The Sustainable Biomass Program (SBP) acknowledges the concerns raised in the NGO report, Sustainable Biomass Program: Certifying the Unsustainable. While we strongly refute several of the claims made, particularly those that misrepresent the scope, rigour, and intent of the SBP certification scheme, we recognise the importance of constructive scrutiny. This statement provides an initial response to the key criticisms levelled at SBP. We will review the full report in greater depth over the coming days and welcome the opportunity to engage directly with the author and contributors to discuss the findings in detail. SBP remains committed to transparency, scientific integrity, and continuous improvement, and encourages dialogue that is grounded in fact and shared commitment to sustainability.
To ensure the remainder of this response is understood in the correct context, it is essential to clarify that SBP is not a forest management certification scheme, nor has it ever claimed to be. The SBP Standards are designed to assess the sustainability and legality of biomass sourcing at the level of the Biomass Producer, not at the forest management unit (FMU) level.
SBP does not certify forest operations or forest managers. Instead, it works alongside established forest certification schemes such as FSC and PEFC, and applies a risk-based approach to ensure that feedstock is responsibly sourced, particularly in areas where forest certification coverage is limited. This distinction is clearly stated in SBP’s normative documents and is central to understanding the scope and intent of the SBP certification scheme.
Mischaracterising SBP as a forest management certification scheme leads to inappropriate comparisons and expectations that fall outside the remit of the SBP Standards. The following sections address the specific claims made in the NGO report in light of SBP’s actual role and responsibilities.
Field audits and forest management oversight
SBP certification is closely linked to forest management practices, even though SBP does not certify forest operations directly. Biomass Producers are required to conduct comprehensive Supply Base Evaluations and implement Risk Assessments in line with SBP Standards. This process demands a clear understanding of the conditions within the Supply Base and the competencies of the evaluation team, as outlined in clauses 3.8 and 6.2 of SBP Standard 2 (v2.0).
Where risks are identified, mitigation measures must be applied across the supply chain, including, where necessary, at the forest level. Biomass Producers are expected to work with all suppliers and sub-suppliers to ensure that mitigation measures are implemented effectively at the source of the feedstock.
These requirements are enforced by independent, third-party Certification Bodies, which conduct on-site audits to assess the adequacy of mitigation. These audits may include direct engagement with forest managers, logging contractors, and other upstream actors to verify that sustainability risks are being addressed in practice, as required under clauses 6.14, 6.16, and 6.22 of SBP Standard 3 (v2.0).
Use of FSC and PEFC schemes
SBP does not misrepresent the role or credibility of other certification schemes, nor does SBP intend to replicate or compete with them. On the contrary, the SBP scheme makes a clear and deliberate distinction between feedstock certified under a Forest Management (FM) claim (for example, FSC FM) and feedstock certified under a Controlled Claim (for example, FSC Controlled Wood or PEFC Controlled Sources). This distinction is embedded in the SBP Standards, specifically in clause 3.2 of Standard 2 (v2.0), and is reflected in the claims that Biomass Producers are permitted to make.
Contrary to the report’s assertion that SBP merely screens out the worst practices, the SBP scheme requires that identified risks are actively mitigated and that mitigation measures are verified as effective before feedstock can qualify for an SBP-compliant claim. The objective is not simply to avoid problematic sources, but to drive improvements in sourcing practices through a structured, risk-based approach.
Feedstock carrying FSC Controlled Wood and PEFC Controlled Sources claims are only eligible for an SBP-controlled claim, not an SBP-compliant claim. This ensures transparency and avoids conflating lower-tier due diligence mechanisms with full sustainability certification. Where residual risks remain, SBP requires that they be addressed through additional, scheme-specific mitigation measures.
Carbon accounting methodology
SBP does not make overarching climate impact claims. If the report refers to GHG emissions from biomass supply chains, SBP’s scheme is designed to collect data across harvesting, production, and all transportation stages up to the End-user’s gate. This data is compiled in the SAR (SBP Audit Report) and calculated using the EU REDIII-compliant methodology outlined in Instruction Document 6D (v2.0). The claim that SBP relies on national averages is incorrect.
