Entry into force of RED III

On May 21, 2025, RED III entered into force in all EU member states. This means that the new RED III requirements now apply in recognized EU certification systems.

Unfortunately, SURE only received the necessary confirmation from the EU Commission for RED III recognition on May 20, 2025, so the revised system documents can only be published now. A translation of the documents and forms, currently only available in English, into German is in progress and will also be published in the coming days. We have compiled an overview of the significant (but not all) changes for you below. Please note that this is not a complete overview of the changes and does not release system participants from their obligation to carefully familiarize themselves with the amended requirements and implement them if necessary.

For whom are the changes?

In principle: Existing and valid RED II certificates remain valid, but economic operators are also required to implement the new RED III requirements. This will be verified during the subsequent recertification audit or, if necessary, through surveillance audits conducted by the certification bodies. A significant tightening of requirements resulting from the entry into force of RED III now also applies to the demonstration of a greenhouse gas reduction of 70/80% for so-called existing plants (biomass and biogas plants that first started operating before 2021). The demonstration requirement depends on the type of biomass plant, its capacity, and the years of operation. It is important to note that for the demonstration of GHG reduction, all economic operators in the supply chain must provide information on the respective GHG emissions of their activities, e.g., by stating "use default value" (if applicable) or by determining their own emission values. SURE recommends that affected economic operators inform themselves early on about their own obligations and the accounting methodology and, if necessary, obtain further information from industry associations, especially SURE's "National Supporting Bodies."

IMPORTANT: In the SURE system, only the GHG reduction targets specified by the member states in the implementation of RED III into national law apply. If the new RED III GHG reduction targets have not yet been transposed into national law, but the RED II regulations or laws are still in force, only these are legally required, and no corresponding RED III GHG reduction obligation arises in the SURE system. In the SURE system, the GHG reduction obligations as defined in national law always apply.

IMPORTANT: The same applies to the introduction of the RED III compliance requirement for biomass plants with an installed thermal capacity of 7.5 MW to 20 MW. SURE does not require economic operators to demonstrate compliance with the sustainability and GHG reduction requirements of RED III; this is done exclusively by the legislature through corresponding regulations or laws.

1) Forest Biomass

The biggest changes apply to producers of forest biomass. With the introduction of so-called "no-go areas," certain land types, such as old-growth forests and heathlands, and certain protected areas, are exempt from the production of forest biomass. Furthermore, producers of biomass fuels from forest biomass must provide a declaration of assurance that they have only processed forest biomass that meets the requirements of RED III according to Article 29 (6a). Provided that the new criteria (no-go areas and declaration of assurance) are also required by law and that this has been demonstrated through an updated risk assessment and assessed as low risk, producers of forest biomass may, for the first time, demonstrate compliance through a self-declaration or through a supplier audit of the primary gathering point. The primary gathering point then has a special responsibility to monitor and ensure the suppliers' compliance with RED III. This will be verified by SURE during the primary gathering point's audit. However, this is expressly only permitted if a valid and recognized RED III risk assessment with a "low risk" status is available.

The SURE group certification approach remains possible in any case. Previously issued self-declarations remain valid provided their risk status is confirmed by an updated risk assessment. In the event of an inspection, the additional criteria will be verified as part of a gap inspection. However, if the risk status of the risk assessment changes, or if no valid risk assessment with a "low-risk" result is available, a new self-declaration with "specified risk" status must be submitted to the primary gathering point no later than the next delivery of forest biomass. The self-declaration can be updated at a later date if a "low-risk" risk assessment is available in the meantime. Using the group certification approach with "low risk" status requires the submission of a valid and recognized risk assessment with a corresponding statement that evaluates the legal implementation and enforcement of the new RED III criteria (no-go areas and assurance statement). At this time, no valid risk assessment is available; only a draft risk assessment for Austria has been submitted to SURE for comment and approval. Please note that SURE does not conduct the risk assessments; this is the responsibility of the respective associations, national bodies, or other institutions in the respective forest biomass extraction areas.

2)

For producers of agricultural biomass, the exclusion of certain land types for biomass production is expanded, e.g., on heathland. Furthermore, measures to increase soil carbon content must demonstrate that the biodiversity of the area is not affected. Self-declarations issued in the group certification of agricultural producers remain valid. Proof of compliance with the new RED III requirements (no-go areas and biodiversity conservation in esca measures) will be verified as a gap inspection in the event of an inspection.

3)

There are no new requirements for the verification of the supply chain of biomass fuels from waste and residues. Existing self-declarations remain valid. For a detailed description of the changes, please refer to the revision history of the respective system documents.

Please review any necessary action for you and contact the industry associations or National Supporting Bodies if you have any questions. Please understand that SURE does not offer consulting services and is only available to a limited extent due to the high demand for information.