Report on the evaluation of the LULUCF Regulation

The Forum on Forests and Climate Change appreciates the opportunity to provide the following comments on the evaluation of the LULUCF Regulation. Our entity is a non-profit association made up of forest sector organisations and other related Spanish entities and companies, which, since 2004, has unanimously defended the role played by forests in the face of climate change.

Filed in Spanish · English published by the European Commission

Sweden is clearly one of the countries that needs strong guidance, and most likely punishments, for not living up to its LULUCF obligations. Our national targets will certainly not be met, and the government has even presented actions to make them even harder to reach (e.g. by lowering gasoline prices).

Growing Media Finland acknowledges that LULUCF removals must be in the toolbox of reaching the 2040 and 2050 climate targets. However, the track record since 2018 in practical carrying out of LULUCF regulation has not been very encouraging starting from its overall target of 310 Mt for the EU in 2030, which is unrealistic due to many uncertainties in forest growth, inventory data and methodological misconceptions…

The European Commission is charting the path to making the EU climate-neutral by 2050 and thus recommends a 90% net greenhouse gas emissions reduction by 2040 compared to 1990 levels. We agree that this is a needed minimum, and further underline the scientific proof that this can not be achieved without a fundamental shift within land use in general, and forestry in particular.

The revised LULUCF Regulation represented a welcome improvement from the previous version, as it established an EU target for CO2 removals in land and forests for 2030, with mandatory targets for each Member State. However, WRI would argue that the overall target in the next version of the LULUCF regulation to take effect from 2025 should be more ambitious than the current 310 MtCO2.

Ladies and gentlemen, I speak here as Chair of Hümmling-Süd Forest Protection Cooperative in Lower Saxony. We worry foresters about the meaning of the planned LULUCEF Regulation! I hope you have the respect for the work we do and read what I want to tell you in brief. In the following, I will show you why it is counterproductive to make it harder for forest owners to work with even more laws.

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The land sector plays a key role in achieving the socially desired and politically decided goal of climate neutrality in Europe. Only additional carbon sinks will it be possible to offset unavoidable residual emissions from, inter alia, construction and agriculture. However, from the point of view of the German Farmers’ Association, it is important to put this achievement on a broad footing.

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RMK welcomes the discussion about LULUCF. We hereby share our observations: 1. According to the scientific publications, analyses and data we cannot reach the EU climate goals with current LULUCF methodology. Already in 2013 Nabuurs et al., found that the carbon sink of European forests is saturated.

The European Commission is charting the path to making the EU climate-neutral by 2050 and thus recommends a 90% net greenhouse gas emissions reduction by 2040 compared to 1990 levels. We agree that this is a needed minimum, and further underline the scientific proof that this can not be achieved without a fundamental shift within land use in general, and forestry in particular.

April, the French leader in the vegetable oil and protein sector (8Mds of turnover, 7500 employees), is firmly committed to climate action. Due to the outlets of oilseed crops, Avril is an important player in human (table oil) and animal (protein for livestock), but also in decarbonising the economy (renewable energy for transport, renewable oil-based chemistry).

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The German Nature Conservation Network (DNR) expressly welcomes the European Union’s efforts to strengthen and expand the carbon sink performance of ecosystems and to reduce emissions from the land use sector. Thank you for the opportunity to participate. We would like to stress that the LULUCF Regulation is of great importance, needs to be maintained and progressively more ambitious.

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We welcome the opportunity to provide feedback on EU rules on land use, land use change and forestry (LULUCF). In the attached paper we highlight three crucial points: 1. Evidence shows that sustainably managed forests can have greater long-term carbon benefits than unmanaged forests 2.

Stora Enso welcomes the opportunity to provide feedback to ensure that the EU Regulation on land use, land use change, and forestry (LULUCF) is fit-for-purpose going forward. To guide the long-term vision for EU forests to maximise climate change mitigation and adaptation effects, any revision of the LULUCF Regulation must reflect the new 2040 EU climate target, factoring in the latest trends and developments, as…

We welcome the opportunity to provide feedback on the LULUCF Regulation. Most Member States, including Germany, are not on track to meet their LULUCF targets. As a result, the EU is currently missing its target of -310 million tonnes of CO2 emissions in 2030, according to official data. In recent years, carbon removal by ecosystems has been declining instead of increasing as planned.

