Forest Biomass Certification according to the DM of August 7, 2024

The DM of August 7, 2024, has for the first time extended the national sustainability certification system to forest biomass destined for the production of electrical and thermal energy. This regulatory innovation, awaited for years by the wood-energy sector, introduces specific requirements to guarantee the environmental and social sustainability of the forest-wood-energy supply chain, in line with the RED II Directive and the Consolidated Law on Forestry and Forest Supply Chains (D.lgs. 34/2018).

Following the entry into force of the decree, the Ministry of Environment and Energy Security (MASE) published a series of FAQ and answers to specific queries that clarify fundamental operational aspects for forest operators. This article analyzes these clarifications in detail, providing a practical guide to understanding how to correctly structure forest supply chains, identify who must be certified, and comply with sustainability requirements.

Why was forest biomass included in the certification system?

Before the DM of August 7, 2024, the national sustainability certification system exclusively concerned biofuels and bioliquids primarily intended for the transport sector. The extension to forest biomass responds to the need to ensure that the production of electrical and thermal energy from biomass fuels also meets rigorous environmental, social, and economic sustainability criteria.

The RED II Directive (2018/2001/EU) establishes that biomass fuels used in installations with a thermal capacity equal to or exceeding 20 MW (or 2 MW for gaseous biomass fuels) must meet specific sustainability criteria to access national support mechanisms. The Italian decree transposes these European provisions, adapting them to the peculiarities of the national forest supply chain, which is characterized by fragmented ownership and the presence of numerous small operators.

Forest biomass certification is not only a regulatory obligation to access incentives but also constitutes a tool to enhance sustainable forest management, guarantee the legality of harvesting operations, and promote traceability throughout the supply chain, from the felling site to the energy production plant.

How a forest biomass supply chain can be structured?

One of the main operational difficulties introduced by the DM of August 7, 2024, concerns the understanding of how the forest biomass supply chain must be organized for certification purposes. Unlike other more linear supply chains, the forest one presents considerable organizational complexity, with subjects who may hold multiple roles simultaneously or organize themselves according to very different territorial models.

The three main phases of the forest supply chain

The Ministry, in its responses to operators’ queries, clarified that three main sectors or phases can be distinguished in the forest-wood-energy supply chain.

The utilization phase includes all operations from the forest to the log yard (imposto), which is the clearing or open space where the timber obtained from forest cutting is stacked. In this phase, forest owners or specialized forestry companies operate directly, performing felling, delimbing, cross-cutting, and extraction (esbosco). The result can be structural timber, such as logs with or without bark destined for the sawmill, or material for energy biomass, which includes timber residues, processing waste, or whole lower-quality timber.

The primary processing phase takes place from the log yard until the first marketable product is obtained. Structured companies and businesses operate in this phase, such as sawmills, firewood producers, pellet production plants, or chipping plants. Activities include sawing to obtain rough structural timber, splitting and seasoning for firewood, chipping for forest chips (cippato), and pelletizing for pellets.

The secondary processing phase leads from rough woody material to a finished industrial product, such as furniture, window frames, or floors, or to the generation of the final energy service through direct combustion or cogeneration to produce electrical and thermal energy.

The main subjects in the forest supply chain

Various subjects can operate along this chain, each with specific roles and responsibilities. Forest owners include owners of wooded areas, whether they are private individuals, municipalities, public bodies, or managers of forest areas such as consortia or mountain communities. These subjects can decide to sell the standing timber or manage the cutting and sale operations of the woody material directly.

Forestry companies are the subjects who physically carry out the silvicultural and cutting operations. They can operate on behalf of the forest owner, limiting themselves to felling and extraction, or they can purchase the standing timber directly and manage the entire supply chain up to commercialization.

Secondary processing operators include producers of pellets, wood chips, firewood, and other solid biofuels. These subjects purchase the woody material from the forestry company or the forest owner and transform it into a standardized product ready for final use.

Collectors are intermediate figures who gather biomass from multiple sources, potentially carry out further processing such as chipping or drying, and then sell the material to power plant operators. They can manage temporary storage facilities and perform supply aggregation functions.

Power plant operators are the subjects who use forest biomass for the production of electrical and thermal energy. They can be thermoelectric power plants, cogeneration plants, or industrial thermal power plants. In some cases, these operators may also integrate vertically into the supply chain, purchasing the standing timber directly and managing all subsequent phases.

Who is the first economic operator in the forest biomass supply chain?

