COMMISSION STAFF WORKING DOCUMENT STAKEHOLDER CONSULTATION - SYNOPSIS REPORT Accompanying the document Communication from the Commission to the European Parliament, the Council, the European Economic and Social Committee and the Committee of the Regions A Strategic Framework for a Competitive and Sustainable EU Bioeconomy
Date: 2025-11-27
Institutions: Directorate-General for Environment, European Commission
Subjects: bio-industry, biomass, biomaterials, circular economy, competitiveness, innovation, investment, management of resources, natural resources, sustainable development

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 27.11.2025  SWD(2025) 895 final  COMMISSION STAFF WORKING DOCUMENT  STAKEHOLDER CONSULTATION - SYNOPSIS REPORT  Accompanying the document Communication from the Commission to the European Parliament, the Council, the European Economic and Social Committee and the Committee of the Regions A Strategic Framework for a Competitive and Sustainable EU Bioeconomy {COM(2025) 960 final}  
 
 
1. 

INTRODUCTION 

This  staff  working  document  presents  the  key  findings  from  the  public  consultation 
activities  conducted  for  the  new  EU  bioeconomy  strategy.  Its  goal  is  to  synthesise  and 
summarise  the  insights  gained  through  those  activities.  It  highlights  the  main  issues, 
drivers and recommendations that emerged, offering an evidence base for the strategy. 

The public consultation employed a threefold approach combining a call for evidence, a 
public consultation survey and targeted stakeholder workshops (‘workshops’). The call for 
evidence  and  the  public  consultation  survey  were  supported  by  the  European 
Commission’s  ‘Have  your  say’  portal.  The  two  tools  invited  stakeholders  to  provide 
feedback through structured questionnaires, open-ended responses and position papers. In 
addition, four workshops were organised to gain more in-depth insight into specific topics. 

The information summarised in this annex reflects the views expressed by stakeholders. 
The  contributions  received  via  the  European  Commission’s  ‘Have  your  say’  portal  and 
through workshops do not represent the official position of the Commission, nor do they 
reflect a representative sample of the EU population. Accordingly, they are not binding on 
the Commission when formulating future policy initiatives. 

2.  CONSULTATION STRATEGY, ACTIVITIES AND PROFILE OF RESPONDENTS 

2.1.  Consultation strategy 

The consultation sought to explore stakeholder views on the existing policy framework, 
assess the bioeconomy’s potential for growth and competitiveness and identify areas for 
policy  improvement.  The  process  focused  on  integrating  insights  into  barriers  to 
bioeconomy innovation, sustainability and resource efficiency, while ensuring that broader 
societal and environmental benefits of the bioeconomy are achieved. 

Consultation activities 

The  call  for  evidence  was  open  between  31 March  and  23 June  2025.  A  total  of  444 
responses were received, with 300 respondents submitting position papers in addition to 
their direct written responses to the call for evidence. The call for evidence aimed to gather 
stakeholder  input  on  the  Commission’s  understanding  of  bioeconomy  challenges  and 
solutions.  Stakeholders,  in  particular  businesses,  SMEs,  primary  producers  and  NGOs, 
were invited to provide feedback on several issues such as resource efficiency, regulatory 
barriers and the need for improved financing. Several Member States, regional authorities 
and non-EU countries responded. 

The public consultation survey was open during the same period as the call for evidence, 
from  31 March  to  23 June  2025.  It  received  362  responses,  with  149  respondents 
submitting additional files, such as documents supporting their survey answers or position 
papers. The survey aimed to gather the views of a wide range of stakeholders on the new 
EU bioeconomy strategy, focusing on its main objectives, risks and regulatory measures. 

A total of 76 organisations submitted their responses to both the call for evidence and the 
public consultation survey. 

1 

 
 
 
 
Four targeted stakeholder workshops were held online on 8-9 July 2025. The workshops 
focused  on  the  following  topics:  Improving  circularity  (Workshop  1);  Securing  a 
sustainably sourced biomass supply (Workshop 2); Scaling up and accelerating innovation 
(Workshop 3); and  Financing the scale-up of innovators (Workshop 4).  Each workshop 
lasted  half  a  day  and  combined  plenary  presentations  with  breakout  group  discussions. 
Between 23 and 39 stakeholders, representing industry, academia, NGOs, civil society and 
public authorities, attended each session of the workshops. 

2.2. 

Profile of respondents 

As shown in Figure 1, industry representatives were by far the most active respondents in 
all  consultation  formats,  engaging  consistently  in  both  written  consultations  and 
workshops. Academic and research institutions participated fairly actively in all channels, 
while NGOs and civil society were much more engaged in written consultations than in 
workshops. Public authorities made only a modest contribution, while other stakeholders 
did not attend the workshops. 

Figure 1. Number of respondents/participants in stakeholder groups by consultation activity 

0

20

40

60

80 100 120 140 160 180 200

Academic/research institutions

60

36

28

Industry representatives (primary producers and
associations)

Non-governmental organisations and civil society

Public authorities

19

24
28

9

Other

0

62

31

189
190

77

77

109

Call for evidence

Public consultation survey

Targeted stakeholder workshops

The call for evidence attracted the largest number of respondents (444), followed by the 
public  consultation  survey  (362),  with  the  targeted  stakeholder  workshops  drawing  the 
smallest number of participants (133). 

Figure 2. Number of respondents/participants by consultation activity 

2 

 
 
 
0

50

100

150

200

250

300

350

400

450

500

Call for evidence

444

Public consultation survey

362

Targeted stakeholder workshops

133

The  consultation  activities  covered  a  wide  range  of  stakeholder  groups,  ranging  from 
academic  and  research  institutions  to  industry  representatives,  NGOs  and  civil  society, 
public authorities and other actors. For the call for evidence and the public consultation 
survey,  respondents  selected  their  stakeholder  type  from  a  standardised  drop-down  list. 
The  targeted  stakeholder  workshops  used  a  different  system  in  which  the  stakeholder 
subgroups were classified directly by the European Commission. To ensure consistency in 
all consultation activities, the classifications were standardised using stakeholder groups, 
as shown in Table 1. 

