Unfortunately, various sustainability conditions in the RED would have little consequence. For example, one repeated instruction is that harvesting trees should occur sustainably, but sustainable does not equal low carbon (Supplementary Note 5). Perhaps the strictest version of sustainability, often defended as a landscape approach, claims GHG reductions so long as harvest of trees in a country (or just one forest) does not exceed the forest’s incremental growth24,25,26,27. Yet, by definition, this incremental growth would otherwise add biomass, and therefore carbon storage to the forest, holding down climate change28. This carbon sink, in large part due to climate change itself, is already factored into climate projections and is not disposable. Harvesting and burning this biomass reduces the sink and adds carbon to the air just like burning any other carbon fuel. The directive only requires forests to maintain existing carbon stocks in limited circumstances, but given the size of the global forest sink, even applying such a rule everywhere would still allow global industrial wood harvests to more than triple (Supplementary Note 6)29,30.

The directive also repeatedly cites a goal to preserve biodiversity, but its provisions will afford little protection. Prohibitions on harvesting wood directly for bioenergy apply only to primary forests—a small share of global forests (Supplementary Note 5). In addition, any forests could be cut to replace the vast quantities of wood diverted from existing managed forests to bioenergy.

Some argue that increasing carbon in the atmosphere for decades is fine so long as reductions eventually occur, but timely mitigation matters. More carbon in the atmosphere for decades means more damages for decades, and more permanent damages due to more rapid melting of permafrost, glaciers and ice-sheets, and more packing of heat and acidity into the world’s oceans. Recognizing this need, the EU otherwise requires that GHG reductions occur over 20-years, but that timing does not apply to forest biomass (Supplementary Note 5).

Instead, the directive incorporates the view that forest biomass is inherently carbon neutral if harvested sustainably (Supplementary Note 5). Although the RED requires that bioenergy generate large greenhouse gas reductions, its accounting rules ignore the carbon emitted by burning biomass itself (Annex VI, section C, par 13 in ref. 31). They only count GHGs from trace gases and use of fossil fuels to produce the bioenergy, which is like counting the GHGs from coal-mining machinery but not from burning the coal.

The main new Commission thinking, reflected in the sustainability provisions, is that bioenergy rules do not need to count plant carbon so long as countries that supply the wood have commitments related to land use emissions under European rules or the Paris accord (RED, Article 26, point (6)(1)(ii)) (Supplementary Note 5). But this thinking repeats the confusion that occurred at the time of the Kyoto Protocol between rules designed only to count global emissions and laws designed to shape national or private incentives32. Under accounting rules for the UN Framework Convention on Climate Change (UNFCCC), countries that burn biomass can ignore the resulting energy emissions because the countries that cut down the trees used for the biomass must count the carbon lost from the forest. Switching from coal to biomass allows a country to ignore real energy emissions that physically occur there, but the country supplying the wood must report higher land use emissions (at least compared to the no-bioenergy alternative). The combination does not make bioenergy carbon free because it balances out global accounting, the limited goal of national reporting.

But this accounting system does not work for national energy laws. If a country’s laws give its power plants strong financial incentives to switch from coal to wood on the theory that wood is carbon-neutral, those power plants have incentives to burn wood regardless of the real carbon consequences. Even if a country supplying the wood reports higher land use emissions through the UNFCCC, that carbon is not the power plant’s problem. Only if all potential wood-supplying countries imposed a carbon fee on the harvest of wood, and this fee equaled Europe’s financial incentive to burn it, would European power plants have a financial reason to properly factor the carbon into their decisions. No country has done that or seems likely to do so.

In fact, few countries have any obligation to compensate for reduced carbon in their forests because few countries have adopted quantitative goals in the land use sector as part of the Paris accord33. Even if countries did try to make up for reduced forest carbon due to bioenergy with additional mitigation of some kind, all Europe would achieve is a requirement that its consumers pay more to do something harmful for the climate so that other countries could then spend additional money to compensate.

Europe has also created a kind of reverse REDD + strategy by treating forest and all other biomass as carbon neutral in its Emissions Trading System, which limits emissions from power plants and factories. While the not yet realized hope behind REDD + is to reward countries for preserving carbon in forests, this bioenergy policy means forest owners can be rewarded for the carbon in their trees—so long as they cut them down and sell them for energy. The higher the price of carbon rises, the more valuable cutting down trees will become. Strangely, this policy also undermines years of efforts to save trees by recycling used paper instead of burning it for energy. Even as recycling polices push consumers to save trees, this policy will encourage others to burn them.