Probos Foundation requests comments on draft report ‘Level A Assessment’ of Forest Biomass
2025-11-03
The Probos Foundation has conducted a comparison between European sustainability requirements for forest biomass and Dutch legislation and regulations for timber harvesting. The results of this so-called ‘Level A Assessment’ are documented in a draft report. Stakeholders are invited to submit their comments on the findings in this report.
Background: European requirements for sustainable forest biomass
The European Renewable Energy Directive (RED) sets sustainability requirements for biomass used for the production of electricity, heat, and biofuels. For forest biomass, the requirements are laid down in Article 29(6) (sustainable forest management) and Article 29(7) (maintenance of carbon stocks). Countries and companies must be able to demonstrate that they meet these requirements through a certification scheme approved by the European Commission.
There are two ways to demonstrate compliance:
- Level A (national level): When national legislation and regulations already provide sufficient safeguards and there is effective supervision and enforcement. In that case, market participants are not required to conduct an assessment for each individual forest area.
- Level B (regional or company level): When national legislation does not provide sufficient coverage, a market participant must demonstrate that the specific areas of origin of the biomass meet the RED requirements.
Level A assessment for the Netherlands
To use the Level A approach for Dutch forest biomass, an independent, expert party must first determine whether Dutch regulations meet the RED sustainability requirements. The Probos Foundation conducted this analysis for the sustainable forest management requirements in Article 29(6) of the RED. The clients are the Netherlands Enterprise Agency (RVO) and the Better Biomass certification scheme.
As part of its analysis, the Probos Foundation invites stakeholders to submit their views on the draft report. The responses received will be incorporated into the final report. After completion, the final Level A assessment will be published by Better Biomass and other recognized certification schemes, so that market participants can use it when certifying forest biomass under the RED.
The draft report (in Dutch) can be found here on the Probos website.
You can submit your comments from November 1st to November 30th, 2025, via mail@probos.nl.