Table 1. Stakeholder groups and subgroups participating in consultation activities 

Stakeholder group 
1. Academic/research institutions 

2. Industry representatives 
(primary producers and 
associations) 

3. Non-governmental 
organisations and civil society 

Stakeholders 
- Academic/research institution (call for evidence and public consultation survey) 
- Organisations supporting research and innovation (workshops) 
- Business association (call for evidence and public consultation survey) 
- Company/business (call for evidence and public consultation survey) 
- Trade union (call for evidence and public consultation survey) 
- Businesses and Industries, including SMEs (workshops) 
- Primary producers of biomass, farmers, and foresters (workshops) 
- Social partners and representatives of professions, industry, manufacturing, and 

services (workshops) 
- Consultancies (workshops) 
- Consumer organisation (call for evidence and public consultation survey) 
- Environmental organisation (call for evidence and public consultation survey) 
- EU citizen (call for evidence and public consultation survey) 
- Non-EU citizen (call for evidence and public consultation survey) 
- Non-governmental organisation (NGO) (call for evidence and public consultation 

survey) 

4. Public authorities, including 
Member States and national and 
regional public authorities 
5. Other 

- Non-governmental organisation organisations (workshops) 
- Public authority (call for evidence and public consultation survey) 
- National and regional public authorities, EU decentralised agencies, and other 

bodies (EU agencies) (workshops) 

- Other (call for evidence and public consultation survey) 

Respondents from a total of 38 countries participated in the consultation activities. Of 
the  38  countries,  26  EU  countries  (all  Member  States  except  Cyprus)  and  12  non-EU 
countries (Australia, Brazil, China, Kenya, Nigeria, Norway, Peru, Serbia, South Africa, 
Switzerland, the United Kingdom and the United States) provided stakeholder feedback. 
Figure 3 shows the distribution of each country from which more than two stakeholders 
participated  in  any  one  consultation  activity.  There  were  many  more  participants  from 
western  European  countries  than  from  central  and  eastern  European  countries.  Most 
responses from Belgium, the country with the largest number of respondents, came from 
EU organisations, meaning that they do not really represent a national position. 

3 

 
 
 
Figure 3. Number of respondents/participants by country (two or more only) 

0

50

100

150

200

250

Belgium
Germany
Italy
France
Netherlands
Finland
Sweden
Spain
Austria
Denmark
USA
Norway
Czechia
Switzerland
Hungary
UK
Ireland
Greece
Poland
Brazil
Estonia
Portugal
Bulgaria
Luxembourg
Sweden
Kenya

Call for evidence

Pubic consultation survey

Targeted stakeholder workshops

The ‘Other’ category includes certain international organisations that responded, such as 
the  Food  and  Agriculture  Organization  (FAO),  the  International  Cotton  Advisory 
Committee (ICAC), the International Sericultural Commission and the World Economic 
Forum. 

3.  RESULTS OF THE PUBLIC CONSULTATION ACTIVITIES 

3.1.  Overall summary of the public consultation 

All  contributions  to  the  consultation  were  analysed  using  a  mixed-method  approach 
integrating quantitative and qualitative techniques. Pattern-based detection was applied to 
identify  coordinated  campaigns  in  closed  responses,  while  multidimensional  content 
analysis  was  used  to  examine  open-text  inputs.  A  quality  assurance  framework  was 
implemented to address potential duplicates and abusive content. 

When preparing the analysis, duplicate position papers were removed to ensure accuracy 
and  consistency.  A  thorough  review  was  also  carried  out  to  identify  any  abusive  or 
inappropriate  language,  and  none  was  found.  One  coordinated  campaign  was  detected, 
which  highlighted  concerns  from  agriculture  and  forestry  stakeholders  that  current  life 
cycle assessment (LCA) tools, such as the product environmental footprint category rules 
(PEFCRs)  for  apparel  and  footwear,  undervalue  the  environmental  benefits  of  natural 
fibres while overlooking the negative impact of synthetics. The campaign calls for policy 

4 

 
 
 
reforms  to  ensure  that  sustainability  assessments  reflect  the  full  life  cycle  of  materials, 
support  growth  of  the  bioeconomy  and  promote  the  use  of  renewable,  environmentally 
beneficial resources. 

The contributions from national parliaments, local and regional authorities and agencies 
were limited to the call for evidence and the public consultation survey. The contributions 
highlighted  key  issues  across  Europe.  In  Austria,  for  instance,  public  authorities 
emphasised the role of biomass  and renewable energy in  the country’s energy strategy. 
Belgium’s  contributions  were  focused  on  plant  science,  biogas  and  the  promotion  of  a 
circular, bio-based economy. In Bulgaria and Romania, public authorities concentrated on 
shaping bioeconomy-related public policies. The focus of the authorities in Denmark was 
on  fostering  environmental  sustainability  and  promoting  bio-based  solutions.  Finland’s 
contributions  centred  on  furthering  the  bioeconomy  and  its  industrial  applications. 
Germany’s  public  authorities  provided  insight  into  the  country’s  economy,  rural  affairs 
and environmental protection. In France the public authorities concentrated on biochemical 
production  and  development  of  the  bio-based  industry,  while  Sweden’s  agencies 
highlighted the country’s perspectives on bioenergy. 

EU  decentralised  agencies  and  bodies  (‘EU  agencies’)  that  have  contributed  to  the  EU 
bioeconomy strategy include the European Environment Agency (EEA), the European 
Investment  Bank  (EIB),  the  European  Food  Safety  Authority  (EFSA)  and  the 
European Chemicals Agency (ECHA). Most of those agencies were involved in one of 
the workshops, providing expertise on regulatory coherence, sustainability standards and 
the financial mechanisms required to support the scaling-up of bioeconomy innovations 
across the EU. 

When  it  comes  to  what  the  main  objectives  of  the  bioeconomy  strategy  should  be  (see 
Figure 7.), survey respondents signalled increasing circularity across bioeconomy value 
chains (63%). This was closely followed by fostering environmentally sustainable biomass 
production, supply, and use (56%), and contributing to climate mitigation and adaptation 
(55%). Improving the EU's position in the global bioeconomy (44%) and strengthening the 
biotech and biomaterials sectors (40%) also ranked highly. The feedback reflects a strong 
focus on sustainability, climate action, and enhancing the EU's global competitiveness in 
the bioeconomy sector. 

The consultation highlighted a set of key topics encompassing all the objectives of the 
new  EU  bioeconomy  strategy.  Stakeholders  consistently  emphasised  the  need  for 
improved financing and investment tools, stronger infrastructure and scale-up capacity and 
clearer,  harmonised  regulatory  frameworks.  They  also  pointed  to  the  importance  of:  (i) 
developing  standards,  labelling  and  certification;  (ii)  using  public  procurement  and 
incentives to stimulate demand; and (iii) embedding circularity and the cascading use of 
biomass. Other central priorities identified were: (i) ensuring sustainable biomass sourcing; 
(ii) strengthening skills and public awareness; (iii) improving monitoring and data systems; 
and (iv) furthering international cooperation. These topics cut across all pillars and, taken 
together, set the systemic conditions for a successful bioeconomy. 

Figure 4. Key topics encompassing all stakeholder recommendations 

5 

 
 
Source: Drawn up by the study team. 

When  identifying  barriers  to  specific  product  groups,  public  consultation  survey 
respondents  most  commonly  referred  to  bio-based,  biodegradable  and  compostable 
plastics, pointing to insufficient legislative support and regulatory fragmentation. Natural 
fibres  and  textiles  were  highlighted  as  being  at  a  disadvantage  to  synthetics,  as  current 
assessment tools do not adequately reflect their environmental benefits. Certified forest-
based  and  wood  products  were  mentioned  in  relation  to  conflicting  regulations  and  the 
need to promote cascading use. Additional groups raised included  bio-based chemicals, 
biowaste-derived fertilisers, bio-based construction materials, novel foods such as algae 
and  fungi,  and  biopesticides,  with  further  references  to  biolubricants  and  CO₂-based 
plastics.  These  examples  illustrate  how  there  are  product-specific  barriers  to  both 
established and emerging bio-based sectors. 