There is no way around it: the EU LULUCF carbon sink is shrinking. The European Scientific Advisory Board on Climate Change (ESABCC) confirmed that the EU net sink has been declining rapidly over the last 10 years, decreasing by 2021 to a third of its 2005 total (ESABCC, 2024).

The LULUCF sector is the key sector not only in the transition towards the EUs net zero emissions targets, but also in terms if biodiversity protection. The potential benefit LULUCF alterations offer in combating both climate and biodiversity crisis are vast.

The International Emissions Trading Association (IETA) welcomes the opportunity to provide evidence to support the Commissions review of the LULUCF Regulation. IETA believes this evaluation of the LULUCF rules is an important opportunity to consider how the EU policy toolkit can enhance activity and ambition.

The EUs LULUCF sector is critical for the EUs 2030 and 2050 climate targets, as well as for the protection of biodiversity but the EU is about to miss its targets both for carbon removals as well as for halting biodiversity loss in the land sector. The carbon sink of the LULUCF sector has been in decline since 2010 and according to the EEA the last 10-year trend has consistently pointed in the wrong direction.

European forest owners welcome the Commissions initiative to evaluate the LULUCF Regulation. Forest owners who manage approximately 60% of EU forests play a central role in contributing to the EU-wide climate change mitigation efforts.

EUSTAFOR welcomes the Commission's initiative to discuss the main opportunities and challenges in reaching the climate neutrality by the Member States and evaluating whether LULUCF Regulation is fit for its purpose. In EUSTAFORs opinion the upcoming evaluation should address the following issues: 1.

The European Association of Remote Sensing Companies (EARSC) is a trade association representing over 135 company members across Europe in the Earth Observation (EO) industry. EARSC welcomes the European Commission's efforts to assess the implementation and impacts of the revised Regulation on land use, land use change, and forestry (LULUCF) in Member States since its adoption in 2018, evaluate to what extent the…

Denmark welcomes the opportunity to comment on the European Commissions Public Evaluation on the LULUCF-regulation. Denmark welcomed an ambitious revision of the LULUCF-regulation as an important part of the Fit-for-55 package. The Fit-for-55 agreement enables the EU once fully implemented to reduce EUs net greenhouse gas emissions by 57% by 2030.

It is clear that LULUCF removals have a role to play for the purpose of reaching the 2030, 2040 and 2050 climate targets. At the same time, Bioenergia ry the Bioenergy Association of Finland strongly supports the starting point in the Commissions communication (February 2024) that the role of technological carbon sinks needs to become more apparent after 2030. The LULUCF regulation does offer room for improvement.

Dear Sir/Madam, we agree with the opinion of the AGDW. Further explanations can be found in the attached file. Extract: In order to achieve an increased sink of the forest, it is necessary to manage the forests. Limiting the use of wood with the aim of stockpiling to increase the natural carbon pool of forests is in no way conducive to the resilience and sustainability of forests.

Filed in German · English published by the European Commission

The Swedish Wood-Fuel Association is an organization for Swedish producers of solid wood fuels within the forest and recycling industry. We align ourselves with the feedback from Bioenergy Europe. We see that bioenergy is an essential key to leave the fossil dependence and energy security. The achievement of the EU carbon neutrality goal will also depend on bioenergy generation.

Growing Media Europe AISBL supports the ambitions of the LULUCF regulation in setting rules for emissions reductions and carbon removals of up to -310 Mt of CO2 equivalent in the LULUCF sector. There are, however, fundamental issues with the reporting with regards to Horticultural peat, where emissions can be double reported.

Drafting and amending EU regulations is a large-scale work that requires a lot of resources from the parties involved. Therefore, before deciding on the revision of the regulation, the information on the basis of which the LULUCF regulation and other regulatory acts are developed should be critically evaluated. It is about the IPCC methodology.

