127 submissions from 109 organizations told the European Commission what they think about this file. Here is what each of them said, in their own words.
The Commission received 149 submissions on this file. Shown here: the 127 from organizations. Not shown: 6 from private individuals. Their submissions are personal data; the Commission publishes them under its own legal basis, and republishing them by name here would need one we do not have. Organizations act in a public capacity, so their positions are public record. Also not shown: 16 further submissions we do not publish for other reasons: no quotable text (a comment under 250 characters and no readable paper), no organization named, or a private person who filed under their own name. About this data →
RapporteurVille Niinistö (Greens/EFA)
Published in the Official Journal · 21 Apr 2023
Signed · 19 Apr 2023
PLENARY_ACTIVITY · 17 Apr 2023
Approval of the EP's first reading position by the Council (adoption of the legislative act) · 28 Mar 2023
Discussions within the Council or its preparatory bodies · 23 Mar 2023
Who showed up
71 submissions from industry — companies and their trade associations — against 38 from civil society: NGOs, consumer organizations, environmental groups and trade unions. That is 1.9 industry submissions for every one from civil society.
Industry 71Civil society 38Public authorities, academia, other 18
Groupings use the respondent type each organization selected when filing. Counting submissions, not organizations — a body that filed twice is counted twice.
What the room declares
60 of 109
in the EU Register
353
full-time lobbying staff
€37.8M+
declared costs a year
223
EP accreditations declared
Self-declared to the EU Transparency Register (snapshot 14 Sept 2026). The cost figure sums band floors, so the true total is higher.
The file, right now
The consultation closed on 8 Nov 2021 — it ran from 15 Jul 2021.
www.bauernverband.de Stellungnahme des Deutschen Bauernverbandes zur Änderung der Verordnung (EU) 2018/841 - „LULUCFVerordnung“ B erlin, 08.11.2 02 1 Allgemeine Anmerkungen Aus Sicht des Deutschen Bauernverbandes ist das Bekenntnis zur Berücksichtigung des Kohlenstoffbindungspotentials des Sektors Landnutzung, Landnutzungsänderung und Forstwirtschaft (LULUCF) ein zu unterstützendes Signal im Handeln gegen den…
Filed in German · English published by the European Commission
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
We welcome the Commission’s commitment to create a regulatory framework for the consideration of emissions and removals from LULUCF and its contribution to achieving the climate objectives of the European Union for 2030 and 2050.
Filed in Spanish · English published by the European Commission
Copa and Cogeca take note of the new proposal for the revision of the Land Use, Land Use Change and Forestry (LULUCF) regulation. The review of the regulation, which is set in the context of the 2030 climate policy ambitions, puts forward a new regulatory setting that presents new challenges and opportunities for the agriculture and forestry sectors, the only sectors capable of providing not only carbon…
The proposed revisions to the LULUCF Regulation would provide for a framework to incentivise EU Member States to commit to more climate-friendly land use. In this regard, carbon sinks would be key for EU Member States.
To stay ahead in the global race for the best climate and energy technology solutions, companies need a clear and reliable fit-for-55 implementation plan providing a clear commitment to Europe as an attractive business, investment and innovation location.
The trade association Svensk Torv supports more ambitious LULUCF objectives and sees in detail that peatlands and peat extraction are to be included in the accounts from 2026 onwards. We are keen to showcase the positive climate action that our industry contributes when, without external funding, we look after our catchment areas to attractive natural areas, while at the same time making the peat useful for arable…
Filed in Swedish · English published by the European Commission
CIA — Italian farmers welcoming the opportunity to provide feedback to the Commission’s Proposal to amend Regulation (EU) 2018/841. CIA is one of the broad agricultural organisations in Europe and its representations more than 900, 000 full members in Italy: Farmers and agricultural business owners.
Filed in Italian · English published by the European Commission
Please find attached a document containing comments on: Flexibility mechanism In relation to the CO2 rights market — Infringement of fundamental rights by appropriation of private property without compensation. The initiative does not address biomass excesses, nor their regulation. There is a need to adequately enhance the supply of feedstock substitutes for hydrocarbon products
Filed in Spanish · English published by the European Commission
November 05, 2021 Response to the public consultation on the proposal for revision of the Land Use, Land Use Change and Forestry Directive (LULUCF) Sonae is a multinational corporation that manages a large portfolio of retail, financial services, technology, wood-based panels, shopping centres and telecommunications businesses, creating value across various geographic areas.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
The Spanish magnesia industry fully supports the objectives of the European Green Deal, as well as the “Goal 55” package aimed at reducing net greenhouse gas emissions by at least 55 % by 2030, as set out in the European Climate Law.
Filed in Spanish · English published by the European Commission
Forest owners are concerned about the new carbon reduction target of 310 million tonnes of CO2 equivalent, which could lead to a reduction in the quantities harvested in sustainably managed forests. A possible decline in harvest levels hampers the active contribution of forests to the fight against climate change.
