SURE has begun distributing information about the end of the transitional period for implementing RED III. Some of the information may sound contradictory and may cause panic among suppliers and buyers.
My personal comment on this situation is that we are experiencing an unprecedented example of the EU’s unpreparedness to implement its own Green Deal regulations, when the EU approves a new SURE methodology as a voluntary but recognised scheme one day before RED III enters into full force.
I therefore allow myself to explain the basic facts:
Below is the transcript of the SURE letter dated 21 May 2025.
“Dear Sir or Madam,
On 21 May 2025, the RED III Directive entered into force in all EU Member States. This means that the new RED III requirements now apply in the EU‑recognised certification schemes. Unfortunately, SURE received the necessary confirmation of RED III recognition from the European Commission only on 20 May 2025, so the revised system documents can only be published now. The translation of documents and forms, which are currently available only in English, into German is underway and will also be published in the coming days. Below we have compiled an overview of significant (but not all) changes. Please note that this is not a complete overview of changes and does not release system participants from their obligation to carefully familiarise themselves with the amended requirements and implement them where necessary.
In principle:
Existing and valid RED II certificates remain valid, but 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 carried out by certification bodies. A significant tightening of requirements resulting from the entry into force of RED III now also applies to demonstrating 70/80% greenhouse gas emission reductions for so‑called existing installations (biomass and biogas plants that first began operating before 2021). The obligation to demonstrate reductions depends on the type of biomass installation, its capacity, and years of operation.
It is important to note that, in order to demonstrate greenhouse gas emission reductions, all operators in the supply chain must provide information on the relevant greenhouse gas emissions from their activities, e.g., by indicating the “use of default values” (where relevant) or by determining their own emission values. SURE recommends that affected operators inform themselves in good time about their own obligations and accounting methodology and, if necessary, obtain further information from industry associations, especially from SURE’s “national support bodies”.
IMPORTANT:
Only the greenhouse gas reduction targets defined by Member States when implementing RED III into national law apply within the SURE system. If the new RED III greenhouse gas reduction targets have not yet been transposed into national law, but regulations or laws under RED II are still in force, only those targets are legally required, and the SURE system does not impose any corresponding RED III greenhouse gas reduction obligations.
The SURE system always applies the greenhouse gas reduction obligations as defined in national law.
IMPORTANT:
The same applies to the introduction of the RED III compliance requirement for biomass power plants with an installed thermal capacity from 7.5 MW to 20 MW. SURE does not require operators to demonstrate compliance with the sustainability and greenhouse gas reduction requirements under RED III; this is done exclusively by the legislator through the relevant regulations or laws.
The biggest changes concern producers of forest biomass. With the introduction of so‑called “no‑go areas”, certain types of land, such as old‑growth forests and peatlands, and certain protected areas, are excluded from forest biomass production. Producers of biomass fuels from forest biomass must also provide a credibility statement confirming that they have processed only forest biomass that meets the RED III requirements under Article 29(6a). Provided that the new criteria (no‑go areas and credibility statement) are also required by law and that this has been demonstrated through an updated risk assessment and assessed as low risk, forest biomass producers may demonstrate compliance for the first time through a self‑declaration or through a supplier audit at the first gathering point. The first gathering point then has special responsibility for monitoring and ensuring supplier compliance with RED III. SURE will verify this during the audit of the primary gathering point.
This is explicitly permitted only if a valid and recognised RED III risk assessment with “low‑risk” status is available. The SURE group certification approach remains possible in all cases. Previously issued self‑declarations remain valid provided that their risk status is confirmed by the updated risk assessment. In the event of an audit, the additional criteria will be verified as part of the deficiency check. However, if the risk status changes in the risk assessment or if no valid risk assessment with a “low‑risk” result is available, a new self‑declaration with “specified risk” must be submitted at the first gathering point for the next delivery of forest biomass. The self‑declaration may be updated later if a “low‑risk” assessment becomes available in the meantime.
Using the group certification approach with “low‑risk” status requires submitting a valid and recognised risk assessment with the corresponding statement assessing the legal implementation and enforcement of the new RED III criteria (no‑go areas and credibility statement). Currently, no valid risk assessment is available; only a draft risk assessment for Austria has been submitted to SURE for comments and approval. Please note that SURE does not carry out risk assessments; these are the responsibility of relevant associations, national authorities, or other institutions in the respective forest biomass sourcing areas.
For producers of agricultural biomass, the exclusion of certain land types from biomass production is expanded, e.g., peatlands. In addition, soil carbon enhancement measures must demonstrate that biodiversity in the area is not affected. Self‑declarations issued under group certification of agricultural producers remain valid. Evidence of compliance with the new RED III requirements (no‑go areas and biodiversity protection measures under ESCA) will be verified as part of deficiency checks in the event of an audit.
There are no new requirements for verifying the supply chain of biomass fuels from waste and residues. Existing self‑declarations remain valid. A detailed description of the changes can be found in the revision history of the relevant system documents.
Please review all necessary measures and contact industry associations or national support bodies if you have any questions. Please note that SURE does not offer consulting services and is available only to a limited extent due to high demand for information.
Your SURE Team”