One of the most frequent questions from forest operators concerns the identification of the First Economic Operator who must be certified. The DM of August 7, 2024, establishes that in the forest biomass supply chain, the first economic operator is the manager of the first collection point.

The decree defines the first collection point as “the storage facility, treatment facility, or eventual felling site, managed directly by the economic operator, or by another counterparty to a contractual agreement, that procures raw materials directly from forest biomass producers.

Identification of the first operator based on the supply chain structure

The Ministry clarified that the identification of the first economic operator must be done on a case-by-case basis, depending on the specific organizational structure of the supply chain. There is no single solution applicable to all situations.

If the forest owner sells the standing timber to a forestry company, the latter becomes the first economic operator, as it proceeds with the felling, extraction operations, possibly chipping, and the sale of the biomass to the power plant operator or collector. In this scenario, the forestry company manages the first collection point and must therefore be certified.

If, on the other hand, the forest owner sells the timber and forest biomass directly and hires the forestry company to perform only the cutting of the trees as a service, the first economic operator becomes the forest owner themselves. In this case, the owner must be certified as they directly carry out the sale of the biomass.

A third possibility is represented by cases where the power plant operator purchases the standing timber from the forest owner and manages all subsequent operations directly: felling, delimbing, cross-cutting, extraction, transport, chipping, selection, drying, and final use. In this scenario of complete vertical integration, the power plant operator is the first and only economic operator in the supply chain.

The role of the fellers

The Ministry explicitly clarified that the feller who performs the mere felling operation is not subject to the certification obligation. However, if the feller also manages the storage or treatment facility for obtaining the biofuels destined for biomass-fueled power plants, then they become an economic operator and must be certified.

This distinction is fundamental because it makes it possible to exclude small woodcutters operating as service providers on behalf of the owner or other entities from the certification, concentrating the certification obligation on those who actually manage the physical and economic flow of the biomass.

Group certification for forest biomass

Given the fragmented ownership that characterizes the Italian forest sector, with thousands of small owners and operators supplying limited quantities of biomass, the DM of August 7, 2024, provides for the possibility of using group certification.

Who can form a group in the forest supply chain?

Group certification is a tool designed to aggregate multiple small operators under a single certification, reducing costs and simplifying procedures. According to the decree, economic operators involved in the production and harvesting phase of woody agricultural and forest biomass can form group certifications, as well as, in the case of waste less than 100 tonnes per year or residues, the economic operators where the waste or residues originate.The Ministry also introduced the figure of the intermediary within group certifications.

The intermediary is identifiable as the subject who collects the product from the producer and sells it to the group coordinator or the final user. It is essential that the intermediary has the physical possession of the goods and carries out loading and unloading operations, potentially including temporary storage.

Composition and functioning of the groups

A group can be composed of small forest owners, small-sized forestry companies, producers of residual biomass, and a coordinator who manages the overall certification. The coordinator is responsible for ensuring that all group members comply with the sustainability requirements and maintain the necessary documentation.

In the specific case of group certification where an agricultural cooperative grouping a number of agricultural or forest companies is present, the Ministry clarified that in the estimation of the sample to be subjected to verification, the total number of agricultural companies must be counted, not the cooperative as a single operator. This approach ensures that the verification is actually representative of the entire production base of the group.

What are the specific sustainability requirements for forest biomass?

The DM of August 7, 2024, establishes that forest biomass must comply with the sustainability criteria provided by paragraphs 10 and 11 of Article 42 of the D.lgs. 199/2021, taking into account the provisions of Implementing Regulation (EU) 2022/2448.

Demonstration of sustainability through national forestry law

A particularly relevant aspect, which has garnered consensus from all trade associations, concerns the possibility of demonstrating compliance with sustainability criteria by making use of existing Italian forestry legislation. The decree explicitly states that compliance with sustainability requirements can also be proven by leveraging the D.lgs. 34/2018 (Consolidated Law on Forestry and Forest Supply Chains – TUFF), EU Regulation 2023/1115 on deforestation, and documentation proving the traceability of woody biomass pursuant to the DM of March 2, 2010.

This means that for the forest sector, environmental sustainability is always guaranteed by adhering to the pan-European principles of Sustainable Forest Management (SFM), defined by the second Forest Europe conference held in Helsinki in 1993 and transposed by the TUFF. The national legislation on forestry aims at environmental and biodiversity protection, landscape conservation, and the prevention of hydrogeological instability and forest fires.