Filed in German · English published by the European Commission
Please see full position paper on the LULUCF propsal from the Swedish Forest Industries attached. Forests are one of the most important solutions to addressing the effects of climate change as they provide important carbons sinks absorbing and storing large quantities of CO2 and supplying raw materials to substitute fossil resources.
IFOAM Organics Europe welcomes a revision of the current LULUCF regulation to ensure its contribution to the EU climate goals. While climate mitigation should clearly focus on absolute emissions reductions, carbon sequestration in the land use sector has also a crucial role to play to meet the long-term climate objectives.
MOL Group’s proposal for introducing flexibility to access negative emission credits generated from land use, land-use change, and forestry (LULUCF) project in the European Union’s Emission Trading Systems (industrial ETS and new road transport and building ETS) To stimulate additional, long-term actions in the land use sector to achieve a climate-neutral land sector in 2035 in the European Union, and to help…
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
The Bioenergy Association of Finland welcomes the Commission proposal to revise the accounting methodology from 2026 onwards. Accounting becomes easier and more transparent and is consistent with the new formulation of the EU 2030 climate target adopted as part of the EU Climate Law. We also support the phased approach (2021-2025, 2026-2030, 2030+) the Commission has presented.
The Swedish Wood-Fuel Association welcomes the Commission’s recognition of the LULUCF sector’s contribution to mitigate climate change. Since 1990 both the forest area and the volume of growing stock have continued to increase in all regions in Europe. The sector is one of the most important sectors in the Green Deal and the only sector that can produce green circular biobased products and energy.
Climate protection is a task for society as a whole which, in addition to the effective reduction of CO2 emissions and the expansion of renewable energies, requires a fundamental transformation into climate-friendly products and processes in the coming years.
Filed in German · English published by the European Commission
Climate protection is a task for society as a whole which, in addition to the effective reduction of CO2 emissions and the expansion of renewable energies, requires a fundamental transformation into climate-friendly products and processes in the coming years.
Filed in German · English published by the European Commission
Bioenergy Europe welcomes the opportunity to provide feedback on the proposed LULUCF regulation. Overall, Bioenergy Europe is concerned that the current draft is neither suited to support the transition to a bioeconomy nor to phase out the use of fossil materials and energy.
The Confederation of European Forest Owners (CEPF) welcomes the Commission’s recognition of the LULUCF sector’s contribution to mitigate climate change. However, CEPF has concerns on the new carbon removal target of 310 Mt of CO2e that may lead to reducing harvesting levels in forests which are currently sustainably managed.
Neova Group supports the Commission’s ambitious climate policy and actions towards a more sustainable future where local products would be promoted, biodiversity would be enhanced, and pollution would be minimised. Regarding the LULUCF regulation, Neova Group argues that the role of horticultural peat should be understood from a holistic perspective and regulation should not be overly burdensome.
EUSTAFOR welcomes the opportunity to discuss and give feedback on the recently proposed amendment of the LULUCF Regulation. Although it has been so far often communicated that in order to achieve the increased 2030 climate target and the climate neutrality by 2050 objective, it will be necessary to sequester more greenhouse gases from the atmosphere, how exactly this will be accomplished still remains very unclear.
Yara International welcomes the European Commission’s efforts to design an ambitious Fit for 55 regulatory package, and in particular the proposal that all GHG emissions and removals from agriculture, forestry, other land uses and land use change are considered in combination.
The Ger. Landowners’ Org.(FABLF)WELCOMES the EC’s efforts to combat clim. change and to pave the way for a transformation towards a greener economy.Nevertheless,WE FEEL OBLIGED TO POINT OUT some structural weaknesses that jeopardise the proposed goals in the EU Green Deal and in the amendment to the LULUCF Reg.2018/841 (draft) as presented on 14.7.21.(1)The draft aims at future CO2 storages within the LULUCF…
Stellungnahme Änderungsvorschlag zur Verordnung über die Einbeziehung der Emissionen und des Abbaus von Treibhausgasen aus Landnutzung, Landnutzungsänderungen und Forstwirtschaft Die Europäische Kommission hat im Juli 2021 einen Vorschlag zur Änderung der Verordnung (EU) 2018/841 über die Einbeziehung der Emissionen und des Abbaus von Treibhausgasen aus Landnutzung, Landnutzungsänderungen und Forstwirtschaft…
Filed in German · English published by the European Commission
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
With this, we urge that the methodology for reporting and accounting for national greenhouse gas (GHG) emissions from horticultural peat in the Land Use, Land-Use Change and Forestry (LULUCF) sector wetlands category are to be reviewed in a transparent and unbiased manner. It is not correct to assume that all extracted peat is immediately oxidised, so the instantaneous oxidation method must be refused.
