Land use, land use change and forestry – establishing trajectories towards 2030
21 submissions from 21 organizations told the European Commission what they think about this file. Here is what each of them said, in their own words.
The Commission lists 35 submissions on this file. Shown here: the 21 from organizations. Not shown, by design: submissions from private individuals, which we never publish, and anything filed since our last weekly refresh.
Who showed up
14 submissions from industry — companies and their trade associations — against 5 from civil society: NGOs, consumer organizations, environmental groups and trade unions. That is 2.8 industry submissions for every one from civil society.
Industry 14Civil society 5Public authorities, academia, other 2
Groupings use the respondent type each organization selected when filing. Counting submissions, not organizations — a body that filed twice is counted twice.
The file, right now
The consultation closed on 12 Dec 2025 — it ran from 14 Nov 2025.
Policy area
Climate (DG CLIMA)
Where it stands
Awaiting adoption
Adoption expected
31 Dec 2025
How it got here
Draft implementing regulation12 Dec 2025
Also on the Commission’s pipeline for this file, with no date recorded: Initiative planned, Implementing regulation.
The German Farmers’ Association recognises the importance of climate protection and the fundamental role of the land use, land use change and forestry (LULUCF) sector in supporting European climate goals. At the same time, since the revision of the LULUCF Regulation in 2021, significant challenges to offset residual cross-sectoral emissions have been transferred to actors in this single sector.
Filed in German · English published by the European Commission
Unfortunately, the net sink target in the LULUCF Regulation and subsequently also in the draft implementing regulation for Regulation (EU) 2018/841 must be regarded as technically unrealistic. The possibilities to store additional carbon in agricultural and forestry land are limited. On the contrary, due to the effects of climate change, releases are even more likely to occur, especially in forests.
Filed in German · English published by the European Commission
We welcome the opportunity to provide feedback on the draft implementing act setting annual GHG removal limits under the LULUCF Regulation for the period 20262029. Following up on this important pillar for carbon emission neutrality in the European Union is crucial. Setting the LULUCF target paths for 2026 to 2029 provides the necessary planning security and continuity for climate policy goals within this sector.
The German Forestry Council is pleased to contribute to this consultation. Forests in Germany and Europe are suffering from the effects of climate change, increasing periods of drought, storm damage, and insect infestations. Forest owners are committed to preserving and sustainably managing forests.
The Federation of Swedish Farmers (LRF) welcomes the opportunity to comment on the proposed development trajectories for Land Use, Land Use Change and Forestry (LULUCF) up to 2030. As a representative of Swedens farmers and forest owners, LRF supports ambitious EU climate goals but urges that targets and methodologies be realistic, science-based, and supportive of both climate, bioeconomy and rural development.
We welcome the Commissions intention to review the national greenhouse gas inventory data as well as to set the annual limit values. Taking into account current situation and latest scientific knowledge, we propose to amend Latvias annual limit values.
From a forest owners perspective, the current LULUCF trajectories are neither realistic nor well designed to support effective climate mitigation. They impose STEEP, annually binding removal targets on the forest sector which is already weakened by drought, storms, pests, ageing stands and costly conversion towards more climate resilient forests.
Filed in German · English published by the European Commission
The Finnish forest industries support ambitious EU climate policy and contribute to climate solutions through bio-based products that replace fossil-intensive alternatives and store bio-based carbon. Based on domestic renewable raw materials, wood, the sector strengthens Europes self-sufficiency, resilience, economy, and employment.
Union of Unions appreciates the opportunity to comment on the draft Implementing Regulation setting annual limit values on net removals for Member States for the period 2026-2029. Spain shares the EU’s climate objectives, but considers it essential that the methodology and interpretation of trajectories adequately reflect the biophysical and structural characteristics of the agricultural and forestry sectors in each…
Filed in Spanish · English published by the European Commission
Stora Enso welcomes the opportunity to provide input regarding the establishment of LULUCF trajectories for 20262029. We strongly support the EUs climate ambitions and, as a major actor in the European forest sector, are committed to the Science Based Target initiatives (SBTi) 1.5°C pathway. As such, Stora Enso is targeting a 50% absolute reduction in Scope 13 COe emissions by 2030 and reaching net-zero by 2040.
