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Conféderation Européenne des Propriétaires Forestiers

CEPF

CEPF represents 15 million family forest owners across Europe, promoting sustainable forest management, private property rights and the economic viability of the forest sector.

Lobbying Activity

Forest owners urge EU to simplify taxonomy using existing certification

5 Dec 2025
Topic — This initiative reviews technical screening criteria for the EU taxonomy environmental act.
Message — CEPF requests using existing forest certification and national data instead of new rules. They want to avoid duplicating current forest management planning and record keeping. The group also asks for clearer guidelines for social and environmental compliance.123
Why — This approach would lower compliance costs and reduce administrative burdens for forest owners.45
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Meeting with Elisabeth Werner (Director-General Agriculture and Rural Development)

29 Sept 2025 · Exchange on key EU forest-related policy files currently under development or implementation

European forest owners urge indicative targets over binding mandates

15 Sept 2025
Topic — The initiative updates the European Climate Law with a 2040 target.
Message — The organization proposes using indicative targets instead of legally binding mandates with penalties. They want climate policy to encourage using wood products to replace fossil-based materials. They also warn against any policies that discourage timber harvesting.12
Why — Forest owners would maintain their revenue streams and avoid financial penalties.34
Impact — Conservation groups lose if emphasis shifts from forest preservation to harvesting.56
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Forest owners demand active management funding for climate resilience

4 Sept 2025
Topic — This initiative proposes an integrated framework for climate risk management across European sectors.
Message — The CEPF requests support for locally suited active forest management to increase climate resilience. They advocate for unbureaucratic funding through the CAP and the use of forest insurance. The organization prefers concrete investments over administrative risk assessments or large-scale monitoring frameworks.123
Why — Forest owners would receive direct financial support while avoiding complex regulatory and monitoring costs.45
Impact — Environmental regulators focusing on static carbon sinks may lose influence over forest management.6
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Meeting with Eric Mamer (Director-General Environment) and

25 Aug 2025 · Key forest-related EU policy files under development including the new EU Bioeconomy Strategy, nature credits, the EU Deforestation Regulation and the implementation of the EU Forest Strategy

Forest owners urge property rights protection in pollinator monitoring

17 Jul 2025
Topic — A regulation establishing mandatory methods for monitoring pollinator diversity across Member States.
Message — CEPF requests that monitoring access respects national property laws and keeps site locations confidential to prevent data interference. They also call for more flexible monitoring methods that align with existing national practices.123
Why — This would safeguard land control and minimize administrative costs for private forest owners.45
Impact — Scientific researchers lose open access to location data for independent ecological verification.6
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Meeting with Maxi Espeter (Cabinet of Commissioner Christophe Hansen)

25 Jun 2025 · Mutual introduction and exchange of views on Nature Credits

European Forest Owners urge central role in EU bioeconomy strategy

18 Jun 2025
Topic — The consultation explores strategies for a circular, regenerative, and competitive bioeconomy across the European Union.
Message — European forest owners call for a simplified framework that includes the entire forest-based value chain. They oppose mandatory rules for biomass allocation and emphasize voluntary, market-based biodiversity practices.123
Why — A market-driven approach allows forest owners to maximize profits by selling wood to the highest bidder.4
Impact — Environmental groups seeking strict protection of carbon sinks lose out to commercial logging interests.5
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Meeting with Taru Haapaniemi (Cabinet of Commissioner Christophe Hansen)

26 Mar 2025 · Ongoing and future EU forest-related files, including implementation of EU Green-Deal forest related policies and coming new / updated policies; bioeconomy; closer-to-nature forest management; sustainable forest management

Meeting with Jessika Roswall (Commissioner) and

25 Mar 2025 · Forestry

Meeting with Emmanuelle Maire (Head of Unit Environment) and European State Forest Association

20 Mar 2025 · Exchange of views on bioeconomy

Forest owners urge local approach in EU water strategy

4 Mar 2025
Topic — The EU is developing a strategy to manage water scarcity and achieve water resilience.
Message — The organization calls for a balanced perspective on forests' contributions. They emphasize that no one size fits all solution exists and forest owners require support for climate adaptation.123
Why — Forest owners would secure financial and policy backing for their ongoing management and adaptation efforts.45
Impact — Environmental advocates lose if the strategy ignores forests' potential by labeling them as not central.67
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European Forest Owners urge simplified nature restoration plan formats

7 Feb 2025
Topic — Creating a uniform template for Member States to submit nature restoration plans.
Message — The organization demands a simple format that does not exceed the regulation's requirements. They request removing optional fields and maps to minimize the administrative burden on members. Plans must respect property rights and account for potential negative socio-economic impacts.123
Why — This avoids high compliance costs and prevents the unauthorized designation of private land.45
Impact — Public authorities and environmental groups lose access to detailed restoration monitoring data.6
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European forest owners urge rethinking of LULUCF carbon sink expansion approach

