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Renewable Energy Directive (RED): towards a greener future or natural catastrophe?

The start of 2021 looks promising in terms of sustainability and global efforts to tackle climate change. However, with one eye on the past, average global temperatures have dramatically arisen, ranking the past decade (2010-2020) as “the warmest decade on record”.[1] If Covid-19 was perceived as the sorrowful trademark of last year, another non-vaccinable global threat haunted 2020: global warming. The past year was the warmest year on record for Europe. The leading cause of such an upsurge in temperature is the rise of human-made greenhouse gas emissions, which, compared to the industrial time of the late 19th century, arose of almost 1°C. If this temperature does not sound too alarming, bear in mind that scientists point an increase of 2°C will lead to catastrophic and unchangeable consequences for climate and humanity as a whole.

The EU is among the biggest gas emitters, third after China and the U.S., and its response, positive or negative that is, is a game-changer for tackling climate change at the global level. A first action was endorsed in 2008 when the EU briefed the target to cut greenhouse gas emissions by 20% compared to 1990 by 2020. As of 2015, the EU, in line with the Paris Agreement, met such goal, and recently extended it to at least 55% by 2030 as well as achieving carbon-neutrality by 2050.[2] These objectives are part of a new European-led global plan called the Green New Deal, which aims at driving the world toward a green transition through several sustainable measures, placing the EU ahead of the next UN Climate Conference (COP26).

In a nutshell, the Green New Deal is a framework of legislations and regulations that aims to render the European Union the first carbon-neutral continent by 2050, or, in the eco-terrestrial words of the European Commission president Ursula von der Leyen, “Europe’s man on the moon moment”.[3] This new executive framework aims to protect human life, animals and plants while helping companies become role-players in clean energy and technologies. As stated by Executive Vice-President of the European Commission Frans Timmermans, the EU proposes “a green and inclusive transition to help improve people’s well-being and secure a healthy planet for the generation to come.”[4]

In making this green transition possible, but first plausible, all the 27-Members of the block shall endorse this body of legislation through shared-responsibility and both top-down and bottom-up approaches. Indeed, due to a vast engagement by the European public sphere, concerns for climate change have recorded an upsurge at the institutional level, especially by the young generation. To put into numbers, 93% of Europeans see climate change as a severe problem as well as have taken at least one action to tackle climate change, while other data shows that a good 79% agree that taking action on climate change will lead to innovation.[5]

Europe’s past, present and future with energy

 In the run-up to reach climate neutrality by 2050, the EU will need multilateral action in various interdependent sectors such as energy, urban development, industry, and mobility. Looking at the energy sector, the production and use of this resource account for almost 75% of the EU’s greenhouse gas emissions. Therefore, we have to question how the European Union intends to significantly decarbonize this critical sector without worsening the world’s natural resources. [6] A valuable option accounts for bioenergy, whose demand and consumption, according to several studies, has doubled from 2005 to 2020, and it is expected to grow by 2030 steadily. However, the increasing need for carbon-neutral resources has the side effect of raising pressure and competition over wood resources and land to grow crops.[7]

Drawing deeper attention to the figures, as shown in the graph below, the EU 27 have witnessed a linear increase in wooded land of more than 22 million ha in the past 20 years only, indicating that the forest industry has become a prime contributor to biomass for heat. The energy-driven bioenergy market from forests, stems, sawdust, and biowaste is not expected to grow significantly in the next 10 years. In contrast, the timber industry residues are certain to grow by almost 30%.[8]


(Bioenergy consumption outlook to 2020. Source: European Commission, 2014 in EUBioenergy)

Hence, if last year biomass accounted for 60% of EU’s renewable source, studies have already outlined that the demand for woody biomass, combined with the need for paper and pulp, will outrun EU’s sustainable supply.[10] Along with this, Europe lacks sustainable land to grow new crops for energy, thus opening the market and producing biomass to foreign countries. Despite having the potential to strengthen the economic relations with a few of the most potent world-players, a growth in bioenergy use “without setting necessary safeguards comes with serious risk of socio-environmental impacts.”[11]

The Renewable Energy Directive (RED): carbon-free or playing with fire?

