In an interview with biochar zero, biomass experts Hendrik Bauer and Torben Halfer from the Brüning Group discuss biogenic and fossil feedstock under RED II & III, PEFC and waste wood recycling and whether pyrolysis is considered material or thermal recycling. You can also find out which certificates are required by biochar-producing companies at which stage of the product life cycle.
The Brüning Group offers a comprehensive service for the supply and disposal of energy-supplying bulk materials. They trade in round timber and energy-containing residues from the biomass processing industry. Torben Halfer and Hendrik Bauer work in support for the operational business.
This is the continuation of the interview with Brüning, part 3 of 3 and therefore the last part.
RED II
Anne: Let’s talk about standards and certifications for biomass
Torben: Biomass is a core business area of the Brüning Group. Topics such as RED II & RED III, FSC, PEFC are standard requirements in the biomass trade. Several people in the team deal with these enquiries. Hendrik specialises in environmental management and certification plus sustainability and the supply chain. Quality management and certifications (ENplus, EBC, GMP+) are my responsibility. The Brüning Group is ISO 9001 and ISO 14001 certified.
To decide on the right [certification] systems, I need to know in advance: Where do I want to go with my biochar product?
Anne: You mentioned RED II and RED III. At biochar zero, we had discussions about the possibility of wood being legally banned as a renewable raw material under RED. Will that happen?
Hendrik: Let me briefly explain the background: in 2018, the EU member states agreed on standardised sustainability criteria for the use of biomass in power generation, cooling and heating plants with an output of more than 20 megawatts. In simple terms: the large plants are obliged to be able to demonstrate the use of sustainable biomass in black and white.
To this end, the term ‘sustainable’ was defined in Article 29 of the RED II Regulation.
Firstly, a distinction is made between the physical states of biomass. There are different criteria based on this.
EU member states have approved the directive and it must now be transposed into national law. So far, only some EU member states have managed to effectively implement the criteria, although the deadline for this was mid-2021.
Let’s now turn to wood: The EU Commission discussed whether fresh wood/primary wood should no longer enjoy sustainable status. The manifestation of this statement in law was prevented under the Swedish Presidency.
There are few changes to RED II under RED III. It has been fine-tuned and there are additional approaches, such as ‘no-go areas’. Ultimately, almost nothing has changed in terms of access to sustainable biomass.
In view of the prospect of follow-up legislation to RED III, the industry will always have to continue this battle, as the voices of dissent (‘keeping the wood in the forest’) are very strong.
At the moment, I don’t see any movement towards RED IV.
I believe we will see a strong dynamic in the interest in biogenic waste and residual materials. In the waste wood sector and in laws such as the German Circular Economy Act, there is the stipulation ‘materials before incineration’.
German politicians are pioneers in the waste wood sector and have been working on an amendment to the so-called ‘Altholzverordnung’ (Waste Wood Regulation) for years. In the course of this reform, there is discussion to ban incineration of A1 waste wood (i.e. the best quality). As things stand today, plants are allowed to utilise A1 for thermal purposes under certain restrictions.
Anne: A1 wood would be super interesting for biochar/biocarbon production.
Hendrik: Definitely. But it has to be a flexible system. We see the following reasons for this.
Recycling before incineration. There are, for example, representatives of the wood-based materials industry (e.g. chipboard manufacturers) who need waste wood for their wood-based material core layer. This creates a large demand for A1 wood. In this industry, a clear statement on recycling before incineration would be viewed positively. This is often correct in theory and is the better option. However, there are also situations where A1 wood should justifiably be used for incineration.
The danger is that if pyrolysis plant technology is categorised as combustion, certain feedstock biomasses are no longer available or useful.
Economic dynamics causing demand to rise and fall: For example, problems arise when the ‘construction industry is suffering a downturn’. In recent weeks and months, we have seen a very weak building materials industry. All manufacturers who use waste wood as a material have simply stopped buying. In situations like this, we need alternatives.
What do you do with the surplus then? Should they be stored until the run restarts?
Seasonality: Fresh wood and waste wood have different seasonalities. In the case of fresh wood, the volume depends on forest management activities. In the case of waste wood, areas with a strong infrastructure can be identified as an indication of a higher quantity, where production and municipal waste occur at different times.
These considerations contribute to the notion that, overall, the system must remain very flexible. This cannot always be regulated by rigid bans alone.
Torben: If we look at the biocarbon market, the ‘material before incineration’ rule still needs to be clarified. In other words, how do we categorise pyrolysis technology with the biocarbon product in this overall concept – what proportion is energy-related and what proportion is material-related?
Suppose one has got biomass,
- does one burn the volatile components and generate energy/vapour. Does this make one a combustor or an energy user?
