Wood: climate saver or climate offender?

24.10.2025

Source: E & M powernews

A report by the Federal Environment Agency casts doubt on the climate neutrality of wood energy. Industry representatives react indignantly.

"Stunned" is Marlene Mortler, Chairwoman of the German Wood Energy Association (FVH) in the German Bioenergy Association, according to a statement from the association. "It is sad to see how the Federal Environment Agency is doing the job of the fossil fuel industry and entrenching itself in a trench war against wood energy."

The reason for the uproar is a short report prepared by lawyer Markus Lehnshack from the Institute for Climate Protection, Energy and Mobility (Ikem) on behalf of the Federal Environment Agency (UBA). It is entitled "Climate impact of the use of wood for energy". It concludes that electricity and heat from wood cannot be fully classified as renewable energy within the meaning of the Paris climate targets.

In particular, the author criticizes the existing practice in the areas of accounting, emissions trading and consumer protection: "The current regulations convey inconsistent signals that can give companies and consumers the misleading impression that the use of wood for energy is generally climate-neutral."

In the context of national and European climate targets, the extraction of wood for energy use is accounted for in the so-called "LULUCF" sector (land use, land use change and forestry). In the sectors that use wood for energy - such as transport, buildings or industry - the emissions from the use of wood for energy are only reported without having a negative impact on the emissions budgets. This is intended to avoid double accounting.

In line with the polluter pays principle - according to which those who cause environmental pollution have to bear the costs - this could lead to miscommunication in consumer protection, writes Lehnshack. Furthermore, emissions from wood imports from third countries are not accounted for in any sector and are therefore considered climate-neutral.

Criticism that the FVH does not want to take seriously: "Wood energy is and remains a fully-fledged renewable energy source in all relevant laws and funding programs and makes a significant contribution to climate protection," writes the association, citing data published by the UBA itself: In 2024 alone, around 32 million tons of CO2 were saved by generating electricity and heat from wood instead of fossil fuels such as coal, oil and gas.

"The UBA hasn't heard the shot yet"

But Lehnshak's comments go even further. Overall, a generally valid definition for renewable energy from woody biomass is lacking, both in terms of legislation and funding programs. A comprehensive reform is necessary, the lawyer concludes, and proposes the adoption of a new law in which all requirements for the use of biomass are summarized.

This could be done in connection with the implementation of the RED III directive, writes the expert: "Such a biomass sustainability law could be structured in such a way that the definitions, principles and greenhouse gas saving and sustainability criteria are regulated in a general section." Further chapters could then set out specific requirements for sustainability certificates for electricity, fuels or heat from biomass. The principle of cascading use, which only provides for the use of wood for energy in exceptional cases and only at the end of the value chain, should also be specified.

According to Lehnshack, the regulations in emissions trading should also be adapted. However, the prerequisites and consequences of shifting reporting from the LULUCF sector to other sectors are "highly complex and would have to be considered in a comprehensive research project", he writes. However, it would be possible to quickly implement concrete measures in the area of consumer protection, for example. Germany could take on a pioneering role here and develop a definition of "climate-neutral products".

However, the FVH does not believe that the proposals have much chance of being implemented: "In the coalition agreement, the German government has clearly committed to reducing bureaucracy - not expanding it. The UBA's proposals are irrelevant for companies and citizens and therefore belong in the waste paper basket," rages Marlene Mortler: "The UBA has not yet heard the shot when it calls for further regulations and detailed rules in the heating sector or for the use of wood. What we definitely don't need are further regulations that make the legal jungle even denser, more complicated and more bureaucratic."

The report "Climate impact of wood use for energy" is available on the UBA website.

Author: Katia Meyer-Tien