable in other countries). However, there is very little information about the effectiveness of 
such  measures.  Impact  and  process  evaluation  appears  to  be  particularly  rare  in  this  space  but  could  help 
refine  and  direct  measures  to  ensure  they  achieve  their  desired  outcomes  and  avoid  unintended 
consequences. 

National strategies to address domestic solid fuel use, including bioenergy, are likely to be 
needed in order to meet EU air quality and climate ambitions, as well as to address social 
issues such as fuel poverty 

As noted above, domestic woody biomass use accounts for around half of the PM2.5 emissions in the EU and is 
likely to act as a barrier to achieving the EU’s Clean Air ambitions unless addressed. As also noted in this report, 
this is a complex problem, with links not only to climate policy and the promotion of renewable heat, but also 
social issues such as fuel poverty. A dedicated strategic approach to addressing the air pollution impacts of 
bioenergy is likely to be needed within each Member State. The aim is to ensure that a range of measures is 
available, to be implemented in different areas to address the different nature of the issues (e.g. urban and rural 

11/13788A/11 

67 of 104 

28 March 2024 

Increasing policy coherence between bioenergy and clean air policies and measures Final Project Report 

situations),  and  that  account  can  be  taken  of  wider  issues  such  as  fuel  poverty.  It  is  also  more  efficient  to 
evaluate the effectiveness of a strategy, rather than of each individual measure, and allows the enabling nature 
of information campaigns to be more fully assessed. 

8.2 

Recommendations 

8.2.1 

EU Level 

•  Greater consistency is required from the European Commission as to the expected role of bioenergy and 
solid  fuel  use  more  generally,  within  the  overall  energy,  climate  and  clean  air  policies  for  the  EU. 
Differentiation  is  needed  between  large  and  medium  scale  bioenergy  use  (e.g.  in  power  generation  or 
district heating) and small-scale domestic use, and on suitable locations for use. In particular, any policy or 
legislation which promotes the use of bioenergy needs to include a full impact assessment of likely effects 
on air quality and public health. Moreover, measures to protect air quality should be built into policies and 
legislation  which  incentivise  or  drive  the  uptake  of  renewable  heat  in  particular,  attempting  to  avoid 
widespread uptake of small-scale bioenergy in urban areas. While it is for Member States to determine their 
energy policies and strategies, the Commission has a role in coordinating across policy areas and helping 
to set expectations 

•  More needs to  be  done,  by  the  EU  institutions, to realise  the  PM2.5  emission reduction  potential  in  source 
legislation,  such  as  the  EPBD  and  Ecodesign  Directive.  The  former  includes  an  optional  indicator  for 
operation PM2.5 emissions from buildings but this needs to be developed into a workable metric for use by 
Member  States.  In the  case  of the  Ecodesign  Directive,  mandatory  PM emission  standards  for  bioenergy 
appliances need to be tightened, bringing them into line with more progressive Member State standards. 
Consideration should also be given to developing even more stringent, non-mandatory standards, for use 
by  Member  States  in  labelling  and  incentive  schemes.  This  will  allow  the  manufacturers  and  suppliers  to 
better coordinate their approaches to bringing lower emission appliances to the market 

• 

Further, coordinated support is needed from the European Commission for schemes to replace older wood 
combustion appliances (with lower emission appliances or, preferably, non-combustion heating), especially 
in less wealthy Member States. There is a risk that this “legitimises” bioenergy use in situations where it may 
not be appropriate, such as urban areas, and so such support needs to be contingent on location 

•  Given  that  achieving  compliance  with  EU  goals  on  clean  air  is  contingent  on  local  level  action,  the 
European Commission could develop, and encourage the use of, tools for policy evaluation at local levels, 
for use where they do not already exist at Member State level 

8.2.2  Member State level 

•  Member  States  should  develop  a  coherent  plan  for  addressing  the  air  quality  impacts  of  bioenergy,  in 
particular the use of biomass for  domestic-scale energy purposes (and, by extension, domestic solid fuel 
use138  more  generally),  within  their  overall  air  quality  and  energy  strategies.  This  will  require  coordination 
across Government Departments or Ministries to ensure a consistency of messaging for the general public 
and the bioenergy supply industries 

•  Drawing on the research to support this project, a mix of measures is required, including: 

•  Operational and fuel quality improvements 

• 

Stock  improvements,  removing  older  appliances  (including  open  fireplaces)  and  upgrading  the 
emission performance of installed appliances 

138 Coal, lignite and other solid fuels remain widely used as a domestic heating source in many Member 
States. 

11/13788A/11 

68 of 104 

28 March 2024 

 
Increasing policy coherence between bioenergy and clean air policies and measures Final Project Report 

• 

• 

Restrictions on use where other forms of heating are readily available, and local air quality impacts more 
significant, and 

Information  and  training,  both  on  the  use  of  appliances  and  their  potential  impacts  on  local 
environments (and public health). 

• 

In  accordance  with  the  principles  set  out  in  section  6.7,  such  strategies  need  to  consider  the  country’s 
specific  domestic-scale  bioenergy  picture  and  develop  a  suite  of  measures  accordingly,  deploying  (or 
facilitating)  measures  to  suit  local  circumstances,  with  use  restrictions  being  more  appropriate  for  urban 
areas and stock changes elsewhere 

•  Within  their  overall  strategies,  Member  States  should  include  a  plan  for  the  evaluation,  revision  and 
refinement of their measures over time, utilising good practice evaluation techniques. This should include 
the building in of evaluation processes from the start, such as the development and testing of theories of 
change 

•  Member States should actively collate, publish and exchange information on their measures to mitigate the 
impact of the use of biomass for energy on air quality. This project has identified a number of good practice 
and innovative measures which appear to be unknown outside their country or region of implementation. 
Given the transboundary nature of air pollution, it is in the interests of all Member States, and their citizens, 
to ensure that efforts to improve air quality are coordinated across different countries 

11/13788A/11 

69 of 104 

28 March 2024 

Increasing policy coherence between bioenergy and clean air policies and measures Final Project Report 

9 

Bibliography 

Bioenergy  Europe  (2021).  Bioenergy  explained:  Slashing  emissions 
from 
https://epc.bioenergyeurope.org/wp-content/uploads/2021/01/Air-Emissions.pdf 

residential  wood  heating. 

Cea, B., Fraboulet, I., Feuger, O., Hugony, F., Morreale, C., Migliavacca, G., Andersen, J. S., Warming-Jespersen, 
M. G., Bäckström, D. and Janhäll, S.: Development and Evaluation of an Innovative Method Based on Dilution 
to Sample Solid and Condensable Fractions of Particles Emitted by Residential Wood Combustion, Energy and 
Fuels, 35(23), 19705–19716, https://doi.org/10.1021/acs.energyfuels.1c02595, 2021. 

Chakraborty, R.et al., Indoor Air Pollution from Residential Stoves: Examining the Flooding of Particulate Matter 
into Homes during Real-World Use. Atmosphere 2020, 11, 1326. https://doi.org/10.3390/atmos11121326 

Coolproducts & ECOS, 2022, Out of the woods: Using ecodesign to reduce the negative impacts of solid fuel 
heating, https://www.coolproducts.eu/wp-content/uploads/2022/03/ECOS_Out-of-the-woods_final.pdf. 

Cottom  J.W.  and  Mitchell  E.J.S.  (2021),  Up  in  smoke:  the  contribution  of  domestic  outdoor  burning  to  UK 
particulate  matter  emissions.  Report  by  Clean  Stove  Consultants  Ltd.  for  Stove  Industry  Alliance.  Leeds,  UK. 
https://stoveindustryalliance.com/wp-content/uploads/2022/02/22-01-31-The-contribution-of-domestic-
outdoor-burning-to-UK-particulate-matter-emissions.pdf 

Couvidat, F. et al., 2021, ETC/ATNI Report 2020/6 on the Development of renewable energy and impact on air 
quality: co-benefits and trade-offs, https://www.eionet.europa.eu/etcs/etc-atni/products/etc-atni-reports/etc-
atni-report-6-2020-development-of-renewable-energy-and-its-impact-on-air-quality-co-benefits-and-trade-
offs. 

Danish  Ecological  Council,  2016,  Pollution  from  residential  burning  -  Danish  experience  in  an  international 
Umwelthilfe, 
perspective, 
https://www.ccacoalition.org/en/resources/pollution-residential-burning-danish-experience-international-
perspective. 

Ecological 

Deutsche 

Council, 

Danish 

Clean 

Heat, 

Denier van der Gon, H. A. C et al., Particulate emissions from residential wood combustion in Europe  – revised 
estimates  and  an  evaluation,  Atmos.  Chem.  Phys.,  15,  6503–6519,  https://doi.org/10.5194/acp-15-6503-2015, 
2015. 

EEB, 2021, Where there’s fire, thre’s smoke, Emissions from domestic heating with wood, European Environment 
Bureau  &  Green  Transition  Denmark,  https://eeb.org/library/where-theres-fire-theres-smoke-emissions-from-
domestic-heating-with-wood/. 

EFSA, 2008, Polycyclic Aromatic Hydrocarbons in Food, Scientific Opinion of the Panel on Contaminants in the 
Food  Chain,  (Question  N°  EFSA-Q-2007-136),  Adopted  on  9  June  2008,  The  EFSA  Journal  (2008)  724,  1-114, 
https://efsa.onlinelibrary.wiley.com/doi/pdf/10.2903/j.efsa.2008.724 

EPHA,  2022,  The  impact  of residential  heating  and cooking  on  air  quality  in  Europe:  The  health  argument for 
(EPHA)  Position  paper,  Brussels, 
clean  heating  and  cooking,  European  Public  Health  Alliance 
https://epha.org/wp-content/uploads/2022/03/epha-position-paper-clean-heating.pdf. 

European  Commission,  Joint  Research  Centre,  Camia,  A.,  Giuntoli,  J.,  Jonsson,  R.  et  al.,  The  use  of  woody 
biomass for energy production in the EU, Publications Office, 2021, https://data.europa.eu/doi/10.2760/831621 

Fraboulet, I.: Validation and comparison of methods of measurement of the condensable fraction of aerosols 
emitted 
URL 
https://www.nanoparticles.ch/archive/2016_Fraboulet_PO.pdf,  20th  ETH-Conference  on  Combustion  Generated 
Nanoparticles June 13th – 16th, 2016 at ETH Zentrum, Zürich, Switzerland, 2016. 

combustion 

appliances 

residential 

(poster), 

boilers 

wood 

and 

by 

11/13788A/11 

70 of 104 

28 March 2024 

Increasing policy coherence between bioenergy and clean air policies and measures Final Project Report 

Green  Transition  Denmark,  2022,  Pollution  from  residential  burning  -  Danish  experience  in  an  international 
perspective,  Green 
Transition  Denmark,  Clean  Heat,  Deutsche  Umwelthilfe,  https://rgo.dk/wp-
content/uploads/GTD_Pollution-from-wood-burning_2022-1.pdf. 

Kindbom, K., & Mawdsley, I. (2018). Emission factors for SLCP emissions from residential wood combustion in the 
Nordic countries. Swedish Environmental Research Institute, IVL-report C292. 