Helen Ltd. thanks the European Commission for the opportunity to give feedback on the Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL amending Regulations (EU) 2018/841 as regards the scope, simplifying the compliance rules, setting out the targets of the Member States for 2030 and committing to the collective achievement of climate neutrality by 2035 in the land use, forestry and agriculture…
The draft amendment to the LULUCF Regulation sets much more ambitious targets for the land use sector than the current Regulation. The proposed EU target for the removal of 310 million t CO2eq in 2030 will be a major burden and challenge for many of the Member States, which will be difficult to meet in the face of current projections of removals and threats to forests from climate change.
Filed in Polish · English published by the European Commission
Build Europe supports the EU’s environmental objectives and ambitions, and welcomes the objective to turn Europe into the first carbon neutral continent by 2050. Build Europe's full feedback is in the attachment. The current regulation requires Member States to ensure that the LULUCF sector does not generate net emissions.
We thank you for submitting comments on the proposal for the revision of the LULUCF Regulation. The RGO notes with satisfaction that the revision implies a future target for sinks in the LULUCF sector at EU level, which is burdened to Member States.
Filed in Danish · English published by the European Commission
Cepi represents the European pulp and paper industry and gathers, through its 18 member countries, some 895 pulp, paper and board mills across Europe directly, employing more than 180,000 people. Our sector is investing at a rate of more than €5 billion per annum, increasing our production volumes while simultaneously reducing our carbon footprint.
In view of the continuing deterioration of climate change with the continued untapped release of fossil CO2 caused by the exploitation of underground coal, oil and natural gas deposits, the agricultural and forestry sectors must urgently focus on maintaining our livelihoods in the region.
Filed in German · English published by the European Commission
The already adopted EU climate protection law with a net climate target enables the economy to compensate its emissions with natural sinks. DUH had already criticized the watering down effect for the 2030 target and called for the introduction of a separate target for the conservation and expansion of sinks.
Consultation responses to LULUCF — revision of EU rules from We thank you for providing input to the EU review of the LULUCF Regulation. Please find below our comments: Although the new overall target of 310 million tonnes for 2030 is higher than the current level and much higher than the projected level for 2030 of 225 million tonnes, it is not ambitious enough.
Filed in Danish · English published by the European Commission
Make Negative emissions an explicit part of Fit for 55 already now With the urgency to build a completely new industry for negative emissions where the commitment of governments to engage in this task must be ensured without delay, negative emissions should already now become part of the Fit for 55 package.
The Association of Owners of Municipal, Private and Church Forests in the Czech Republic (SVOL) welcomes the Commission’s recognition of the contribution of the LULUCF forestry sector to climate change mitigation.
Filed in Czech · English published by the European Commission
Stora Enso supports the EU’s climate ambitions enshrined in the European Climate Law and the corresponding 55% emissions reductions target. Forests and the European forest industry play a key role in mitigating climate change.
The Northern Sparsely Populated Areas network, NSPA, represents the interests of the four northernmost regions of Sweden (Norrbotten, Västerbotten, Jämtland Härjedalen and Västernorrland), the seven eastern and northernmost of Finland (Central Ostrobothnia, Kainuu, Lapland, North Karelia, Northern Ostrobothnia, Pohjois-Savo and South Savo), as well as the two northernmost regions of Norway (Nordland, Troms &…
Carbon Market Watch welcomes the opportunity to respond to the LULUCF proposal. We would suggest improvements in three main areas: 1. AFOLU pillar Combining non-CO2 agriculture emissions from the ESR with land-based sinks from the LULUCF under an AFOLU pillar is problematic for several reasons: A. It will not incentivize emissions reductions in the agriculture sector, where progress has been slow.
EDA calls upon the EU Commission to develop cost-efficient policy tools in the context of the LULUCF revision. Such implementation tools should be in line with the EU environmental commitments and at the same time should not undermine food safety, quality, security, affordability and the European food culture, and should not damage nutrition and health.
The European Landowners’ Organization (ELO) strongly supports the goals set by the EU and the Paris Agreement to combat climate change. We believe forestry and land use play a crucial role in this regard. Therefore, the ELO is alarmed by the LULUCF Regulation amendment proposal. In the proposal, the use of forest materials is limited: forests should grow as carbon sinks.
MTK welcomes COM proposal to review LULUCF EU rules. MTK's feed-back includes aspects of proposed calculation methodology, ambition level, compatibility with Paris Agreement, compatibility with coming initiative on restoring sustainable carbon cycles, voluntary carbon market mechanisms, general flexibility, establishing AFOLU, flexibilities of the framwork and environmental integrity.
Finnish Forest Industries’ response to the consultation on the LULUCF regulation Finnish Forest Industry Federation Industry (FFIF) silver that the FF55 package including LULUCF will provide regulatory stability which promotes the industry’s investments in climate friendly products and production as well as in sustainable forestry.