Figure 5. Barriers to specific product groups identified by public consultation survey respondents 
(N=167) 

6 

 
 
 
Source: Drawn up by the study team. 

3.2. 

Summary  of  the  feedback  received  on  the  call  for  evidence  document 
describing the initiative 

Key  concerns  raised  included  regulatory  complexity,  financial  gaps  and  challenges  in 
market access for bio-based products. Stakeholders in all sectors emphasised the need for 
a more circular and sustainable bioeconomy, with particular focus on addressing regulatory 
burdens, improving access to financing and creating demand for bio-based solutions. 

A  number  of  barriers  to  the  development  of  the  bioeconomy  were  identified  by 
stakeholders. Regulatory complexity was seen as a major issue, with many respondents 
highlighting  the  need  for  simpler  and  more  harmonised  regulations  across  EU  Member 
States. This complexity was particularly problematic for innovation, as it led to delays and 
additional  costs  for  companies.  Financial  barriers  were  also  a  significant  concern,  in 
particular the lack of dedicated funding for early-stage bioeconomy companies and start-
ups. Furthermore, stakeholders pointed out that competition from fossil-based products, 
which are often more affordable and better established, prevented bio-based products from 
accessing the market. These challenges were compounded by the lack of adequate financial 
and institutional infrastructure to support the scaling-up of bio-based solutions. 

Specific  recommendations  from  stakeholders  focused  on  addressing  these  barriers  in  a 
targeted way. Industry representatives called for regulatory sandboxes and innovation hubs 
to test bio-based solutions in real market conditions. There was also a strong emphasis on 
increasing access to finance, with many stakeholders suggesting that financial instruments 
be  created  to  support  the  transition  from  research  to  commercial  deployment.  Public 
authorities  stressed  the  importance  of  aligning  bioeconomy  strategies  with  other  EU 
policies,  particularly  those  related  to  agriculture  and  climate  change,  and  improving 
coordination between EU, national and regional levels to ensure effective implementation. 

7 

 
 
 
NGOs and members of the public highlighted the importance of integrating sustainability 
and  biodiversity  goals  into  the  strategy,  calling  for  a  stronger  focus  on  environmental 
protection and sustainable practices across bioeconomy sectors. 

In response to the barriers and recommendations, stakeholders suggested several policy 
measures  to  help  unlock  the  full  potential  of  the  bioeconomy.  A  key  proposal  was  to 
simplify regulatory processes, including  the streamlining of permitting and certification 
procedures for bio-based products. Financial support for innovation was another crucial 
aspect,  with  many  respondents  calling  for  dedicated  funding  mechanisms  and  green 
finance  initiatives  to  support  start-ups  and  scale-ups  in  the  bioeconomy  sector.  Public 
awareness and education were also seen as important, with stakeholders recommending 
that efforts be made to raise awareness of the benefits of bio-based products and their role 
in achieving climate and sustainability goals. These policy measures, when implemented, 
will be critical in addressing the challenges facing the bioeconomy and ensuring its long-
term success. 

Stakeholders across various sectors have  also recognised barriers  and recommendations 
that  relate  to  the  need  for  a  more  circular  and  sustainable  bioeconomy  as  particularly 
relevant.  For  bio-based  chemicals  and  polymers,  it  was  pointed  out  that  a  significant 
challenge arises from current frameworks, such as the Renewable Energy Directive, which 
may  inadvertently  favour  bioenergy  production  over  bio-based  materials,  thereby 
hindering circularity objectives. To counteract this, stakeholders who responded to the call 
for evidence suggested developing clearer circularity standards and implementing tailored 
incentives  for  bio-based  products  as  crucial  steps.  Similarly,  the  sector  of  natural  fibre 
textiles  faces  regulatory  barriers  due  to  inconsistent  classification  and  definitions. 
According  to  the  stakeholders,  addressing  this  requires  broadening  the  definition  of 
circularity 
to  encompass  biodegradability,  ecological  regeneration,  renewability, 
regenerative  land  use,  and  product  longevity,  ensuring  a  more  holistic  approach  to 
sustainable material cycles. 

3.3. 

Summary of results by EU bioeconomy strategy objectives and key topics 

This chapter provides an overview of the four key themes set out in the public consultation 
and the call for evidence. In each objective, main topics of interest and issues raised during 
the  consultation  activities  are  outlined,  followed  by  recommendations  put  forward  by 
stakeholders. Lastly, a note is included on how the European Commission has integrated 
the feedback received from consultation activities on development of the strategy. The four 
themes were: 

1.  Bioeconomy innovations and investments: from lab to deployment 
2.  Delivering lead bioeconomy markets 
3.  Securing sustainably sourced biomass supply 
4.  Building on Europe’s strengths to advance a sustainable bioeconomy globally 

3.3.1. 

Bioeconomy innovations and investments: from lab to deployment 

This objective aims to address the barriers to taking bio-based innovations from research 
and development (R & D) to commercialisation. It focuses on overcoming the ‘valleys of 
death’ that start-ups and innovators face in scaling-up, particularly in relation to funding 
gaps,  regulatory  hurdles  and  the  need  for  supportive  infrastructure.  Stakeholders 
highlighted  the  need  for  better  financing  models,  regulatory  support  and  collaborative 

8 

 
 
innovation ecosystems in order to speed up the transition of bio-based innovations from 
lab to market. 

Main topics of interest and issues raised in all consultation activities 

Innovation gaps  and  scalability challenges.  Both  the call for  evidence  and the public 
consultation  survey  emphasised  that  there  is  a  significant  innovation  gap  in  the 
bioeconomy, particularly in scaling up innovations from R & D to industrial applications. 
Respondents  pointed  out  the  challenge  of  surviving  the  ‘valleys  of  death’,  where 
innovations often fail to secure sufficient funding to move beyond the lab stage. Industry 
representatives highlighted the need for increased public and private investments to bridge 
this  gap.  They  also  noted  that  the  lack  of  supportive  financial  and  institutional 
infrastructure to scale up bio-based innovations was a major challenge. On the other hand, 
workshops  moved  beyond  simply  identifying  the  funding  gap  to  proposing  practical 
solutions.  That  is  to  say,  workshop  participants  focused  on  measures  to  close  the 
innovation gap and provide targeted financial support. They emphasised the need for co-
investment and blended finance models to de-risk new bioeconomy ventures and identified 
slow and uncertain regulatory approval as a major obstacle to scaling-up. There was also 
a strong push for greater cooperation between industry and research to assist scaling-up. 

Regulatory barriers to scaling up innovation: The two consultation activities conducted 
through  the  ‘Have  your  say’  portal  identified  regulatory  hurdles  as  one  of  the  primary 
obstacles  to  scaling  up  bio-based  innovations.  Respondents  from  industry  and  public 
authorities pointed to the complexity and fragmentation of regulations across the EU, in 
particular on biotechnology and novel bioproducts. The public consultation survey called 
for more predictable and harmonised regulations to ease the scaling process, particularly 
for  start-ups  looking  to  enter  the  market.  Workshop  participants  reiterated  the  need  for 
regulatory  simplification.  Industry  representatives  stressed  that  differing  national 
regulations  create  an  additional  barrier  to  scaling  up  bio-based  innovations.  They 
emphasised  that  simplified  regulatory  frameworks,  along  with  pilot  schemes  and 
sandboxes,  would  provide  greater  flexibility  for  start-ups.  NGOs  also  pointed  out  that 
environmental regulations should be aligned more closely with the scaling-up of bio-based 
innovations. 