The execution of any silvicultural intervention throughout the national territory, whether on public or private property, is always subject to compliance with the principles of sustainable forest management transposed by the Regions and Autonomous Provinces in their own sector rules and regulations. These regulations identify and define, based on naturalistic silviculture, the ordinary forest management practices for their territorial, ecological, and socioeconomic contexts. Furthermore, the execution of any silvicultural intervention must be authorized by the competent authorities of the Regions and Autonomous Provinces.

Silvicultural interventions carried out in compliance with the current national and regional legislation, the Maximum Prescriptions and Forest Police referred to in R.D.L. 3267/1923, forest regulations consistent with the TUFF, and the conservation measures for Natura 2000 network sites and protected areas, guarantee positive or neutral impacts on ecosystem biodiversity.

Document checks and field inspections

For forest biomass, the certification body’s documentary verification must cover the sustainability of all land plots and the documentation or authorizations attributable to the forest lots. This implies that an operator may have multiple land plots, each of which may comprise multiple lots.

During the initial and surveillance verifications, the certification body must carry out on-site inspections to check compliance with sustainability criteria. The Ministry clarified that for forest operations, the inspection can be carried out during harvesting operations or at a time when crop residues are still present. The presence of stumps and mother trees is considered equivalent to the presence of crop residues, thus allowing compliance to be verified even after the conclusion of cutting operations.

In the case of group certification for products from the agricultural or forest phase, the Ministry confirmed that 20% of the land plots to be verified in the field must be calculated for each of the sampled agricultural or forest companies, thus ensuring an adequate level of control over the actual application of sustainable practices.

Admissible woody matrices and their qualification

Another fundamental aspect concerns the correct qualification of the different woody matrices that can be used for energy production. The Ministry has provided specific clarifications on various types of biomass.

Poplar groves and woody tree plantations

Dedicated woody crops, such as poplar and eucalyptus, fall under agricultural production and not forest production. This distinction is important because it involves the application of different verification procedures and the obligation to comply with the criteria relating to agricultural land provided by the decree.

Poplar groves and woody tree plantations are also included in agricultural activities. This classification reflects the intensive and planned nature of these crops, which substantially differ from the management of natural or semi-natural forests.

Residues from woody agricultural crops

Residues resulting from the pruning of vines, olives, and fruit trees, as well as uprooting and prunings of public green spaces, require correct qualification for certification purposes.

Tree rows, windbreaks, and hedges

Tree rows, windbreaks, and hedges perform crop protection functions, and their maintenance is carried out as part of the farm’s agricultural production. The Ministry clarified that the woody material resulting from these activities must be considered as a by-product of agricultural activities, thus facilitating certification management for farmers.

Urban green waste and public prunings

Prunings obtained from public or private green spaces must be considered waste as they are obtained from the execution of a service and not a production process. If considered waste, the woody material from the maintenance of urban green spaces, in order to be used in energy production as woody biomass, must undergo an end-of-waste procedure or be used within a facility authorized for waste treatment.

Fluvial wood and riparian material

A particular issue concerns the recovery of woody material taken from riparian areas. The Ministry clarified that this activity must be considered a forest matrix because the collection of vegetation resulting from natural seasonal turnover processes, transported by floods and deposited in riverbeds and adjacent state-owned areas, is entirely comparable to the harvesting of woody material in the forest.

Generally, the operations that allow the recovery of these materials are subject to authorization or concession by local authorities with jurisdiction over the state-owned areas concerned. Therefore, recovery operations cannot be assimilated to the provision of a service but are part of a production process by which the agricultural or forest company procures woody biomass as a raw material.

This interpretation remains valid even when companies participate in tender calls issued by local authorities for hydraulic maintenance purposes, provided the tender includes the localization, estimation, and acquisition of the quantity of woody material to be harvested. In this case, although the entity requests a service, there are converging interests: the company has a primary interest in procuring biomass, and the local entity has an interest in removing obstacles to water flow.

Economic operators exempted from certification

The DM of August 7, 2024, provides specific exemptions from the certification obligation for some categories of operators. Correctly understanding these exemptions is fundamental to avoiding unnecessary compliance efforts.

Small occasional forest operators

One specifically exempted category concerns producers of residual solid agricultural biomass derived from occasional processing who supply the biomass, for a total annual amount not exceeding 1,000 tonnes, to a power plant operator configured as an economic operator.

This exemption also includes biomass resulting from uprooted or wind-snapped trees, clean-up operations, and cutting in case of extreme weather events such as storms or tornadoes. The goal is not to burden operators who intervene sporadically or in emergency situations with certification obligations.The Ministry clarified that for these exempted operators, those who receive the waste or residues must still ensure the accurate maintenance of traceability, introduction documentation, and the mass balance for said materials.