To stay on track with the commitment of reducing greenhouse emissions by 45 % and eventually reaching carbon neutrality by 2050, the Commission, in 2008, kicked-off a new plan of action called Renewable Energy Directive (RED) [Directive 2009/88/EC of the European Parliament and of the Council of 23 April 2009 on the promotion of the use of energy from renewable sources – OJEU L 140, 5.6.2009], amended and entered into force in 2018 with RED II [Directive(EU) 2018/2001 of the European Parliament and of the Council of 11 December 2018 on the promotion of the use of energy from renewable sources (recast) – OJEU L 328, 21.12.2018], and currently facing public consultation.[12] The latter, carried out by the executive in joint action with Parliament and European Council, has set out a list of new legal obligations on using and producing renewable resources. This action will put the EU one step closer to achieve the Green New Deal successfully. Indeed, this new green policy set a new binding renewable target for the EU of 32% by 2030, which could be increased according to future preliminary data by 2023. As highlighted by Smeets and Faaji in their assessment of the bioenergy potentials from forestry in 2050, using woody-biomass as the primary source for renewable energy stands out as an economically appealing solution.[13] However, the two authors remark how these advantages do not consider the socio-ecological consequences, such as increasing deforestation, that Europe will witness by enforcing this directive.[14] In short, although RED II could make the EU become the global beacon of sustainable governance, are we sure that all that glitters is gold, or all that burns is green?

Among the various obligations enlisted within the policy, RED II addresses liquid biofuels for transport and biomass for heating and cooling as sustainable energy sources. Below you can find the classifications of renewable sources, (forest) biomass, and forest regeneration that apply within the directive. These same definitions are the primary reason for environmentalists and scientists’ backlash against the potential environmental damages.

  • Article 2:

(1): ‘energy from renewable sources’ means energy from renew­ able non-fossil sources, namely wind, solar […], biomass, landfill gas, sewage treatment plant gas, and biogases.

(24): ‘biomass’ means the biodegradable fraction of products, waste, and residues from biological origin from agricultural, […], forestry, and related industries   […].

(26): ‘forest biomass’ means biomass produced from forestry.

(31): ‘forest regeneration’ means the re-establishment of a forest stand by natural or artificial means following the removal of the previous stand by felling or as a result of natural causes […].[15]

In order to stimulate the 27 Members of the bloc and their international allies to comply with such a directive, the Commission offers excellent incentives to the use of biomass in the production of bioenergy and biofuel. Although, as stated in Article 29 of the directive, there are indeed some criteria on where and how biomass should be produced, these are just restricted to the native people’s land and endangered biosphere.[16] Hence, by leaving the description of such conditions relatively broad, many internal and external forest-related businesses will likely see converting entire forests into bioenergy as a legitimate and sustainable action.

This first problem, according to Doctor Moomey, co-author of the Nobel Peace Prize-winning Intergovernmental Panel on Climate Change report, “comes from the industry-promoted idea that biomass simply makes use of wood that would have decayed anyway.”[17] Moreover, this assumption made by the EU refers to the agreed terms of the 2009 Kyoto Protocol in which “the owner, not the end-user of wood products, is supposed to account for the carbon lost when a forest is cleared.[18] In this regard, the UN claims that CO2 will eventually be absorbed by forest regrowth which, acting as a carbon sink, makes this process carbon neutral.[19] Nevertheless, avoiding double-counting by just recording the landowner’s emission (wood’s exporter) relies on the wrongful idea that burning a tree is carbon-free. As voiced by the majority of climate scientists and the same Commission’s scientific committee, burning woody-biomass does, however, release greenhouse gas and, as a consequence of deforestation, it has the side-effect of reducing the carbon sink to store CO2. According to Dixon (1994), almost half of “the total terrestrial carbon stock is stored in forests and forest soils.”[20] In simple terms, burning biomass now means emitting more carbon in the atmosphere than what forests can capture; ergo, the planet is heating up, not cooling down. Although planting new trees, as brought forward by several wood-related corporates, has the potential of reabsorbing the carbon-debt in the long run, scientific evidence shows that growing forest secures far less CO2 than one left unharvested.[21]

“Ironically, if a country burns coal, it counts in its emission tally, but if it burns imported wood biomass it doesn’t, even though wood [..] emits more C02 per unite of energy produced”. [22]