Market  barriers  to  scaling  up  innovation.  The  call  for  evidence  and  the  public 
consultation  survey  identified  significant  market  barriers  to  scaling  up  bio-based 
innovations, such as unfair competition from fossil-based products, lack of demand and 
price  competitiveness.  Industry  representatives  highlighted  the  need  for  incentives  to 
encourage consumers and businesses to  adopt  bio-based alternatives.  In the workshops, 
stakeholders  focused  on  actionable  solutions,  such  as  green  procurement  policies,  tax 
incentives and public awareness campaigns, to reduce price gaps and stimulate demand for 
bio-based products. While the public consultation survey and the call for evidence mainly 
highlighted structural barriers such as market access, the workshops placed more emphasis 
on demand-side solutions and policy-driven market incentives. Despite these differences, 
all consultation formats agreed on the need to overcome market barriers through targeted 
policies and financial instruments. 

Moreover,  public  consultation  survey 
further 
opportunities and innovations for the new EU bioeconomy strategy. The most frequently 
mentioned clusters concern circularity and valorisation, such as cascading use of biomass, 
recycling  and  biochar  deployment,  alongside  biotechnology  and  biomanufacturing, 
including enzymes, precision fermentation and new genomic techniques. Stakeholders also 

identified  several 

respondents 

9 

 
 
highlighted food and agriculture innovations, with references to plant-based foods, fibre 
crops  and  aquaculture.  Further  opportunities  include  energy  and  climate  solutions  (e.g. 
bioenergy with carbon capture and storage / bioenergy with carbon capture and utilisation, 
biomethane)  and  digital  and  governance  enablers.  Overlaps  were  noted  across 
biotechnology, circularity, agriculture and digitalisation. 

Figure 6. Additional opportunities and innovations from public consultation survey respondents 
(N=177) 

Source: Drawn up by the study team. 

In terms of funding and financing measures, the public consultation survey highlighted 
a clear prioritisation of certain areas critical to furthering the bioeconomy. The responses 
given indicated that financing research and innovation was the top priority, with 87% of 
respondents (316 out of 362) considering it important or very important, reflecting strong 
support for deepening knowledge of bioeconomy innovations. The second highest priority 
was  the  need  to  improve  funding  and  capacity  building  for  scaling  up  bioeconomy 
innovations,  which was  considered  important  or  very important  by  80% of respondents 
(289). While sustainable financing tools for primary producers and data-driven approaches 
were also deemed important, they were considered a lower priority, with 66% (239) and 
60% (216), respectively, of respondents rating them as important or very important. 

Table 2. Public consultation survey results on funding and financing measures (N=362) 

Funding and financing measures 

Develop and facilitate the uptake of sustainable financing 
tools, in particular private investments, that reward primary 
producers and landowners for environmentally sustainable 
biomass production, improving the resilience and integrity of 
ecosystems and the provision of ecosystem services (e.g. 
carbon/nature credits) 
Finance more research and innovation to strengthen 
knowledge based on bioeconomy, including biomass supply 
and demand innovations 

10 

Very 
important + 
Important 

Neutral 

Slightly 
important + 
Not at all 
important 

239 (66%) 

60 (17%) 

37 (10%) 

316 (87%) 

25 (7%) 

16 (4%) 

 
 
 
Improve funding and capacity building for regions and 
Member States to scale-up bioeconomy innovation and allow 
the transition from laboratory to the market 
Support the uptake of innovative bio-based products and 
services (e.g. product-as-a-service applications for example 
related zto fertilizers) 
Incentivise data-driven approaches to the bioeconomy value 
chain: from satellite data for biomass production to new 
digital solutions in support of logistics, traceability, etc. 

289 (80%) 

41 (11%) 

11 (3%) 

250 (69%) 

58 (16%) 

12 (3%) 

216 (60%) 

85 (23%) 

35 (10%) 

Recommendations put forward by stakeholders 

Addressing the  innovation gap with targeted funding. The call for  evidence  and the 
public  consultation  survey  recommended  increasing  the  availability  of  targeted  funding 
mechanisms  to  bridge  the  innovation  gap.  Stakeholders  called  for  financial  support  for 
start-ups and SMEs to help scale up their innovations, with particular focus on the early 
stages of innovation. The need for flexible financial instruments addressing the high risk 
of bio-based ventures was another key point. In the workshops, stakeholders suggested co-
investment  and  blended  finance  models  as  a  solution  to  scale  up  innovations.  Industry 
representatives  also  advocated  setting  up  EU-level  funds  specifically  designed  for 
bioeconomy  scale-ups. There was  a strong push for regional funds  capable of targeting 
local bioeconomy clusters and promoting their growth. 

Streamlining regulatory frameworks. The call for evidence and the public consultation 
survey identified the need for regulatory simplification to enable bio-based innovations to 
scale up. Industry stakeholders highlighted the barriers caused by fragmented regulations 
across the EU and called for more predictable and harmonised regulations to support the 
scaling-up of innovation. The workshops expanded on this by recommending regulatory 
sandboxes  and  pilot  schemes  as  flexible  tools  for  scaling  up  bio-based  innovations. 
Industry stakeholders argued for clearer and simpler regulatory pathways to fast-track bio-
based innovations into commercialisation. Other stakeholders, by contrast, tended to have 
concerns  about  the  sustainability  of  innovations  and  called  for  regulations  that  were 
environmentally sound as well as simpler. 

Improving  public-private  partnerships  for  scaling  up  innovations.  The  call  for 
evidence  and  the  public  consultation  survey  recommended  developing  public-private 
partnerships  (PPPs)  to  support  the  scaling-up  of  bio-based  innovation,  emphasising  the 
need for cooperation between public authorities, industry and research institutions. In the 
workshops,  stakeholders  highlighted  PPPs  as  crucial  for  de-risking  investments  and 
advocated  EU-wide  initiatives  to  support  start-ups  and  SMEs,  with  NGOs  calling  for 
stronger sustainability criteria. While all consultation formats agreed on the importance of 
fostering  cooperation,  the  workshops  provided  more  detailed  recommendations  on 
structuring those partnerships. 

The Commission’s consideration of feedback on this objective 

The new bioeconomy strategy aims to create a seamless investment journey for sustainable 
bio-based  solutions,  from  pilot  to  deployment,  and  to  support  small  and  medium-sized 
enterprises  (SMEs).  Under  the  new  Multiannual  Financial  Framework  (MFF),  the 
Commission  proposed  to  create  a  ‘bioeconomy  window’  inside  both  the  European 
Competitiveness  Fund  and  the  future  Horizon  programme  to  fund  innovation,  mobilise 
large-scale investment, de-risk industrial deployment and bridge the gap between research, 
innovation and market upscaling. 

