Worried about whether your wood-based fuel still counts as renewable? The EU sustainable biomass criteria tightened under RED III, with new forest harvesting rules and greenhouse gas thresholds, plus a transition clause for some older support schemes.
For the wider policy context, read the overview of the european bioeconomy strategy.
| Item | Value |
|---|---|
| RED III transposition deadline | 21 May |
| Transition (grandfathering) clause | Article 29(15) of RED III |
| Support must have been granted before | 20 November 2023, under RED II criteria |
| Fuels excluded from the clause | Wood waste and residues |
| Member states fully transposed RED III quotas (release of 29 July 2025) | Romania and Czechia |
| Member state invoking the clause (release of 29 July 2025) | France |
These figures come from a European State Forest Association release, France first member state to implement the grandfathering clause of the RED III directive, published 29 July 2025. National transposition moves quickly and figures can change, so check the source before you rely on them.
What changed from RED II to RED III?
The difference between RED III and the preceding RED II is the introduction of stronger sustainability criteria. The EUSTAFOR release ties these to three areas:
- new harvesting criteria for forest biomass;
- greenhouse gas (GHG) emission reduction thresholds;
- the size of economic operators that can implement RED III requirements.
The release does not give the numeric thresholds, so this page does not either. For exact values, go to the directive text and your national transposition law.
For the wider sector behind forest-sourced fuel, see the guide to forest bioeconomy in europe.
How does the Article 29(15) grandfathering clause work?
RED III also includes Article 29(15), a so-called grandfathering clause. It acts as a transition period. Member States may accept energy produced with RED II compliant biomass from power plants that meet two conditions:
- Support was granted before 20 November 2023, in accordance with RED II criteria.
- Support was granted as long-term funding set at a fixed amount agreed at the start, with a safeguard in place to prevent any overcompensation.
Both conditions must hold. A plant that received support after that date, or whose support was not fixed in advance, falls outside the clause as the release describes it.
Which fuels and suppliers does the clause cover?
The clause also applies to the suppliers of the qualifying installations. The release calls this relevant for state forest organisations, which it describes as the primary producers of forest biomass.
There is one exception: wood waste and residues are not accepted under the clause. If your material falls in that category, you should assume RED III criteria apply.
The clause is optional for Member States. As of the release published 29 July 2025, France was the only country that had decided to invoke it.
Which biomass criteria apply before and after 21 May?
For every country that has not invoked the clause, the rule turns on production and storage dates. The release sets it out as follows:
- RED II compliant biomass fuel produced and stored before 21 May remains valid.
- That fuel can still be sold after 21 May.
- Any batch made after 21 May falls under the RED III rules instead.
In practice, the production date of a batch matters as much as the certificate attached to it. Keep records that show when and under which criteria each batch was made.
Where did implementation stand in mid-2025?
The 21 May transposition deadline for RED III had passed by the time of the release. According to EUSTAFOR, only Romania and Czechia had fully transposed the new RED III quotas as of its publication on 29 July 2025. Consultations were ongoing in other member states, including the Netherlands and Germany.
The rules are still being worked on. EUSTAFOR lists a response dated 27 January 2026 to the revision of annex V & VI of the Renewable Energy Directive, so the detail may keep shifting.
The climate-policy backdrop to these rules is covered in the piece on the EU green deal and bioeconomy.
Frequently asked questions
Do the stricter RED III criteria replace RED II for biomass?
Show answer
For fuel produced after 21 May, yes: it must meet RED III criteria. Fuel that was RED II compliant and produced and stored before 21 May stays valid and can still be sold afterwards.
Which countries use the grandfathering clause?
Show answer
As of the EUSTAFOR release published 29 July 2025, only France had decided to invoke it. Other countries may decide differently later, so check national rules.
Does the clause cover wood waste and residues?
Show answer
No. The release states that wood waste and residues are the exception and are not accepted under it.
What support qualifies for the clause?
Show answer
Support granted before 20 November 2023 under RED II criteria. It must also be long-term funding at a fixed amount agreed at the start, with a safeguard against overcompensation.