- Or does only the C-fix portion of the product count and is one’s process a non-thermal/energy use, then?
We are still missing this statement. The only way to understand which system providers are decisive and what quantity one can make available is by clearly categorising the pyrolysis technology with biomass. The danger is that if pyrolysis plant technology is categorised as combustion, certain feedstock biomasses are no longer available or useful.
In the vast majority of cases, biochar has not yet been RED II-certified. It is therefore difficult for a power plant that falls under RED II and/or European emissions trading to demonstrate CO2 neutrality.
Hendrik: I would even broaden the view to the application and ask: Where does the biochar go? Where can biochar be used: material or thermal use? The next considerations are also linked to this distinction.
Shall biochar be a fuel substitute for a fossil material, then it must be clear to accept that there is an interface between biochar (emission avoidance in a voluntary system) and a power plant in which it is to be used as a fuel (part of the current CO2 emissions trading system). The power plant needs the sustainable fuel for CO2 neutrality in order to be able to operate economically in the CO2 debate.
Sooner or later, worlds will collide. This is because, in the vast majority of cases, biochar has not yet been RED II-certified. It is therefore difficult for a power plant that falls under RED II and/or European emissions trading to demonstrate CO2 neutrality. RED II-certified biochar producers are still a rarity.
Anne: What are the ways to obtain RED II certification?
There are 14 recognised systems across the EU that can be used to demonstrate conformity with the RED II requirements. Some of these are more global in nature. Economic operators are required to join at least one of these voluntary certification schemes.
It is not yet clear where biochar fits in and which is the right or most appropriate system.
It is not yet clear where biochar fits in and which is the right or most appropriate system.
Anne: Can you give us two or three examples of systems?
Hendrik: There are existing systems that have incorporated the RED II standard. Other systems were created specifically in 2018 as a one-fits-all solution for RED II.
Old systems in the wood industry include the Sustainable Biomass Programme (SBP), Better Biomass and NTA8080. These systems have managed the balancing act to RED II.
One example of a new system created in 2018 is the SURE-EU system. This and similar schemes claim to be able to cover all solid and gaseous biomasses from A to Z and their entire supply chains.
The crux of the matter when choosing certification systems is that most systems are only recognised for certain biomasses or do not have an EU-wide scope.
Anne: In which system do you see biochar feedstock?
Hendrik: Currently in the SURE system, as it is a simple system. In this system, the differences in recognition begin with the type of feedstock.
Another issue where there is still some uncertainty is transport. In the case of import/export, biochar-based products to be transported must be registered in REACH, whereby particular attention should be paid to their self-igniting properties.
Anne: A biochar-producing company must provide proof of RED II for its input materials, quality assurance systems and audits are required in production, and the product – the biochar – should also be EBC-certified, for example. If the products are exported within Europe, the material must be registered in accordance with REACH. What else will a biochar manufacturer have to face, perhaps in relation to biomass?
Torben:
It will also be necessary to indicate which biomass is involved, where exactly the biomass was produced or originated and possibly how high the biogenic content is.
- Primary biomass (biomass from plantations on a plantation, from the agricultural sector or other plant residues and residues)
- Secondary biomass – biomass from waste or residues.
Hendrik:
The EBC certification is doing something exciting here. With its positive list, it follows a different approach to RED II. If biomass comes from the forest, EBC requires FSC or PEFC-certified goods, for example. FSC or PEFC are not yet recognised systems in RED II. Most of the feedstock suppliers must already be RED II certified. It is not enough just to have your own pyrolysis plant certified in accordance with RED II.
Another issue where there is still some uncertainty is transport. In the case of import/export, biochar-based products to be transported must be registered in REACH, whereby particular attention should be paid to their self-igniting properties. It is therefore important to consider whether or not it is considered a transport of dangerous goods.
Anne: Is there anything the young biochar industry can learn from other sectors?
Hendrik: There is no one right way. I believe that good risk management solves many issues and is the basis for effective protection
As a manufacturer of biochar products, one has to be aware that it doesn’t end where the material leaves the plant. Instead, one needs to know the entire supply chain right through to the application and also request the necessary information, because only then one can generate CO2 certificates sustainably or consciously, or avoid levies.
Anne: Which systems are crucial for the biochar-producing companies?
Torben: All certifications from the biomass supply sector that declare whether the feedstock is sustainable.
- the huge area of process technology, which is specified by the technologies used, including explosion protection, occupational safety, etc.
- all certification systems that are product- and application-dependent.
To decide on the right [certification] systems, I need to know in advance: Where do I want to go with my biochar product? Because based on this, there are retrospective requirements for the certification system for the entire supply chain.