Secondly, but no less importantly, claiming that newborn forests would eventually pay off the carbon-debt gained is based on a dangerous miscalibration of time. Michael Norton, a researcher at the European Academy of Sciences, along with other scientists, agree with OECD that the measures taken within the next decade will have massive effects on our planet.[23] Therefore, as argued by Moomay, time is a crucial factor, and “the only question that matters is how long does that take, and how much more carbon could be absorbed if trees were allowed to keep growing instead of being harvested and burned”.[24]

Thirdly, another key issue related to both points mentioned above is the deforestation threat emerging from biomass supply-chains. On the one hand, despite setting out the (un)sustainable clauses to conduct such business, RED II offers to forest-owners incentives in the name of producing sustainable energy. Subsidizing the private sector for pursuing a green transition seems technically the right move as it allows big and small businesses to join the green race without facing substantial economic losses. However, as the demand for biomass has been on the rise in the past years and will likely outrun the European supply capacity, the EU has been forced to open the market to foreign countries. The latter will increase the global rate of deforestation, thus of carbon emission, and undermine the few lawful sustainable criteria agreed on with Kyoto Agreement, namely transparency and accountability. As a matter of fact, data shows how large quantity of wood imported in the UK and Denmark, the biggest European consumers of pellets for bioenergy, comes from North America and U.S.[25] Although President Joe Biden recently re-entered the new green agenda, the latter was not part of the Kyoto Agreement. Hence, the country “was not bound to keep track of emission from forest loss”, thus casting many doubts on the degree of sustainable practices taken in the production and supply of biomass.[26]


All in all, despite containing several deceptive loopholes, RED enables both big and small forest-related businesses to invest in sustainable resources and thus actively taking part in the global green transition. However, offering incentives to the private and public sectors will likely shift a fair share of investors from more sustainable renewables, such as solar panels or wind turbines, into pellet production. Moreover, by selling the idea that woody-biomass is a carbon-free solution for producing bioenergy, the EU runs the risk to endorse a policy that is even more polluting than fossil fuels. Finally, as shown above, the impact of RED II will have damaging effects upon the world’s forests as more and more internal and external suppliers will compete to meet the rising request for wood as a source of bioenergy. In other words, it seems that what the EU has designed as a winning-green-strategy is, as conceived now, environmentally disruptive.

Greenlash and the future of RED II

RED II raised many concerns at the civil level since its provisions pose an environmental threat to the world’s forests. In this regard, several NGOs, such as the World Wildlife Fund (WWF), Fern, Friends of the Irish Environment, 2C, to mention a few, from France, Slovakia, Ireland, Romania, and Estonia, joined a plaintiff to charge the EU for damages against the environment. According to Dr. Mary S, Booth, director of the Partnership for Policy Integrity and head of the advisory committee of the case, “the EU’s policy relies on the false and reckless assumption that burning forest wood is carbon neutral”.[28] According to one of the NGO plaintiffs, the legal basis for such a lawsuit claims that the EU’s policy “has failed to comply with nearly all of the principles for environmental policy that are laid out in the Treaty of the Functioning of the EU”.[29] What comes hard to believe is how the EU expects to reach the set goal of carbon neutrality if it keeps negotiating for policies that are not rightly addressing climate change or taxing the polluters. In the midst of a climate emergency, the EU is treating forests, the only organic carbon sink the planet has, as fuel.[30]

Backing this legal action there was the majority of the environmental scientist community as well as conservationists and members of civil society that couldn’t stand this ecological injustice and the alarming harm it will cause to the planet. Precisely, a group of 16 worldwide acknowledged scientists and professors, along with the 796 signatures of academics, signed a letter to plead the EU Parliament to recognize the unsettling harm that RED poses to the world’s forests and the acceleration of climate change. As stated in the letter’s introduction, the directive gives considerable space to countries, power plants and factories to claim credit toward renewable energy targets by cutting down entire forests and burn them for bioenergy.[31]

Despite the strong campaign carried out by these environmentalists to raise awareness and support for the lawsuit, on 14 January 2021, the European Court of Justice (ECJ) delivered a final negative judgment. The legislative body argued that the applicants did not have a standing legal basis to bring the complaint.[32] However, although the lawsuit was discarded, environmental scientists and activists, as shown below, released a list of recommendations to urge the Commission to amend RED II as fast as possible to avoid catastrophic damages.