Klimont, Z., Kiesewetter, G., Kaltenegger, K., Wagner, F., Kim, Y., Rafaj, P., Schndlbacher, S., Heyes C., Z., Denby, 
B., Holland, M., Borken-Kleefeld, J., Purohit, P., Fagerli, H., Vandyck, T., Warnecke, L., Nyiri, A., Simpson, D., Gomez 
Sanabria, A., Maas, R., Winiwarter, W., Ntziachristos, L., Georgakaki, M., Bleeker, A., Wind, P., Hoglund-Isaksson, 
L.,  Sander,  R.,  Nguyen,  B.,  Poupa,  S.,  Anderl,  M.,  2022a.  Support  to  the  development  of  the  third  Clean  Air 
Outlook. International Institute for Applied Systems Analysis, Laxenburg, Austria. 

Klimont, Z., Kiesewetter, G., Kaltenegger, K., Wagner, F., Kim, Y., Rafaj, P., Schndlbacher, S., Heyes C., Z., Denby, 
B., Holland, M., Borken-Kleefeld, J., Purohit, P., Fagerli, H., Vandyck, T., Warnecke, L., Nyiri, A., Simpson, D., Gomez 
Sanabria, A., Maas, R., Winiwarter, W., Ntziachristos, L., Georgakaki, M., Bleeker, A., Wind, P., Hoglund-Isaksson, 
L.,  Sander,  R.,  Nguyen,  B.,  Poupa,  S.,  Anderl,  M.,  2022b.  Support  to  the  development  of  the  third  Clean  Air 
Outlook; Annex to the Final Report. International Institute for Applied Systems Analysis, Laxenburg, Austria. 

Klimont, Z., Kupiainen, K., Heyes, C., Purohit, P., Cofala, J., Rafaj, P., ... & Schöpp, W. (2017). Global anthropogenic 
emissions of particulate matter including black carbon. Atmospheric Chemistry and Physics, 17(14), 8681-8723. 

Kortekand, M. et al., 2022, Health-related social costs of air pollution due to residential heating and cooking in 
the  EU27  and  UK.  CE  Delft,  https://cedelft.eu/publications/health-related-social-costs-of-air-pollution-due-to-
residential-heating-and-cooking/. 

Kukkonen  et  al.,  2020,  The  influence  of  residential  wood  combustion  on  the  concentrations  of  PM2.5  in  four 
Nordic cities, Atmos. Chem. Phys., 20, 4333–4365, https://doi.org/10.5194/acp-20-4333-2020, 2020.  

Liu  et  al.  2022:  An  online  technology  for  effectively  monitoring  inorganic  condensable  particulate  matter 
emitted from industrial plants, Journal of Hazardous Materials, https://doi.org/10.1016/j.jhazmat.2022.128221. 

MEMO/01/270,  2001,  Fact  Sheet  on  dioxin  in  feed  and  food,  European  Commission,  Brussels,  20  July  2001, 
https://ec.europa.eu/commission/presscorner/detail/en/MEMO_01_270. 

Mitchell, E. J. S., Gudka, B., Whittaker, C., Shield, I., Price-Allison, A., Maxwell, D., ... & Williams, A. (2020). The use 
of agricultural residues, wood briquettes and logs for small-scale domestic heating. Fuel Processing Technology, 
210, 106552. 

Musule, R., Bonales-Revuelta, J., Mwampamba, T. H., Gallardo-Alvarez, R. M., Masera, O., & García, C. A. (2021). 
Life cycle assessment of forest-derived solid biofuels: a systematic review of the literature. BioEnergy Research, 
1-22. 

Nussbaumer  T.,  2010,  Overview  on  Technologies  for  Biomass  Combustion  and  Emission  Levels  of  Particulate 
Matter prepared for Swiss Federal Office for the Environment (FOEN) as a contribution to the Expert Group on 
Techno-Economic  Issues  (EGTEI)  under  the  Convention  on  Long-Range  Transboundary  Air  Pollution  (CLRTAP) 
Zürich, June 2010, http://tftei.citepa.org/en/documents/small-and-medium-combustion-plants 

Ohlwein  S,  Kappeler  R,  Kutlar  Joss  M,  Künzli  N,  Hoffmann  B.  Health  effects  of  ultrafine  particles:  a  systematic 
literature  review  update  of  epidemiological  evidence.  Int  J  Public  Health.  2019  May;64(4):547-559.  doi: 
10.1007/s00038-019-01202-7. 

Patel et al., 2013, Indoor Air Pollution from Burning Biomass & Child Health, International Journal of Science and 
Research (IJSR), Volume 2 Issue 1, January 2013. 

11/13788A/11 

71 of 104 

28 March 2024 

Increasing policy coherence between bioenergy and clean air policies and measures Final Project Report 

Pope, C.A. & Dockery, D.W., 2006, Health Effects of Fine Particulate Air Pollution: Lines that Connect, Air & Waste 
Manage. Assoc.56:709–742. 

Sampaio et al., 2021, Polycyclic Aromatic Hydrocarbons in Foods: Biological  Effects, Legislation, Occurrence, 
Int.  J.  Mol.  Sci.  2021,  22,  6010. 
Analytical  Methods,  and  Strategies  to  Reduce  Their  Formation. 
https://doi.org/10.3390/ijms22116010. 

Salvi, S.S. & Barnes, P.J., 2009, Chronic obstructive pulmonary disease in non-smokers, Lancet 2009, 374: 733–743. 

Savolathi et al., Residential wood combustion in Finland: PM2.5 emissions and health impacts with and without 
abatement measures, Int J Environ Res Public Health. 2019 Aug 14;16(16):2920. doi: 10.3390/ijerph16162920. 

Schraufnagel,  D.E.  The  health  effects  of  ultrafine  particles.  Exp  Mol  Med  52,  311–317 
https://doi.org/10.1038/s12276-020-0403-3 

(2020). 

Seljeskog M, Sevault A, Østnor A, Skreiberg Ø. Variables Affecting Emission Measurements from Domestic Wood 
Combustion. Energy Procedia [Internet]. 2017;105(1876):596–603. http://dx.doi.org/10.1016/j.egypro.2017.03.361 

Sigsgaard,  T.  et.  al.,  Health  Impacts  of  Anthropogenic  Biomass  Burning  in  the  Developed  World,  European 
Respiratory Journal 46: 1577-1588, https://doi.org/10.1183/13993003.01865-2014, 2015. 

Simpson et al. (2020), https://emep.int/publ/reports/2020/emep_mscw_technical_report_4_2020.pdf 

Simpson, D., Kuenen, J., Fagerli, H., Heinesen, D., Benedictow, A., Van Der Gon, H.A.C.D., Visschedijk, A., Klimont, 
Z., Aas, W., Lin, Y., Yttri, K.E., Paunu, V.-V., 2022. Revising PM2.5 emissions from residential combustion, 2005–2019; 
Implications for air quality concentrations and trends. (No. TemaNord 2022:540). Nordic Council of Ministers. 

Tsiodra et al., Annual exposure to polycyclic aromatic hydrocarbons in urban environments linked to wintertime 
wood-burning episodes, Atmos. Chem. Phys., 21, 17865–17883, https://doi.org/10.5194/acp-21-17865-2021, 2021.  

UK Air Quality Expert Group for Defra, 2017, The Potential air quality impacts from biomass combustion, Report: 
The Potential Air Quality Impacts from Biomass Combustion - Defra, UK. 

WHO, 2015, Residential heating with wood and coal: health impacts and policy options in Europe and North 
America, 
https://apps.who.int/iris/bitstream/handle/10665/153671/9789289050760-
eng.pdf?sequence=3&isAllowed=y. 

Wyss A.B., et al. (2016), Particulate matter 2.5 exposure and self-reported use of wood stoves and other indoor 
combustion 
in  Norway.  PLoS  ONE  11(11):  e0166440, 
doi:10.1371/journal.pone.0166440. 

in  urban  nonsmoking  homes 

sources 

Wöhler,  Marius,  et  al.  "Investigation  of  real  life  operation  of  biomass  room  heating  appliances–Results  of  a 
European survey." Applied Energy 169 (2016): 240-249. 

11/13788A/11 

72 of 104 

28 March 2024 

 
 
Increasing policy coherence between bioenergy and clean air policies and measures Final Project Report 

10  Annexes 

A1: Measurement standards 

A2: Literature review 

A3: Stakeholder Interview Guides 

A4: Stakeholder survey 

A5: Summary of the EU policies, legislation and other regulatory instruments which currently impact on bioenergy 

A6:Policies and Measures at Member State, regional or local level 

A7: Proposed metric for operational PM2.5 emissions from buildings 

A8: Policy Evaluation 

11/13788A/11 

73 of 104 

28 March 2024 

 
Increasing policy coherence between bioenergy and clean air policies and measures Final Project Report 

A1  Measurement standards 

This section provides more technical background of the different measurement methods, and also describes 
how the appliance type test operating procedures fit in there. The section covers two areas: 

• 

• 

Procedures  for  appliance  tests  (i.e.  concerning  combustion  phases  tested,  types  of  nominal  or  reduced 
combustion speed, fuel quality) and how these relate to real-life emissions 

The pollutant sampling method (with or without condensables for particulate emissions) used to determine 
the emissions 

Appliance test operating procedures compared to real-life emissions 

For type testing of appliances, operating procedures have historically been set as optimal operating conditions 
(e.g. the procedures EN 13240, EN 13229 and the draft European standard prEN 16510-1). In addition to this, the 
latest version of the European standard proposes optional tests at nominal power and at partial load, the latter 
however  upon  the  discretion  of  the  manufacturers.  No  standardized  documentation  exists  which  describes 
combustion  conditions  with  limited  air  intake,  whereas  these  conditions  are  particularly  representative  for 
overloading or night use, hence useful to simulate. In real life conditions, combustion conditions described in 
standards are often relatively far from the real operating conditions where the user will often have to operate 
his appliance at low output (with a combustion air intake limited, with a variable wood load and quality, under 
natural draft which is generally different from the fixed 12Pa flue draft of the standards, etc.). 

Wohler et al. (2016) investigated real life operation of biomass room heating appliances in Europe, it was based 
on  a  survey  performed  in  16  European countries  amongst which the  most represented were  Italy,  Germany, 
Austria  and  Sweden.  The  results  of  this  paper  showed  important  differences  between  how  room  heating 
appliances are operated in the field and type testing protocols. The authors mentioned that these differences 
might be responsible for higher emissions in the field and that survey results may support further developments 
of type testing standards. 

Several alternative testing protocols describing real life use have been imagined in different countries, amongst 
which the BeReal protocol proposed by the European BeReal Project (BeReal: Advanced Testing Methods for 
Better Real-Life Performance of Biomass Room Heating Appliances)139. The protocols proposed for pellet and 
woodlog stoves are presented in Figure 10-1. 

139 BeReal final publishable report, available from https://cordis.europa.eu/docs/results/606/606605/final1-bereal-
final-publishable-report.pdf  

11/13788A/11 

74 of 104 

28 March 2024 

 
Increasing policy coherence between bioenergy and clean air policies and measures Final Project Report 

Figure 10-1: “BeReal –Firewood” – test procedure and measurements (from BEREAL final report) 

According to the BeReal140 study, performing tests according to the conditions described in standards could 
lead to strongly underestimating the real emissions of PM from woodlog stoves emitted essentially during the 
ignition and extinction phase and when low output combustion conditions are used and to overestimating the 
energy efficiency by 16%. A similar trend was observed within the Afac141 project with an overestimation of the 
energy efficiency by 5% when using combustion conditions described in standards compared to using “real-
life” combustion conditions.  