11 

 
 
 
The Commission will review the Circular Bio-Based Joint Undertaking, a public-private 
partnership that helps accelerate the innovation process and the market deployment of bio-
based  solutions.  It  will  identify  the  most  effective  and  impactful  future  collaboration 
options under the next MFF. The Strategy will align investment priorities with Member 
States and coordinate EU support mechanisms with national projects. 

The Commission will also focus on targeted financial tools and will consider revising the 
EU Taxonomy Delegated Acts to ensure sustainable biomanufacturing and other bio-based 
economic  activities  are  properly  recognised  as  key  enablers  of  the  green  transition,  to 
improve investment certainty. 

The  Commission  will  also  set  up  a  European  Bioeconomy  Regulators  and  Innovators’ 
Forum to exchange best practices related to risk assessments of novel bio-based solutions, 
ensure  transparency,  monitor  progress,  and  engage  in  early  discussions  with  firms 
developing novel bio-based solutions. It will coordinate national and EU actions to fast-
track authorisation for new entrants and remove barriers. 

3.3.2. 

Delivering new lead bioeconomy markets 

This  objective focuses  on  promoting  the use of  bio-based materials  within bioeconomy 
lead markets and on creating a level playing field for competing uses of biomass. It aims 
to create sustainable markets for circular bio-based solutions, enhance resource efficiency 
and reduce waste. Stakeholders have highlighted the need for clear frameworks, market 
demand stimulation and regional cooperation to drive circularity across value chains. The 
goal  is  to  ensure  that  high  economic  and  environmental  added-value  applications  are 
prioritised to optimise biomass use and to foster innovation. 

Main topics of interest and issues raised in all consultation activities 

Creating  demand.  In  both  the  call  for  evidence  and  the  public  consultation  survey, 
creating  markets  for  circular  bio-based  solutions  was  a  key  concern.  Stakeholders 
emphasised the importance of using biomass more efficiently in all value chains, with a 
strong  push  for  stimulating  market  demand.  Stakeholders  representing  industry  were 
particularly vocal about the need for clear market incentives to ensure the uptake of bio-
based products. In the workshops, the main topic of discussion was how to create demand 
for  bio-based  products.  Stakeholders  identified  the  lack  of  regulatory  coherence  and 
competition  from  fossil-based  alternatives  as  significant  barriers.  Regional  differences 
emerged in the discussion, with stakeholders from central and eastern Europe focusing on 
the  lack  of  local  strategies  and  infrastructure,  while  those  from  western  Europe 
concentrated more on policy coherence and EU-wide market creation. 

Circularity and the biomass cascading principle. The call for evidence and the public 
consultation  survey  highlighted  the  cascading  principle  as  essential  for  the  circular 
bioeconomy. They called for biomass to be prioritised for high-value applications such 
as  materials  and  food  before  considering  energy  production.  However,  some  industry 
stakeholders pointed out that energy production recovery from biomass is often the most 
financially viable option. Participants in both consultation activities recognised regulatory 
barriers  as  the  main  obstacles  to  effectively  implementing  the  cascading  principle.  The 
workshops  highlighted  the  challenges  of  balancing  the  cascading  principle  in  the 
marketplace, where industry stakeholders advocated for economic considerations, such as 
maximising  biomass  use  for  energy,  while  NGOs  emphasised  the  importance  of 

12 

 
 
environmental  sustainability.  There  was  therefore  a  significant  divergence  between 
industry and NGOs, with the former focusing on economic value and the latter pushing for 
stronger regulations to ensure environmental added value. 

Waste  management  and  valorisation.  All  three  consultation  activities  recognised  the 
importance of improving waste management and creating value from biological residues, 
in particular for materials, fertilisers and soil health improvements. Stakeholders across the 
board agreed on the need for EU-level funding for waste-to-resource projects, albeit with 
a slight difference in focus. NGOs, civil society and academic research institutions placed 
greater emphasis  on improving waste collection systems,  while industry  representatives 
called  for  regulatory  incentives  to  improve  the  valorisation  of  biowaste.  The  public 
consultation  survey  suggested  that  public  procurement  policies  should  play  a  more 
proactive  part  in  driving  waste  valorisation.  In  addition,  workshop  participants  also 
emphasised the idea of  minimising waste generation from the outset, suggesting that 
businesses integrate circularity into their processes to reduce waste generation in the first 
place. 

Regional  cooperation.  Both  the  call  for  evidence  and  the  public  consultation  survey 
recognised the importance of regional cooperation in fostering context-specific solutions 
to promote circular bioeconomy practices. Stakeholders, particularly those from local or 
regional  initiatives,  emphasised  the  need  for  localised  biomass  valorisation  to  address 
regional disparities in  biomass  availability and infrastructure. The survey indicated that 
cross-border cooperation could help optimise resource use and improve biomass supply 
chains. In the workshops, participants focused on regional cooperation as a critical aspect 
of  stepping  up  circular  bioeconomy  efforts.  The  importance  of  localised  biomass 
valorisation was noted by industry representatives from regions with limited infrastructure, 
in particular, who called for tailored solutions taking account of the potential of regional 
biomass.  Cross-border  cooperation  was  also  highlighted  as  essential  for  improving 
resource efficiency and ensuring a more resilient bioeconomy. 

According  to  the  public  consultation  survey  data,  circularity  was  seen  as  the  most 
important objective for the new bioeconomy strategy. That is to say, when asked ‘What 
should be the main objectives of the new EU  bioeconomy strategy?’, most respondents 
(229 out of 362, or 63%) selected the ‘… increasing circularity across bioeconomy value 
chains’ option. The graph below compares this objective to others. 

Figure 7. Public consultation survey results on the main objectives of the new bioeconomy strategy 
(N=362) 

13 

 
 
What should be the main objectives of the new EU 
Bioeconomy Strategy (multiple answers possible)?

0% 10% 20% 30% 40% 50% 60% 70%

...increasing circularity across bioeconomy value
chains

...fostering environmentally sustainable
production, supply and use of biomass, in…
...contributing to climate mitigation and
adaptation

...improving the position of the EU bioeconomy in
the global competition
...strengthening the biotech and biomanufacturing
sectors in the EU
...ensuring food security in the EU and promoting
sustainable food systems in the EU

...improving the provision of renewable and
affordable energy

...protecting and restoring the ecosystems that
provide services for people in the EU (e.g. clean…
...ensuring income and welfare in the rural and
remote areas of the EU

...increasing employment possibilities in
bioeconomy sectors

12%

Recommendations put forward by stakeholders 

63%

56%

55%

44%

40%

31%

27%

27%

25%

Creating a level playing field. The call for evidence and the public consultation survey 
both called for demand-side measures, in particular public procurement to drive the uptake 
of bio-based products. The survey also highlighted the need for EU-level harmonisation of 
regulations  to  reduce  inconsistencies  between  Member  States.  Industry  representatives 
insisted on the need for tax and other financial incentives for bio-based products. In the 
workshops,  there  was  broad  agreement  on  the  need  for  public  procurement  policies  to 
stimulate demand. 

