Three main asks: 

• Establish a robust EU biomass hierarchy to ensure limited bioresources are directed to the highest climate value  and societal uses. 

• Unlock secondary raw materials by removing barriers in waste classification and enabling nutrient recovery from bio-waste streams. 

• Scale up sustainable alternatives to feed, including marine resources, with stronger and more targeted action. 

Quotes: 

«Europe’s biological resources are limited, and the new Bioeconomy Strategy makes it clear: we need to use them wisely! A biomass hierarchy is thus needed to ensure they are directed to the highest value uses that deliver the most climate / benefits. With rising pressure on land and forests, clear prioritisation is key to safeguard ecosystems and protect our land sinks.»

Context: Bellona welcomes the direction set out in the EU Bioeconomy Strategy 2025, particularly its emphasis on using Europe’s biological resources where they deliver the greatest environmental, societal and economic value. Nevertheless, greater ambition is required: the Commission must establish a biomass hierarchy, including waste and residues, rooted in the cascading principle. Such a hierarchy is essential to guide decisions when multiple sectors compete for the same bioresources and to ensure they are allocated to the highest-value applications, prioritising food, feed, and materials over energy. While the Strategy mentions “efficient use of biomass”, Bellona stresses this must explicitly translate into a politically supported value hierarchy to manage resource scarcity effectively. Efficiency for bioeconomy should be understood holistically, encompassing energy efficiency, carbon efficiency, as well as climate, societal and biodiversity impacts. 

The Strategy recognises the role of biofuels and bioenergy in the EU energy transition, particularly where residues and secondary biomass are used. However, Bellona reiterates that without proper prioritisation, biomass may be diverted to low-value energy uses at the expense of higher-value applications, particularly food-grade materials, feed, and bio-based products. Clear guidance is critical to avoid undermining resource efficiency, climate goals, and ecosystem resilience. 

The Strategy also acknowledges the challenges in the land- and forest-based bioeconomy, which remains Europe’s largest biomass source and carries significant climate and biodiversity implications. Strengthening sustainability safeguards, improving land-use efficiency, and ensuring that forest biomass contributes to both biodiversity protection and emission reduction, in line with LULUCF and planetary boundaries, must remain central to implementation. Sustainability, additionality and quantification criteria in the upcoming delegated act on Carbon Farming within the Carbon Removal and Carbon Farming Certification Framework (CRCF) will need to be scientifically robust and transparent to certify removals and feed into the Bioeconomy Strategy. 

On new sources of biomass, the Strategy highlights the blue bioeconomy as an opportunity to provide sustainable alternative feed ingredients, including valorisation of fisheries and aquaculture side-streams, as well as the development of algae-based value chains. Bellona stresses that targeted measures and investments are needed to scale these solutions. With 38% of biomass in Europe already used for animal feed (2022) and demand rising, diversifying sustainable feed ingredients is essential to reduce land pressure, strengthen resource security, and lower emissions. Climate-aligned alternatives such as low-trophic aquaculture and other marine biomass pathways must be prioritised.  

The Strategy’s links to the Common Agricultural Policy, regenerative practices, and emerging Nature Credits demonstrate the growing role of land managers in the bioeconomy. While Bellona supports measures that reward nature-positive outcomes, robust safeguards are essential to ensure nature credits do not become instruments for offsetting or greenwashing, but instead genuinely support environmental integrity. 

Finally, Bellona welcomes the initiative to strengthen lead markets for bio-based technologies and construction products, while cautioning that bioresources must not be treated as mere commodities. Public oversight is essential to ensure that climate and biodiversity objectives are met and that materials are prioritised for high-value, sustainable uses. In this context, Bellona supports the Commission’s intention to lower embodied carbon through increased use of bio-based products and to develop a robust methodology for certifying long-lasting biogenic carbon storage in buildings under the CRCF.  

Bellona also welcomes the plan to improve green public procurement requirements and create lead markets for bio-based materials and clean strategic technologies through the revision of EU public procurement legislation. However, several considerations must be taken into account: 

• Under the CRCF, the scope of the certified products should be limited to load bearing structural elements, which can be reliably monitored (e.g., via satellite), and remain complementary to whole life-carbon assessments, as highlighted in Bellona’s consultation response.

• The current green public procurement framework is weak, as environmental criteria set out under the Construction Product Regulation applies in less than half public procurement processes, The revision of the EU public procurement legislation must make environmental considerations mandatory, and set a high level of ambition to truly foster lead markets for bio-based materials. 

• Press Release (pdf)