Another study performed in the UK142, gathered results of several studies that showed that real-world emissions 
can be higher than legislated limits due to a number of factors including fuel quality and operator behaviour. 
This  study  also  recommended  to  reduce  uncertainties  in  inventory  estimates  particularly  around  small-scale 
burning, by including the assessment of real-world emissions. 

The  Real-life  project143  aims  at  continuing  the  work  initiated  within  the  BeReal  project  by  determining  EFs  of 
several appliances in Europe using real-life protocols. 

Emissions from biomass combustion and how these are measured using different methodologies 

140 BeReal 2016, Deliverable D7.1, Documentation and evaluation of field data demonstration. 
141 AFAC, Détermination de facteurs d'émission de polluants des foyers domestiques alimentés au bois, Etude 
ADEME, rapport Ineris 2016 
142 Air Quality Expert Group, The Potential Air Quality Impacts from Biomass Combustion, Prepared for: 
Department for Environment, Food and Rural Affairs; Scottish Government; Welsh Government; and 
Department of the Environment in Northern Ireland 
143 Real-LIFE emissions project, Harmonizing reliable test procedures representing real-LIFE air pollution from 
solid fuel heating appliances, LIFE Preparatory Project 2020, 01/05/2021 – 30/04/2024 https://sites.uef.fi/real-life-
emissions/ 

11/13788A/11 

75 of 104 

28 March 2024 

 
 
Increasing policy coherence between bioenergy and clean air policies and measures Final Project Report 

This section discusses provides more a more in-depth description of the different types of particles and gases 
emitted  by  biomass  combustion  appliances  and  to  what  extent  these  are  measured  by  the  different 
measurement methods. 

The  particles  present  in  ambient  air,  resulting  directly  or  indirectly  from  wood  combustion  processes,  can  be 
divided into two categories144:  

• 

• 

Primary  particles  include  those  present  in  the  solid  state  in the  chimney  flue  and, by  convention,  the  so-
called condensable fraction. The solid particles emitted form mainly in the coldest areas of the combustion 
chamber.  The  condensable  fraction  is  made  up  of  semi-volatile  species  (SVOCs)  with  a  high  molecular 
weight which, when cooled outside the flue, form particles by condensation. The concentration of the solid 
fraction  can  be  quantified  by  simple  collection  on  a  heated  filter,  while  the  concentration  of  the 
condensable fraction can be quantified using a method involving trapping in an appropriate cooled liquid 
(impinger  or  washing  bottle  method)  or  on  a  filter  after  dilution  of  the  gases  (dilution  methods  including 
dilution tunnel method) 

Secondary  particles  (Secondary  Organic  Aerosols)  are  formed  in  the  atmosphere  after  emission  by 
photooxidation phenomena, mainly from the most reactive gaseous precursors (semi-volatile and volatile 
organic compounds). To date, there is no standardised method for characterising the potential of a source 
to form SOA 

During  combustion,  biomass  decomposes,  forming  a  wide  variety  of  organic  compounds  with  very  different 
characteristics in terms of chemical structure and vapour pressure. The more incomplete the combustion, the 
greater the quantity of volatile organic compounds formed. These compounds are present in large numbers 
and, after nucleation, coagulation and condensation, form aerosols. Depending on their boiling point, these 
compounds  can  be  divided  into  two  main  families:  Volatile  Organic  Compounds  (VOCs)  and  Semi-Volatile 
Organic Compounds (SVOCs).  

Depending on temperature and flue gas dilution, the latter compounds can change phase. Initially present in 
gaseous  form  in  the  flue,  they  can  be  transformed  into  liquid  aerosols  by  condensation,  or  solid  aerosols  by 
adsorption onto fine particles.  

These compounds form the condensable fraction and their inclusion in reported emissions is very much method 
dependent,  as  explained  earlier  in  this  report.  Existing  methods  for  the  determination  of  residential  wood 
combustion PM emissions are presented in a report published by RISE during the IMPRESS 2 project145.  

As already mentioned, sampling on a heated filter (HF) and sampling in a dilution tunnel (DT) are the two main 
methods that have historically been used in Europe to characterize emissions. Three other type of measurement 
methods, more marginally used, involve either sampling through an electrostatic precipitator, combining the 
heated filter (HF) to condensation of organic using a solvent (HF+impinger method, for example US EPA 5H) or 
diluting using higher dilution ratios. 

A study published in 2017 (Seljeskog et al. 2017) compared the two main measurement methods of PM (HF and 
DT). In average, the mass of particles collected at the outlet a the tested appliances with the full flow DT method 
was about 6.5 times the mass of particles collected using the Heated Filter method. 

This situation has an impact on both performance testing and the determination of emission factors, since the 
results presented in the inventories are necessarily linked to the measurement methods used and the associated 
measurands.  Indeed,  the  quantities  measured  by  these  methods  may  differ:  the  SP  method  specifically 

144 SYNTHESE DES ETUDES A L’EMISSION REALISEES PAR L’INERIS SUR LA COMBUSTION DU BOIS EN FOYERS 
DOMESTIQUES, Avril 2018, Synthèse des études à l'émission réalisées par l'Ineris sur la combustion du bois en foyers 
domestiques | Ineris 
145  Emissions of particles and organic compounds from small and medium scaled biomass combustion  
Sara Janhäll, Daniel Bäckström and Lennart Gustavsson, RISE Report : 2018:57, Impress 2 EMPIR Project 

11/13788A/11 

76 of 104 

28 March 2024 

 
Increasing policy coherence between bioenergy and clean air policies and measures Final Project Report 

determines the solid fraction of the aerosol, whereas the DT method also includes the condensable fraction. The 
following diagram (Figure 10-2) summarizes the parameters that can be measured at emission and contribute 
to particulate levels in ambient air. 

Figure 10-2: Comparability of results obtained by existing methods in relation to concentrations emitted 
and measured in ambient air (source: after Nussbaumer, 2010) 

Emissions from solid fuel space heaters, such as wood  stoves, are regulated in the Ecodesign Regulation (EU) 
2015/1185, and the Construction Product Regulation 305/2011 which regulates woods stoves as a construction 
product,  while  solid  fuel  boilers  are  regulated  according  to  Ecodesign  Regulation  (EU)  2015/1189  The  1185 
Ecodesign regulation, refers to three sampling methods (the HF method, the DT method, and a method based 
on  the  use  of  an  electrostatic  precipitator)  that  can  be  used  by  notified  laboratories  to  determine  the 
performance of equipment to be placed on the market from 2022 onwards; with distinct limit values depending 
on the methods used.  

11/13788A/11 

77 of 104 

28 March 2024 

 
Increasing policy coherence between bioenergy and clean air policies and measures Final Project Report 

In  a  study146  published  in  2016  The  Danish  Ecological  Council  recommends  harmonization  of  particle 
measurements from stoves and boilers by using methods that include condensates (smoke temperature 25-30 
°C) per energy unit (joule) or per standard fuel unit (kg dry wood). Furthermore, in 2020 an international expert 
group convened by the EMEP programme recommended the inclusion of condensables in emission inventories 
(Simpson et al., 2020). 

In 2021, the French Energy management and Environment Agency (Ademe) carried out a study of international 
benchmarks on heating appliances and air quality147. The aim of this study is to identify the policies put in place 
in various countries to limit the impact of domestic combustion heating on air quality, as well as their assessment 
methods,  and  to  gain  a  better  understanding  of  the  emission  factors  used  in  these  countries  for  this  activity 
sector. This study shows that it is essential to work towards harmonizing emission measurement methods on a 
European scale, in order to limit the methodological impact on the heterogeneities observed. This harmonization 
work is particularly important in the case of particulate matter, in order to decide how the condensable fraction 
should be taken into account, and how it should be measured. 

In 2022 CEN TC295 in charge of Residential solid fuel combustion appliances published an updated heated filter 
method for determination of dust emission (PM) as part of the non-harmonized part 1, EN16510 standard known 
as EN-PME method and based on the recommendation formulated following the EN_PME_TEST project. The idea 
of the EN-PME method is to make a clear distinction between solid particles and VOCs, with both components 
being measured separately. This method was intended to be used for the evaluation  of new stoves, but as a 
result emissions derived from this method do not include the condensables. 

There has been much scientific activity going on with regard to measuring condensables in Europe in recent 
years. A simplified version of the US EPA 5H method, combining a heated filter to washing bottles containing 
isopropanol as solvent has been developed by INERIS (e.g. HF-IPA impingers) and successfully compared with 
the  dilution tunnel  method by  Fraboulet  and  al  (2016).  More recently,  a  simple  method  of  dilution  aiming  at 
taking  into  account condensables  has  been  developed  by  ENEA4/ISSI5  and  evaluated  using  wood  log  and 
pellet stoves within the EMPIR Impress 2 project by five European partners (ENEA/ISSI,DTI, RISE and INERIS). Results 
are presented in a paper published by Cea et al. (2021). Finally, a method combining the EN_PME_TEST method 
to a dilution device positioned at the outlet of the EN-PME probe and heated filter is being developed within 
the Real-life on-going project. This method will be tested in comparison with the DT and HF-IPA impinger methods 
and its performance will be evaluated through an intercomparison, for which first results are expected at the 
end of 2024.  

146 Pollution from residential burning – Danish experience in an international perspective, Green Transition 
Denmark, 2016, https://www.ccacoalition.org/en/resources/pollution-residential-burning-danish-experience-
international-perspective 
147 Domestic heating and air quality, international benchmarks. French Ademe Report (2021), 
https://librairie.ademe.fr/air-et-bruit/4208-chauffage-domestique-et-qualite-de-l-air-benchmark-
international.html 

11/13788A/11 

78 of 104 

28 March 2024 

 
Increasing policy coherence between bioenergy and clean air policies and measures Final Project Report 

A2  Literature review 

Document Title 

Data Source  Author 

Access Location 

Year of 
Publicatio
n 

NEC Directive  

Legislation 

European Commission 

2016 

https://eur-lex.europa.eu/legal-
content/EN/TXT/PDF/?uri=CELEX:32016L
2284&from=EN  

Access 
Date 

05.01.2023 

Ambient Air Quality Directive(s)  

Legislation 

European Commission  

2008 

Renewable Energy Directive(s)  

Legislation 

European Commission  

2018 

Industrial Emissions Directive  

Legislation 

European Commission  

2010 

Medium Combustion Plant Directive  

Legislation 

European Commission  

2015 

Energy Performance of Buildings Directive  

Legislation 

European Commission  

2018 

Ecodesign Regulation  

Legislation 

European Commission  

2022 

Energy Labelling Regulation  

Legislation 

European Commission  

2017 

Monitoring Mechanism Regulation  

Legislation 

European Commission  

2013 

https://eur-lex.europa.eu/legal-
content/EN/TXT/PDF/?uri=CELEX:32008L
0050&from=EN  

04.01.2023 

https://eur-lex.europa.eu/legal-
content/EN/TXT/PDF/?uri=CELEX:32018L
2001&from=EN  

04.01.2023 

https://eur-lex.europa.eu/legal-
content/EN/TXT/PDF/?uri=CELEX:32010L
0075&from=EN  

04.01.2023 

https://eur-lex.europa.eu/legal-
content/EN/TXT/PDF/?uri=CELEX:32015L
2193&from=EN  

04.01.2023 

https://eur-lex.europa.eu/legal-
content/EN/TXT/PDF/?uri=CELEX:32018L
0844&from=EN  

04.01.2023 

https://environment.ec.europa.eu/syst
em/files/2022-
03/COM_2022_142_1_EN_ACT_part1_v6
.pdf  