Financial and regulatory support for circular biomass projects. The call for evidence 
and the public consultation survey strongly recommended EU-level funding for circular 
biomass  projects,  with  particular  emphasis  on  supporting  smallholders  and  innovators. 
Many  stakeholders  highlighted  the  importance  of  simplifying  access  to  EU  funding, 
particularly for start-ups and small-scale innovators. Industry stakeholders, on the other 
hand,  stressed  the  need  for  predictable  policy  environments  to  encourage  long-term 
investment. In the workshops, EU-level funding for circular biomass projects was, again, 
a  key  recommendation.  Industry  stakeholders  focused  on  public-private  partnerships  to 
scale up innovation, while NGOs stressed the importance of environmental safeguards in 
addition to financial support. 

Encouraging co-production models. The call for evidence and the public consultation 
survey highlighted the need for co-production models in which biomass could be used for 
a number of high-value purposes. Industry stakeholders focused on financial incentives to 
support such models, while NGOs emphasised the importance of stronger regulations to 
ensure sustainability. Similarly, in the workshops, industry representatives advocated co-
production business models, emphasising the need for market-driven solutions. NGOs, on 
the other hand, stressed the need for environmental regulations to ensure sustainability of 
the models. 

14 

 
 
 
The Commission’s consideration of feedback on this objective 

One of the main goals of the new Bioeconomy Strategy is to encourage the development 
of  lead  markets  by  promoting  bio-based  materials  over  their  fossil-based  alternatives. 
Demand  creation  and  support  measures  have  been  proposed  for  materials  (bio-based 
plastics and polymers, textiles from bio-based fibres and fabrics, bio-based chemicals, bio-
based  construction  products,  bio-based  fertilisers  and  plant  protection  products)  and 
technologies  (biorefineries,  advanced  fermentation  and  permanent  storage  of  biogenic 
carbon). Additional measures have been proposed with the launch of a ‘Bio-Based Europe 
Alliance’  and  the  possibility  of  exploring,  within  the  recast  of  the  Public  Procurement 
Directives, the possible creation of lead markets in clean and strategic technologies. 

In order to decouple growth in the bioeconomy from demand for biological resources, it is 
necessary to create a level playing field for different uses of biomass and to direct biomass 
to where it delivers the highest value. For that purpose, the Commission will work with the 
Knowledge Centre for Bioeconomy to provide examples of where biomass is of the highest 
economic  and  environmental  added-value,  building  on  the  experience  of  the  cascading 
principle as mentioned in the Renewable Energy Directive. 

In addition, the allocation of public funding and the setting of policy priorities in tools such 
as  National  Energy  and  Climate  Plans  and  national  or  regional  bioeconomy  strategies 
should be guided towards higher-value and material uses of biomass. This approach is fully 
in line with the Clean Industrial Deal State Aid Framework, which encourages Member 
States to ensure that projects and activities supported by State aid contribute to the circular 
economy to the largest extent possible. 

Co-production  models  will  be  encouraged  in  this  strategy.  For  example,  biorefineries 
process and convert biomass – in particular, biowaste – into a range of valuable products 
including  biochemicals,  biomaterials  and  bioenergy.  The  sector  integrates  advanced 
technologies to optimise biomass transformation, nutrient recycling and the co-production 
of energy, materials and chemicals. 

3.3.3. 

Securing sustainably sourced biomass supply 

This objective focuses both on ensuring that the growth of the bioeconomy is supported by 
a reliable and sustainable supply of biomass  and on balancing  environmental goals and 
economic needs. Stakeholders highlighted the challenges presented by biomass sourcing, 
land  management  and  regulatory  frameworks,  with  emphasis  on  ensuring  long-term 
sustainability and biodiversity protection. 

Main topics of interest and issues raised in all consultation activities 

Sustainability criteria and certification systems. The call for evidence and the public 
consultation survey both emphasised the need for clear and consistent sustainability criteria 
for biomass sourcing and uses. Both consultation formats stressed that setting up EU-wide 
certification  schemes  would  help  standardise  practices  and  improve  traceability.  In  the 
workshops, stakeholders agreed on the importance of harmonising sustainability criteria 
and highlighted the role of EU-level certification in improving transparency throughout 
the biomass supply chain. The workshops placed emphasis on biodiversity protection and 
environmental criteria in sustainability frameworks. 

15 

 
 
Competition for biomass and land use. The call for evidence and the public consultation 
survey  recognised  the  growing  competition  for  biomass.  Food,  feed  production  and 
bioenergy  (the  latter  to  a  lesser  extent)  take  in  a  great  portion  of  the  existing  biomass, 
making  it  difficult  for  new  sectors  of  the  bioeconomy  to  ensure  sufficient  supply.  The 
survey  highlighted  concerns  from  some  EU  primary  producers,  who  fear  that  existing 
policies could often prioritise bioenergy over biomaterials, leading to potential conflicts 
over land use.  NGOs in the survey raised alarms about land degradation and the need to 
ensure that sustainable biomass production does not lead to deforestation or biodiversity 
loss.  In  the  workshops,  the  competition  for  land  was  a  central  issue.  Industry 
representatives pointed out that biomass production should be balanced across bioenergy, 
materials, and food production, with an emphasis on finding win-win solutions. They also 
suggested co-management models to increase biomass production without compromising 
land  sustainability.  On  the  other  hand,  NGOs  emphasised  the  importance  of  land  use 
regulations that prevent deforestation and protect biodiversity. 

Regulatory  barriers  and  simplification.  Both  the  call  for  evidence  and  the  public 
consultation survey emphasised the need to simplify the regulatory landscape for biomass 
sourcing.  Respondents  pointed  to  the  complexity  of  sustainability  frameworks  and 
traceability  requirements,  which  can  act  as  barriers  to  entry  for  smallholders  and  new 
producers.  Industry  representatives  noted  that  the  lack  of  clear,  harmonised  regulations 
across the EU, in particular, makes it difficult to plan long-term biomass sourcing, leading 
to  market  fragmentation.  In  the  workshops,  stakeholders  agreed  that  regulatory 
simplification is key to fostering a sustainable supply of biomass. Industry representatives 
called for clearer regulations and consistent standards across the EU to facilitate biomass 
trade and production. They also  highlighted the  need for flexible permitting  systems  to 
reduce the administrative burden.  NGOs, however, cautioned that simplification should 
not come at the expense of environmental safeguards, stressing that simplified regulations 
should still ensure sustainability and biodiversity protection. 

The public consultation survey highlighted significant concern over the lack of a stable 
supply of sustainably sourced biomass and competition for it between different uses, 
such as food, materials, products, energy and ecosystem services. A total of 76% of 
respondents considered that risk to be important or very important (275 out of 362, see 
Figure 8), indicating broad recognition of the challenges posed by biomass scarcity and its 
potential impact on the EU bioeconomy. While a smaller share of respondents, 11% (39), 
remained neutral, only 10% (36) downplayed the importance of the issue, suggesting that 
a  stable  biomass  supply  is  considered  a  critical  factor  for  securing  the  sector’s  future 
competitiveness and sustainability. 