11 Jul 2024
Topic — Evaluation of EU regulation on land use and forestry carbon emissions and removals.
Message — Forest owners request policy changes to recognize substitution effects of harvested wood products and separate forestry goals from other sectors. They argue the current net-zero rule unfairly positions forestry to offset emissions from other sectors while limiting harvest in sustainably managed forests.12
Why — This would allow continued harvest for forest-based products while reducing pressure to expand carbon sinks.34
Impact — Climate goals lose immediate carbon sink expansion as harvested wood releases stored carbon over time.5
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Response to GreenData4All - Revision of EU legislation on geospatial environmental data and access to environmental information

25 Mar 2024

European forest owners would like to express concerns regarding the GreenData4All initiative. We believe there are significant risks and challenges that must be addressed to ensure its development and to adequately respect the rights and interests of European forest owners. First and foremost, the lack of reference to the initiative's potential impact on privacy and business-sensitive data is worrying. Forest owners possess data that are sensitive from both a privacy and business perspective, among others including information on land ownership, harvesting schedules, or market strategies. The publication or open availability of data relating to production information of a company, or a business operator/entrepreneur restricts the possibilities of use of property and thus can infringes upon the core of the right to property. Limitations of fundamental rights, especially classical fundamental rights such as the right to property, require very substantial justifications and careful consideration. Therefore, robust data protection measures must be in place, to avoid any risk of data breaches and unauthorized accesses, that would jeopardize the privacy and security of forest owners' information. Moreover, we are deeply concerned about the lack of clarity surrounding data ownership and rights. Forest-related data, including information on forest management practices, biodiversity, and ecosystem services, can be generated and maintained by forest owners or other authorized entities. However, there is a glaring absence of clear guidelines on data ownership within the initiative. Without robust mechanisms in place to protect forest owners data rights, there is a genuine risk of exploitation and unfair treatment. Furthermore, given that the initiative focuses mostly on supporting environmental goals, we fear that the emphasis on data sharing and the need for it will come at the expense of the other aspects of sustainability, including economic viability of forest management. Forests serve as vital socio-economic assets for many rural communities, providing employment opportunities and contributing to local economies through timber production and other forest-related activities. Many forest-related data are relevant not only to environmental aspects but also socio-economic ones. Policies that prioritize data sharing over economic sustainability threaten to undermine the livelihoods of forest owners and rural communities. Lastly, the initiative's focus on data relevance and accuracy, and the inherent risks of data mishandling and misreading both raise additional concerns. Forest ecosystems vary significantly across Europe, with each region presenting unique challenges and opportunities for sustainable management. Without proper safeguards and oversight by relevant experts, there is a significant chance that the shared data could be mishandled for unintended purposes, misconstrued, or erroneously interpreted. In the case of forests in Europe, a one-size-fits-all approach to data collection and sharing fails to account for this diversity, potentially leading to misguided policies and ineffective management strategies. Additional In conclusion, the Call for Evidence of the GreenData4All initiative raises serious concerns and risks for forest owners across Europe. Without addressing these concerns in a meaningful and substantive manner, the initiative risks alienating forest owners and undermining its stated objectives of promoting environmental sustainability and data-driven decision-making. It is imperative that policymakers heed our concerns and take proactive steps to ensure that the initiative respects the rights and interests of forest owners.
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Meeting with Maroš Šefčovič (Executive Vice-President) and European farmers and

14 Mar 2024 · High level dialogue on forest-based bioeconomy

Meeting with Eglantine Cujo (Cabinet of Commissioner Virginijus Sinkevičius) and European farmers and

9 Feb 2024 · Deforestation issues

Forest owners demand data privacy in EU monitoring proposal

7 Feb 2024
Topic — The initiative establishes a framework for observation and strategic planning of EU forests.
Message — The organization wants the proposal refined to ensure coherence and clear objectives for data collection. They demand protection for sensitive business information and private property rights regarding open access. They also reject using delegated acts to change crucial parts of the law.123
Why — This would protect private property rights and prevent expensive administrative duplication for owners.45
Impact — The public and researchers lose access to transparent information about forest management.6
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Meeting with Wolfgang Burtscher (Director-General Agriculture and Rural Development)

30 Jan 2024 · exchange on current topics relating to European Forest policy

Meeting with Helena Braun (Cabinet of Vice-President Maroš Šefčovič) and Maa- ja metsätaloustuottajain Keskusliitto – Central Union of Agricultural Producers and Forest Owners and