04.01.2023 

https://eur-lex.europa.eu/legal-
content/EN/TXT/PDF/?uri=CELEX:32017R
1369&qid=1672841306552&from=en  

04.01.2023 

https://eur-lex.europa.eu/legal-
content/EN/TXT/PDF/?uri=CELEX:32013R
0525&from=EN  

04.01.2023 

11/13788A/11 

79 of 104 

28 March 2024 

Increasing policy coherence between bioenergy and clean air policies and measures Final Project Report 

Document Title 

Data Source  Author 

Access Location 

Year of 
Publicatio
n 

Regulation on Land Use, Land Use Change 
and Forestry  

Legislation 

European Commission 

2018 

https://eur-lex.europa.eu/legal-
content/EN/TXT/PDF/?uri=CELEX:32018R
0841&from=EN  

Access 
Date 

26.01.2023 

Zero Pollution Action Plan  

Legislation 

European Commission 

2021 

European Green Deal  

Legislation 

European Commission 

2019 

https://ec.europa.eu/environment/pdf
/zero-pollution-action-
plan/communication_en.pdf  

26.01.2023 

https://eur-
lex.europa.eu/resource.html?uri=cellar:
b828d165-1c22-11ea-8c1f-
01aa75ed71a1.0002.02/DOC_1&format
=PDF  

26.01.2023 

Investigation of real-life operation of 
biomass room heating appliances – Results 
of a European survey  

Impact of fuel moisture, charge size, feeding 
rate and air ventilation conditions on the 
emissions of PM, OC, EC, parent PAHs and 
their derivatives from residential wood 
combustion  

Scientific 
Literature 

Scientific 
Literature 

Bottom-up inventory of residential 
combustion emissions in Poland for national 
air quality modelling: current status and 
perspectives  

Scientific 
Literature 

Wohler et al.  

2016 

https://www.sciencedirect.com/scienc
e/article/pii/S0306261916301076  

04.01.2023 

Shen et al. 

2013 

https://www.sciencedirect.com/scienc
e/article/pii/S1001074212602587  

04.01.2023 

Gawuc et al.  

2021 

Annual exposure to polycyclic aromatic 
hydrocarbons in urban environments linked 
to wintertime wood-burning episodes  

Scientific 
Literature 

Tsiodra, et al. 

2021 

04.01.2023 

04.01.2023 

https://www.researchgate.net/publicat
ion/355938899_Bottom-
Up_Inventory_of_Residential_Combustio
n_Emissions_in_Poland_for_National_Air_
Quality_Modelling_Current_Status_and_
Perspectives 

https://www.researchgate.net/publicat
ion/356848263_Annual_exposure_to_po
lycyclic_aromatic_hydrocarbons_in_urb
an_environments_linked_to_wintertime_
wood-
burning_episodes#:~:text=Tsiodra%20et
%20al.%20%282021%29%20found%20tha
t%20local%20winter,contributor%20%28

11/13788A/11 

80 of 104 

28 March 2024 

Increasing policy coherence between bioenergy and clean air policies and measures Final Project Report 

Document Title 

Data Source  Author 

Access Location 

Year of 
Publicatio
n 

Access 
Date 

76%25%29%20to%20increased%20exces
s%20lifetime%20cancer%20risk.  

Sustainability constraints in determining 
European bioenergy potential A review of 
existing studies and steps forward 

Scientific 
Literature 

Indoor air pollution from residential stoves: 
examining the flooding of particulate matter 
into homes during real-world use 

Scientific 
Literature 

Chakraborty et al. 

2020 

Kluts et al. 

2017 

https://www.sciencedirect.com/scienc
e/article/pii/S1364032116307638  

04.01.2023 

Particle emissions from residential wood 
combustion in Europe – revised estimates 
and an evaluation 

Scientific 
Literature 

Denier van der Gon et 
al. 

2015 

The influence of residential wood 
combustion on concentrations of PM2.5 in 
four Nordic cities 

Scientific 
Literature 

Kukkonen et al.  

2020 

Residential wood combustion in Finland: 
PM2.5 emissions and health impacts with and 
without abatement measures 

Scientific 
Literature 

Savolahti et al. 

2019 

Cleaning the flue in wood-burning stoves is 
a key factor in reducing household air 
pollution 

Scientific 
Literature 

Rahman et al. 

2022 

https://www.researchgate.net/publicat
ion/346715580_Indoor_Air_Pollution_fro
m_Residential_Stoves_Examining_the_Fl
ooding_of_Particulate_Matter_into_Ho
mes_during_Real-World_Use 

https://www.researchgate.net/publicat
ion/307823348_Particulate_emissions_fr
om_residential_wood_combustion_in_E
urope_-
_revised_estimates_and_an_evaluation  

(PDF) The influence of residential wood 
combustion on the concentrations of 
PM 2.5 in four Nordic cities 
(researchgate.net) 

(PDF) Residential Wood Combustion in 
Finland: PM2.5 Emissions and Health 
Impacts with and without Abatement 
Measures (researchgate.net)  

https://www.researchgate.net/publicat
ion/364382745_Cleaning_the_Flue_in_W
ood-
Burning_Stoves_Is_a_Key_Factor_in_Red
ucing_Household_Air_Pollution  

04.01.2023 

04.01.2023 

04.01.2023 

04.01.2023 

04.01.2023 

Health-related social costs of air pollution 
due to residential heating and cooking in 
the EU27 and UK. CE Delft  

Scientific 
Literature 

Kortekand, M. et al. 

2022 

https://cedelft.eu/publications/health-
related-social-costs-of-air-pollution-due-
to-residential-heating-and-cooking/ 

04.01.2023 

11/13788A/11 

81 of 104 

28 March 2024 

Increasing policy coherence between bioenergy and clean air policies and measures Final Project Report 

Document Title 

Data Source  Author 

Access Location 

Year of 
Publicatio
n 

Health Impacts of Anthropogenic Biomass 
Burning in the Developed World. European 
Respiratory Journal 46: 1577-1588 

Scientific 
Literature 

Sigsgaard, Torben et. 
al.  

2015 

https://www.researchgate.net/publicat
ion/282278252_Health_impacts_of_anth
ropogenic_biomass_burning_in_the_de
veloped_world 

Access 
Date 

04.01.2023 

The Lancet Countdown on Health and 
Climate Change: Policy Brief for Europe.  

Scientific 
Literature 

Van Daalen, Kim.  

2021 

Commission Report COM/2021/3 final ‘The 
2nd Clean Air Outlook’ and forthcoming 3rd 
Clean Air Outlook 

Commission/
EEA reports 

European Commission 

2021 

Renewable energy in Europe 2019 - Recent 
growth and knock-on effects  

Commission/
EEA reports 

EEA  

2019 

ETC/ATNI Report 2020/6 on the 
Development of renewable energy and 
impact on air quality: co-benefits and trade-
offs  

Commission/
EEA reports 

Couvidat et aql. 

2021 

Managing Air Quality in Europe  

Commission/
EEA reports 

EEA  

2022 

https://www.thelancet.com/journals/la
ncet/article/PIIS0140-6736(21)01787-
6/fulltext 

04.01.2023 

(3rd outlook) https://eur-
lex.europa.eu/legal-
content/EN/TXT/?uri=comnat:COM_202
2_0673_FIN24 

26.01.2023 

https://www.eionet.europa.eu/etcs/et
c-cme/products/etc-cme-
reports/renewable-energy-in-europe-
2019-recent-growth-and-knock-on-
effects  

https://www.eionet.europa.eu/etcs/et
c-atni/products/etc-atni-reports/etc-
atni-report-6-2020-development-of-
renewable-energy-and-its-impact-on-
air-quality-co-benefits-and-trade-offs 

26.01.2023 

04.01.2023 

https://www.eea.europa.eu/download
s/801821f1df9d4591a149ae8f1c8845b2/
1656665799/managing-air-quality-in-
europe.pdf 

04.01.2023 

EU Clean Air Technology Hub - Final Report 
under request for services in the context of 
Framework Service Contract 
EEA/ACC/18/001/LOT2 

Commission/
EEA reports 

Ramboll  

2022 

EU clean air technology hub - 
Publications Office of the EU 
(europa.eu) 

Healthy environment, healthy lives: how the 
environment influences health and well-
being in Europe. European Environment 

Commission/
EEA reports 

EEA 

2020 

https://www.eea.europa.eu/publicatio
ns/healthy-environment-healthy-lives 

04.01.2023 

11/13788A/11 

82 of 104 

28 March 2024 

 
Increasing policy coherence between bioenergy and clean air policies and measures Final Project Report 

Document Title 

Data Source  Author 

Access Location 

Year of 
Publicatio
n 

Access 
Date 

Agency (EEA) Report No 21/2019, European 
Union, Luxembourg 

The impact of residential heating and 
cooking on air quality in Europe: The health 
argument for clean heating and cooking. 
European Public Health Alliance (EPHA) 
Position paper, Brussels 

Commission/
EEA reports 

EPHA  

2022 

https://epha.org/wp-
content/uploads/2022/03/epha-
position-paper-clean-heating.pdf 

04.01.2023 

The use of woody biomass for energy 
production in the EU  

Commission/
EEA reports 

European Commission, 
Joint Research Centre 

2021 

https://op.europa.eu/en/publication-
detail/-/publication/7120db75-6118-
11eb-8146-01aa75ed71a1/language-
en 

04.01.2023 

National Air Pollution Control Programmes 
(NAPCPs) for all Member States (as 
submitted to EEA’s Common Data 
Repository, CDR) (and their evaluation by 
the Commission)  

National 
Reports 

National Energy & Climate Change Plans for 
all Member States and their evaluation by 
the Commission   

National 
Reports 

Revising PM2.5 emissions from residential 
combustion 2005-2019, implications for air 
quality concentrations and trends. Report 
for Nordic Council of Ministers  

National 
Reports 

European Commission 

Located in NAPCP review tab 

European Commission 

Located in NECP review tab 

Simpson, Kuenen et al.  

2022 

temanord2022-540.pdf (norden.org) 

04.01.2023 

Pollution from residential burning – Danish 
experience in an international perspective  

National 
Reports 

Green Transition 
Denmark 

2016 

Report on ‘Potential air quality impacts from 
biomass combustion’ 

National 
Reports 

UK Air Quality Expert 
Group for Defra 

2017 

https://www.ccacoalition.org/en/resou
rces/pollution-residential-burning-
danish-experience-international-
perspective 

04.01.2023 

Report: The Potential Air Quality 
Impacts from Biomass Combustion - 
Defra, UK 

04.01.2023 

11/13788A/11 

83 of 104 

28 March 2024 

 
 
Increasing policy coherence between bioenergy and clean air policies and measures Final Project Report 

Document Title 

Data Source  Author 

Access Location 

Year of 
Publicatio
n 

Impact of fossil fuel usage reduction policy 
on PM2.5 level changes in a Lesser Poland 
Area 

National 
Reports 

Dąbrowski K.M. 