European forests are essential to achieve the target of -310 Mt CO2 in the LULUCF sector. In the form of wood, they are a renewable source of raw materials available across Europe, on which a strong value chain depends. However, this report shows that the health and sinking effects of forests are declining due to climate change and ageing, and that the sink effect has so far been greatly overestimated.

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The Norwegian Forest Owners Federation (NFOF) represents 4 forest cooperatives with approx. 30 000 forest owners. We align our selves with the feedback of MTK, LRF and CEPF. NFOF would like to emphasis that it is essential to have a realistic and ambitious climate policy. The main goal should be to reduce the fossil-based emissions. To substitute fossil-based products, we need to increase the use of biomass.

Land Use, Land Use Change and Forestry reporting shows EU climate targets are in danger of not being met 2030 LULUCF target not on track: risk to overall EU climate target As the first reporting period for the Land Use, Land Use Change and Forestry (LULUCF) Regulation ends in 2025, this is a good moment to consider progress towards the target of removing 310 megatons (Mt) of carbon by 2030.

Friends of the Earth Czech Republic welcomes the opportunity to participate in this call for evidence on the land use, land use change and forestry (LULUCF) Regulation. The LULUCF sector plays a key role in achieving the EU climate neutrality objective; and it needs to be preserved.

The International Peatland Society (IPS) is a non-governmental expert organization in the field of peatlands and their responsible management. We consider matters that require improvement in the LULUCF Regulation on greenhouse gas emissions and removals accounting under the UNFCCC Kyoto Protocol, especially in the Wetlands Category.

Cepi, the Confederation of European Paper Industries, welcomes the possibility to give feedback to the LULUCF Regulation review process. Please find our full feedback in attachment. Our key messages are: 1)Forests should not be used to offset emissions in difficult-to-decarbonise sectors.

1. Family farms Land und Forst e.V. consider that the targets tightened in 2023 for the LULUCF sector are unrealistic and unachievable. For the further development of the LULUCF targets, it is essential to base its scientific and evidence-based reasoning. 2.

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European forests are currently the biggest contributors to achieving -310 Mt CO2 in the LULUCF sector. With wood, you also offer a renewable source of raw materials available across Europe, with a high-performance value chain. Nevertheless, the report shows that the vitality and sinking effect of forests is declining due to climate change and age and has been greatly overestimated.

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The Federation of Swedish Farmers and Family Forest Owners (LRF) represent a majority of Swedish farmers and family forest owners. We align our selves with the feed-back of CEPF and Copa Cogeca. The forests in EU (and all around the globe) mitigate climate change in three general ways. They sequester carbon through the photosynthesis, they store carbon in products and the substitute fossil products and energy.

We thank for the opportunity to give feedback on the Land use, Land Use Change and Forestry (LULUCF) Regulation and agree with the need for a review to ensure that LULUCF 2030 targets are met, considering that the EU is still about 50 million CO2 equivalent tons short from reaching the target.

Comment on the Evaluation of the Land-Use, Land-Use Change, and Forestry Regulation Bioenergy Europe welcomes the opportunity to provide feedback on the Land-Use, Land-Use Change, and Forestry (LULUCF) regulation.

Although the general objectives underlying the LULUCF legislation are shared, the bureaucratic approach applied, which does not carry out case-by-case evaluations between member states, risks leading to controversial results that are often the opposite of the desired ones.

In the view of the LTRK, the initiative does not mention flexibility mechanisms and options for rethinking objectives, which are currently very vague. Nor has one of the major problems identified, the most obvious solution, which may lead to disruptive effects on essential sectors of the economy, if short-term objectives are met.

Filed in Latvian · English published by the European Commission

As a representative of a forest-owner’s community, I object to the LULUCF Regulation on the following grounds: As our forest and other European forest areas have lost the quantities of felled for several years, if not decades, as a result of calamities, it is unacceptable to further restrict the use of wood.

Filed in German · English published by the European Commission

The present LULUCF system is unfair and incorrect and must be significantly revised. Most importantly, the change in carbon stock is reported when sourcing raw materials, but as a rule, this does not describe the actual greenhouse gas emissions. A change in the carbon stock does not equal emissions!

