The Swedish Forest Industries urge the European Parliament and the Council to reject all REDIII proposals introducing new rules and criteria for forest biomass.
The Swedish Forest Industries support the Green Deal and the important goal of a climate neutral society by 2050. We acknowledge that green transition requires raised ambitions on biodiversity, climate and renewable energy. We further acknowledge the contribution from renewables to climate change mitigation shall be governed by the RED III through targets and principles, under the legal basis for measures to develop new and renewable forms of energy. However, we do not acknowledge that there are any legal, scientific or practical grounds for governing biodiversity and forestry in detail through the RED III.
In summary, our justifications are:
- EU legislation on renewable energy must not govern forestry and raw material markets in detail, and should not be a tool for implementing any common EU forest policies
- The proposed rules and criteria must be in line with the proportionality as well as the subsidiarity principles.
- The proposed rules and criteria could even be contradictory to EU energy and climate objectives in hindering use of waste and residues and the development of the circular forest-based bioeconomy.
- The Risk Based Approach (RBA) must continue to be the basis for any forest biomass sustainability criteria.