2022 

Impact of fossil fuel usage reduction 
policy on PM2.5 level changes in a 
Lesser Poland Area | Elsevier Enhanced 
Reader 

Access 
Date 

04.01.2023 

Ref2 alternative emission inventory: 
alternative PM estimates for small 
combustion (including biofuels) consistently 
including the condensable component of 
PM  

National emission inventories and 
accompanying Informative Inventory 
Reports (IIRs) which describe the 
methodologies used in each Member State 
to estimate emissions in their national 
inventories  

Relevant 
Datasets 

Relevant 
Datasets 

LIFE Clean Heat  

Real-LIFE emissions (uef.fi), especially the 
results of the first project workshop which 
took place 9 November 2022 

LIFE Projects 

LIFE Projects 

PrepAIR (biomass pillar in this project)  

LIFE Projects 

LIFE Green Stoves 

Economic cost of the health impact of air 
pollution in Europe: Clean air, health and 
wealth. WHO Regional Office for Europe, 
Copenhagen 

LIFE Projects 

Other 
Sources 

Factsheet: Slashing Emissions from 
Residential Wood Heating. Available at 
Switch4Air website of Bioenergy Europe 

Other 
Sources 

Residential heating with wood and coal: 
health impacts and policy options in Europe 
and North America 

Other 
Sources 

WHO  

2015 

https://www.who.int/europe/publicatio
ns/i/item/WHO-EURO-2015-4102-43861-
61759 

04.01.2023 

Bioenergy Europe 

2019 

WHO  

2015 

https://epc.bioenergyeurope.org/wp-
content/uploads/2021/01/Air-
Emissions.pdf  

04.01.2023 

https://apps.who.int/iris/bitstream/hand
le/10665/153671/9789289050760-
eng.pdf?sequence=3&isAllowed=y  

04.01.2023 

11/13788A/11 

84 of 104 

28 March 2024 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Increasing policy coherence between bioenergy and clean air policies and measures Final Project Report 

Document Title 

Data Source  Author 

Access Location 

Year of 
Publicatio
n 

Out of the woods: Using ecodesign to 
reduce the negative impacts of solid fuel 
heating  

Other 
Sources 

Coolproducts & ECOS 

2022 

Where there's fire, there's smoke. Emissions 
from domestic heating with wood 

Other 
Sources 

EEB and Green 
Transition Denmark   

2021 

https://www.coolproducts.eu/wp-
content/uploads/2022/03/ECOS_Out-
of-the-woods_final.pdf 

Where-theres-fire-theres-
smoke_domestic-heating-
study_2021.pdf (eeb.org) 

Access 
Date 

04.01.2023 

04.01.2023 

UNECE LRTAP Stage 3 Review Reports 2022  

Health-related social costs of air pollution 
due to residential heating and cooking in 
the EU27 and UK  

Other 
Sources 

Other 
Sources 

CE Delft  

2022 

Wood burners cause nearly half of urban air 
pollution cancer risk – study 

Other 
Sources 

The Guardian 

2021 

CE_Delft_210135_Health-
related_social_costs_of_residential_hea
ting_and_cooking_Def_V1.2.pdf 
(cedelft.eu) 

04.01.2023 

Wood burners cause nearly half of 
urban air pollution cancer risk – study | 
Air pollution | The Guardian 

04.01.2023 

Code of Good Practice for Solid Fuel 
Burning and Small-scale Combustion 
Installations;  TFTEI/LRTAP submission to WGSR 
2019. 

Other 
Sources 

Reduction of emissions of black carbon and 
PM2.5 from domestic heating and open 
agricultural burning 

Other 
Sources 

Climate Change Mitigation of Climate 
Change 

Annual Report 2021   

Inventory of national strategies for reducing 
the impact on air quality from residential 
wood combustion 

Other 
Sources 

Other 
Sources 

Other 
Sources 

TFTEI  

2019 

PowerPoint Presentation (unece.org)  

04.01.2023 

Bodin, S. 

2017 

EECCA_TFTEI Berling 20190514 
Reduction of BC and PM2.5 from OB 
and DH (unece.org) 

04.01.2023 

IPCC   

2022 

IPCC_AR6_WGIII_FullReport.pdf  

04.01.2023 

IEA Bioenergy  

2021 

IEA-Bioenergy-Annual-Report-2021.pdf 
(ieabioenergy.com) 

04.01.2023 

IEA Bioenergy  

2022 

11/13788A/11 

85 of 104 

28 March 2024 

 
 
 
 
 
 
Increasing policy coherence between bioenergy and clean air policies and measures Final Project Report 

A3  Stakeholder Interview Guides 

A3.1 

Introduction 

The  European  Commission  has  commissioned  a  consortium  led  by  Logika  Group  to  deliver  a  project  on 
Increasing  Policy  Coherence  between  Bioenergy  and Clean  Air  Policies  and  Measures,  in which  stakeholder 
interviews form an integral part of the study. You have been invited to participate in these interviews due to your 
experience and expertise in this area, but participation is completely voluntary. Further detail about the study 
and the interview, including interview questions, are provided below. 

A3.2  Project Context 

Bioenergy, in the form of woody biomass, constitutes a significant part of the energy mix for many EU Member 
States  and  the  use  of  wood  and  other  biomass  fuels  offer  a  renewable,  relatively  low-cost  combustion  fuel. 
However, it carries with it the risk of greatly increased air pollutant emissions. This problem is not a new one and 
not all forms of bioenergy have the same impacts. Potential solutions exist to help mitigate the negative effects 
of bioenergy on air quality, and to increase policy coherence between bioenergy and clean air policies in the 
EU. The aim of this project is to gather evidence to identify and reduce unintentional trade-offs between different 
objectives found in EU law (existing or forthcoming) and related policy documents.  

A3.3 

Interview Context 

Stakeholders  have  been  identified  to  provide  input  in  the  format  of  targeted  interviews,  to  discuss  the 
identification of relevant policies and measures in place in Member States to mitigate  the air quality impacts 
from bioenergy use. The key aim of these interviews is to supplement our literature review which aimed to identify 
relevant policies and measures at a national and sub-national level.  

The focus of the discussion will be on:   

• 

• 

Identification of relevant measures to mitigate trade-offs 

Their application and location 

•  Any information on effectiveness which may be available 

• 

Possible contacts for further research 

The target time for the interviews is around 45 minutes. Participation in this interview is voluntary and you may 
decline from answering any of the questions.  

A3.4  Confidential Information 

You will have been sent a participant information sheet and consent form. At the start of the interview, we will 
ensure that you are happy to proceed and full consent will be obtained.  However, if at any point after agreeing 
to  proceed  with  the  interview  you  would  prefer  to  not  answer  a  particular  question(s)  or  stop  the  interview, 
please let us know.  

The  information  that  we  collect  from  your  interview  will  be  combined  with  information  gathered  from  other 
interviews for the purpose of the study. Responses will not be attributable to individuals and no names will be 
referred to in any reports produced.  

All  information  that  you  provide  will  be  held  confidentially  by  the  study  team,  in  accordance  with  GDPR 
requirements and our contract with the European Commission. We will provide you with a copy of the written 
notes from the interview so that you can check these for both accuracy and sensitivity.  

11/13788A/11 

86 of 104 

28 March 2024 

Increasing policy coherence between bioenergy and clean air policies and measures Final Project Report 

In order to capture the full detail of the information you provide during the interview, it would be beneficial to 
record  the  discussion.  The  recording  will  be  used  to  enable  us  to  produce  accurate  summary  notes  of  the 
discussion and will be deleted once these notes have been agreed. We recognise that you may not wish the 
discussion to be recorded, so please let us know if you would prefer to proceed without recording. In that case, 
we  will  take  written  notes  during  the  interview  and  share  these  notes  with  you  after  the  interview  for 
confirmation. Interview Questions 

We have requested this interview because of your and your organisation’s expertise regarding  bioenergy use 
and  its  potential  impacts.  Note  that  the  main  aim  of  the  interview  is  not  to  establish  the  advantages  and 
disadvantages  of  bioenergy  in  general.  The  purpose  of  the  interview  is  to  identify  and  examine  measures 
implemented to address the impacts of bioenergy on air quality by Member States and/or their regions or cities, 
and what evidence there may be on the effectiveness of such policies or actions. 

A3.4.1  You and your organisation 

1)  What is the role/function of your organisation? 

2)  How does this relate to the use of bioenergy? 

3)  What is your role within the organisation? 

A3.4.2  Bioenergy and clean air 

4)  The  introductory  sections  above  gives  an  overview  of  the  scope  of  the  study  in  relation  to  the  use  of 
bioenergy  and  the  challenges  it  can  bring  for  clean  air  objectives.  Would  you  like  to  add  any  general 
observations on the link between bioenergy use and air quality? 

5)  Would you like to add any observations on the consistency between bioenergy and air quality in the EU 

policy framework? [if aware – perhaps not relevant for interviewees in Third countries] 

A3.4.3  National scale actions (in EU countries) 

We have provided a data collection proforma in Annex 1. Any/all of it can be pre-filled with existing knowledge 
you have on policies and measures in order to guide the conversation. Alternatively, we complete this during 
the interview if you prefer. 

6)  Are you aware of any EU Member States where the issues identified above [i.e. Q4] are either seen as more 

prevalent, or are a more pressing environmental concern? 

7)  What leads you to this view? 

8)  Are you aware of any particular actions being undertaken by Member States to address air pollution from 

bioenergy, or their regions or cities? 

9)  For each policy or measure targeting limiting air pollution from bioenergy that you are aware of: 

a)  Where and at what scale (e.g. local, national, regional?) is this measure/policy applied?  

b)  What is the primary aim of the measure/policy? 

c) 

Is this a legislative measure, or a ‘soft’ measure (for example, non-legislative awareness campaigns) 

d)  Are you aware of any evidence of its effectiveness, or impacts on bioenergy use/emissions?  

e)  Are you aware of any obstacles or barriers that may be preventing the effectiveness of these measures? 

11/13788A/11 

87 of 104 

28 March 2024 

Increasing policy coherence between bioenergy and clean air policies and measures Final Project Report 

f)  Do  you  know  who  is  responsible  for  the  implementation  of  the  policy/measure?  Do  you  have  any 

contact details for further discussion? 

10)  What brought these to your attention? 

A3.4.4  Actions outside the EU 

11)  Are you aware of any countries outside the EU where the issues identified above [i.e. Q4] are either seen as 

more prevalent, or are a more pressing environmental concern?  

12)  Are you aware of any particular actions being undertaken in these countries, which are designed to address 

such issues? 

13)  Do you have any information or evidence on how effective these measures have been? 

Contacts for follow-up 

14)  If we wanted to investigate any of the measures mentioned further, do you have any contacts we could 

utilise, which you would be willing to share? 

15)  Are there any other organisations which you would recommend we speak to? 

Thank you for your time today. We will be in touch to share the notes from the meeting for your comments and 
approval. Are there any further questions for us? 

11/13788A/11 

88 of 104 

28 March 2024 

 
 
Increasing policy coherence between bioenergy and clean air policies and measures Final Project Report 

A4  Stakeholder survey 

Bioenergy and Clean Air Polices and Measures 

* Required 

1)  Your name *  

2)  Name of organisation *  

3)  Email (this will not be shared with any other organisation) *  

4)  We are aiming to examine the overlaps between the use of bioenergy, specifically biomass heating, and 
clean air objectives. Would you like to add any general observations on the link between bioenergy use 
* 
and 

quality? 

air 

5)  Are you aware of any EU Member States where issues relating to the impact of biomass on air quality are 

either seen as more prevalent, or are a more pressing environmental concern? *  

6)  Are  you  aware  of  any  particular  actions  being  undertaken  by  Member  States,  their  regions  or  cities,    to 

address air pollution from biomass use? *  

7)  Are you aware of any studies into, or evidence of, the effectiveness of those actions? *  

11/13788A/11 

89 of 104 

28 March 2024 

 
 
 
 
 
 
 
Increasing policy coherence between bioenergy and clean air policies and measures Final Project Report 

8)  Are you aware of any countries outside the EU where the challenges related to biomass use and air quality 
are  either  seen  as  more  prevalent,  or  are  more  a  more  pressing  environmental  concern,  and  whether 
specific actions have been undertaken?  *  

9)  Are you happy for us to contact you with follow up questions?  *  

Yes 

No 

11/13788A/11 

90 of 104 

28 March 2024 

 
Increasing policy coherence between bioenergy and clean air policies and measures Final Project Report 

A5  Summary of the EU policies, legislation and other regulatory instruments 

which currently impact on bioenergy 

Legislation/Policy 

Summary 

Air Quality  

Ambient Air Quality Directives 
(AAQD) 
Directives 2008/50/EC and 
2004/107/EC 

Sets air quality limit and target values (i.e. concentration limits) to 
be achieved in Member States for a range of pollutants, of which 
PM10, PM2.5 and PAH are most relevant for bioenergy, alongside 
assessment, reporting and mitigation requirements. 

