ETIP Bioenergy Position Statement on the Consultation “Sustainable finance – EU classification system for green investments”

The European Technology and Innovation Platform Bioenergy (ETIP Bioenergy) has recently submitted a position statement on the European Commission’s consultation “Sustainable finance – EU classification system for green investments”.

ETIP Bioenergy fully supports the ambition of the Green Deal for net climate neutrality in 2050, as well as increasing the GHG emission target to at least 55 % in 2030. Also the initiative to create a classification system for sustainable economic activities (‘taxonomy’) is very welcome.


- Although some references are made to other pieces of EU legislation, synergies and coherence with current and future legislation should be aimed for whenever possible.

- Full alignment with the sustainability criteria of RED 2 is important.

- Excluding the use of food and feed crops in general does not reflect several innovative approaches for sustainable supply.

- Classifying bioenergy and biofuels as "transitional activity", which can only be supported if there are no technologically and economically feasible low-carbon alternatives, is not justified in our view, as modern bioenergy can lead to significant GHG reductions.

-The focus on zero tailpipe CO2 emissions in transport (section 6) is wrong in our view. Instead of focusing on zero tailpipe CO2 emissions a well-to-wheel approach must be considered. Reducing CO2 emissions in transport is one of the biggest challenges for the European Union. To ensure the contribution of the transport sector to the overarching EU targets of -55 % G in 2030 and net carbon neutrality in 2050, all options will be needed, including low carbon fuels.

-4 weeks is not an adequate timespan to read and digest the 529 pages of the Delegated Act and its Annexes, which are crucial for this piece of legislation. - The EC’s better regulation agenda stipulates that “the delegated act cannot change the essential elements of the law”. It can be questioned if this principle is respected when reading Article 1 “Subject matter and scope” of the Sustainability Regulation 2020/852.

Read the full position statement here: