Europaudvalget 2024-25
EUU Alm.del Bilag 573
Offentligt
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J.nr. 2025-1356
Consultation response from Denmark:
EU-Commission New Bioeconomy Strategy
–
Towards a Circular, Regenerative, and Competitive Bioeconomy
June 23th 2025
The European bioeconomy stands at a critical crossroads. With mounting
challenges such as climate change, resource depletion, and increasing global
competition, there is an urgent need for the EU to accelerate its transition towards
a sustainable, innovative, and circular bioeconomy. This transition can contribute
to the EU’s climate targets by 2030 and climate neutrality by 2050, but not at least
for securing long-term
economic growth and EU’s competitiveness.
In particular, the growing global competition from especially the United States and
China underscores the pressing need for the EU to strengthen its position as a leader
in bio-based innovation and sustainable development. If we do not take action right
now, EU risks falling behind in the global competition for technological innovation
and economic leadership in this key sector.
Denmark therefore welcomes a new Bioeconomy Strategy as it is important for
safeguarding the
EU’s competitiveness,
resilience and green transition. Denmark
views the future strategy as a key opportunity to:
1)
Ensure EU’s
food, feed, material, pharmaceutical and energy security by
enhancing a responsible, efficient and sustainable production and
consumption of renewable biological resources, and thereby addressing
the biomass availability gap.
2) Create growth and new jobs in rural areas in all European countries by
developing innovative high value products and processes, new markets as
well as diversifying income opportunities for primary producers.
3) Deliver on climate targets, accelerate decarbonisation and support
development of landscapes that are resilient towards climate change,
protect biodiversity as well as deliver on water security.
4) Secure the competitiveness of the EU Bioeconomy and foster a strong
European investment environment.
In order to develop a circular, efficient, and sustainable value chain for the
Bioeconomy sector, Denmark proposes that the coming Bioeconomy Strategy
should include the whole bio-based value chain also the health, microbiology, food
and ingredients sector and have a strong focus on three issues:
1) scale up
2) cascading use
3) market pull
Ministeriet for Grøn Trepart
•
Vester Voldgade 123
• 1552
København V
[email protected]
•
www.mgtp.dk
 EUU, Alm.del - 2024-25 - Bilag 573: Notat og høringssvar vedr. Kommissionens høring om EU’s bioøkonomistrategi.
Scale up:
In order to scale up the production of sustainable biomass, bio-based
products as well as bio-based technological solutions to ensure EU
competitiveness on global markets, it is important to:
•
Improve and simplify access to finance for scaling up and developing test,
demonstration and production facilities as well as infrastructure in the
Bioeconomy sector by:
o
Addressing the late-stage funding gap through the Capital Markets
Union and increase use of de-risking tools, tailoring EU financial
instruments and simplify the application procedure for EU funds
towards
o
o
large-scale logistic, agricultural technologies and biotech projects
etc. and support clusters and centers of excellence.
Analyzing possible models for a European life science investment
fund, with the goal of establishing the fund through the European
Investment Fund (EIF) in order to attract institutional investors
that primarily invest in local venture funds and secondly include
syndication investments in life science companies.
•
Create and invest in a limited number of European world-class innovation
hubs to gain critical mass to rival the size, appeal and impact of major US
hubs.
•
•
Create better synergies with national and regional funding instruments.
Continue to support research and innovation in new types of biotechnology,
synthetic biology and molecular engineering for improved biological
processing, biological production and new bio-based high value products.
•
•
Ensure framework conditions for the replication of best-case projects e.g.
flagship projects.
Diversified biomass supply since large scale monocultures can lead to
biodiversity loss, soil degradation, and water resource depletion and
biodiversity is crucial for the future biomass supply as well as the future of
the Bioeconomy sector.
•
In order to promote innovation-friendly regulation within key regulatory
frameworks such as Novel Food, New Genomic Techniques (NGT), REACH,
feed additives, animal by-products, and Biocides. Concretely, we encourage
the Commission to:
o
Eliminate
unnecessary
administrative
burdens
without
compromising safety for humans, animals, nature and the
environment.
o
o
Take initiatives to propose a new regulation concerning New
Genomic Techniques (NGTs) in microorganisms.
Support regulatory sandboxes to test novel products, production
methods and business models in collaboration with regulators,
enabling faster market entry and regulatory learning.