National Emissions reduction 
Commitments Directive (NECD)  
Directive 2016/2284/EC 

Industrial Emissions Directive 
Directive 2010/75/EU, and BAT 
conclusions 

European Pollutant Release 
and Transfer Register (E-PRTR) 
Regulation (EC) No 166/2006 

Sets emission reduction commitments at the Member State level 
of a range of pollutants, including PM2.5 and NMVOC, to 2020-29 
and 2030 onward. Among the obligations under the NECD is the 
requirement to prepare and report National Air Pollution Control 
Programmes (NAPCPs), which must include mitigation actions 
where the emission reduction commitments are projected not to 
be met. 

The main EU instrument regulating pollutant emissions from 
industrial installations. The Directive sets out the main principles for 
permitting and controlling large industrial and livestock (hereafter 
agro-industrial) installations based on an integrated approach 
and the detailed permit conditions are defined in the BAT 
conclusions, adopted by the Commission as implementing 
decisions. Best Available Techniques (BAT) as defined in BAT 
Reference documents (BREFs) should be applied to reach a high 
level of environmental protection. The IED covers around 50,000 
agro-industrial installations in the EU.  

Outlines the legal reporting requirements of the E-PRTR regulation, 
which provides easily accessible environmental data from 
industrial facilities across EU Member States, Iceland, 
Liechtenstein, Norway, Switzerland, Serbia and the UK. Annual 
data is reported by around 34,000 industrial facilities across 65 
economic activities. The data covers 91 key pollutants including 
heavy metals, pesticides, greenhouse gases and dioxins.  

Likely impact on 
bioenergy use 

Timelines  

Key driver for actions to 
reduce local/urban 
emissions from any source, 
including (biomass) 
combustion  

Key driver for actions to 
reduce national air 
pollutant emissions, 
including from (biomass) 
combustion 

Political agreement on 
revision reached in Feb 
2024 

entered into force on 31st 
December 2016 

Key driver to reduce air 
pollutant emissions from 
industrial sources 

Entered into force on 6th 
January 2011. Proposed 
revision adopted on 5th 
April 2022 

Key driver to reduce air 
pollutant emissions from 
industrial sources 

Entered into force on 24th 
February 2006. Proposed 
revision adopted on 5th 
April 2022. 

11/13788A/11 

91 of 104 

28 March 2024 

Increasing policy coherence between bioenergy and clean air policies and measures Final Project Report 

Legislation/Policy 

Summary 

Likely impact on 
bioenergy use 

Timelines  

Climate and Energy  

Renewable Energy Directive 
(RED) Directive 2018/2001/EU, 
amended by Directive (EU) 
2023/2413 

Regulation on the governance 
for the energy union and 
climate action  
Regulation (EU) 2018/1999 

Sets a common target for the proportion of renewable energy in 
EU total consumption (of at least 42.5% binding at EU level by 
2030 - but aiming for 45%, following the 2023 amendment). It also 
contains measures to support renewables uptake in transport, 
heating and cooling, to create an energy efficient and circular 
energy system that facilitates renewables-based electrification 
and promotes the use of renewable and low-carbon fuels, 
including hydrogen, in sectors where electrification is not yet 
feasible. Note that while the RED does not address air quality, the 
impact assessment for 2018/2001/EU notes that poor quality 
biomass combustion can have a negative impact on air 
quality.148 It further notes that there is EU legislation in place to 
address poor air quality (citing the AAQDs and NECD) and that 
the eco-design directive is best placed to address the poor 
performance of appliances.  

This regulation aims to ensure that the EU's energy union strategy 
is implemented effectively and to ensure that the EU achieves its 
objectives for climate including those under the 2030 policy 
framework for climate and energy and the Paris Agreement. It 
requires EU Member States to develop integrated national energy 
and climate plans based on a common template, covering 
decarbonisation, energy security, energy efficiency, internal 
energy market, and research, innovation and competitiveness.  

Driver for uptake of 
renewable heat, including 
bioenergy + electricity  

Revised Directive adopted 
in October 2023 and 
entered into force in all EU 
countries on 20 November 
2023, with a transposition 
deadline of 21 May 2025 
(1st of July 2024 for the 
permitting-related 
provisions). 

Governance framework to 
ensure delivery of energy 
and climate targets  

Entered into force on 24th 
December 2018 

Regulation on Land Use, Land 
Use Change and Forestry   
Regulation (EU) 2018/841 

Requires EU Member States to ensure that GHG emissions from 
land use, land use change or forestry are offset by at least an 
equivalent removal of CO2 from the atmosphere in the period 
2021 to 2030. Introduces a standardised system of accounting 
rules, as well as flexibility mechanisms for transferring accounted 
emissions and removals with the Effort Sharing Regulation. It is the 
third pillar of the EU's 2030 climate and energy framework.  

Mandates that GHG 
emissions from biomass 
are accounted for in MS 
climate commitments 
(and thus could impact 
bioenergy demand)  

Adopted on 30th May 
2018 

REPowerEU Plan  
COM/2022/230 

Plan to make Europe independent from Russian fossil fuels before 
2030, in light of Russia's invasion of Ukraine. It contains a series of 
measures to reduce dependence on Russian fossil fuels and 

Driver for a faster transition 
to renewable energy 
(including bioenergy) 

Presented on 18th May 
2022 

148 https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:52021SC0621&qid=1682590610107  

11/13788A/11 

92 of 104 

28 March 2024 

 
Increasing policy coherence between bioenergy and clean air policies and measures Final Project Report 

Legislation/Policy 

Summary 

Likely impact on 
bioenergy use 

Timelines  

accelerate the green energy transition. Some of the measures 
look to boost investment in renewable energy and the adoption 
of more ambitious renewable energy targets. 

Sets out binding measures to reach the EU's energy efficiency 
targets. The recast Directive, adopted in July and set to come 
into force in September or October 2023, mandates an additional 
11.7% reduction in final energy demand by 2030 (based on 2020 
projections). This is on top of the target in the 2018 amending 
Directive of a 32.5% reduction by 2030, over a 2007 baseline. The 
revisions aim to ensure that the 2030 target of GHG emission 
reduction by 55% (by 1990) is met by the EU. Additional specific 
measures are aimed at the public sector, industry and at 
alleviating fuel poverty. 

Driver to reduce overall 
energy use  

Recast Directive adopted 
July 2023. 

Sets environmental performance standards for consumer 
products, covering (currently) some 31 product groups, including 
domestic heating appliances. By introducing mandatory, 
minimum standards, the product Regulations aim to improve the 
environmental performance of products and to eliminate the 
least performing products from the market. 

Includes product level 
emission limits including on 
air pollutants  

Sets up a framework for energy labelling and repeals the previous 
Directive 2010/30/EU. It lays down a framework for the labelling of 
energy-related products placed on the market or put into 
service. It standardises the display of product information 
regarding energy efficiency, the consumption of energy and of 
other resources by products during use and supplementary 
information about the product. The aim is to allow customers to 
clearly understand the energy efficiency of their products and 
encourage them to purchase more efficient ones. Requirements 
for specific products are set out in product Regulations. 

Driver to increase energy 
efficiency, reducing 
overall energy use 

Amended on 25th 
October 2012. Currently 
under revision (proposal 
for a new Regulation on 
Ecodesign for sustainable 
products adopted on 30 
March 2022). 

Entered into force on 1st 
August 2017 

Energy Efficiency Directive  
Directive (EU) 2018/2002, 
Directive on energy efficiency 
and amending Regulation (EU) 
2023/955 (recast) 

Product specific emission control  

Ecodesign Directive 
(2009/125/EC and currently 
under revision) and associated 
Regulations 

Energy Labelling Regulation  
Directive 2017/1369 and 
associated Regulations 

Installations and buildings 

11/13788A/11 

93 of 104 

28 March 2024 

  
  
  
Increasing policy coherence between bioenergy and clean air policies and measures Final Project Report 

Legislation/Policy 

Summary 

Likely impact on 
bioenergy use 

Timelines  

Medium Combustion Plant 
(MCP) Directive  
Directive 2015/2193 

Limits the emissions of certain pollutants into the air from MCPs by 
regulating pollutant emissions from the combustion of fuels in 
plants with a rated thermal input equal to or greater than 1 
Megawatt thermal (MWth) and less than 50MWth.  

Energy Performance of 
Buildings Directive (EPBD) 
Directive 2010/31/EU 

Main legislative instrument aimed at improving the energy 
performance of buildings in the EU. This is key for achieving the 
EU's 2030 and 2050 decarbonisation objectives, as buildings 
account for 40% of energy consumed and 36% of energy-related 
direct and indirect greenhouse gas emissions. The EPBD takes into 
account outdoor climatic and local conditions, as well as indoor 
climate requirements and cost-effectiveness. 

Includes emission limits for 
the emission of SO2, NOX 
and ‘dust’ from MCPs but 
not relevant for small 
domestic units 

Driver to reduce overall 
energy use in buildings  

Construction Products 
Regulation 
Regulation (EU) 305/2011 

Initiates the development of harmonised European 
standards/technical specifications which provide a common 
language for assessing the performance of construction 
products, including space heaters. 

Driver to reduce air 
pollutant emissions from 
space heater appliances  

Approved on 25th 
November 2015 

Entered into force on 18th 
June 2010. Revised in 2018 
by the Directive 
amending the Energy 
Performance of Buildings 
Directive (2018/844/EU). In 
December 2021, the 
Commission proposed a 
revision of the directive 
(COM(2021) 802 final).149 
Agreement reached on 
revision, due for adoption 
in early 2024150. 

Approved on 9th March 
2011.  proposal for a 
revised Construction 
Products Regulation (CPR) 
was adopted on 30 March 
2022.151 

149 https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A52021PC0802&qid=1641802763889  
150 https://ec.europa.eu/commission/presscorner/detail/en/ip_23_6423  
151 https://ec.europa.eu/docsroom/documents/49315  

11/13788A/11 

94 of 104 

28 March 2024 

 
Increasing policy coherence between bioenergy and clean air policies and measures Final Project Report 

A6  Policies and Measures at Member State, regional or 

local level 

Annex 6 is published separately, here. 