Automatic exclusion from the closing verification

The Ministry confirmed that the new types of economic operators excluded from the certification obligation according to the National Scheme can be exempted immediately and will therefore also be exempted from the closing verification required in case of certification cessation.

Carriers and other exempted figures

Carriers who provide service for third parties remain exempted from the certification obligation, provided they do not take ownership of the biomass and do not carry out commercial intermediation functions.

Traceability and mass balance for forest biomass

The traceability system represents the central element of forest biomass sustainability certification. Every economic operator must be able to document the origin of the biomass, the quantities moved, the transformations undergone, and the final destinations.

Mass balance system

The decree requires all economic operators to apply a mass balance system that allows checking the consistency between the quantities of biomass entering and leaving each phase of the supply chain.

In the case of forest biomass, the mass balance must take into account several aspects. Firstly, natural losses due to moisture: fresh timber can lose significant amounts of weight during seasoning or drying. Secondly, processing waste: chipping operations, cleaning of bark or soil, and other processing can generate material losses.

The system must allow each batch of biomass to be uniquely identified through an alphanumeric code that includes the certification body’s identification code and the economic operator’s identification code. For forest biomass, the physical location where the first collection point occurred must also be indicated.

Declarations of Sustainability

Each economic operator, accompanying every batch sold, issues a Declaration of Sustainability to the next economic operator, drafted according to the models provided by the decree.

Specific timings and deadlines for forest biomass

The deadlines for forest biomass certification present some specificities compared to other biofuels, considering the particular organizational complexity of the sector.

The extension to June 30, 2026

The decree recognizes the peculiarities of the solid biomass sector by granting a further extension until June 30, 2026, to complete the certification process. Operators who intend to benefit from this extension must have signed and accepted the quote for sustainability certification with the certification body within the previous deadlines and demonstrate the concrete start of the certification process.

This extension was provided to allow forest operators, timber harvesting and processing companies, and pellet and wood chip producers to gradually adapt to the new and more stringent forest sustainability requirements. The sector welcomed this provision, which recognizes the need for time to organize documentation, train personnel, and structure traceability systems.

Gradual application of sustainability criteria

Article 21 of the decree establishes that the sustainability criteria for forest biomass are to be complied with starting 9 months after the date of entry into force of the ministerial decree. This transitional period allows already active operators to adjust their operating procedures to the new requirements without interrupting activity.

During this period, operators can continue to operate according to previous methods, provided they simultaneously initiate the process of adapting to the new requirements. At the end of the 9 months, all operators who intend to access incentives must be fully compliant.

Sanctions and Non-Conformity management in the forest sector

The decree introduces an articulated system for managing non-conformities, with particular attention to the specificities of the forest sector.

In the event of a minor non-conformity detected during the initial verification, the Ministry clarified that the request can be resubmitted after only 3 months, instead of the 9 months provided for critical or relevant non-conformities. This provision, introduced by the ministerial FAQs, facilitates the certification process for operators who present easily resolvable issues.

For critical non-conformities found during a surveillance or renewal, resulting in the revocation of the certificate, 9 months must elapse before the company can submit a new certification request.

Retroactive cancellation of declarations

The Ministry confirmed that in the event of a critical non-conformity, certificates can be retroactively cancelled. This provision has significant consequences for the entire downstream supply chain of the non-compliant operator, as the Declarations of Sustainability issued lose validity with retroactive effect.

Non-conformity in certified groups

In the case of group certifications, the Ministry clarified that a critical non-conformity detected on a group member does not automatically lead to the revocation of the certificate held by the coordinating entity. The certification body proceeds with a further verification on another sample. Only if the non-conformity extends to more than 50% of the sampled members does the non-conformity apply to the entire group.

For the individual member subject to critical non-conformity, although not formally explicitly stated in the decree, temporary suspension from the group should apply.

Closing verifications and transfer between certification bodies

The new decree introduces the obligation of a closing verification in specific circumstances, representing a significant change from the previous system.

Decree’s specific aspects: energy production and final users

The decree extends specific requirements to final users producing electrical and thermal energy from forest biomass, clarifying the scope of the obligation.

Certification obligation for users

The definition of “user” is broad and includes “every natural or legal person who uses biofuels for energy purposes other than transport.” This means that the obligation is not limited to electricity generation plants but extends to all plants that use biomass fuels, including direct combustion for heat production.

