European State Forest Association (EUSTAFOR)

As noted in previous consultation inputs by European State Forest Association (EUSTAFOR), we believe that the current criteria in the REDII are robust enough and effective, requiring that the biomass is sourced sustainably and negative impacts on biodiversity are minimized. Their revision risks bringing even more uncertainty to the market and unjustified administrative burden for operators and Members States.

As announced in this initiative summary, under the European Green Deal the Commission has committed to stronger action on climate change and will assess how the EU’s greenhouse gas emissions could be responsibly reduced by at least 50-55% by 2030.

European multifunctional forests and forest-based products should be at the core of the EU climate change agenda. Sustainable forest management can help to diversify the energy supply, lower greenhouse gas emissions and create jobs and growth in rural areas.

EU carbon removals certification should incentivize long-term climate benefits over short term carbon offsets: EUSTAFOR calls for an extra careful approach while setting up a carbon removals certificate system through EU legislation. Such a system cannot serve solely as a tool to offset the emissions of the emitting sectors by natural ecosystems, i.e. forests.

EUSTAFOR welcomes the Commission's initiative to discuss the main opportunities and challenges of different solutions for the capture, storage or use of carbon, necessary for reaching the goal of climate neutrality. Before proceeding with identifying the types of carbon removals, the following must be taken into account: 1.

EUSTAFOR is in favor of the proposed ecosystem-specific approach and recommends that restoration needs are determined based on verified field data and properly recognize differences and specific contexts of various ecosystem types and land uses. Notably, forest ecosystems have longer cycles than other habitat types and therefore require a longer time for proper observation of major trends and changes.

EUSTAFOR, acting as a voice of European state forest management organizations at EU and pan-European levels, wishes to share the following contribution to this roadmap consultation: Restoration commitment requires properly defined objectives: From a forest manager’s perspective, the restoration objectives, especially those in old-growth forests and primary forests, must be precise and based on sound scientific…

The European State Forest Association (EUSTAFOR) welcomes the opportunity to contribute to the European Commissions feedback consultation on the 2040 climate target. In particular, we would like to highlight the critical and complex role of the Land Use, Land-Use Change and Forestry (LULUCF) sector, with a focus on forests, their management and providing renewable materials, enhancing carbon sinks, as well highlight…

The European State Forest Association (EUSTAFOR) submitted its initial contribution to the Commissions Call for Evidence on Simplification of administrative burdens in environmental legislation on 10 September 2025.

The European State Forest Association (EUSTAFOR) welcomes the opportunity to contribute to the European Commissions feedback communication on the Roadmap towards Nature Credits. EUSTAFOR represents state forest organisations managing more than one-third of Europes forests.

Forests are essential components of Europes climate resilience strategy. Beyond their well-known role in carbon sequestration, forests contribute to climate adaptation by regulating hydrological cycles, preventing soil erosion, buffering temperature extremes, and reducing the risk of floods, droughts, and heatwaves.

The European State Forest Association (EUSTAFOR) represents state forest companies, enterprises and agencies that have sustainable forest management (SFM) and sustainable wood production as major concerns. As the Commission develops guidance under Article 5 of the proposed Performance Regulation, it is critical that the "Do No Significant Harm" (DNSH) principle is applied in a way that is clear, harmonized, and…

EUSTAFOR welcomes the opportunity to voice its opinion in the public consultation on the proposed Revision of Annex V & VI of the Renewable Energy Directive. Our organisation supports continuous evaluation and updating of the methodology to accurately reflect reality, including the latest scientific evidence, and thus positively impact the mitigation of climate change.

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.

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…

EUSTAFOR welcomes the possibility to be able to provide its views on the new Forest Monitoring Framework Regulation (FML). It is clear to our organization that high quality, precise and timely forest data is a prerequisite for accurate planning and management of forests.

EUSTAFOR appreciates the possibility to deliver its input to this consultation. As the association which represents 36 European State Forest Management Organisations (SFMOs) we are of the view that developing a credible forest information system should use the most innovative methodologies and technical solutions.

The European State Forest Association (EUSTAFOR) welcomes the opportunity to contribute to the public consultation on national targets and flexibilities in the EU climate policy framework after 2030. EUSTAFOR represents 40 European state forest companies, enterprises, and agencies for whom sustainable forest management (SFM) and sustainable wood production are core responsibilities.

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 State Forest Association (EUSTAFOR) welcomes the Commission Communication from July 2019 that tackles deforestation and forest degradation – reducing the impact of products placed on the EU market. The protection of World’s forests and reversing of negative trends in deforestation and forest degradation globally has been a topic of international forest policy debate since at least the Rio Earth Summit…

--See document attached for full EUSTAFOR input-- The current CAP already represents a significant shift towards a performance-based delivery model, granting Member States greater flexibility in designing and implementing interventions.

As a representative of 36 State Forest Management Organizations which, together, manage 1/3 of Europe’s forests, we would like to share the experiences of our members regarding the present EU rules on illegal logging, specifically the EU Timber Regulation (EUTR) as part of the FLEGT Action plan.