The Sustainable Biomass Program (SBP) has today published an updated version of the REDIII Level A Risk Assessment for Denmark. The revision follows the recent guidance statement issued by the Danish Energy Agency on 20 January 2026 regarding the interpretation of “heathlands” as a “no‑go area” under the sustainability requirements for biofuels (Ref: J no. 2026‑499).
In the guidance, the Agency confirms that heathlands overgrown with trees are not considered to be in a climax stage of development as defined in Article 29(6)(iv) of the Renewable Energy Directive (REDIII). As a result, heathlands that are overgrown, or in the process of becoming overgrown (where tree removal forms part of conservation management) are not considered to be in a climax state and are therefore excluded from the scope of the assessment.
The risk assessment update reflects this clarified interpretation, ensuring continued alignment between SBP’s risk assessments and national guidance.
The Agency’s clarification does not affect the outcomes of the REDIII Level B Risk Assessment for Denmark. However, Biomass Producers operating under the SBP framework are required to update their management systems to reflect the revised Level A assessment.
The updated REDIII Level A Risk Assessment for Denmark is available on the SBP website here.
