Swift Implementation of EU Biotech and Biomanufacturing Initiative is Key to Strengthen EU Competitiveness and Accelerate Defossilization

Ensure Alignment with EU Circular Economy and Industrial Sustainable Carbon Initiatives to Promote All Sources of Renewable Carbon

More than 90% of chemical production remains based on fossil carbon sources from the ground. The Commission recognizes that all alternative renewable carbon feedstocks (sustainable carbon from biomass, recycled waste and carbon capture and utilization, (CCU)) ¹ will play a part to make the transition away from fossil feedstocks.

This underlines the need to ensure consistency with other EU initiatives aimed at promoting the transition to renewable carbon sources, such as the Circular Economy Action Plan, the Sustainable Carbon Cycles Initiative, and the Industrial Sustainable Carbon Management Strategy. Alignment is critical on a number of aspects, for example, in what is considered “sustainable carbon” across different feedstock sources (biomass, CCU, recycling, etc.). The recent call on a policy package on sustainable carbon cycles by the Netherlands, France, the Czech Republic, and Ireland also underlines the need to overcome barriers between sectors and create a consistent and comprehensive framework.

Accelerate Action to Stimulate Market Demand for Bio-Based and Other Renewable Carbon Feedstocks

The main barrier to increase the use of bio-based feedstocks—as well as other renewable carbon feedstocks—is the lack of market demand. Weak demand is explained by fossil feedstocks remaining cheaper, as their price does not reflect the costs coming from their negative climate externalities. It will not be possible to transition away from fossil feedstock in the EU without addressing this market failure through policies.

Stimulating market demand is the precondition for the EU to develop a thriving and globally leading renewable feedstock manufacturing industry. It needs to be one of the cornerstones of the EU’s industrial policy moving forward, in line with the calls made by Industry in the Antwerp Declaration and by Mr. Enrico Letta in his report on the Future of the Single Market.

An accelerated impact assessment on options to stimulate demand for renewable carbon feedstocks, not only bio-based, should be the main priority in the follow-up to the initiative. RCI will support the follow-up through evidence and dialogue; among others through a comprehensive project that identifies and analyses policy measures and their effectiveness with regard to accelerating the shift to renewable carbon. Already now it is clear that there is a need for a secure legal framework to unlock investments—may it be through renewable carbon content targets in product-related legislation or others.

Ensure a Clear Pathway for the Transition of Fossil Manufacturing to Manufacturing Based on Renewable Carbon Feedstocks

The long-term aim for the EU should be to fully defossilize its carbon-based chemical and material industries. Chemical factories using fossil feedstocks today can be repurposed to use bio-based and other renewable carbon feedstocks in the future. This supports the objective of a just transition of the EU’s industry.

The Initiative identifies some of the key priorities to create a clear pathway for this transition, such as the need to review the life cycle assessment of fossil-based and bio-based products to ensure equivalence of treatment. This needs to consider all aspects from feedstock to end of life.

The definition of fair sustainability criteria, in line with the Renewable Energy Directive [(EU) 2018/2001] and the EU Taxonomy, as well as access to all kinds of sustainable biomass feedstock is also of utmost importance to support the timely transition of the chemical industry to renewable carbon feedstocks. The bioeconomy can only reach scale if all bioresources, such as biowaste, lignocellulosic co-products, wood, and food and feed crops, are used. Food and feed crops have high land efficiency and protein-rich co-products. To increase overall feedstock efficiency, it will also be crucial to implement the cascading principle, which is already enshrined in Article 3 of the Renewable Energy Directive. An effective implementation would have to give clear preference of renewable carbon use to those sectors and industries that keep it in the loop the longest—which is chemicals and materials.

However, the current definition of biomanufacturing in the Initiative is too narrow, as it does not explicitly include all physical, chemical, and thermochemical processes that can be run on biomass (or other renewable feedstocks)—even though those processes are included later on in the communication implicitly, for example, through the mentioning of wood products and other non-biotech applications. The other processes make up for the—by far—largest share of biomass uses today and possess a strong innovation potential as well. This should be further reviewed and refined in any future action to ensure that the EU leverages all possible biomanufacturing pathways to transition away from fossil feedstocks.

The RCI is a global network of more than 60 prominent companies dedicated to supporting and accelerating the transition from fossil carbon to renewable carbon for all organic chemicals and materials. The overall mission of the RCI is to fully replace fossil carbon with renewable carbon sources, including biomass, CO₂, and recycling. RCI is led and supported by a wide range of different stakeholders in the chemicals and materials industry. These include brands, major suppliers, large manufacturers, small and midsize enterprises (SMEs), start-ups, and research institutes. RCI has established a unique approach supported by a broad alliance of stakeholders from different sectors. Website: www.renewable-carbon-initiative.com