The Probos Foundation is submitting a draft report on the extent to which Dutch timber harvesting regulations align with European requirements for sustainable forest biomass. The report compares the criteria from the revised Renewable Energy Directive with Dutch legislation and oversight. Stakeholders can submit their views in November, after which a final version will follow.
Test on national framework
The Level A approach assesses whether national legislation and enforcement provide sufficient guarantees for sustainable forest management. If so, companies that certify biomass can refer to the national framework. Probos conducted this assessment for the requirements of Article 29, paragraph 6. The commission was commissioned by the Netherlands Enterprise Agency (RVO) and the Better Biomass certification scheme.
The draft report outlines for each criterion where the Netherlands scores strongly and where improvements may be needed. These include the legality of timber harvesting and the protection of designated nature reserves, as well as topics such as post-logging regeneration, soil management, and biodiversity conservation. For each component, Probos describes the existing legal instruments, how oversight works, and where practices are still vulnerable.
Impact on certification
The outcome will determine how companies will demonstrate forest biomass compliance with the directive. Where national assurance is in place, referring to Level A is sufficient. For criteria that are not fully covered, an assessment based on the area of origin remains necessary, the Level B route. This clarifies which information auditors may base on Dutch policy and where area data remains essential.
Stakeholders can submit their responses to the draft report in November. Probos will incorporate the submissions into the final version. After completion, Better Biomass and other recognized schemes will publish the Level A document, allowing market participants to use it in certification processes for electricity, heat, and biofuels.
Frameworks and monitoring in the Netherlands
The assessment examines all regulations and their implementation, from the Environment Act and species protection to forest monitoring and compliance. The question is not only whether the correct regulations exist, but also whether they are effectively applied and monitored. It is precisely this combination of standards, supervision, and data that determines whether the Netherlands qualifies for a Level A approach.
The draft report can be found here RED-III Level A risk assessment for Dutch forests.
Source: Probos Foundation