If the report refers to forest carbon stock accounting, we acknowledge that current guidance does not explicitly prohibit offsetting carbon-rich forest losses with regrowth in less dense areas. However, this practice is not in the spirit of the SBP scheme. SBP is developing new guidance that:
- Establishes a hierarchy of data sources for assessing carbon stock changes.
- Directs assessors to use IPCC Guidelines for National GHG Inventories, which exclude primary and old-growth forests from carbon stock calculations.
- Encourages the use of ecologically relevant sub-scopes (for example, catchments) rather than administrative boundaries.
- Clarifies that proxies such as annual allowable cut may not reflect below-ground carbon and should not be used to determine whether there is stable or increasing forest carbon in a Supply Base.
Forest carbon vs. supply chain emissions
While the report appears to conflate forest carbon loss with supply chain emissions, SBP’s scope is focused on the latter. However, SBP’s Standards also require the protection of High Conservation Value (HCV) areas and prohibit sourcing from primary and old-growth forests, in line with EU RED and national definitions.
Smokestack emissions
SBP’s mandate is to define and certify sustainable biomass sourcing, not to regulate combustion emissions. However, SBP does not defer responsibility. Under Standard 4 (v2.0), clause 1.21, certified organisations must comply with all applicable laws, including emissions regulations. Certification Bodies are required to verify this compliance during audits. Where regulators have set emission limits, SBP ensures that these are respected through its certification process.
Forest residues and primary forest
SBP does not treat any category of feedstock as inherently low-risk. Forest residues are subject to the same level of scrutiny as other feedstock types, including primary forest. SBP Standard 1 (v2.0), indicator 2.2.4 requires that the environmental impacts of residue extraction be evaluated, ensuring that no feedstock can bypass risk assessment requirements.
SBP also does not permit whole logs to be classified as residues or byproducts. The SBP Glossary provides clear definitions for each feedstock category, and any misclassification would constitute a breach of certification requirements. If the report has evidence of such practices, SBP would welcome the opportunity to investigate and take appropriate action.
In addition, processing residues and post-consumer feedstock are subject to verification, inspection, and audit under Standard 2 (v2.0), Annex 1. These requirements ensure that all feedstock types, regardless of origin, are subject to appropriate oversight.
Finally, SBP requires compliance with the EU Renewable Energy Directive sustainability criteria for all Certificate Holders. These criteria include, among other provisions, a prohibition on sourcing feedstock from primary and old-growth forests (Article 29, paragraph 3(a)), a requirement that SBP enforces through its certification framework.
Indigenous Peoples’ rights and FPIC
SBP upholds the rights of Indigenous Peoples through explicit requirements in Standard 1 (v2.0), indicators 4.2.4 and 4.2.6. Where FPIC has not been obtained, a formal consultation and accommodation process must be implemented. Certification cannot proceed unless risks are demonstrably mitigated to a low level.
Consultation and engagement with interested and impacted Parties are central to SBP’s governance and assurance systems. Stakeholder consultations are conducted during the development and revision of SBP Standards, as well as during the preparation of Regional Risk Assessments. In addition, all Certificate Holders are required to engage stakeholders when developing their own risk assessments.
To further strengthen these relationships, last year SBP launched its Regional Forums, a new platform designed to enhance dialogue and collaboration with stakeholders across different geographies and contexts.
Governance and conflict of interest
SBP is governed by a multi-stakeholder structure with strict conflict of interest policies. Board and committee members serve in a personal capacity and do not represent their employers.
Closing remarks
SBP is an independent, not-for-profit organisation committed to ensuring that biomass used for energy is sourced responsibly and sustainably. We remain open to constructive dialogue and welcome opportunities to collaborate with civil society, academia, and industry to strengthen sustainability outcomes. In the coming weeks, we will continue to review the full NGO report in detail and assess any specific evidence presented. Where appropriate, we will engage directly with the report’s authors and contributors to clarify misunderstandings, address concerns, and identify opportunities for improvement. SBP remains committed to transparency, accountability, and continuous improvement in support of credible, science-based climate and forest stewardship.