Figure 8. Public consultation survey results on risks for the EU bioeconomy (N=362) 

16 

 
 
Perceived importance of the risk "Lack of stable supply of 
sustainably sourced biomass and competition for it between 
different uses, such as for food, materials, products, energy and 
ecosystem services" for the EU bioeconomy 

17, 5%

19, 5%

12, 3%

39, 11%

175, 48%

100, 28%

Very Important

Important Neutral Slightly important Not at all important

I do not know

Recommendations put forward by stakeholders 

Harmonising sustainability criteria  and certification systems.  Stakeholders from  the 
call  for  evidence  and  the  public  consultation  survey  agreed  on  the  need  for  EU-wide 
sustainability criteria and certification systems. The survey suggested that harmonisation 
could  help  resolve  regulatory  inconsistencies  and  create  a  level  playing  field  for  all 
producers. There was strong support for making the criteria clearer and more transparent, 
with industry representatives highlighting the importance of traceability and certification 
to build consumer trust. In the workshops, industry stakeholders also emphasised the need 
for EU-wide certification schemes to ensure sustainable biomass sourcing and eliminate 
regulatory confusion. They also stressed the importance of consistent traceability standards 
to  improve  supply  chain  transparency.  NGOs  argued  for  more  rigorous  sustainability 
criteria  to  protect  biodiversity  and  avoid  land  degradation,  stressing  that  the  EU 
certification system should be aligned with climate and biodiversity targets. 

Public procurement policies to stimulate demand for sustainably sourced biomass. 
Stakeholders in the call for evidence, the public consultation survey and the workshops 
recognised  public  procurement  policies  as  a  key  mechanism  to  drive  demand  for 
sustainably  sourced  biomass.  The  former  two  consultation  formats  emphasised  that 
government procurement could play a key role in creating market incentives for bio-based 
products.  Respondents  also  noted  that  public  procurement  could  help  overcome  market 
barriers  by  providing  guaranteed  demand  for  bio-based  products.  In  the  workshops, 
stakeholders called for EU-wide procurement policies that would create demand for bio-
based products from sustainable biomass sources. 

The Commission’s consideration of feedback on this objective 

Production systems that maintain and increase the supply of biomass while restoring and 
maintaining  ecosystem  health  are  to  become  mainstream  in  agriculture,  forestry  and 
aquaculture. A balance has to be struck between the functioning of ecosystems as carbon 
sinks and the need  for  an expanding  bioeconomy and long-term  availability  of primary 
biomass. 

17 

 
 
 
The future common agricultural policy will play a catalytic role by supporting farmers who 
adopt bioeconomy innovation and sustainability practices and contribute to the emerging 
bioeconomy value chains. In the forestry sector, biomass production and supply must be 
offset against ecological constraints. Resilience should be built by improving sustainable 
forest  management,  restoring  degraded  areas  and  implementing  low  impact  harvesting 
methods.  Water  efficiency  and  resilience  considerations  should  also  be  integrated  into 
bioeconomy development, in line with the EU water resilience strategy. 

Although the demand for bioenergy remains substantial, it is limited by legislations like 
the Renewable Energy Directive which restrict the use of land-based biomass for energy. 
The  Commission  will  improve  methodologies  and  modelling  for  assessing  sustainably 
sourced biomass availability and the cumulative impacts, on land use of different biomass 
uses and non-use for the provision of ecosystem services. 

Public  procurement  can  play  a  pivotal  role  in  driving  demand  within  the  sector  by 
prioritising products made from a wide range of locally available secondary raw materials, 
in  compliance  with  the  Union's  international  commitments  and  EU  procurement 
legislation. The Commission  will explore how bio-based materials  and products  can be 
promoted in public procurement. 

3.3.4. 

Building  on  Europe’s  strengths 
bioeconomy globally 

to  advance  a  sustainable 

This objective focuses on enhancing the EU's role in global bioeconomy initiatives and 
fostering international cooperation on sustainability through green diplomacy. It includes 
supporting international partnerships to scale up bio-based innovations, encourage policy 
alignment and promote sustainable practices in bioeconomy sectors worldwide. None of 
the four workshops specifically addressed this objective. 

Main topics of interest and issues raised in all consultation activities 

International  partnerships  and  trade.  Both  the  call  for  evidence  and  the  public 
consultation survey emphasised the importance of international partnerships for supporting 
global expansion of the bioeconomy. The survey stressed that international cooperation is 
crucial  for  scaling  up  bio-based  innovations  and  addressing  global  challenges  such  as 
climate  change  and  resource  scarcity.  Stakeholders  also  pointed  out  the  need  for  trade 
agreements to facilitate the exchange of sustainable bio-based products while complying 
with environmental standards. Many respondents stressed the potential for working with 
developing  economies  to  promote  green  growth  and  knowledge  transfer.  Industry 
representatives  called  for  alignment  of  global  supply  chains  and  policy  coordination  to 
avoid trade barriers. 

Green  diplomacy  and  global  bioeconomy  leadership.  The  call  for  evidence  and  the 
public  consultation  survey  recommended  that  the  EU  should  position  itself  as  a  global 
leader in green diplomacy to promote sustainable bioeconomy practices worldwide. The 
survey emphasised that the EU has a unique opportunity to use its policy frameworks and 
technological  expertise to foster international  cooperation on bioeconomy  issues. There 
was broad support for the EU participating more actively in international forums, such as 
the UN and the World Trade Organization, to promote sustainable practices and encourage 
the adoption of bio-based solutions globally. Industry representatives specifically called 

18 

 
 
for global market access for bio-based products and support for international cooperation 
aligned with EU sustainability targets. 

The  public  consultation  survey  showed  strong  support  for  promoting  global 
partnerships and cooperation for a sustainable and circular bioeconomy, with 73% of 
respondents rating it as important or very important. This reflects a clear consensus on the 
need  for  international  cooperation  to  strengthen  the  bioeconomy  and  support  its 
sustainability goals. However, 17% of respondents (60) were neutral, and a smaller share, 
6%,  either  downplayed  its  importance  or  were  unsure,  suggesting  some  difference  of 
opinion on how urgent global partnerships are for – and what impact they have on – the 
bioeconomy. 

Figure 9. Public consultation survey results on the importance of promoting global partnerships 
(N=362) 

Perceived importance of promoting global 
partnerships and cooperation for sustainable and 
circular bioeconomy as a measure to engage with 
value chain actors
4, 1%

16, 4%

18, 5%

60, 17%

95, 26%

169, 47%

Very Important

Important Neutral Slightly important Not at all important

I do not know

Recommendations put forward by stakeholders 

Strengthening  global  bioeconomy  governance  and  trade  agreements.  Both  the 
respondents from the call for evidence and the public consultation survey called on the EU 
to  strengthen  its  global  bioeconomy  governance  through  trade  agreements  and  policy 
coordination.  Industry  representatives  who  completed  the  survey  emphasised  the 
importance of trade partnerships supporting bio-based products and encouraging mutual 
recognition of sustainability standards. There was also support for international regulatory 
alignment to  ensure a level  playing field  and  increase  the competitiveness  of bio-based 
solutions in global markets. The survey suggested that the EU should actively engage in 
multilateral trade agreements to promote the bioeconomy’s role in climate action. 