Filed in Finnish · English published by the European Commission
In order to meet the internationally agreed climate targets, in addition to an effective and rapid reduction of greenhouse gas (GHG) emissions, removals of greenhouse gases from the atmosphere are necessary in order not to increase emission levels further (‘1.5 °C target’), to offset residual emissions by GHG sinks and to achieve GHG neutrality.
Filed in German · English published by the European Commission
CDP Europe supports the adoption by the European Commission of the new LULUCF Regulation to guide the land use sector to contribute to the EU´s Emission reduction target. As the IPCC highlighted, 24 to 30% of the mitigation potential to keep global warming well below 2 degrees depends on the ability to stop deforestation and ecosystem degradation, whilst stimulating the restoration of degraded forest and land.
Bayer Crop Science appreciates the opportunity to comment on the proposal of the European Commission for the revision of Regulation EU 2018/841 on greenhouse gas emissions (GHG) and removals from Land Use, Land Use Change and Forestry (LULUCF). We welcome the revision’s fresh focus on enhancing carbon sinks and the new sensitivity toward boosting carbon removals across the landscape and including agriculture.
Cefic welcomes the European Commission’s ‘Fit for 55’ package and supports strong action on climate change in line with the scientific advice provided by the Intergovernmental Panel on Climate Change (IPCC). We welcome the European Commission’s ‘Fit for 55’ package as a crucial step towards the EU climate-neutrality objective by 2050.
The DAFC support the strong focus on carbon removals as part of the EU’s enhanced climate ambition since it constitutes an important step towards the climate target for 2030 and 2050. With the revision of the LULUCF regulation the Commission proposes to incentivize carbon removals through certification of carbon removals in the period until 2030.
Amending Regulation (EU) 2018/841 and (EU) 2018/1999 – Land use, land use change and forestry: Submission from SBP Introduction SBP is a multi-stakeholder, voluntary certification scheme designed for solid woody biomass used in large-scale energy production.
At the outset, it is stated that the first problem is that carbon depletion in the land sector has declined in recent years: due to increasing harvest rates in connection with wood demand and forest aging, persistent emissions from organic soils, natural disasters and a lack of political and financial incentives.
The Danish Chamber of Commerce is positive about a green progressive line from the EU Commission. We support the higher ambitions of the LULUCF Regulation. As a starting point, common EU rules are unequivocally good for Danish companies, as they provide more equal conditions of competition in the EU's internal market.
In the context of this draft amendment to the Regulation on Land Use and Forestry for 2021-2030 (LULUCF), the European Commission proposes to combine a stricter contribution from the LULUCF sector as a further step in reducing greenhouse gas emissions from agriculture beyond CO2 emissions with the land use, land use change and forestry sector, thereby creating a newly regulated land sector that covers emissions and…
Filed in German · English published by the European Commission
The revised LULUCF-regulation annouces major change in European climate policy by the foreseen merger of agricultural non-CO2 emissions with LULULCF emission beyond 2030. Therefore a thorough impact assessment is necessary, which also investigates the impact for the individual farmer (administration, cost of efforts, additional income, …).
The Confederation of Norwegian Enterprise (NHO) and its Nordic sister organisations supports the EU/EEA ambition of net-zero greenhouse gas emissions (climate neutrality) by 2050 to reach the objectives of the Paris Agreement. NHO would like to refer to our feedback to the parallel Roadmap of updating the EU emissions trading system (ETS) and Effort sharing regulation (ESR).
We strongly support the option to strengthen the current LULUCF regulation and increase its ambition in line with 2030. The EU should aim to double the absorption of CO2 by sinks by 2030. More ambitious goal of doubling CO2 removal through sinks should be achieved by: - successive implementation of the EU Biodiversity strategy for 2030 – strict protection of old and natural forests that are much more effective in…
WWF fully supports strengthening the LULUCF Regulation in order to incentivise the substantial increases in carbon dioxide removal through the restoration of forests and other ecosystems that are urgently needed to limit global temperature rise to1.5°C. However WWF strongly opposes the suggestion that this be achieved by facilitating offsetting with the ESR or ETS sectors.
The European Commission stresses the importance of a just and inclusive transition to climate neutrality. CELPA — Papermaking Association welcomes the 2050 climate neutrality target. While the 2030 climate target has increased to 55 %, CELPA emphasises the importance of not relying much on forest sinks due to the likelihood of increased natural disturbances in the near future.
Filed in Portuguese · English published by the European Commission
This contribution is made on behalf of France Nature Environnement (FNE), the French Federation of Nature and Environmental Protection Associations. The full contribution is attached. FNE recalls that: — In order to achieve the carbon neutrality targets in 2050, emission reductions need to be promoted first.
Filed in French · English published by the European Commission
UECBV supports the overall ambition to act on climate change and finds it essential that the agricultural and forestry sector contributes to the debate on climate action. It profoundly supports the initiative to significantly raise the sustainability standards in the EU in a harmonized way.
