In November 2023, the European Commission published the new version of the Renewable Energy Directive (RED III – Directive (EU) 2023/2413). This document introduced new technical references for the bioenergy market, directly impacting the sustainability certification process.
In response to the new guidelines, 2BS worked with its Technical Committee and market experts to implement the necessary updates to its documentation. Our aim remains to offer a simple certification process that complies with current European regulations. 2BS has submitted updated documentation to the European Commission.
Driven by RED III, we have proposed a revision of our 2BS Standards (2BS-STD-01 and 2BS-STD-02) and Procedures (2BS-PRO-01 to 2BS-PRO-06).
This documentation has been reviewed by the European Commission. We will inform you once we receive official recognition from the Commission, which will be formalized by an ad hoc publication in the Official Journal of the European Union.
Meanwhile, we are sharing below a relatively short and straightforward list of changes affecting the certification process for each operator category in our different supply chains.
Please note that the changes listed below will apply from May 21, 2025, to all operators subject to the requirements of the RED II Directive. Only the transposition of RED III into national law will impose obligations on new operators who were previously not subject to them.
Please note that existing 2BS certificates remain valid until their next surveillance audit: re-certification audits under RED III will take place on the usual anniversary date.
1. Certification Bodies’ responsibilities and audit implications
- Union Database (UDB): Once the platform is operational, auditors must verify the accuracy and completeness of data entered in the European Commission’s UDB or national databases (Revised RED EU/2018/2001 (RED III) – article 31a; 2BS PRO02 – section 9.1.10).
- For now, auditors must check that economic operators have an active private space in the UDB.
- More information on the UDB will be shared in the future.
2. Updates for First Gathering Points in the Biofuels and Bioliquids supply chain
- Land sustainability: “Old-growth forests” and “heathlands” have been included in the definition of non-sustainable plots. Specific definitions have also been added.
- For French operators using the 2BS Mapping Tool, these new categories have no impact as they were already included in the “non-sustainable” category. Operators outside of France will need to demonstrate land sustainability according to these new criteria.
- GHG Calculation – ECCR Factor (Carbon Capture and Replacement): GHG reductions related to carbon capture and storage (CCS) only apply to CO₂ from biomass that replaces fossil CO₂ in the production of goods and services, and only for products made before January 1, 2036.
3. Updates for Processing units in the Biofuels and Bioliquids supply chain
- GHG Savings Thresholds: Higher GHG saving thresholds are now required for biomass fuels used in facilities commissioned from 2023 onwards for the production of heat, cooling, and electricity. In some cases, producers must demonstrate higher savings. Refer to the chart below to determine the threshold applicable to your case.
Click on the photo to expand it or here to download it.
4. Updates for Biomethane producers
- Certification Criteria: Certification is now mandatory for new operators: facilities producing gaseous biomass fuels with an average biomethane output above 200 m³ methane equivalent/hour (adjusted if biogas is a mix of methane and other gases) must be certified under RED III. This applies after RED III is transposed into national law by each Member State.
5. Updates for Biomass Boiler installations
- Certification Criteria: Certification is now mandatory for new operators: solid biomass fuels used in facilities producing electricity, heating, or cooling with a total rated thermal input ≥ 7.5 MW must be certified under RED III. This applies after RED III is transposed into national law by each Member State.
6. Updates for Waste and Residues supply chain
- Definition of “Point of Origin”: The point of origin of municipal waste is now defined as the first collector (municipality or private company). This clarification may affect certification requirements.
- Reminder: GHG emissions include all transport steps from the point of origin to the final interface.
- Definition of Waste Treatment Processes at First Gathering Points: Better recognition of waste treatment processes such as sorting, sedimentation, filtration, shredding, grinding, hygienization, and unpacking – all considered GHG emission-free treatments. This broadens acceptable processes and may affect emission calculations.
- Clarification on Landfill Gas: Its point of origin is the non-hazardous waste landfill or the wastewater treatment plant.
The final validation of the updated documents is still pending from the European Commission. The current text is indicative and will be fully implemented according to the deadlines set. Once validated, our website will be updated.
You can find the updated documentation for each supply chain on our Documents page.