The Commission’s consideration of feedback on this objective 

Through  free  trade  and  partnership  agreements,  regulatory  dialogues  and  diplomatic 
engagement,  the  EU  will  partner  up  with  non-member  EU  countries  to  create  shared 

19 

 
 
 
benefits for a sustainable global bioeconomy, supporting new feedstocks and increasing 
access to further the biotechnology and bio-based products in those countries.  The Global 
Gateway  strategy  provides  a  key  framework  for  advancing  the  objectives  of  the  EU 
Bioeconomy Strategy by linking sustainable investments in resilient supply chains with 
innovation ecosystems. The EU will also participate more actively in the main international 
forums where the international playing field for the bioeconomy is set and its rules and 
principles are laid down. One of EU’s priorities will be to launch a flagship research and 
innovation  initiative  deploying  sustainable  bioeconomy  solutions  in  high-potential 
regions. The initiative will raise capital, strengthen industrial ecosystems beyond the EU’s 
borders  and  ensure  that  all  actions  are  supported  by  robust  environmental  and  social 
safeguards. 

4.  OTHER CONSULTATION ACTIVITIES 

On 16 May 2025 European Commissioner Jessika Roswall welcomed stakeholders from 
industry and civil society to a meeting on shaping a forward-looking bioeconomy strategy. 
Various topics were discussed at the meeting, including: 

- 

- 

- 

- 

- 

- 

competitiveness:  the  need  to  address  regulatory  and  financial  shortcomings, 
simplify permitting procedures and promote a circular economy; 
sustainability:  the  importance  of  ensuring  sustainability  in  biomass  sourcing, 
addressing the biomass gap and promoting regenerative practices; 
regulatory considerations: the need for simplification, predictability and strategic 
alignment across policy frameworks; 
funding:  the  crucial  role  of  funding  in  surviving  ‘valleys  of  death’  in  the 
bioeconomy and biotech sectors, and the need for public-private partnerships and 
revised funding rules; 
sustainability  criteria  and  cascading  use:  the  need  to  firmly  implement  the 
cascading principle and to build on existing frameworks for sustainability criteria; 
context-specific  research:  supporting  context-specific  research,  innovative 
support and tailored expertise to adapt to climate conditions. 

It  was  also  emphasised  that  the  new  bioeconomy  strategy  should  prioritise  resource 
optimisation,  production  diversification,  circularity,  nature  restoration  and  regenerative 
practices. 

Stakeholders  generally  agreed  that  the  bioeconomy  has  significant  potential  for  their 
specific sectors and the broader EU economy, e.g. by replacing fossil-based resources and 
increasing EU resilience and competitiveness. 

In addition to the responses from the call for evidence and the public consultation survey, 
the European Commission also received ad hoc contributions from 20 organisations after 
the consultation period had ended. The contributions came from stakeholders who had not 
been able to respond within the designated time frame due to technical issues or for other 
reasons. Table 3 lists the names and further details of the organisations who submitted the 
additional ad hoc contributions. 

Table 3. Ad hoc contributions 

Organisation name 

Member State 

Stakeholder type 

Austrian Biomass Association 

Austria 

Non-governmental organisations and 
civil society 

20 

 
 
Academic/research institutions 
Non-governmental organisations and 
civil society 
Non-governmental organisations and 
civil society 

Public authorities 

Non-governmental organisations and 
civil society 
Public authorities 
Non-governmental organisations and 
civil society 
Industry representatives (primary 
producers and associations) 
Public authorities 
Industry representatives (primary 
producers and associations) 
Industry representatives (primary 
producers and associations) 
Public authorities 
Industry representatives (primary 
producers and associations) 
Public authorities 

Public authorities 

European Plant Science Organisation 
European Biogas Association 

Municipal Waste Europe, European Biogas 
Association and European Compost 
Network 
Circular Bio-Based Europe Joint 
Undertaking (CBE JU) 
Environmental Coalition on Standards 

Belgium 
Belgium 

Belgium 

Belgium 

Belgium 

Bulgarian and Romanian governments 
CONCITO 

Bulgaria, Romania 
Denmark 

European Biosolutions Coalition 

Denmark 

Finland 
Finland 

France 

Germany 
Germany 

Germany 

Germany 

Finnish government 
Stora Enso 

GFBiochemicals 

Stefan Köhler MEP 
BASF 

German Ministry of Economic Affairs and 
Energy 
German Ministry of the Environment, 
Climate Action, Nature Conservation and 
Nuclear Safety 
Baden-Württemberg Ministry of Food, 
Rural Affairs and Consumer Protection 
Eni S.p.A. 

Stockholm Exergi 

The Protein Project 

Germany 

Public authorities 

Italy 

Sweden 

UK 

Industry representatives (primary 
producers and associations) 
Industry representatives (primary 
producers and associations) 
Academic/research institutions 

investment.  These 

The  ad  hoc  contributions  outline  a  wide-ranging  debate  on  the  future  direction  of 
sustainable production and resource use. Although perspectives differ, there is consensus 
that economic transformation and ecological responsibility must go hand in hand. Industry 
contributions  emphasise  competitiveness,  innovation  and  the  conditions  necessary  to 
secure 
include  predictable  regulatory  frameworks,  simplified 
authorisation processes, incentives for scaling first-of-a-kind plants and recognition of new 
categories of products such as bio-attributed materials. The business sector highlights its 
role  in  technological  transformation  –  from  biorefineries  and  advanced  fertilisers  to 
biotechnology  and  digital  farming  tools  –  arguing  that  Europe  risks  losing  global 
leadership if supportive frameworks are not put in place. 

Environmental  and  civil  society  actors,  by  contrast,  focus  attention  on  ecological 
boundaries.  They  underline  the  risks  of  overexploiting  biomass,  which  could  erode 
biodiversity, carbon sinks and ecosystem services. Their proposals call for binding material 
footprint targets, robust sustainability standards applied across biomass uses, and stronger 
monitoring  systems  to  prevent  rebound  effects  or  greenwashing.  The  ‘cascading  use’ 
principle is considered critical for ensuring that biomass is prioritised for high-value and 
circular applications rather than short-lived. The contributions also express concern that 
undefined  terms  such  as  ‘regenerative  practices’  may  obscure  rather  than  enforce 
ecological safeguards. 

National  and  regional  authorities  and  sectoral  organisations  often  position  themselves 
between these perspectives. Some highlight the importance of stable supply chains, rural 
development and regional infrastructure for scaling up innovative practices, particularly in 

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agriculture, forestry and waste management. Others stress that industrial growth must be 
carefully aligned with local ecosystems to avoid scarcity and degradation. Research and 
innovation  communities  add  yet  another  layer,  focusing  on  plant  factories,  microbiome 
applications and new biotechnologies that could provide solutions for food security, health 
and  materials,  while  acknowledging  challenges  of  scalability,  regulation  and  consumer 
acceptance. 

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