EuropaBio supports the Commission’s intent in developing sustainable financing as part of the Green Deal and welcomes the opportunity to provide feedback on the draft Taxonomy Delegated Act for environmental objectives.

The bioeconomy can play a significant role in contributing to the environmental objectives outlined in the draft Delegated Act and in particular the transition to a circular economy. Use of bio-based products can help accelerate the shift towards a sustainable circular bioeconomy, creating jobs and growth, and reducing dependence on fossil-based carbon and CO2 emissions.

EuropaBio fully supports the sustainable sourcing of biomass, taking food security, land use and biodiversity loss into account. Biomass is a valuable resource, and many parameters need to be considered when assessing its use. In many cases, food and non-food uses of biomass are complementary. Efficient use of resources should be promoted.

However, only including bio-waste and excluding the use of other renewable feedstock like primary biomass is unfounded. To tackle climate change, it is critical that we decrease using fossil resources, and therefore embrace renewable carbon from all types of sustainably sourced feedstock as alternatives. On this basis, EuropaBio would urge the Commission to take a more inclusive view of feedstocks eligible for sustainable financing mechanisms under this criterion, by for instance focusing on sustainable sourcing, rather than simply limiting feedstocks. This approach would promote the future innovation and investment in the bioeconomy and in doing so assist in the gradual further transition towards alternative feedstocks away from fossil.

Enzymes are key enablers of the bioeconomy: they are bio-manufactured proteins that offer bio-based solutions and bring a broad range of sustainability benefits. They are used in small amounts, reduce energy consumption, are biodegradable and can replace chemicals harmful to humans and the environment. Enzymes can accelerate the degradation of biodegradable and compostable plastics. Therefore, exclusion of enzymes from use in plastic feedstocks would hinder enzyme-based innovation in plastics without bringing significant environmental benefits.

Read our comments here: https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/13237-Sustainable-investment-EU-environmental-taxonomy/F3411694_en