It defines bioeconomy as the set of activities that deliver sustainable solutions based on biological resources to create added value—including products, services, scientific applications and technologies—in areas as diverse as agriculture, forestry, fisheries, aquaculture, biomass processing, manufacturing, biotechnology, food systems, health, energy and ecosystem and other services.
Biological resources include primary biomass (directly harvested biological material, such as crops, wood and aquatic biomass) and secondary biomass (by-products and residues from agriculture, forestry, fisheries, food processing and other bio-based activities), as well as biogenic carbon captured through innovative technologies.
According to data referenced by the Commission, the bioeconomy was considered to generate up to EUR2.7 trillion in value added in 2023 across bioeconomy-related sectors, supporting an estimate 60–62 million jobs. Demonstrating the bioeconomy’s growing economic weight across EU value chains.
The 2025 EU Bioeconomy Strategic Framework is a policy document that sets the Commission’s vision for the coming legislative cycle but does not itself create new legal obligations. It outlines an agenda for the coming years (principally 2026–2028), signalling where regulatory workstreams are expected to evolve.
As the Commission prepares implementing measures, delegated acts and potential legislative proposals to advance these priorities, companies should consider how this policy direction may interact with, and gradually reshape, existing binding frameworks.
The strategic relevance is already translating into concrete near-term watchpoints for companies and investors. Beyond the Framework’s headline ambition, the practical question for companies will be how quickly its themes translate into operable rules, funding criteria and market signals.
Over 2026–2028, businesses should actively monitor:
(i) follow-up implementing measures and delegated acts linked to product-policy and standardisation workstreams (including those affecting construction materials, packaging and claims substantiation
(ii) the evolving approach to public procurement as a demand-creation lever
(iii) certification/eligibility methodologies shaping carbon removal and biogenic carbon storage.
In parallel, access to finance may vary in practice depending on sector, project maturity and availability of suitable public and private financing instruments. Mobilising funding may therefore require early alignment with emerging eligibility criteria and documentation expectations.
Likely priority audiences for the Framework
In this context, the Framework is likely to be most immediately relevant for companies with bio-based dependencies, bio-based products input dependencies, bio-based portfolios, or scale-up investments linked to those emerging workstreams:
- Legacy materials and chemicals players diversifying into bio-based polymers, bio-based chemicals, and biomanufacturing (including energy majors pivoting into bio-based materials)
- Consumer goods and retail brands with heavy packaging footprints, seeking scalable compliant alternatives and credible claims
- Packaging, converters and materials manufacturers exposed to product requirements, recyclability constraints and definitions/certification
- Construction product manufacturers and developers using timber/biobased insulation and looking at carbon storage/certification pathways
- Agri-food, forestry and biomass aggregators commercialising residues/by-products and managing traceability/sustainability constraints
- Investors, project financiers and infrastructure funds underwriting first-of-a-kind plants, offtake structures and de-risking instruments
The sections that follow therefore outline the interfaces between the new Framework and the current legislative landscape, highlighting where future compliance expectations are most likely to tighten.
1. Closing investment gaps and scaling innovation
The Framework highlights persistent financing gaps across the bioeconomy value chain. The European Investment Bank identifies structural shortfalls in scale-up biomanufacturing, advanced bio-based materials and circular bioeconomy infrastructure—barriers that prevent promising innovations from reaching commercial maturity.
To address these gaps, the Commission foresees enhanced funding under the next Multiannual Financial Framework (2028–2034), including the European Competitiveness Fund, Horizon Europe’s biotech/agri/bioeconomy window, and continued blended-finance mechanisms via InvestEU, the European Circular Bioeconomy Fund (ECBF) and national promotional banks. From 2026, the Commission will improve access to finance and related services for start-ups and scale-ups via the Scale-up Europe Fund and new European Innovation Council instruments.
New enabling measures include a European Bioeconomy Regulators and Innovators’ Forum (2026), a Bioeconomy Investment Deployment Group (2026–2028), and the “Bio-based Europe Alliance” (CCT pilot) targeting EUR10 billion of collective offtake by 2030.
2. Lead markets for bio-based materials and technologies
The Framework aims to develop lead markets by aligning national and regional tools, including Common Agricultural Policy (CAP) Strategic Plans, National Energy and Climate Plans (NECPs), cohesion policy and national bioeconomy strategies.
The forthcoming revision of the Public Procurement Directives should further enable public-sector uptake of bio-based solutions.
Under the Packaging and Packaging Waste Regulation (PPWR), the Commission will assess whether EU-wide definitions and certification schemes can scale bio-based polymers. In construction, bio-based materials—wood, hemp, straw and fibre-composites—are highlighted as alternatives capable of reducing embodied carbon and building energy demand.