MASE confirmed that:

• Plants that produce biogas through anaerobic digestion and subsequent combustion, if they use certified forest/agricultural matrices in the mixtures, are also included in the scope.
• For biogas plants converted to biomethane, a single sustainability certificate covering both activities may be issued, simplifying administrative management.

EU ETS and Advantages of Voluntary Certification

A relevant aspect concerns operators subject to the EU Emission Trading System (EU ETS). These can now voluntarily certify their use of biomass to demonstrate the zero emission factor of the biomass used. This provides a direct advantage in the accounting of emissions for ETS purposes. For these operators, it is crucial that the biofuel suppliers are also certified, ensuring traceability and sustainability throughout the supply chain.

Timing of issuance

For newly constructed plants, the company certification can be issued immediately after the successful outcome of the initial verification and the completion of commissioning procedures. This regulatory measure allows operators to immediately start selling the product with the declaration of sustainability as soon as the plant becomes operational, minimizing the risk of losing incentives due to bureaucratic delays in certification.

Calculation and traceability: Greenhouse Gas (GHG) Emissions

A technical pillar of the decree is the methodology for calculating Greenhouse Gas (GHG) emissions associated with the forest biomass supply chain.

Methodology and Unit of Measurement

The calculation of emissions must follow the methodology provided by Regulation (EU) 2022/996, using the standard European unit of measurement in gCO₂eq/MJ (grams of CO2​ equivalent per megajoule) to compare the climate impact.

It is fundamental to note that for forest biomass, there are no minimum mandatory emission reduction thresholds, unlike for biofuels. However, compliance with SFM (Sustainable Forest Management) does not exempt the operator from actually calculating the emissions associated with their specific supply chain.

Key emission factors

In the GHG calculation, operators must consider the entire life cycle:

• Harvesting and processing: fuel consumption of chainsaws, forest excavators, chippers, and other machinery.
• Transport: transport from the forest to the log yard, up to the final user.
• Processing and drying: electricity consumed for chipping/pelletizing and, crucially, the emissions associated with the eventual artificial drying of the woody material.

Certificative classification of forest products

The Ministry has provided clarifications on the qualification of finished products and by-products for the purpose of the certification obligation.

• Wood Chip as finished product: forest wood chip (cippato) is considered a finished product as it is a ready-to-use biofuel for energy production. The wood chip producer must therefore issue a Declaration of Sustainability as a final product, certifying the correct traceability and mass balance of the preceding phases.
• By-products and certification Obligation: activities that generate by-products must necessarily be subject to certification if not expressly excluded by the decree. This ensures that even secondary woody material, if sold for incentivized energy production, complies with sustainability criteria and is properly tracked throughout the supply chain.

Towards RED III

The certification system is dynamic and will evolve with the future transposition of the RED III Directive (2023/2413/UE), which will further tighten sustainability requirements.

New strengthened criteria are anticipated, focusing on biodiversity protection and minimizing impacts on soil quality. The Ministry’s approach is to await the transposition of RED III before introducing further significant changes, ensuring regulatory stability for operators. Furthermore, greater digital integration and the use of electronic platforms are expected to simplify traceability and the effectiveness of controls.

Frequently asked questions on Forest Biomass Certification

Who must be certified first for Forest Biomass Certification?

The manager of the first collection point (Forest Owner, Forestry Company, or User, depending on the contractual structure).

Must small properties be certified?

No, they can join a group certification coordinated by an aggregator (e.g., cooperative, consortium).

Is a forest certification (FSC/PEFC) mandatory?

No. Compliance with national and regional forestry legislation (TUFF and authorizations) is sufficient to demonstrate sustainability.

How much time do I have to comply to Forest Biomass Certification?

Up to June 30, 2026, to complete the process, provided the process has been concretely started.

Can fluvial wood be certified?

Yes, it is considered certifiable forest biomass, provided the collection is authorized by the competent bodies.

What happens if I change Certification Body?

It is mandatory to conduct a closing audit with the previous CB before the transfer.

The Certification of Forest Biomass as a strategic investment

The certification of forest biomass according to the DM of August 7, 2024, is a fundamental step to guarantee access to incentives and to position oneself as a credible actor in the energy transition. The intrinsic complexity of the supply chain requires a personalized approach and in-depth knowledge of the ministerial clarifications. Investing today in correct implementation means not only guaranteeing compliance but also enhancing Italian forest management and accessing an expanding energy market.

Do you need to certify your forest biomass supply chain according to the DM of August 7, 2024?

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