11/13788A/11 

95 of 104 

28 March 2024 

Increasing policy coherence between bioenergy and clean air policies and measures Final Project Report 

A7  Proposed metric for operational PM2.5 emissions from 

buildings 

A7.1 

Energy Performance of Buildings Directive (EPBD): potential metrics for PM2.5 

A7.1.1 

Introduction 

The  Energy  Performance  of  Buildings  Directive  (EPBD,  2010/31/EU)  is  the  main  EU  instrument  targeted  at 
improving the overall energy performance of buildings in Europe. The Directive was amended in 2018 (along 
with the Energy Efficiency Directive in 2019) as part of the ‘Clean energy for all Europeans’ package. In October 
2020, the Renovation wave strategy was published by the Commission, as part of the European Green Deal. This 
includes  an  action  plan  with  a  series  of  regulatory,  financing  and  enabling  measures  to  enhance  building 
renovation with one of its key initiatives being a revision of the EPBD. 

In December 2021, the Commission proposed a review of the Directive (COM(2021) 802 final) to update the 
existing regulatory framework to reflect higher ambitions and more pressing needs in climate and social action, 
with flexibility to account for the differences in the building stock across Europe. This revision is part of the ‘Fit for 
55’  package  and  looks  to  help  the  EU  meet  its  objective  of  a  minimum  55%  reduction  in  greenhouse  gas 
emissions by 2030 compared to 1990. The proposed updates include152:  

•  A new EU definition of a ‘zero emissions building’ which applies to all new buildings from 2027 and to all 

renovated buildings from 2030 

• 

• 

The acceleration of energy-efficient renovations through Minimum energy performance standards 

Improvements in the reliability, quality and digitalisation of Energy Performance Certificates (EPCs)  

•  A revised A-G scale of EPCs (based on common criteria)  

• 

EPCs to include calculated figures for, inter alia: 

• 

Energy performance (in kWh(m2.year)) 

•  Operational greenhouse gas emissions (in kg CO2/(m2.year)) 

• 

Renewable energy production 

• 

The end to subsidies for fossil fuel boilers  

Of particular relevance to this project, Annex V of the proposed revised EPBD includes an optional indicator on 
operational  emissions  of  fine  particulate  matter  (PM2.5)  for  inclusion  in  an  EPC  (Annex  V,  2(q)).  Buildings 
contribute around half of primary PM2.5 emissions in the EU and are a significant cause of premature death and 
illness153. The application of such an indicator in the Member States’ implementation of the Directive could be 
important for driving building owners and developers towards measures that reduce PM2.5 emissions.  

A7.1.2  Challenges 

For such an indicator to be useful (assuming it is applied by the Member States), there would need to be some 
consistency in how emissions are calculated and reported. This needs to start with a clear definition of what 
should be considered within scope of “operational emissions”. For greenhouse gas emissions, this is defined as 

152 https://www.europarl.europa.eu/thinktank/en/document/EPRS_BRI(2022)698901 Note that agreement has 
been reached on the proposal: https://www.consilium.europa.eu/en/press/press-releases/2023/12/07/fit-for-
55-council-and-parliament-reach-deal-on-proposal-to-revise-energy-performance-of-buildings-directive/ 
153 cf Recital 10 of the recast EPBD proposal 

11/13788A/11 

96 of 104 

28 March 2024 

 
Increasing policy coherence between bioenergy and clean air policies and measures Final Project Report 

“…emissions associated with energy consumption of the technical building systems during use and operation of 
the  building”  in  the  proposed  recast  of  the  Directive.  It  is  assumed  that  for  PM2.5  emissions  this  should  be 
consistent, i.e. that the emissions estimate should only include combustion systems associated with heat and 
power  generation  and  not,  for  example,  cooking  operations  or  transport  (which  could  both  be  significant 
emission sources for PM2.5). 

EPCs also include a requirement for reporting annual operational CO2 emissions (as mass per unit area per year). 
However, calculating such a figure for PM2.5, for reasons summarised below, is likely to require more information 
than  is  routinely  available  for  the  compilation  of  EPCs.  In  addition,  a  mass  emission  figure  is  unlikely  to  be 
meaningful for prospective building users and would thus fail to act as a driver for improvement. Therefore, a 
greatly  simplified  metric  is  proposed,  based  on  an  A-G  scale  which  consumers  will  be  familiar  with  due  to  is 
existing use for energy performance, both in EPCs and for consumer products. 

The primary challenge relates to how operational PM2.5 emissions can be estimated for a particular building in a 
consistent  and  robust  manner.  For  CO2,  the  calculations  are  much  simpler,  based  directly  on  energy  usage 
(which has to be captured already) and using standardised emission factors. Whilst a similar framework can be 
applied for PM2.5 emissions, there are a number of variables that need to be considered which influence emission 
factors and overall emissions. These include: 

• 

• 

Type of appliance, including its age and mode of operation 

Fuel type(s) and quality – for biomass the fuel type is important for emissions including e.g. logwood vs pellets, 
moisture content of wood  

•  Activity levels i.e. fuel consumption (this may be estimated if forward looking and/or based on actual usage 

when retrospectively estimating emissions)  

To an extent, all of these factors will also impact on the CO2 emission calculation. However, CO2 emissions are 
likely  to  be  determined  by  the  main  source  of  heat  (space  and  water)  for  the  building  and  for  which  the 
necessary data (or standard emission checklists) will generally be available. However, emissions of PM2.5 can 
often be dominated by secondary heating appliances, such as fireplaces or stoves, for which data, especially 
on use, will be much less accessible. 

It should also be noted that all solid combustion fuels, including coal, lignite, manufactured solid fuels (MSF), 
peat, etc. will give higher PM2.5 emissions than natural gas, often by several orders of magnitude. Thus, any PM2.5 
metric needs to consider all combustion fuels and not just wood or woody biomass. 

Each of these factors will need to be considered in turn to understand how information on operational PM 2.5 
emissions  could  be  incorporated  into  the  EPC.  Furthermore,  it  is  assumed  that  the  metric  will  need  to  be 
formulated on the basis of the information currently required by the EPC compilation process (Annex I): 

•  Annex I, paragraph 1, states that “energy performance of a building shall be determined on the basis of 
calculated  or  actual  metered  energy”.  Metered  energy  generally  refers  to  grid  electricity  or  mains  gas, 
although  deliveries  of  other  fuels,  such  as  bottled  gas,  wood  pellets  or  coal,  could  also  be  taken  into 
account.  However,  in  practice,  delivered  fuel  use  is  usually  accounted  for  by  using  standard  usage 
checklists, based on the average use for that type of heating source, in that type and size of building, in a 
given  Member  State.  Wood  fuels  obtained  through  informal  routes  (e.g.  self  gathered  or  small  suppliers) 
make up a significant proportion of wood fuel used in many, potentially all, Member States. It is thus unlikely 
to be included as a delivered fuel even where this is taken into account. Moreover, as noted above, PM 
emissions are often dominated by secondary heating sources, and for which there are multiple variables 
which greatly effect such emissions, i.e. fuel type and quality, frequency of use and operator practice. This 
would render any “average use” statistics highly uncertain, to the extent that they are likely to be misleading 

•  Annex I, paragraph 4, sets out the aspects to take into consideration in determining energy use. This includes 
inter alia the heating installation and hot water supply. Thus, bioenergy installations used as the primary heat 

11/13788A/11 

97 of 104 

28 March 2024 

Increasing policy coherence between bioenergy and clean air policies and measures Final Project Report 

or hot water supply will be listed, including bioenergy boilers. However, it is not certain that supplementary 
heating installations, such as stoves or fireplaces, are also included. As one of the key drivers of bioenergy 
air  quality  emissions  in  many  Member  States,  i.e.  the  use  of  log  burning  stoves  as  a  supplementary  heat 
source, guidance should be strengthened to ensure supplementary heating sources are accounted for in 
EPCs 

• 

The Annex I calculation does not take account of issues which have a significant impact on bioenergy PM2.5 
emissions but which are far less relevant for, say, gas or electrically powered heating, such as fuel quality 
(e.g. moisture content of wood), fuel type (e.g. logs or pellets), or operator actions (including maintenance 
regimes). Thus, any proposed indicator can only be a rough estimate of probable emissions, within a wide 
band of potential emissions 

Therefore, any indicator proposed will necessarily be fairly broad and not fully reflective of actual PM2.5 emissions. 
Given the difficulties in estimating actual emissions, as noted in the third point above, the metric can only reflect 
potential PM2.5 emissions rather than actual. The PM2.5 emission factors for stoves, fireplaces and boilers, taken 
from the 2023 EMEP Guidebook154, are shown in Appendix 1. These reflect one half of the standard emissions 
calculation of activity x emission factor = emission. It should be noted that the values shown are a midpoint, and 
the guidebook provides upper and lower confidence levels. For example, the Tier 2 emission factor for residential 
gas boilers – 0.2 g/GJ PM2.5 – has a confidence range of 0.12-0.28, which is fairly narrow. By contrast, the emission 
factor for a simple wood stove – 740 g/GJ – has a range of 370-1480, i.e. the actual emissions could differ by 
100%, based on tests using the correct fuels. Using unseasoned wood, for example, will increase this range even 
further. 

A7.2  Options for an EPC metric on PM2.5 emissions 

The following option is presented as the preferred option for Member States to consider when opting to add a 
metric  of  operational  PM2.5  emissions  to their  EPC.  It  strikes  a  balance  between  being  overly  simplistic, risking 
presenting  misleading  messages,  and  overtly  complex,  which  would  reduce  the  likelihood  for  adoption. 
Crucially, it provides an indicator which does not require activity  data, such as frequency of use, which is not 
normally gathered through the EPC process. The other two options considered, and rejected, are presented in 
Appendix 2. 

A7.2.1  Option 1: A-G rating based on emissions factors 

The use of an A-G rating, rather than an emission figure, has two main attractions: 

1) 

It avoids the need to gather usage data or to calculate an average use default value for the Member State. 
Emission estimates for small combustion are notoriously uncertain, with most Member States lacking reliable 
data on either the extent of appliance use or the amount of fuel used. While this can be worked around at 
a national level, reducing the national statistics to individual households is likely to be so uncertain as to be 
effectively meaningless 

2)  Even if total emissions on PM2.5 were calculated for each building, they are not likely to carry any context or 
significance  for  householders  and  other  users.  However,  the  A-G  rating  is  familiar  from  other  consumer 
product labelling and provides an easy relative comparison between different buildings 

Splitting out the installations into an A-G rating, based on their class emission factors, would be consistent with 
the  overall  approach  to  energy  performance  ratings  for  EPCs.  This  would  allow  differentiation  between 
appliance and fuel types, and also allow more efficient appliances of different sizes to be combined. Crucially, 
it avoids the need to gather usage data: 

154 https://www.eea.europa.eu//publications/emep-eea-guidebook-2023 

11/13788A/11 

98 of 104 

28 March 2024 

 
Increasing policy coherence between bioenergy and clean air policies and measures Final Project Report 

Rating 

EF range 
(g/GJ) 

Appliance type 

Residential buildings 

Commercial buildings 

A 

B 

C 

D 

E 

F 

0 

Non-combustion heat 

0.1-1.0 

Boiler, gas 

1.1-10.0 

10.1-100 

Boiler, liquid 
Stove, liquid 
Fireplace, gas 

Stove and boilers, wood 
pellet 
Eco-stoves and boilers, wood 

101-200 

- 

201-500 

Boilers and stoves, coal 
Advanced stove, coal 
Open fireplace, coal 
High efficiency stove, wood 
Boiler, wood 

G 

500-1000 

Stove, wood 
Open fireplace, wood 

Boiler, gas 
Gas turbine, gas 

Boiler, > 50 kWth to ≤ 1 MWth, liquid 
Reciprocating engine, gas 
Gas turbine, gas oil 

Boiler, > 1 MWth to ≤ 50 MWth, liquid 
Boiler, > 50 kWth to ≤ 1 MWth, wood 
Boiler, > 1 MWth to ≤ 50 MWth, coal 
Boiler, automatic, wood 
Advanced boiler, auto, coal 
Reciprocating engine, gas oil 
Boiler, > 1 MWth to ≤ 50 MWth, wood 

Boiler, manual, wood 
Boiler, > 50 kWth to ≤ 1 MWth, coal 
Advanced boiler, manual, coal 

- 

- 

This system is relatively complex but still simple enough to be used with the information available through the 
EPC process155, e.g. through the provision of checklists for assessors. The emission factors used have been drawn 
from the 2023 EMEP guidebook, shown in Appendix 1, although other emission factors could be substituted. For 
example, if the pellet fed boilers generally in use in a Member State are of higher (or lower) quality than the EU 
average, a Member State specific emission factor could be used for these156. The scales could also be drawn 
differently for commercial/institutional and residential, so that each rating category is covered. 