30 Nov 2023 · EU forest monitoring and other forest related proposals

Forest owners urge flexible EU soil monitoring and data privacy

3 Nov 2023
Topic — This consultation addresses proposed EU legislation to protect, monitor, and restore soil health.
Message — CEPF rejects uniform standards, preferring locally suited approaches that reflect diverse soil types. They oppose public access to raw monitoring data and call for the removal of the voluntary soil health certification scheme.123
Why — This would lower costs for owners by removing unnecessary and burdensome certification schemes.4
Impact — Transparency advocates lose access to detailed and site-specific environmental monitoring data.5
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Meeting with Martin Hojsík (Member of the European Parliament, Rapporteur) and European Environmental Bureau and

28 Sept 2023 · Soil Health Law

Meeting with Elena Montani (Cabinet of Commissioner Virginijus Sinkevičius) and European farmers and

15 Jun 2023 · EU forest related policies, including the upcoming forest monitoring proposal

Meeting with Helena Braun (Cabinet of Executive Vice-President Frans Timmermans) and European farmers and

15 Jun 2023 · EU forest related policies, including the upcoming forest monitoring proposal

Meeting with Jorge Pinto Antunes (Cabinet of Commissioner Janusz Wojciechowski) and Maa- ja metsätaloustuottajain Keskusliitto – Central Union of Agricultural Producers and Forest Owners and

31 May 2023 · To discuss about the relevant forest-policy priorities, especially the upcoming forest monitoring law.

Meeting with Frans Timmermans (Executive Vice-President) and European farmers and

29 Mar 2023 · Forest owners’ perspectives regarding the state of forests in the EU and discussion about EU policies impacting forest-based bioeconomy activities

Forest owners call for simple carbon removal certification rules

8 Mar 2023
Topic — The consultation seeks feedback on establishing a certification framework for carbon removals.
Message — CEPF demands simple and implementable rules for monitoring and verifying carbon credits. They request that all wood-based products are included in the certification framework. The organization warns against a one-size-fits-all approach to certification criteria preparation.123
Why — A voluntary certification framework allows forest owners to diversify their income streams.45
Impact — Environmental groups lose if biodiversity and restoration requirements are delayed or omitted.67
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Meeting with Markus Pieper (Member of the European Parliament, Rapporteur) and Familienbetriebe Land und Forst Bayern e.V. and Bundesverband Bioenergie e.V.

8 Mar 2023 · RED III

Meeting with Andrea Beltramello (Cabinet of Executive Vice-President Valdis Dombrovskis)

7 Jun 2022 · Taxonomy of environmentally sustainable economic activities

European Forest Owners demand monitoring respects national competencies

6 May 2022
Topic — The initiative establishes an EU-wide framework for forest observation and strategic planning.
Message — The framework must build on national inventories and respect member state powers over forest management. They demand a financial impact assessment and clear objectives for new reporting.123
Why — This approach prevents new administrative costs and protects proprietary data from open-access requirements.45
Impact — EU regulators lose the ability to mandate harmonized standards or intervene in local forest management.67
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European forest owners urge voluntary, market-based carbon removal certification

2 May 2022
Topic — The EU is proposing a regulatory framework to certify and monitor carbon removals.
Message — All sustainable forest management practices and wood products should be incentivised. The framework must be voluntary and market-based, establishing only minimum standards. It should not result in restrictions on sustainable harvesting levels.123
Why — This allows forest owners to monetize wood products and maintain existing commercial operations.4
Impact — Environmental groups lose if the framework prioritizes commercial harvesting over strict forest conservation.5
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Meeting with Frans Timmermans (Executive Vice-President) and European farmers and

7 Apr 2022 · European Green Deal and forest related policies, including the new European Forest Strategy for 2030

Meeting with Helena Braun (Cabinet of Executive Vice-President Frans Timmermans) and European farmers and European Landowners' Organization asbl

16 Mar 2022 · Preparation for EVP Timmermans’ meeting with the representatives of CEPF, COPA-COGECA and ELO on forest related policies

Meeting with Andrea Vettori (Cabinet of Commissioner Virginijus Sinkevičius)

11 Mar 2022 · EU Nature Restoration Law

Meeting with Helena Braun (Cabinet of Executive Vice-President Frans Timmermans)

11 Mar 2022 · EU Nature Restoration Law

Meeting with Jorge Pinto Antunes (Cabinet of Commissioner Janusz Wojciechowski), Roberto Berutti (Cabinet of Commissioner Janusz Wojciechowski)

