WWF's briefing paper argues that bioenergy has a role to play in decarbonisation of the EU energy system. But the sustainability criteria for bioenergy proposed by the European Commission in its recast of the EU Renewable Energy Directive are deeply flawed. Stricter rules are needed to ensure that bioenergy used in the EU delivers genuine climate benefits over the fossil alternative.

The EU should have greenhouse gas criteria based on a full lifecycle assessment including all relevant factors, and based on a climate-relevant timeline. In the absence of that the EU should:

1. Phase out subsidies and incentives for purpose-grown biofuel crops, which are unlikely to be a good use of land from a climate perspective. For pragmatic reasons WWF accepts that this could be done gradually, for example in line with the Commission’s proposal of an initial reduction in the cap on food-based biofuels from 7.0% to 3.8%;

2. Phase out subsidies and incentives for the use of stemwood and stumps. Less coarse harvest residues such as tops and branches should remain eligible for these but only if used in installations employing high efficiency cogeneration (i.e. combined heat and power).

3. Ensure that wastes and residues only benefit from subsidies or incentives if they have no significant alternative uses, whether for food, animal feed or bio-based materials (the cascading use principle).

The EU should also set strict efficiency requirements – and apply these and the other sustainability criteria to all users of biomass fuels over 1MW in size.

Finally, EU policies need to recognise that genuinely low carbon bioenergy from wastes and residues will remain a rare commodity in the EU relative to total energy demand. Bioenergy is therefore unlikely to be a major contributor to decarbonisation or to overall EU energy security, and the majority of EU energy supply in 2050 will need to come from sources such as wind and solar.