In 2026, the Commission will adopt standardisation requests under the Construction Products Regulation (CPR) (e.g., for doors and windows, structural timber products/elements and ancillaries, wood-based panels and elements, and thermal insulation products) and will develop a certification methodology under the Carbon Removal and Carbon Farming Certification Framework (CRCF) for long-lasting biogenic carbon storage in buildings.
The Framework also foresees accelerated pathways for biopesticides, soil improvers, microorganisms and recycled-nutrient fertilisers under chemicals and food/feed simplification packages. Additional workstreams include biogenic carbon storage, bio-waste collection and valorisation under forthcoming circular-economy measures (including the forthcoming Circular Economy Act), related product-policy developments, and voluntary markets through the Nature Credits Roadmap to guide voluntary, high-integrity markets that complement carbon farming. On biogenic carbon, the EU ETS review will explore recognising CRCF-certified permanent biogenic removals, and the Innovation Fund will support scalable Bio-CCUS.
3. Interfaces with binding legislation
Corporate Sustainability Reporting Directive (CSRD)
More generally, companies should expect an increased scrutiny of biodiversity impacts and dependencies under CSRD reporting. Transitions toward bio-based materials might trigger double-materiality under CSRD because they likely impact change: land-use, biodiversity dependencies, resource circularity and renewability, supply-chain resilience, sourcing traceability requirements.
These fall directly under ESRS E1 (Climate change), E2 (Pollution), E3 (Water and marine resources), E4 (Biodiversity and ecosystems) and E5 (Resource use and circular economy). Companies adopting bio-based solutions must therefore assess how these shifts affect climate mitigation pathways, nature impacts and circularity disclosures.
Corporate Sustainability Due Diligence Directive (CSDDD)
Bio-based value chains frequently rely on land-based agricultural or forestry inputs. This potentially increases human rights and environmental adverse impacts covered by CSDDD requiring stronger supplier risk assessments, screening mechanisms, contractual alignment and monitoring—particularly in geographies associated with environmental or social risks.
EU Deforestation Regulation (EUDR)
The Framework does not amend EUDR, but expanded use of EUDR-covered commodities—notably timber (construction materials) and natural rubber (advanced biomaterials)— are likely to increase compliance exposure.
Crucially, EUDR applies equally to EU-domestic and imported production: operators and traders sourcing these commodities within the EU must still provide geolocation, legality evidence, risk assessment and mitigation, and a due diligence statement in the EU system before placing on the market or exporting. As bio-based markets scale, companies can expect heightened supervisory expectations on traceability and verification.
Product and chemicals legislation
Bio-based products remain subject to:
- PPWR (Packaging and Packaging Waste Regulation)
- ESPR (Ecodesign for Sustainable Products Regulation)
- CLP (Classification, Labelling and Packaging Regulation)
- REACH (Chemicals Regulation)
“Bio-based” does not exempt products from performance, safety or recyclability obligations.
Legal context and considerations for companies
Although the 2025 Bioeconomy Strategic Framework is a policy document and does not introduce new legal obligations, several aspects may warrant early attention from a legal perspective. Building on the interface above companies may wish to monitor the following areas over 2026–2028:
Supply-chain considerations
Transitions toward bio-based inputs may increase exposure to land-use, biodiversity and traceability risks—already captured under CSRD (ESRS E1–E5) and CSDDD. For certain materials, particularly timber and natural rubber, the EUDR commodity list and associated CN codes will remain relevant.
Product and materials compliance
Bio-based alternatives continue to fall within existing EU product frameworks. Companies may need to consider whether changes in feedstocks affect classification, safety, eco-design or recyclability requirements.
Upcoming regulatory developments.
- Work expected in 2026–2027 includes the 2026 Energy Union package, which will reflect experience under the Renewable Energy Directive (RED).
- By 2027, in line with Article 3(3) RED, the Commission will publish a report on the impact of member states’ support schemes for biomass.
- In parallel, related developments—including carbon removal certification under the Carbon Removal and Carbon Farming Certification Framework (CRCF), measures under the forthcoming revision of the Public Procurement Directives, and circular-economy actions—may influence future compliance expectations.
How we can help
In summary, while the Framework outlines a trajectory, it might progressively shape in the near future reporting standards, due-diligence requirements and product obligations. Monitoring these developments can help companies anticipate where compliance pressures may evolve over the next legislative cycle.
This is also where targeted legal support may be helpful, in particular to:
- monitor forthcoming EU bioeconomy-related workstreams and translate developments into practical legal implications
- assess how bio-based transitions interact with CSRD/ESRS, CSDDD, EUDR and relevant product/chemicals regimes
- support internal readiness on supply-chain traceability, documentation and governance for audit and supervisory expectations
- advise on risk allocation and compliance positioning in commercial arrangements supporting bio-based inputs and products.
Links:
Bioeconomy Strategy - Environment - European Commission