The LULUCF sector is an important part of the European Union’s climate policy. Its specificity is due to the fact that it is the only sector that has a positive impact on the climate at community level. At the same time, it is the sector most vulnerable to the adverse effects of ongoing climate change.

Filed in Polish · English published by the European Commission

Concrete Europe thanks the Commission for allowing us to provide feedback to the evaluation of LULUCF. We've noted in the evaluation report on LULUCF that the EU carbon sink has been in decline for the last decade and that the EU is not on track to meet the 2030 net removal target, falling short of 50 Mt CO2-eq.

Comments from the Saxony-Anhalt Forest Owners’ Association on the Commission’s report on the application of the LULUCF Regulation We Forest Owners in Saxony-Anhalt, represented by the Saxony-Anhalt Forest Owners’ Association and our Federal Association AGDW – The forest owners generally welcome the efforts at European level to reduce CO emissions and strengthen the natural forest sink with its CO sequestration…

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The European Agroforestry Federation is an international NGO with Registered in France (Transparency RegisterID 913270437706-82). We aim to promote the adoption of agroforestry practices across Europe by supporting efforts to develop awareness, education, research, policymaking and investments which foster the use of trees on farms. We have a network of 31 affiliated organisations in 31 Countries.

The EU is not on track to meet LULUCF targets The EUs LULUCF sector is critical for the protection of Europes biodiversity, water, soils, and carbon sequestration. However, the net LULUCF sink has been declining since 2010, and the projections show that the EU is expected to miss its -310Mt LULUCF 2030 target by 50-125Mt.

Please see below a synthesis of the attached file where our entire feedback is available. The European Organisation of the Sawmill Industry (hereinafter EOS) appreciates the opportunity to provide feedback, which you can see below, on the evaluation of the LULUCF Regulation.

MEMBER STATES NEED TO INCREASE THEIR LULUCF AMBITIONS. Data shows that the worrying declining trend of the LULUCF sink persists and Member States are not taking effective measures to reverse this . As a consequence, the EU is not projected to meet the 2030 obligations with existing measures in place .

The EU's LULUCF sector is essential for protecting Europe's biodiversity, water, and soils. Yet, since the year 2010, the net LULUCF has been sinking and the projections indicate that the EU will most likely miss its -310Mt LULUCF 2030 target by 50-125Mt.

Land use sectors encompasses economic activities whose employees are represented by EFFAT such as agriculture and forestry. Forests are suffering massively and increasingly from climate change. Drought and pests are causing enormous damages, impairing the performance of forestry as a whole.

Wir als Waldeigentümer begrüßen grundsätzlich die Bestrebungen auf europäischer Ebene, die CO2-Emissionen zu reduzieren und die natürliche Senke Wald mit ihrer CO2-Bindungsleistung zu stärken. Um das neu gesetzte Gesamtziel der EU von 310 Mt CO-eq zu erreichen, sind die Mitgliedstaaten zum Erhalt und zur Erweiterung ihrer Kohlenstoffspeicher verpflichtet.

Forests are primarily a CO2 pump because they remove CO2 from the atmosphere and temporarily store it in biomass. According to the LULUCF Regulation, this intermediate storage facility is to be further expanded, which means in practice not harvesting wood. However, storage capacity cannot be extended indefinitely.

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Estonia has not taken decisive steps towards achieving the targets set under the EU LULUCF regulation, putting the country off track. This is primarily due to economic interests, highlighting the need for proper environmental safeguards to balance these interests and meet the LULUCF targets. The state of several important biodiversity-related indicators is alarming.

The EU is not on track to meet LULUCF targets The EUs forests, peatlands, wetlands and grasslands are critical for the protection of Europes biodiversity, water, and soils. They are also crucial sinks, and thereby deliver an essential part for achieving the EUs greenhouse gas targets.

With this feedback Comité Schone Lucht, MOB and Leefmilieu argue that we need to maintain the terrestrial carbon sink through ongoing forest growth and carbon sequestration. We must protect existing primary and old-growth forests in order to retain an accumulated stock of carbon in living and dead biomass and soil organic matter in safe storage and avoiding emissions.