Note that this scale only considers the potential emission level from the building, and also that it is independent 
of the energy performance of the building. Thus, a highly insulated house, fitted with solar panels and air source 
heating could still be rated G for PM2.5 emissions if it had an operational wood burning stove157, regardless of 
how often that stove is actually used. 

A7.3  Appendix 1: PM2.5 emission factors, 2023 EMEP guidebook 

155 The definitions for the different appliance types could also be taken from the EMEP guidebook 
156 This is already standard practice in the calculation of national emissions inventories, where national level 
data can be substituted for standard emission factors, supported by relevant evidence. 
157 Allowance would need to be made for appliances, such as fireplaces, which have been rendered 
inoperable and are retained for decorative purposes only. 

11/13788A/11 

99 of 104 

28 March 2024 

 
 
 
Increasing policy coherence between bioenergy and clean air policies and measures Final Project Report 

Tier 1 Emission factors 

Category 

Type 

Residential combustion 

Hard coal and brown coal 

Gaseous 

Liquid 

Solid biomass 

Commercial/institutional 

Hard coal and brown coal 

Gaseous 

Liquid 

Solid biomass 

Unit 

g/GJ 

g/GJ 

g/GJ 

g/GJ 

g/GJ 

g/GJ 

g/GJ 

g/GJ 

Value 

398 

1.2 

1.9 

740 

108 

0.78 

18 

160 

Tier 2 emission factors, arranged by ascending emissions 

Category 

Range 

Type 

Value (g/GJ) 

Res 

Com 

Com 

Com 

Res 

Com 

Res 

Res 

Com 

Com 

Com 

Com 

Com 

Com 

Res 

Com 

Com 

Res 

Com 

Com 

0.1-1.0 

Boiler, gas 

Gas turbine, natural gas 

Boiler, > 50 kWth to ≤ 1 MWth, gas 

Boiler, > 1 MWth to ≤ 50 MWth, gas 

1.1-10 

Boiler, liquid 

Reciprocating engine, natural gas 

Open fireplace, gas 

Stove, liquid 

Boiler, > 50 kWth to ≤ 1 MWth, liquid 

Gas turbine, gas oil 

10.1-100 

Boiler, > 1 MWth to ≤ 50 MWth, liquid 

Reciprocating engine, gas oil 

Boiler, > 50 kWth to ≤ 1 MWth, wood 

Boiler, automatic, wood 

Stoves and boilers, wood pellet 

Advanced boiler, auto, coal 

Boiler, > 1 MWth to ≤ 50 MWth, coal 

Eco-stoves and boilers, wood 

Boiler, > 1 MWth to ≤ 50 MWth, wood 

101-200 

Advanced boiler, manual, coal 

0.2 

0.2 

0.45 

0.45 

1.5 

2 

2.2 

2.2 

3 

9.5 

30 

30 

37 

37 

60 

70 

72 

93 

98.5 

130 

11/13788A/11 

100 of 104 

28 March 2024 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Increasing policy coherence between bioenergy and clean air policies and measures Final Project Report 

Category 

Range 

Type 

Value (g/GJ) 

Com 

Com 

Res 

Res 

Res 

Res 

Res 

Res 

Res 

Res 

Boiler, manual, wood 

Boiler, > 50 kWth to ≤ 1 MWth, coal 

201-500 

Boiler, solid (not biomass) 

Advanced stove, coal 

Open fireplace, solid (not biomass) 

High efficiency stove, wood 

Stove, solid (not biomass) 

Boiler, wood 

501-1000 

Stove, wood 

Open fireplace, wood 

160 

170 

201 

220 

300 

370 

450 

470 

740 

820 

11/13788A/11 

101 of 104 

28 March 2024 

 
 
 
 
 
 
 
 
Increasing policy coherence between bioenergy and clean air policies and measures Final Project Report 

A8  Policy Evaluation 

Policy evaluation provides an analysis of how existing measures and spending programs have been performing, 
to check that they are efficient, effective, relevant and coherent, and that the intervention is actually adding 
value. By establishing the extent to which the aims of the intervention are being delivered, and specifically which 
aspects are working and which are not, and why, it is possible to adjust measures to be more cost effective (or 
just  more  effective)  over  time.  Different  Member  States  may  have  different  approaches  to  evaluation,  in 
addition to the European Commission’s Better Regulation Guidance158, although all will have common elements 
as  described  below.  The  Better  Regulation  Guidance  is  aimed  mainly  at  evaluation  of  policies  at  an  EU  or 
national  level.  Nevertheless,  the  principles  are  universal  and  references  to  specific  parts  of  the  toolbox  are 
referred to below. 

Theory of change: Key to any policy evaluation is understanding the expected causal effects and intervention 
logic  of  a  policy.  A  first  step  to  an  evaluation  will  be  reviewing  the  intervention  logic  that  was  previously 
developed,  or  developing  a  new  one  in  the  absence  of  one.  The  intervention  logic  frames  the  evaluation 
questions  the  study  seeks  to  answer,  and  it  will  be  used  to  define  the  scope  and  depth  of  the  analysis.  The 
intervention logic starts with the rationale and objectives of the policy (“objectives”) and the problems (“needs”) 
it was designed to address. It then describes the activities required under the policy (“actions”), the expected 
effects (including “outputs”, “results” and “impacts”), and “external factors”, including related policies, that may 
impact  on  the  overall  performance  of  the  intervention,  both  positive  and  negative.  An  evaluation  aims  to 
explore  each  of  the  steps  in  the  intervention  logic  and  the  movement  from  one  step  to  the  next  e.g.  how 
effectively and efficiently actions have been translated into results. 

Baseline  and/  or  points  of  comparison:  An  ex-post  evaluation  seeks  to  look  back  on  what  has  occurred  in 
practice and ideally makes a comparison against a hypothetical scenario of a counterfactual baseline. Where 
possible, the baseline provides a quantitative counterfactual for the main points of change identified by the 
intervention logic. Where prior impact assessment exists, the evaluation baseline will simply refer to the impact 
assessment  baseline.  In  cases  where  there  is  no  prior  impact  assessment,  it  will  be  necessary  to  develop  a 
baseline.  Where it is not possible to establish a  quantitative counterfactual, in line with Tool #46 of the Better 
Regulation Guidelines, a “point of comparison” approach can be used, through identifying key variables for the 
intended effects of the legislation which have been influenced by the actions of the legislation. 

Evaluation questions and matrix: All evaluations and fitness checks base their analysis on the evaluation criteria 
of  effectiveness,  efficiency,  coherence,  relevance,  and  added  value  of  the  intervention,  or  provide  due 
justification why this is not the case. Thus, it is necessary to develop an evaluation question matrix that can frame 
the analysis. The purpose of this analysis will be: 

• 

• 

• 

Effectiveness: assess the extent to which the measure is achieving its intended effects  

Efficiency: review the main costs of implementing the actions of the measure and review whether it is being 
implemented efficiently and fairly across all stakeholder groups  

Relevance:  review  whether  the  objectives  of  the  measure  are  consistent  with  the  current,  new  and 
emerging needs, and other related issues 

•  Coherence: assess the consistency and risks of conflict in the way the measure is implemented, within the 

measure itself and with other related policy areas 

•  Added value: review the extent to which the measure would be effective and efficient in the absence of 

related actions or measures, including national and EU level measures 

158 https://commission.europa.eu/law/law-making-process/planning-and-proposing-law/better-
regulation/better-regulation-guidelines-and-toolbox_en  

11/13788A/11 

102 of 104 

28 March 2024 

 
Increasing policy coherence between bioenergy and clean air policies and measures Final Project Report 

The evaluation question matrix then establishes the specific questions and sub-questions that will be answered 
by the analysis. For each sub-question, operational criteria are needed for how an assessment will be made, 
indicators for how to measure the impacts that will be used as evidence to underpin the analysis, the approach 
to analysis and the identification of key data sources and collection methods that will underpin the evidence 
collection. Guidance on the approach that could be used is set out in  Tool #46 “Design the evaluation” and 
Tool #47 “Evaluation criteria and questions” of the Better Regulation Guidelines. 

Research tools: A number of research tools and methods could be used to support the analysis, including: 

• 

Policy, literature and data review, drawing on available data sources and existing analysis (qualitative and 
quantitative) to establish a robust evidence base 

•  Case studies and/or focused analytical assessments of specific themes to describe, explore and categorise 

in detail key outcomes 

• 

Stakeholder consultation will be performed in accordance with the Better Regulation Guidelines (Tools #51 
to #55) 

Developing conclusions: The final part of the evaluation needs to show a clear and transparent approach  to 
the analysis and development of conclusions. The evaluation matrix should be updated based on all the findings 
and evidence gathered throughout the  process. The analysis should highlight where the evidence has been 
sourced and, as far as possible, aim to triangulate the conclusions from multiple sources. Any discrepancies or 
biases should be clearly identified and discussed. 

11/13788A/11 

103 of 104 

28 March 2024 

 
 
GETTING IN TOUCH WITH THE EU 

In person 

All over the European Union there are hundreds of Europe Direct centres. You can find the address 
of the centre nearest you online (european-union.europa.eu/contact-eu/meet-us_en). 

On the phone or in writing 

Europe  Direct  is  a  service  that  answers  your  questions  about  the  European  Union.  You  can  contact 
this service:  

—  by freephone: 00 800 6 7 8 9 10 11 (certain operators may charge for these calls),  
—  at the following standard number: +32 22999696,  
—  via the following form: european-union.europa.eu/contact-eu/write-us_en. 

FINDING INFORMATION ABOUT THE EU 

Online 

Information about the European Union in all the official languages of the EU is available on the Europa 
website (european-union.europa.eu). 

EU publications 

You  can  view  or  order  EU  publications  at  op.europa.eu/en/publications.  Multiple  copies  of  free 
publications  can  be  obtained  by  contacting  Europe  Direct  or  your  local  documentation  centre 
(european-union.europa.eu/contact-eu/meet-us_en). 

EU law and related documents 

For access to legal information from the EU, including all EU law since 1951 in all the official language 
versions, go to EUR-Lex (eur-lex.europa.eu). 

EU open data 

The  portal  data.europa.eu  provides  access  to  open  datasets  from  the  EU  institutions,  bodies  and 
agencies.  These  can  be  downloaded  and  reused  for  free,  for  both  commercial  and  non-commercial 
purposes. The portal also provides access to a wealth of datasets from European countries.