Which sustainability rules apply to our biomass: rice husk, wood, bagasse or animal waste?
It depends on the type. Residues from farmland need plans to manage soil quality and soil carbon. Crops grown for the purpose face land rules on biodiversity, carbon stock and peatland. Forest biomass has its own tests. Animal waste, fish by-products and similar streams have no sustainability criteria in the directive.
By type of biomass
- Residues from agricultural land, not forestry: operators or national authorities must have monitoring or management plans addressing impacts on soil quality and soil carbon.
- Agricultural biomass, the main crop and its residues: no raw material from land with high biodiversity value that had that status in or after January 2008, no land converted from high carbon stock land, and no biomass from former peatland unless there was no drainage of undrained soil.
- Forest biomass, including forestry residues: tests to limit unsustainable forest production, plus land-use and forestry criteria.
- Other biomass such as animal waste and by-products, and products or residues from aquaculture and fisheries: no sustainability criteria in the directive.
Waste is treated more lightly
Where no default value exists for a waste or residue, its life-cycle emissions at the point it becomes waste may be taken as zero if the emissions of growing and first processing can reasonably be put on the main product. Then only transport to your site and any processing before burning count. For the biomass fraction of municipal or industrial waste, the greenhouse gas saving check may be left out if the other factors are negligible.
Show it is really waste
For the streams with no criteria, keep evidence that the material is a waste or residue and was not deliberately changed or contaminated to qualify as one. Some certification schemes classify borderline cases.
Next step
Sort every biomass fuel you burn into these four groups, then ask each supplier for the matching proof.
What Senseible does here
Senseible reads your fuel, power and steam bills into verified emission records, so the monthly fuel quantities behind a monitoring plan are ready to hand to your verifier. Verified here means rule checks passed against the evidence. It is not third-party assurance, and a CBAM verifier still signs the report.
Sources: European Commission, CBAM Guidance No. 3, calculation of embedded emissions
Last reviewed 2026-11-04.