Biogenic emissions in carbon accounting
Biogenic emissions in carbon accounting
Biogenic CO₂ refers to carbon emissions that originate from biological sources such as plants, biomass, and biogas. When these materials are burned or processed, the carbon they contain is released back into the atmosphere. This is often assumed to be “neutral,” since the carbon was captured during growth. In reality, the impact depends on factors such as regrowth timescales and sustainable sourcing, making biogenic emissions more complex than they may seem, and their treatment in carbon accounting can significantly influence reporting accuracy and climate strategy.
In this blog, we explore how biogenic emissions are addressed in frameworks like the GHG Protocol, CSRD, SBTi and CDP, common pitfalls in reporting, and why it is essential for companies to take them into account.
How Leading Frameworks Treat Biogenic Emissions
The importance of biogenic emissions is increasingly echoed in EU policy debates. The European Commission now recognises biogenic carbon removals, particularly through land use and carbon farming, as a key pillar in its climate strategy. The European Biogas Association (EBA) welcomes the EU’s proposed target of a 90% greenhouse gas reduction by 2040 and highlights that biogas and biomethane can contribute not only to emission reductions but also to capture residual emissions, as a cost-effective and scalable pathway. These insights show that biogenic emissions should not be dismissed in corporate or regulatory climate accounting.
The GHG Protocol requires companies to report biogenic CO₂ separately from fossil emissions, rather than assuming they are zero. At the end of 2025, the GHG Protocol will publish a Land Sector and Removals Guidance to clarify how companies should account for biogenic products and related activities in GHG inventories, building on the Corporate Standard and Scope 3 Standard.
The CSRD and its climate standard ESRS E1 also require companies to disclose gross GHG emissions, including biogenic emissions, along with the methods and assumptions used. In fact, the latest suggested changes to ESRS (Exposure Drafts) still explicitly mention that companies shall disclose its biogenic CO2 emissions from the combustion or biodegradation of biomass separately from the emission scopes (E1-8), showing that EU regulators still find this topic relevant.
Beyond EU regulation, other frameworks reinforce this approach. The Science Based Targets initiative (SBTi) recommends that companies report direct biogenic CO₂ emissions and removals from bioenergy separately, and include them in the target boundary when setting and tracking science-based targets. Similarly, the CDP requires companies within module 7: Environmental Performance – Climate Change, to report biogenic emissions (including CO₂, CH₄, N₂O) separately when setting targets and reporting inventories, ensuring alignment with the GHG Protocol.
Examples of biogenic emission accounting
Organizations can address biogenic emissions in three steps:
- Identify sources such as biomass combustion, biofuels, or organic waste.
- Quantify using emission factors consistent with the GHG Protocol.
- Report separately from fossil CO₂, with clear methods and assumptions.
Key sectors contributing to biogenic emissions are industries utilizing biomass, including bioethanol production, biomass power plants, waste-to-energy facilities, and pulp and paper manufacturing. Some companies already apply this method in practice. Drax Group reports biogenic CO₂ as a separate “memo item” outside Scopes 1–3, consistent with the GHG Protocol. Similarly, Ørsted discloses biogenic emissions from its biomass combustion in its annual report, distinguishing them from fossil emissions to increase transparency.
Misunderstandings and opportunities
A common misunderstanding is that biogenic CO₂ is automatically “carbon neutral.” While it is true that plants and biomass absorb CO₂ during growth, the climate impact of releasing this carbon depends strongly on factors such as the timeframe of regrowth and the sustainability of the biomass source. Another pitfall is the tendency to exclude biogenic emissions from company reporting, which can lead to underestimating the total climate footprint. Both the GHG Protocol and the EU’s CSRD require these emissions to be disclosed separately, rather than omitted.
For companies, the treatment of biogenic emissions is no longer a technical side note but an integral part of credible climate reporting. Ignoring these emissions risks non-compliance with the CSRD and undermines the transparency investors and stakeholders increasingly expect.
At the same time, clear reporting creates opportunities. By separating and disclosing biogenic CO₂, companies can show alignment with international standards like the GHG Protocol and anticipate upcoming EU requirements. This not only ensures compliance but also helps position businesses as proactive in adapting to the evolving regulatory landscape.
Did this article spark your interest, or do you have any questions? Feel free to contact esther@2impact.nl