Reasons why delayed harvest and storing carbon in forests is not the optimal climate solution. It is essential to safeguard the carbon sequestration in forests and other lands. But one must keep in mind that the forestry and agricultural systems are dynamic and fulfill several functions in parallel.
As stated in the Roadmap, to achieve the increased 2030 climate target and the climate neutrality by 2050 objective, it will be necessary to sequester more greenhouse gases from the atmosphere. EUSTAFOR believes that, especially with the ongoing negative climate change impact on forests, this will only be possible with a proactive approach, applying sustainable forest management (SFM) practices that improve the…
Setting a goal of climate neutrality by 2050 is to take unacceptable risks. Emissions have to stop much earlier. The consequences of being wrong about at which atmospheric CO2 levels irreversible effects set in are catastrophic. EU climate policy should follow the precautionary principle (cf. Paragraph 2 of article 191 of the Lisbon Treaty) and be based on the dire warnings from leading climate researchers.
PFPI comments on amendments to the LULUCF Regulation November 26, 2020 The Partnership for Policy Integrity appreciates the opportunity to comment on the inception impact assessment (IAA) for the Amendment of the Land Use, Land Use Change and Forestry Regulation (EU) 2018/841.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Copa and Cogeca and their member organizations support the overall ambition to act on climate change and find it essential that the agricultural and forestry sector contributes to the debate on climate action. European farmers, forest owners and their cooperatives have been successful in reducing green-house gas emissions and increasing the carbon sink significantly in past three decades and in contributing…
By decreasing harvest rates & protecting older natural forests, carbon will continue to be absorbed & stored in the soil. Emissions from forest harvesting are not fully accounted by the LULUCF Regulation. Instead, harvested wood products (HWP), which include paper products & wood used for energy, are considered as CO2 removals.
The European Green Deal, adopted by the Commission in December 2019, aims to neutralise the intensification of climate change in the next decade and to achieve the goals of the Paris Agreement. The objective of climate neutrality by 2050 is one of the central mechanisms of European Union (EU) action.
Filed in Portuguese · English published by the European Commission
The Danish Agriculture & Food council (DAFC) welcomes the Commission’s effort on climate action and supports the joint work on the 2030-climate target as well as the objective of climate neutrality in 2050. DAFC urges the Commission to pursue cost-effective CO2-reductions such as reductions within the emission trading system.
Stora Enso fully supports the Commission’s climate ambitions; we need to reduce our emissions by at least 55% by 2030. The forest industry plays a key role in this green transition and tackling climate change. We are the renewable materials company, providing solutions in transition to circular bioeconomy.
CCFD-Terre Solidaire (CCFD-TS) supports strengthened LULUCF rules in order to transform the policy into a real lever to reach EU climate and biodiversity targets. CCFD-TS recalls that in order to keep temperature rise below 1.5°C, GHG emissions need to be drastically reduced at source, and (and not or) natural carbon sinks must be enhanced.
The Bioenergy Association of Finland supports a well-prepared transition towards EU’s climate neutrality by 2050. Climate change is a transboundary problem, where coordinated EU action can supplement and reinforce national and local action efficiently. A profound question in the proposed revision of the LULUCF regulation is its envisaged contribution to the enhanced EU 2030 Climate Target.
The Swedish Forest Industries (SFIF) supports a strengthened 2030 climate target and climate neutrality by 2050. It is, however, important that a holistic and inclusive approach is applied when defining the contribution from forests, forestry and forest-based products.
Bioenergy Europe welcomes the initiative to align LULUCF rules with the new 2030 climate target, paving the way for carbon neutrality by 2050. While the mention of carbon farming initiative within the Farm to Fork Strategy and the certification of carbon removals part of the Circular Economy Action Plan are relevant, the roadmap does not divulge details on the main drivers for land use: the Common Agricultural…
25.11.2020 Eni’s position on the Revision of EU Emissions Trading Scheme, Effort Sharing and LULUCF Regulation Eni supports the European Commission in the effort to strengthen the current EU climate policy framework in order to enable it to cope with the increased EU climate ambition.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
The review of the EU LULUCF regulation must end allowing member states to reduce their forest sinks as currently planned by many (by means of projected forest reference levels allowing to further increase wood harvesting). Declining sinks are equivalent to increased emissions and therefore goes against the Paris Climate Agreement.
• We welcome the proposed EU LULUCF Revision, alongside the ambitious package of enhanced policies and measures to accelerate the energy transition to a low-carbon economy. We support the European Commission’s approach to consider a emission reduction contribution from all sectors, providing the right policy mix, ensuring cost efficiency across all sectors, but also guaranteeing a clear transition pathway in all…
Fern agrees that the focus should be improving accounting and data gaps, as well as increasing carbon sequestration from land. However, the suggestion that this should be done through land-use trading with other sectors is seriously flawed and may further aggravate disincentives to proper forest management.
Enviva is a leading global energy company specializing in sustainable wood bioenergy. Our mission is to provide an alternative to coal and grow more trees. We do this by producing sustainable, renewable wood pellets and delivering them to customers around the world.