•
Streamline approval
procedures in order to reduce “time to market” for bio-
based solutions within different product groups e.g. Novel Food, plant
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 EUU, Alm.del - 2024-25 - Bilag 573: Notat og høringssvar vedr. Kommissionens høring om EU’s bioøkonomistrategi.
protection products, feed additives and Biocides. This could be done by
pursuing the following actions:
o
Consider the possibility and effects of introducing a fast-track
approval procedure dedicated to microbiological and bio-based
solutions for example via EFSA.
o
o
o
o
Consider introducing Generally Recognized As Safe (GRAS)-like
procedures for selected biotech application .
Enforce stricter assessment deadlines.
Strengthen pre-submission guidance on data, testing and
protocols.
Shift approval focus more toward end products instead of process.
Cascading use:
Cascading use of biomass can contribute towards reducing the
expected biomass availability gap and simultaneously contribute to reducing the
dependency of fossil resources and enhance a responsible and sustainable use of
renewable biological resources for both food, feed, energy, materials and carbon
storage. Therefore, it is important to:
•
Promote cascading use of biomass as a core principle in energy, food and
industry through regulation or other incentives to maximize the value of
biomass.
•
Adopt principles from circular economy like reduce, reuse and recycle in the
Bioeconomy and cascading principles to extend the value of bio-based
materials and reduces the need for virgin biomass and waste generation.
•
Harmonize the implementation of the cascading principle across Member
States and provide guidelines for regulators on how to promote the
Bioeconomy without risking unsustainable production and us of biomass.
•
Strengthen the Single Market and increase awareness among Member
States regarding biomass availability and responsible use through
development of a better and simple EU biomass monitoring and availability
system.
•
•
Provide guidelines for regulators on how to promote the Bioeconomy
without risking unsustainable biomass pathways.
Promote sustainable and regenerative land use and cascading use as part of
the implementation of the Regulation on nature restoration (2024/1991)
with a specific focus on including the principles of cascading use in the
delivery on targets regarding agriculture ecosystems in the context of the
National Restoration Plans.
Market pull:
Biorefineries, cascading use and bio-based products must be
incentivized in order to establish a level-playing field compared to petrochemical
refineries and create bio-based value chains which are compliant with the principle
of cascading use. The transition towards more plant-based food and ingredients and
bio-based solutions will contribute towards a more sustainable use of responsibly
produced biomass as well as growth and jobs in rural areas. Further developing
simple and streamlined monitoring, reporting and verification (MRV) to better
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 EUU, Alm.del - 2024-25 - Bilag 573: Notat og høringssvar vedr. Kommissionens høring om EU’s bioøkonomistrategi.
account for e.g. carbon removal effects is important to support the development of
the market. The market pull could be strengthened through:
•
Financial or other incentives to use bio-based products as for example
carbon displacements/blend-in/circular use. It would be relevant to
specifically look at e.g.:
o
Development of technical screening criteria for biotechnological
climate solutions as enabling technologies based on the framework
developed by the Technical Working Group for enabling
technologies, in the context of the EU Taxonomy.
o
Promote production with less use of natural resources by actively
leveraging the provisions of the Ecodesign for Sustainable Products
Regulation (ESPR) to set requirements for recycled content and
product repairability.
o
o
Promote uniform regulation, measures and policy coherence at EU-
level of GHG emissions from the agricultural sector.
Support the development of simple and streamlined monitoring,
reporting and verification (MRV) for bio-based products and
materials to better account for carbon removal effects.
•
Strengthened farm level participation in the bio-economy to increase new
revenue streams for farmers while increasing decarbonization, reduced
negative impact on biodiversity as well as a sustainable and responsible
production, consumption and land-use through e.g. LCA. This could
include:
o
o
o
•
•
Rewarding farmers to deliver eco-system services.
Introducing carbon pricing mechanisms in the land sector to
incentivize farm level participation in the bio-economy.
Allowing farmers to capitalize on carbon farming initiatives, such
as reduced levels of GHG emissions or carbon sequestration.
Increased earmarking for decarbonization, biodiversity and environmental
efforts in the Common Agricultural Policy across the EU.
Development of an EU action plan on plant-based foods and focus on
diversification of supply of proteins for feed and food.
Finally, it is important that the Bioeconomy Strategy seeks synergy with the
upcoming Strategy for European Life Sciences and the Bioeconomy Strategy
should seek inspiration in recommendations from the Danish Life Science Council,
as a number of these recommendations are also highly relevant for a forthcoming
Bioeconomy strategy. Not at least the strategy should ensure a coordinated effort
across public and private stakeholders, have a holistic approach and cover the
entire ecosystem and focus on development of the strategy with a cross-sectoral
approach and organization across DGs in the Commission.
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