The ongoing trend of declining net carbon sinks in EU forests indicates that the current LULUCF targets may be unrealistic. The regulation's methodology for total target allocation is based on the percentage of managed land relative to the total area under management in the EU. This overlooks several critical factors: 1. The productivity of land use systems varies across MS and regions.

Comments from the FBG Memmingen e.V. on the European Commission’s report on the application of the LULUCF Regulation The Forestry Association Memmingen e.V. and the AllgäuHolz Markenverband generally welcome the ambition at European level to reduce CO2 emissions and strengthen the natural forest sink with its CO2 sequestration performance.

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To reach the climate target set in the Paris Agreement, deep reductions in the anthropogenic greenhouse gas (GHG) emissions and increases in the anthropogenic carbon sinks are required. Globally, the need of the anthropogenic (additional to natural) carbon sink might be even at the level of 10 billion tons of CO2 annually, on average, by the end of this century.

KWF opinion on the application of the LULUCF Regulation The Board of Trustees for Forest Work and Forestry Technology (KWF) generally welcomes the ambition at European level to reduce CO2 emissions and strengthen the natural forest sink with its CO2 sequestration performance. In order to achieve the new overall EU target of 310 Mt CO-eq, Member States are required to maintain and expand their carbon pools.

Filed in German · English published by the European Commission

The AGDW – Forest owners generally welcome the ambition at European level to reduce CO2 emissions and strengthen the natural forest sink with its CO2 sequestration performance. In order to achieve the new overall EU target of 310 Mt CO-eq, Member States are required to maintain and expand their carbon pools.

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The Westallgäu e.V. Forest Owners’ Association and the AllgäuHolz Markenverband generally welcome the efforts at European level to reduce CO2 emissions and strengthen the natural forest sink with its CO2 sequestration capacity. In order to achieve the new overall EU target of 310 Mt CO-eq, Member States are required to maintain and expand their carbon pools.

Filed in German · English published by the European Commission

Ladies and gentlemen, The Saxony Forest Owners’ Association generally welcomes the efforts at European level to reduce CO2 emissions and strengthen the natural forest sink with its CO2 sequestration capacity. In order to achieve the new overall EU target of 310 Mt CO-eq, Member States are required to maintain and expand their carbon pools.

Filed in German · English published by the European Commission

WWF European Policy Office welcomes the opportunity to participate in this call for evidence on the land use, land use change and forestry (LULUCF) Regulation. The LULUCF sector plays a key role in achieving the EU climate neutrality objective; and it needs to be preserved. Overall, the sector has acted as a net CO2 sink for the EU since 1990.

As the German Forestry Council (DFWR), we stress the importance of consistent and effective climate policy based on long-term processes and careful planning. Active forest management is crucial for us to maintain the vitality of European forests and ensure their capacity to provide diverse ecosystem services.

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Austria’s Land & Forestry Holdings welcome the initiative to evaluate the LULUCF Regulation. Sustainable, active forest management plays an essential role in the fight against climate change, which is not sufficiently taken into account in the current form of the Regulation.

Filed in German · English published by the European Commission

The AGDW – Forest owners generally welcome the ambition at European level to reduce CO2 emissions and strengthen the natural forest sink with its CO2 sequestration performance. In order to achieve the new overall EU target of 310 Mt CO-eq, Member States are required to maintain and expand their carbon pools.

Filed in German · English published by the European Commission

LULUCF is an important sector when it comes to achieving climate neutrality, as the sector is the main contributor to carbon removals globally. LULUCF sector also provides renewable raw materials and energy to other sectors and is crucial for accessibility of biomass to many types of carbon dioxide removal (CDR) technologies.

The Bundesverband Bioenergie e.V. (BBE) takes the view that the LULUCF Regulation is not fit for purpose and requires urgent adaptation. The CDR calls for the objectives of the LULUCF Regulation to be science-based and realistically achievable and to take into account a comprehensive consideration of the economy-wide effects and climate impacts.

Filed in German · English published by the European Commission

We argue that the EU needs to maintain the terrestrial carbon sink through ongoing forest growth & carbon sequestration. We must protect existing primary & old-growth forests in order to retain an accumulated stock of carbon in living & dead biomass & soil organic matter in safe storage & avoiding emissions.