Suomen luonnonsuojeluliitto (The Finnish Association for Nature Conservation) is the oldest and biggest environmental non-governmental organization in Finland. We would like to make the following points concerning the LULUCF regulation. Emissions in the EU must be cut at least 65 % by the year 2030 in order to keep the global temperature rise to 1.5 °C.
Finnish Energy welcomes the Commission’s preliminary thoughts on the content of the impact assessment and policy options. In addition to those, Finnish Energy calls for the market creation for carbon removals and clarification the use of international units. Carbon removal technologies (CRT) are important in a post-Paris world (IEA 2016 CCS report).
Carbon Market Watch - Response to Inception Impact Assessment on LULUCF Regulation Carbon Market Watch (CMW) supports increasing the climate ambition of the LULUCF Regulation so it can promote climate action, while providing much needed co-benefits in other environmental fields (especially biodiversity and restoration of ecosystems). CMW also supports the feedback from Climate Action Network Europe and Fern. 1.
How Responsibly Produced Peat can contribute to LULUCF goals Foundation Responsibly Produced Peat (RPP) is aware of the importance of intact peatlands and the reduction of CO2 emissions from degraded peatlands. We believe that responsible peat production can contribute to LULUCF's goals.
Growing Media Europe AISBL (GME) is a non-profit association representing the producers of growing media and soil improvers on European level. Growing media are essential in society as they contribute (on a strongly increasing level) to growing food and to greening urban areas (trees, flowers, parks etc.). Growing in growing media in a controlled environment (e.g.
Climate Leadership Coalition (CLC) is a non-profit organization committed to the pursuit of carbon-neutrality through the sustainable use of natural resources. During the first six years CLC has become the largest European climate business network when measured by the number of members.
NGO Green Pärnu County (MTÜ Roheline Pärnumaa) is grateful for plan to the strengthen of the LULUCF regulation with the aim to protect and restore the forests needed to sequester carbon dioxide in the effort to keep climate change below 1.5 degrees.
Essenscia supports the European ambition to reach climate neutrality and considers that any increase in the 2030 targets should be in line with this ambition and in line with realistic innovation evolutions. The introduction of sinks as means to balance emissions is a valid, long-term perspective and will require the establishment of a solid accounting system, including in the LULUCF sector.
The key elements for forests and forest-based sector to combat the climate change are Substitution, Sequestration and Storage. Forests are unique in doing all this at the same time. All sectors must carry their responsibility in the path towards climate neutrality by 2050.
The Forest is an important CO2 sink, and should be fully incorporated in the climate ambitions of the European Community. However, this does not mean a stop to forestry as the forest is an important source of raw materials for building, paper, chemicals and energy. The forest is both a sink, a source for substitution and naturally a sequestration. These three benefits must be balanced with biodiversity.
The planned revision of the LULUCF is premature and will not allow for a full review of the forestry solutions currently adopted, which required extensive preparation and input from Member States. The methodology of the guidelines adopted to determine the National Forest Settlement Plans is very complex and two expert reviews were needed in order to be adopted (no Plan was adopted after the first review).
Filed in Polish · English published by the European Commission
I refer to the entire opinion in annex, which covers all open policy areas and includes general policy considerations. On the revision of the LULUCF Regulation The age class distribution in forests (partial population ageing), the evolution of tree species, as well as the increasing biotic and abiotic damage events, inevitably lead to lower CO2 uptake during the forest conversion phase, towards climate-resilient…
Filed in German · English published by the European Commission
We welcome the strengthening of the LULUCF regulation with the aim to protect and restore the forests needed to sequester carbon dioxide in the effort to keep climate change below 1.5 degrees. However, this must not lead to a decrease of efforts to reduce emissions in other sectors with the hope of off-setting them through LULUCF removals.
I support the goal of the European Commission in revising its LULUCF regulations and recommend that revised policies properly factor in the carbon trade-offs of different land uses. 1. The goals of increasing the land carbon sink and increasing the harvest of wood for the “bioeconomy" are in tension.
Climate Action Network (CAN) Europe supports strengthening the LULUCF Regulation in order to both safeguard our natural environment and biodiversity and to improve carbon dioxide removal through protection and the restoration of forests and other ecosystems.
The Danish Forest Associations feedback on the European Commission Inception Impact Assessment: Amendment of the Land Use, Land Use Change and Forestry Regulation The need to amend the LULUCF Regulation is based on the fact that the European forests has to sequester and store more carbon and keep on doing it in the future. Only managed forest can rise to that challenge.
St1 Nordic Oy welcomes the initiative to review LULUCF, with an aim to increase carbon sinks to 500 Mt CO2eq./a by 2050. Now,the sinks are declining. A key contributor to the negative trend is that activities related to carbon sequestration are currently not sufficiently rewarded. In EU policy framework, the EU trading of land-based carbon removals is currently limited to the Member State level.
