EU Directive 2023/2413 (RED III): New “No-Go Areas” for Biomass — Opportunities and Implications

1. Why RED III Matters — A Positive Step for Europe’s Energy Transition

The EU Renewable Energy Directive (RED III) — officially Directive (EU) 2023/2413 — is the cornerstone of Europe’s climate and energy policy to 2030 and beyond.
It raises the binding EU-wide renewables target to at least 42.5 % by 2030 (with an aspirational 45 %) and tightens sector-specific rules for transport, heating and industry.

At its core, RED III is a signal of confidence and clarity for investors and governments alike — linking renewable expansion to system efficiency, climate integrity and sustainability. It builds a stronger foundation for energy security in a rapidly electrifying Europe.

Key system-wide advantages:

• Accelerated decarbonisation: Higher targets drive renewables deployment across all sectors.
• Efficiency first: Support is tied to GHG performance and sustainability criteria — rewarding best-in-class technologies.
• Transport clarity: The directive introduces a 29 % renewable share or 14.5 % GHG intensity reduction target in transport, with caps for food-based biofuels and sub-targets for advanced biofuels.
• Stronger traceability: Mandatory certification and chain-of-custody reporting increase transparency and public trust.

Sources: European Commission (energy.ec.europa.eu), EUR-Lex, IEA Bioenergy 2024 Country Report.

2. Biomass under RED III — From “More” to “Better”

RED III fundamentally reshapes the EU’s biomass policy. It moves from volume-based growth to a quality-driven governance model that prioritises efficiency, carbon savings and forest integrity over pure expansion.

2.1 New “No-Go Areas” and Forest Criteria

• No support for biomass harvested from primary or old-growth forests, high-biodiversity woodlands, grasslands, wetlands or peatlands.
• Mandatory forest-management criteria include soil protection, regeneration capacity and biodiversity safeguards.
• Operators must demonstrate due diligence and documented sourcing compliance via audited sustainability systems.

2.2 Efficiency and Eligible Applications

• Electricity-only biomass plants (no combined heat) lose subsidy eligibility.
• Priority shifts to CHP plants, district heating, and BECCS-ready installations that maximise GHG savings per tonne of biomass.

2.3 Emission Thresholds and Scope

• Sustainability and GHG criteria are mandatory for plants ≥ 20 MW thermal input (solid biomass) and ≥ 2 MW (energy gases). Member States may apply stricter limits.

2.4 Certification and Verification

• Chain-of-custody auditing becomes stricter and continuous.
• Schemes such as the Sustainable Biomass Program (SBP) and ISCC EU RED have issued bridging documents for full RED III alignment. This ensures existing certified operators can prove compliance without double auditing.

3. Policy Perspective — Why This Strengthens Biomass

When properly implemented, RED III anchors biomass as a strategic pillar of Europe’s net-zero toolkit.
It keeps biomass in the mix as a dispatchable, storable, and carbon-neutral energy source — particularly for district heating, industrial heat and negative emissions via BECCS.

The Directive effectively filters out controversial feedstocks while protecting the core of the industry: residues, by-products and sustainably managed forests.

4. Advantages and Challenges for the Biomass Sector

Advantages (when compliant and pro-sustainability)

• Higher legitimacy and investment security: EU-wide rules restore confidence among policymakers and financiers.
• Clear focus on “good feedstocks”: Residues, thinnings and processing by-products gain policy support.
• System efficiency: CHP and BECCS integration deliver real, verifiable GHG reductions.
• Transparency: Enhanced certification reduces greenwashing and creates traceable supply chains.
• Grid support: Biomass remains a flexible balancing resource for variable wind and solar generation.

Challenges and Potential Drawbacks

• Narrower feedstock base: Exclusion of no-go areas and primary forests can tighten supply and raise costs.
• Administrative load: Smaller operators face higher audit and reporting burdens.
• Legacy assets: Electricity-only plants may lose support without retrofitting to CHP or BECCS.
• Global compliance risks: Import-dependent chains must maintain robust third-party verification to avoid reputational issues.

5. Strategic Recommendations (for pro-biomass actors)

1. Optimise feedstock portfolio: Prioritise residues and low-risk forestry inputs with full regeneration evidence.
2. Enhance efficiency and BECCS readiness: Integrate heat recovery and plan for future CO₂ capture capability.
3. Go early on certification: Adopt RED III-compatible standards (SBP EU RED, ISCC EU) to secure market access.
4. Diversify inputs: Increase use of agricultural residues and organic waste streams to improve resilience.
5. Communicate transparently: Publish feedstock origins, GHG savings and biodiversity data to build public trust.

6. Conclusion

RED III does not downgrade biomass — it upgrades its credibility.
By setting clear sustainability boundaries and rewarding high-efficiency uses, the Directive paves the way for a stronger, more trusted biomass sector.

Biomass remains essential — as dispatchable renewable power, as low-carbon heat, as industrial feedstock and, in the future, as a carrier of negative emissions.
RED III marks a maturity phase for bioenergy policy: less about growth volumes, more about sustainable impact.

7. References & Further Reading

• Directive (EU) 2023/2413 (RED III) — full text and recitals: EUR-Lex
• European Commission — Biomass & Bioenergy policy overview: energy.ec.europa.eu
• IEA Bioenergy (2024 EU Country Report) — Implementation trends and market impacts
• HFW Legal Briefing (2024) — “How Is Forest Biomass Affected by RED III?”
• Sustainable Biomass Program (SBP) — EU RED bridging documentation
• Control Union Insight (2025) — RED III impact on biomass certification