Preventing the worst impacts of the climate crisis requires rapid phasing out CO2 emissions as well as strengthening the ability of natural ecosystems to sequester and store carbon. We are deeply concerned that, despite the 2030 LULUCF target, forests and other ecosystems in the EU are sequestering progressively less carbon.

While France is committed to meeting the land absorption target of -34 MtCO2/an in 2030, the Secretariat-General for Ecological Planning has just adjusted its forecast to -18 MtCO2/an. The objective of increasing timber harvesting remains central to forestry policy, although it is not consistent with the LULUCF objective.

Filed in French · English published by the European Commission

Norway is grateful for the possibility to provide feedback on the EU rules on land use, land use change and forestry (LULUCF). Norway shares the view that LULUCF is an important sector when it comes to achieving climate neutrality, as the sector is the main contributor to carbon removals globally, as well as being responsible for a sizeable portion of global emissions.

The Finnish Union of Agricultural Producers and Forest Owners (MTK) would like to emphasize the role of the sustainable forest management and a strong bioeconomy sector for achieving the EU climate targets for 2040. The entire answer can be found enclosed. Climate actions by forests are based with long-term processes and careful planning.

To support climate neutrality goals in LULUCF it is crucial to implement actions which have long term results. Increasing proportion of unmanaged forests can give a temporary positive effect but at some point old forests stop growing and mortality increases. In addition, regeneration is negligible and carbon emission is constant or exceeds carbon sequestration. Conversely, forest management supports LULUCF goals.

To maximize the use and effect of the Land Use, Land-Use Change and Forestry Regulation, we suggest more standardized frameworks/schemes that can be used to document the carbon removal. There should be detailed certification rules for the measurement, monitoring, reporting and verification of the carbon removal.

Sweden welcomes the opportunity to provide feedback on LULUCF. Forests provide climate benefits in two ways as a carbon sink in trees, soil and harvested wood products as well as through providing bio-based alternatives that substitute fossil ones. As we design future policy, a holistic approach will be necessary where we create incentives for a long-term carbon sink and promote a sustainable bioeconomy.

Finland is not on track to meet the targets under EU LULUCF Regulation. In 2021 and 2022 the LULUCF sector was a source of GHG emissions and in 2023 a small net sink. The Annual Climate Report 2024 prepared by the Finnish Environment Ministry states: "If no further measures are taken in the land use sector, Finland is not likely to achieve the EU commitments under the LULUCF Regulation without possibly buying…

Climate change is reversible if we act fast and select the correct trees which can produce best quality biochar to be used as a biofertilizer. Using biochar as a biofuel is around 5000 years old technology developed by Aryans in 5000 BC which suggests that a dose of 1 gm / sq meter can increase the land output by 25-30%.Biochar keep the land hydrated and maintains oxygen in the plant roots.

To achieve climate neutrality in 2050 the EU needs to promote carbon removals. The policy framework should recognise the benefits of the biogenic carbon cycle and the climate benefits of wood-based product value chains (sink, sustainable carbon source, carbon stock, substitution). Forest industry is an important part of the solution in all key carbon removal measures aiming for negative emissions: 1.

LULUCF policies should be based on balanced and realistic assessments of the forests natural dynamics and consider other sustainability dimensions Maintaining natural carbon sinks in the long term is a crucial part of reaching climate goals, also beyond 2050. This should, however, not be compromised by focusing on short term targets or unreasonable burdens on specific Member States.

I agree with the rules defined by the EU in particular those that consider synergies between climate change mitigation and biodiversity, as biodiversity is certainly more difficult to address when compared to greenhouse gases (GHG). The caution to be considered is that some actions seeking to address the GHG problem can exacerbate biodiversity problems. A concrete example is agricultural intensification.

Filed in Portuguese · English published by the European Commission

The Regulation as drafted to date will be ineffective in some way to enable the Member States to meet the overall climate targets set out in the Fit For 55 package. When analysing the effectiveness of harvesting reduction, currently advocated, in order to achieve LULUCF’s stated targets, it can be seen that this option is not effective on the climate, even on the contrary, the effects will be: more unwanted GHG…

Filed in French · English published by the European Commission