Summary
This paper sets out why product-level biomass-derived content targets are needed to accelerate the EU bioeconomy and how such targets can be designed and implemented quickly to unlock investment, build lead markets, and support a stronger bioeconomy. EU product-level biomass-derived content targets (covering both bio-based and bio-attributed products) must be desgined to be effective and implemented quickly via the Ecodesign for Sustainable Products Regulation (ESPR) through a dedicated delegated act, complemented where needed by the Biotech Act II that could cover gaps and target legislation already foreseeing possible bio-targets (e.g., ELVR, PPWR).
Key takeaways:
- Adopt product-level biomass-derived content targets to create demand certainty and unlock investment.
- Keep biomass-derived content targets separate from recycled content/captured carbon targets (complementary, not competing).
- Count the contribution of both bio-based and bio-attributed products to meet biomass-derived content targets.
- Set biomass-derived content targets by product or product group, adjusting both the level and requirements to align with the specificities, feasibility, and practical considerations of the selected product/product group.
- Implement incentives such as EPR-Eco modulation and VAT reductions, and consider other dedicated measures to support emerging value chains facing technological and financial challenges. This would help scale innovative biomass-derived materials, especially bio-based ones, and should be aligned with the overall objective of improving the efficiency of waste management and maximising recycling.
- Provide for responsibility at brand-owner level, with a consistent approach across sectors, while recognising the need for a level playing field and a well-functioning value chain. While obligations would sit with brand owners, success depends on a functioning, fit-for-purpose value chain that can supply the required ingredients and raw materials for final products. To this end, safeguards and flexibilities should be introduced.
- Set a predictable ramp-up with milestones and review. A clear, realistic trajectory with short- and long-term targets, including intermediate steps, avoids stop-start market effects and supports timely capacity build-out. It also enables predictable regulation and better market behavior than frequent legislative reviews.
- Add sustainability safeguards for biomass sourcing used in products benefiting from policy incentives, according to RED III Art. 29(2–7).
- Leverage existing product-specific legislation and ESPR and use Biotech Act II to enable targeted amendments introducing clearer definitions, fill gaps with existing product policies, and ultimately yield a coherent policy framework.