SBP notes the recent joint NGO briefing, Greenwashing Carbon Removal, which addresses the forthcoming European Commission delegated acts under the Carbon Removal and Carbon Farming Regulation (CRCF). The briefing raises significant concerns about the methodologies under development for certifying Bio-CCS/BECCS and biochar projects.
We acknowledge the importance of rigorous scrutiny of carbon removal methods. Effective climate action demands scientifically robust, transparently governed, and environmentally sound approaches, particularly where certification is concerned.
However, we must respond to several specific claims made about SBP and biomass sustainability certification more broadly.
Traceability and accountability in SBP certification
The briefing alleges that certification schemes such as SBP “do not provide accountability or even basic traceability.” We categorically reject this characterisation.
SBP certification is grounded in:
- Comprehensive Chain of Custody requirements, ensuring traceability from sourcing area to End-user;
- Digital data transfer and tracking of every transaction in an SBP certified supply chain;
- Risk assessments at the supply base level, including forest and land-use monitoring;
- Third-party annual auditing by ISO 17065 accredited Certification Bodies under a robust performance monitoring and enforcement system; and
- Ongoing alignment with evolving EU regulatory frameworks, including REDIII.
Our Standards are not static. With the introduction of SBP Standards v2.0, we have significantly strengthened our requirements in a number of areas, including environmental, forest carbon, risk mitigation, social, and data collection and communications, aligning with scientific evidence and stakeholder expectations. We support the enhancement of forest carbon stocks through our Standards, in line with sustainable forest management and climate mitigation objectives. And to our knowledge, SBP is currently the only certification scheme that implements the cascading principle.
Further, under SBP Standards v2.0, the SBP certification scheme now has a fully standalone Chain of Custody Standard (Standard 4) and is no longer dependent on other certification schemes.
Having been recognised under the REDII in 2022, SBP was not an object of investigation by the EU Court of Auditors in 2016. It is wrong and misleading to mention SBP in this context. Nor has SBP been the subject of any bioenergy fraud cases.
The role of certification in ensuring credible removals
The briefing calls into question the validity of biomass-based carbon removals and the sufficiency of existing safeguards, including those provided by certification. It is critical to distinguish between:
- The policy frameworks under which removals are incentivised and accounted for (eg CRCF, REDIII); and
- The independent assurance mechanisms provided by certification schemes.
SBP does not make claims about the net carbon benefits of BECCS or biochar as removal technologies. Our role is to verify the sustainability and legality of biomass sourcing, ensuring that feedstocks meet strict requirements obeying the four principles of:
- Feedstock is legally sourced
- Feedstock sourcing does not harm the environment
- Feedstock is only sourced from Supply Bases where the forest carbon stock is stable or increasing in the long term
- Feedstock sourcing benefits people and communities
Certification cannot substitute for sound policymaking. But nor should it be misrepresented. We welcome stronger integration of lifecycle accounting, land-sector integrity, and biodiversity safeguards into EU rules, and we are ready to support that effort.
Moving forward: principles for credible certification
We agree with several of the principles advocated in the briefing, including:
- The need for complete, transparent, and conservative carbon accounting;
- The exclusion of high-risk feedstocks, where applicable; and
- The importance of protecting and restoring biodiversity.
SBP stands ready to contribute constructively to the development of carbon removal methodologies that:
- Are grounded in scientific integrity and environmental safeguards;
- Recognise the differentiated risks and characteristics of biomass supply chains; and
- Are supported by credible, third-party certification that demonstrably adds value.
We are actively exploring practical solutions to support and implement carbon accounting methodologies for BECCS through carbon projects and our Carbon Working Group. Our work will take its lead from with established best practices, such as those set out in the EU ETS Monitoring and Reporting Regulation (MRR).
Invitation to dialogue
SBP welcomes open dialogue with all stakeholders, including Civil Society Organisations, EU institutions, and scientific experts, on how best to ensure sustainable biomass use and credible carbon removal practices.
We invite the signatories of the Greenwashing Carbon Removal briefing, as well as Commission representatives, to engage directly with us to understand how SBP operates, how our certification scheme is evolving, and how we can collectively ensure that sustainability remains the backbone of Europe’s energy and climate future.