The requirements are enormously different: if I compare applications in incineration as a substitute for fossil fuels or in product manufacture, e.g. as an additive in cement or asphalt, as a filler in plastics and therefore perhaps also in injection moulded parts for automotive applications.
As a manufacturer of biochar products, one has to be aware that it doesn’t end where the material leaves the plant. Instead, one needs to know the entire supply chain right through to the application and also request the necessary information, because only then one can generate CO2 certificates sustainably or consciously, or avoid levies.
Topic: Utilising waste and CO2 pricing of fossil feedstocks
Anne: Let’s talk again about using waste on the input side. What does one have to consider when using waste in biochar production?
Hendrik: For users, it is crucial whether they use a product as feedstock or waste. In the latter case, the plant is considered a waste treatment plant. There is a lot to consider at this point to avoid falling under suspicion of illegal waste utilisation.
Anne: Biochar-producing companies then not only have to deal with the biogenic/fossil content of four feedstocks (A4 to A1), but also have many more biomasses.
Torben: Yes, food industry waste, for example, contains different proportions of biogenic materials. In future, there will have to be a very precise analysis of how each material is categorised.
EBC design and the question of whether biochar pyrolysis is a material or thermal use.
Anne: How is EBC positioning itself as a pioneer in the biochar industry?
Hendrik: I would ask: can the positive list be expanded or defined more clearly?
The best example is forestry residues. In the eyes of the layperson, this primarily includes everything except the trunk, i.e. branches or the crown wood. A very simplified picture: Consider a grown tree. The trunk with a certain thickness goes to the sawmill industry. The thinner material goes to the paper and pulp industry. In addition, there is the residual crown wood or deadwood.
If you look at the EBC positive list, you only have two options for this material: It is FSC or PEFC certified.
It is relatively difficult to find FSC certification at forest level in Germany; it is estimated that only 15 % of the forest area is FSC-certified. However, it is estimated that around 75% of the forest is PEFC-certified.
However, there is a small twist in the industry. Forest owners are FSC or PEFC-certified. They usually work together with forestry companies that carry out the measures and are also recognised by a service certification. However, the companies are not FSC/PEFC-certified according to the supply chain certifications.
Now, what happens in practice: You leave the high-quality round timber in the forest as a pile (stack), which is used as material, and this remains the property of the forest owner.
In most cases, the residual forest wood goes to the forestry companies or they are allowed to commercialise it. There is actually only one market for this wood and that is currently incineration. These companies themselves are not certified according to the PEFC Chain of Custody system. This means that they are not allowed to resell this material, which is proven to come from a PEFC-certified forest, as certified themselves. As a typical customer of these forestry companies, this means that the problem facing us is that we cannot pass on the forest residues in a certified form.
There is a twist in the industry that the PEFC does not consider to be so important.
The FSC, on the other hand, has been increasingly moving away from incineration for years, possibly overlooking the fact that not every material can be recycled.
This situation raises the question again: Where is biochar positioned? And what happens during production? Is it material use or incineration?
We have considered which systems could certify the forest residues and, in the course of this, directly bring RED II certification with them in order to ultimately have a one-fits-all solution. This would allow a biochar manufacturer to say: I don’t care which route the biochar takes, I potentially have all the marketing options.
A manufacturer would then know which type of feedstock is used:
- 100 % or proportionally biogenic,
- and thermal utilisation can be pursued through RED II certification from the creation or production of this biomass.
This is precisely where existing systems can perhaps be brought together. In my view, the EBC team should also take a closer look at the logic of what they might be able to achieve by simply recognising other feedstock systems in order to approach the RED II topic. RED II recognition will certainly come their way.
Anne: Incineration is usually seen as a worse option and, in contrast, any material utilisation per se is often presented as super sustainable, sometimes CO2 neutral.
Hendrik: That’s exactly the debate. People who use forest waste wood for thermal utilisation because it cannot always be used as a material are accused of not actively thinning the forest. But if we don’t actively thin the forest, we won’t have enough material that is in demand as a material. So sooner or later, the RED II sustainability certificates will certainly cross paths with the materials industry. So far, only voluntary systems have prevailed in the recycling industry (see FSC/PEFC).
Anne: I once had a discussion with some forestry experts who weren’t so keen on biochar or charcoal. They want as much wood as possible to remain in the forest for regeneration. The forest has to regenerate, it needs dead wood for various ecosystems and insects and animals.
Hendrik: I believe that the forestry industry is well networked as a forest owner organisation and is becoming increasingly involved in the RED II debate.
Restricting or even banning active forest management has several consequences. There is significantly less biomass available for all interest groups. It also supports the idea that the more wood in the forest, the more fire load remains in the forest – i.e. the potential for extreme forest fires. The truth will certainly lie somewhere between your comments and the counter-example.
Anne: Thank you very much for the interview!