German forest owners point to structural mismanagement of LULUCF traps and their impact on forests, wood and bioenergy. The current design overwhelms a crisis-affected sector, narrows national room for manoeuvre and shifts climate risks and costs unilaterally to forest owners and the forest-based value chain.
Filed in German · English published by the European Commission
The German Bioenergy Association (Bundesverband Bioenergie e.V., BBE) considers the EU LULUCF targets and trajectories for Germany to be politically determined, biophysically unrealistic and economically counterproductive. The EU targets were set without adequately considering key natural constraints such as ecosystem dynamics, age structure and health status of forests.
The Great Lakes and Wetlands Association welcomes the opportunity to submit its observations about the trajectories towards 2030: 1) one third of the EU27 calculates with decreasing LULUCF sink: NL, PT, EE, DK, LU, SI, SK, RO, IT. Considering the intertwined biodiversity and climate crises, this is unacceptable.
Since the initial targets were established, Latvias natural and economic conditions have changed significantly. Alterations in forest age structure, drought events, pest outbreaks and other climate-related pressures have reduced forest growth.
The LULUCF regulation and its insufficient consideration of climate change effects and external factors in scenario development, the omission of substitution effects through biogenic materials and energy sources, and methodologically inaccurate sectoral allocations are leading to incorrect assumptions about the actual sink performance of the LULUCF sector and thus to illusory regulation targets.
Ministry of the Environment of the Czech Republic welcomes the opportunity comment on the Draft Commission Implementing Regulation (EU) setting out annual limit values for net greenhouse gas removals of Member States for the period 2026-2029 pursuant to Article 4(5) Regulation (EU) 2018/841 of the European Parliament and of the Council.
EOS, the European Organisation of the Sawmill Industry, calls on policymakers to: Make LULUCF targets flexible and realistic, reflecting natural forest dynamics and the essential role of climate adaptive forest management. Recognize the climate value of HWPs, with higher accounting weights and a dedicated reporting category for structural wood applications.
The Austrian wood industry association supports the European Union’s climate neutrality objectives and is committed to an ambitious European climate policy. However, achieving these objectives requires a regulatory framework that reflects both the ecological realities of forests and the potential of wood use.
Filed in German · English published by the European Commission
The revised Regulation (EU) 2018/841 (LULUCF) introduces new binding targets for Member States to generate additional land-based removals by 2030. The target is unrealistic and is increasingly becoming a burden on the forestry industry. In some countries, such as Austria, Germany, and Luxembourg, timber stocks per hectare have already reached saturation point and cannot be increased further.
The Industrieverband Garten (IVG) welcomes the European Commissions initiative to define binding pathways for the land use, land-use change and forestry (LULUCF) sector up to 2030. Horticulture and the growing media industry are directly affected by these developments, as political decisions on peatlands, biomass resources and land management have immediate consequences for plant production and resource…
The revised Regulation (EU) 2018/841 (LULUCF) introduced new binding targets for Member States to generate additional land-based removals by 2030. These targets are accompanied by national linear trajectories establishing national budgets, in terms of emissions and removals, for the period 2026-2029.
Filed in Italian · English published by the European Commission
Method. Every quote is verbatim from the organization’s own submission to the European Commission, trimmed to its opening passage and never summarized by a model. Where a submission was filed in another EU language we show the English text the European Commission publishes alongside it, labeled on the quote; the original is one click away at the source. Groupings use the respondent type the organization itself selected when filing. We deliberately do not label anyone “supportive” or “opposed” — you read what they wrote and draw your own conclusion. Organizations only, never individuals. Reused under Commission Decision 2011/833/EU; the European Commission is not liable for this reuse.
