08 APRIL 2022

The LULUCF regulation is key for a blossoming European bioeconomy

A balanced land-use, land-use change and forestry policy would contribute at the same time to climate change mitigation and to growing the circular bioeconomy.

The land-use sector and the bioeconomy

As it is defined by the EU Commission, “the bioeconomy means using renewable biological resources from land and sea, like crops, forests, fish, animals and micro-organisms to produce food, materials and energy”. The Commission adds and confirms: “Stronger development of the bioeconomy will help the EU accelerate progress towards a circular and low-carbon economy.”
A successful bioeconomy therefore depends on the availability of sustainable and cost-competitive biomass (from agriculture, forestry, marine ecosystems and waste) and on its efficient use.
Biomass-derived chemistry in particular has the capacity to prolong the benefits of photosynthesis as it uses biogenic carbon as its main raw material and embeds it into circular products that can prolong the storage benefit.

Designing the LULUCF regulation right

The LULUCF regulation is one of the pieces of legislation of the “Fit for Fifty-five” package that has the potential to enhance the potential benefits for climate by:
  • Promoting the increased production of biomass notably through afforestation and reforestation, which, thanks to photosynthesis, will remove carbon from the atmosphere and at the same time, provide and increased amount of biomass.
  • Recognising the prolonged storage of carbon into bio-based products, beyond harvested wood products, that often can be further recycled, hence making this storage even longer.
Nature and biodiversity conservation and protection can beside-benefits of the LULUCF Regulation.

Don't subvert the Regulation and its objectives

In its current report on the draft LULUCF Regulation, the Committee for Environment of the European Parliament is shifting the focus of the legislation from its primary climate mitigation objective towards a biodiversity protection one.
This will put at risk the chances for the bioeconomy to develop in Europe and to contribute to a more sustainable economy.
As an example, active management practices have enabled the forests to increase substantially the amount of carbon stored in Europe and the volume is still increasing.  A too strong focus on forest conservation might reverse this trend and reduce the stored carbon in the forests and even release large parts of the currently stored carbon.   In addition, products from forests are used in a range of applications. where they replace products with substantially higher GHG footprints and this should be further encouraged.   
We, the biomass-derived chemical industry, therefore ask the European Parliament and its members to re-establish the long-term climate benefit as the prime objective of the Regulation and, therefore, to:
  • Limit the removal objective of the regulation to feasible values without disincentivizing the harvesting and marketing of biomass.
  • Recognise that, thanks to research and innovation, new bio-based products can offer a prolonged storage benefit the same way harvested wood products already do, and therefore allow for extending the list of such products as provided for in the Article 9 proposal by the Commission.
  • Avoid using the LULUCF Regulation to achieve biodiversity conservation objectives which shall be more suitably pursued through dedicated biodiversity policies.