The European Commission highlights the importance of just and inclusive the transition towards the climate neutrality. Cepi welcomes the climate neutrality target 2050. Even though the climate target 2030 has been increased to 55%, Cepi stresses the need to avoid relying on the sink function of the forest to meet the target.
The European Woodworking Industry is fully behind the objectives of the European Green Deal and offers the potential to decarbonise key economic sectors such as construction. Timber buildings are globally recognised as key allies in climate change mitigation strategies: they represent an immediate way to achieve long-term carbon storage in products - as mentioned in the 2020 Circular Economy Action Plan - and they…
Please find attached the feedback of EOS, the European Organisation of the Sawmill Industry. Through its member federations and associated members, EOS represents some sawmills in 12 countries across Europe (Austria, Belgium, Croatia, Denmark, Finland, France, Germany, Latvia, Norway, Romania, Sweden, Switzerland) manufacturing sawn boards, timber frames, glulam, decking, flooring, joinery, fencing and several other…
We welcome the strengthening of the LULUCF regulation with the aim to protect and restore the forests needed to sequester carbon dioxide in the effort to keep climate change below 1.5 degrees. However, this must not lead to a decrease of efforts to reduce emissions in other sectors with the hope of off-setting them through LULUCF removals.
Better rules and incentives on LULUCF are needed to be implemented. The Czech republic has been severely damaged by intensive agriculture and forestry. Soils are depleted, mountain catchments degraded. Soil carbon content is minimised. Active river floodplains (forests, meadows) have been drained and made arable.
The key elements for forests to combat the climate change are Substitution, Sequestration and Storage. Forests are unique in doing all this at the same time. All sectors must carry responsibility in the path towards climate neutrality by 2050.
C/ Cristóbal Bordiú 19-21 28003 Madrid Tel.: [phone removed] Fax: [phone removed] [email removed] www.ingenierosdemontes.org COLEGIO OFICIAL DE INGENIEROS DE MONTES REGISTRO DE SALIDA NÚMERO: 131 FECHA: 26/11/2020 OBSERVACIONES A LA REVISIÓN DE LAS NORMAS DE LA UE RELATIVAS AL USO DE LA TIERRA, CAMBIO DE USO DE LA TIERRA Y SELVICULTURA D.
Filed in Spanish · English published by the European Commission
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Wood-based products and sustainable forest management will play an important role when achieving climate neutrality for 2050 as proposed by the Commission in Green Deal. Our industry is up to the challenge. We are contributing to mitigating climate change by decreasing fossil emissions and by bringing novel and traditional products from renewable resources into markets while simultaneously the European forest…
We fully support the objective of aligning the regulatory framework to an EU-wide target to reduce emissions by 55% in 2030 (compared to 1990 levels) and with the goal of becoming a climate-neutral economy in 2050, while ensuring a just transition. We welcome the Commission’s inception Impact Assessment on Amending the Land Use, Land Use Change and Forestry Regulation (LULUCF) - (EU) 2018/841.
New forest reference levels should be set immediately by an independent scientific body, and should be based on either a true comparison of forest levels against 1990 levels, or better, a projection of the desired outcome – i.e., an expansion of growing, healthy natural forests that are sequestering carbon on a trajectory to an ambitious target for 2050.
Natural Resources Institute Finland (Luke) welcomes the proposed increase of the EU emission reductions target for 2030, and the opportunity to provide feedback to the Commissions revision of LULUCF regulation. We notice that in the Context description the initiative fully recognizes the need for substitution of fossil-based materials with bio-based ones (e.g. use of wood in construction).
We welcome the strengthening of the LULUCF regulation with the aim to protect and restore the forests needed to sequester carbon dioxide in the effort to keep climate change below 1.5 degrees. However, this must not lead to a decrease of efforts to reduce emissions in other sectors with the hope of off-setting them through LULUCF removals.
FEP – the European Federation of the Parquet industry – is welcoming the EC Inception Impact Assessment on the “Amendment of the Land Use, Land Use Change and Forestry Regulation (EU) 2018/841”. Taking the offered opportunity to comment this Impact Assessment, FEP would like to make the following remarks: - The Regulation should be fully coherent with the EU Green Deal, the new Circular Economy Action Plan and the…
We welcome the strengthening of the LULUCF regulation with the aim to protect and restore the forests needed to sequester carbon dioxide in the effort to keep climate change below 1.5 degrees. However, this must not lead to a decrease of efforts to reduce emissions in other sectors with the hope of off-setting them through LULUCF removals.
Feedback from FederlegnoArredo on the Inception Impact Assessment on the Amendment of the Land Use, Land Use Change and Forestry Regulation (EU) 2018/841 FEDERLEGNOARREDO is the Italian Federation of woodworking and furniture industries. FederlegnoArredo represents about 2600 enterprises in the sector, from industry leaders to SMEs.