The recommendations go as follow:

  • Matching the use of biomass for power and heating to a sustainable supply level from domestic sources so to reduce the damaging effects that EU biomass is having on global forests and land.
  • The new amended policy should follow the principle of ‘cascading use’: ensuring that biomass’ energy content comes from end-of-life products respecting the waste cycle (reduceàre-useàre-cyclingàrecovering energy).
  • Improving the EU sustainability criteria to ensure that biomass derives from biowaste gathered locally and demanding real carbon savings based on a sound methodology to measure carbon emissions.
  • Lastly, making biomass use following comprehensive environmental and social sustainability criteria. [33]

The concern raised by a community of scientists and backed up by almost all environmental movements has enormous consequences for both the implementation and legitimacy of the EU Green Deal, but most importantly of the world’s forests and environment. Recalling the words of Commission President Von der Leyen, if the upcoming green transition is Europe’s ‘man’s on the moon moment’, the EU has to make sure that the way to get up there is entirely green and sustainable.

[1] European Parliament, <<EU Responses to Climate Change>>, 07 July 2020

[2] Ibid.

[3] Fiona Harvey and Jennifer Rankin, <<what is the European Green New Deal and will it really cost €1tn?, theGuardian, 9 March 2020.

[4] European Commission, <<what is the European Green Deal, December 2019>>,

[5] Ibid.

[6] European Commission <<renewable energy directive>>, 2 February 2021,

[7] Fern, <<EU Bioenergy>>,

[8] Niclas Scott Bensten et al., <<Biomass for energy in the European Union- a review of bioenergy assessments>> 30 April 2012,

[9] European Commission, <<Bioenergy consumption outlook to 2020>>, in EU Bioenergy, 2014,

[10] Ibid.

[11] Brachet Isabel et al., <<Pitfalls and potentials: the role of bioenergy in the EU Climate and Energy Policy post 2020>>,

[12] Ibid.

[13] Edward M. W. Smeets & André P. C. Faaij <<Bioenergy potentials from forestry in 2050>>, April 2007, p.353.

[14] Ibid, p. 358.

[15] RED II DIRECTIVE (EU) 2018/2001, 11 December 2018,

[16] Ibid.

[17] Saul Elbein, <<Europe’s renewable policy is built on American trees>>, 2019,

[18] Ibid.

[19] Angeli Mehta, <<EU urged to stop substituting biomass for coal as concerns over climate impact grow>>, 3 February 2020, Reuters events: sustainable business,

[20] Dixon RK, Brown S, Houghton RA, Solomon AM, Trexler MC, Wisniewski J (1994),<<Carbon pools and flux of global forest ecosystems>>. Science 1994, 263(5144):185–190

[21] Timothy D. Searchinger et al., <<Europe’s renewable energy directive poised to harm global forests>>, 2018, Nature Communications,

[22] Ibid.

[23] Ibid.

[24] Ibid.

[25] Euractive, <<EU must not burn the world’s forests for ‘renewable’ energy>>, 14 December 2017,

[26] Ibid.

[27] Ibid

[28] Fern 25, <<Lawsuit seeks to remove forest biomass from the EU’s renewable energy directive>>, 4 March 2019,

[29] Ibid.

[30] Ibid


[32] Mary S. Booth et al., <<EU refuses to hear international complaints against forest-destroying renewable energy policies>>, January 28 2021, EU Biomass Legal Case,

[33] Duncan Brack, <<Burning Matter. Making Bioenergy work for people and forests>>, March 2015, Fern,

Léon De Tombeur

Diplômé en Histoire à la Sorbonne et en Relations Internationales à Lyon III, je me suis notamment intéressé à la politique internationale de l’Union européenne. Animé par un désir de contribuer à l’Europe afin de la rendre plus sociale et respectueuse de l’environnement, je me suis rendu à Bruxelles afin de travailler de concert avec les institutions européennes. Ma spécialisation tend davantage vers le domaine de la défense et de la sécurité, j’ai réalisé mon mémoire de fin d’études sur le futur de la défense anti-missile du continent européen. C’est pourquoi j’ai choisi le portefeuille de la coopération judiciaire et policière.

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