This submission is on behalf of Drax Group. Drax Group became Europe’s largest decarbonisation project by upgrading its existing facility from using coal to sustainable woody biomass and is now also piloting Europe’s first bioenergy with carbon capture and storage project (BECCS), which, if successful, will allow Drax to become carbon negative by 2030.
Cefic supports Europe’s ambition to become climate-neutral by 2050. We acknowledge the EU’s desire to significantly accelerate the transition, in order to increase our chances to reach climate-neutrality by 2050. Increasing the 2030 level of ambition can secure a balanced reduction pathway towards 2050 and redistribute in time the transition effort towards climate-neutrality.
The European Compost Network (ECN) is glad to share its vision on the role of recycled bio-based compost to help the European Commission in the amendment of the LULUCF Regulation. The European Compost Network operates at European Level for almost 20 years and gathers researchers, practitioners, experts, and companies with the aim to provide advice on sustainable bio-waste management and recycling.
Thank you for the opportunity to provide feedback on the inception impact assessment for the amendment of the LULUCF Regulation (EU) 2018/841. This submission is on behalf of the US Industrial Pellet Association (USIPA), a trade association consisting of sustainable biomass producers in the Southeast US as well as others in the bioenergy supply chain - www.theusipa.org The Commission, through the proposed revision…
Until now meat and dairy production have been exempt from the emissions trading scheme. This is surprising as the emissions involved are relatively accurately known. It may be impractical to implement it at producer level, because each individual farm only contributes a small amount to the total, so collecting the relatively small amounts would not be cost effective.
EBA strongly support the goal of the European Commission to sequester more greenhouse gases from the atmosphere. We also confirm that the current EU policy framework need to be revised in order to achieve a better harmonization of national trading and incentive schemes for land-based carbon emissions and removals.
• After forests and forest owners are (and a fortiori become) affected by climate change, the starting point for climate change policy must always be a realistic view of the overall situation: How many additional THGs can still sustain the atmosphere as a whole in order not to exceed what level of global warming? How much of this comes from the EU?
Filed in German · English published by the European Commission
We welcome the fact that the EU Commissioner, through the LULUCF Roadmap, intends to take account of current developments in agriculture and forestry. Agriculture and forestry are directly affected by climate change. They are also part of the solution and must therefore play a central role in the future EU climate policy.
Filed in German · English published by the European Commission
The European Panel Federation (EPF), welcomes the Inception Impact Assessment on the Amendment of the Land Use, Land Use Change and Forestry Regulation and the opportunity to provide feedback on the intended initiative.
Harnessing the potential of the LULUCF Regulation will be essential for achieving the goals of the EGD. With the climate neutrality target (by 2050) in mind, the ETS should be geared towards immediately incentivising also negative emissions (“carbon removal solutions”). In its projections the EU integrated negative emissions before 2050.
Business Finland is the Finnish innovation funding, trade, investment, and travel promotion organization, fully owned by the Finnish government. We recognize the strategic importance of the EU Green Deal and support the increased ambition level of 2030 and 2050 emission reduction targets.
Mediterranean agroforestry landscapes are special landscapes within the EU, characterized by having co-evolved with human beings over centuries. In fact, they are recognized as a "cultural landscape" and their values are associated with human management, which generates mosaic landscapes.
Eduardo Rojas-Briales (Professor in Forest Science, UPV, Spain) The key role of forests for climate change is widely recognized in its 3 dimensions: a) Preserving and enlarging the C stocks either by increasing forest area or stocks/ha b) Using forest products (wood, cork, bamboo) as long lasting materials locking C for longer periods, basically in construction c) Substituting non-renewable materials with high…
The European Agroforestry Federation (EURAF) represents organisations in 20 European States working to increase the use of trees on farms. These widely spaced trees, lines of trees and small copses are usually not on forest land, and we feed it necessary to improve the way in with Member States (and Associated States) report the impact of trees outside the forest on GHG emissions.
Fortum supports a separate target for greenhouse gas emission reductions and carbon removals. The proposal for at least 55% emission reductions should be absolute and it should not include carbon sinks. Also the use of flexibilities from the LULUCF sink should be limited to the current level until there is a robust and trustworthy enough MRV system in place.
Dear EU members, Concerning Land use, land use change & forestry, the Collectif Scientifique National pour une Méthanisation raisonnée (CSNM) would like to point out several issues. Methanization is actually promoted strongly in quite all EU member states, and outside EU.
ePURE, representing the European producers of renewable ethanol from crops, waste and residues, supports the Commission’s proposal to increase the 2030 EU GHG emissions reduction target to 55% compared to 1990, as an intermediate step to reach climate neutrality by 2050.
Further development of the LULUCF Regulation Mitigating climate change and its consequences is undoubtedly the biggest challenge for mankind today. Climate change (droughts, storms, pests, etc.) also threatens forest ecosystems themselves.
Filed in German · 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.