22 Nov 2021 · Taxonomy

Response to Revision of the Renewable Energy Directive (EU) 2018/2001

18 Nov 2021

The Confederation of European Forest Owners (CEPF) takes note of the Commission´s initiative to review the EU renewable energy rules to contribute to a higher climate ambition as part of the European Green Deal. However, CEPF wants to raise some concerns regarding the amended sustainability criteria for forest biomass which would hinder the use of biomass for energy and thus prevent reaching the EU goal of ruling out the use of fossil fuels. Firstly, CEPF calls for stability and predictability in EU policies. The implementation of the latest Renewable Energy Directive (RED II) has just started and the Commission has not yet published guidelines on sustainability criteria which retards the whole process. Possible amendments on this criteria should be considered only after implementing and evaluating the current directive. The Commission´s presumption of ”timber harvest for energy use” stated in the impact assessment needs to be clarified. European forests are not managed for bioenergy purposes but management practices are based on a long-term planning and silvicultural practices performed in a timely manner. CEPF reminds that wood energy market can support EU forest owners to manage their forests – which enhances both the growth of forests and sinks – by providing them an opportunity to get revenues from management operations. It should be acknowledged that wood bioenergy is largely based on residues and wastes from logging and timber processing and low quality wood. The market ensures that high-quality timber is used for high-value added products. CEPF is highly concerned about the Commission’s proposal to introduce a delegated act on cascade use of woody biomass. The principle on cascading use is already implemented in practice through the markets of different wood uses. If embedded into EU legislation in a strict way, it would hamper the market functions and the substitution of fossil materials and energy which is in key role in contributing to the climate neutrality target. In addition, the use of a delegated act for such action is questionable since Member States should be closely involved in the discussion. European forest owners also have high concerns about the proposed changes regarding the risk-based approach. The new entries on biodiversity and soil quality introduce new requirements in a rather general way (e.g “degradation of primary forests”, “vulnerable soils” or “large clear cut”) which have not been defined. As a result, it can be very challenging for national forest legislations to comply with these new requirements. This new risk-based approach would thus require regulatory changes in Member States and create a large amount of bureaucracy for forest owners who should start reporting sustainability on a forest holding level. Additionally, CEPF does not support the Commission´s initiative to apply no-go areas on highly biodiverse forests given that this terminology is based on undefined terms, it does not provide scientifically based criteria and is too broad to be used in practice in a way that would be relevant for all forest types. If needed, this terminology should be clarified at national, regional and local level. CEPF would also like to remind about the ongoing work on other forest-related definitions under the EU Biodiversity Strategy and the need to ensure consistency among the different EU forest-related policies. EU-wide and undefined terms could risk the availability of wood biomass for energy by excluding several forest holdings performing sustainable forest management and related bioenergy production. These kind of restrictions on forest use would hamper those forest owners who have been managing their land in a sustainable way by preventing them gaining a possible revenue from low quality wood. It could also pose their forests in a high risk in terms of natural disturbances (pests, fires and insects) if they are forced to leave all wood material suitable for bioenergy in the forest.
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Meeting with Jorge Pinto Antunes (Cabinet of Commissioner Janusz Wojciechowski)

9 Nov 2021 · Forestry

European forest owners warn LULUCF targets could harm wood harvesting

8 Nov 2021
Topic — The EU is reviewing rules for emissions and carbon removals from land and forestry.
Message — CEPF demands that the EU continues supporting active management and avoids limiting wood harvesting. They believe the removal target is too ambitious and should not result in forests offsetting other sectors’ emissions.123
Why — This would protect the economic viability of forest owners and maintain bioeconomy jobs.4
Impact — Polluting industries lose the chance to use forest carbon removals to cover their own emissions.5
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Meeting with Joan Canton (Cabinet of Commissioner Thierry Breton) and European farmers and

8 Nov 2021 · Forest based industries

Response to Restoring sustainable carbon cycles

7 Oct 2021

The Confederation of European Forest Owners welcomes the opportunity to express first general views on the European Commission’s initiative to develop a long-term vision for sustainable carbon cycles (including capture, storage, and use of CO2) in a climate-neutral EU economy and to kick-start the development of technological and nature-based solutions. EU forest and forest-based sector offers key solutions for achieving the 2050 carbon neutrality goal by contributing to climate change mitigation in three essential ways: carbon sequestration, carbon storage in trees and wood products, and carbon substitution by providing raw material as a substitute for fossil-based and other carbon intensive material and energy. Releasing this nature-based potential, including via contributing to the development of a bioeconomy, could lead to a win-win situation for society in mitigating climate change and for forest owners to continue to manage their forests in a sustainable way (through applying Sustainable Forest Management concept and principles), so as to provide all benefits expected by society. European Forest Owners note that “The Communication will discuss a range of options for carbon removal and storage solutions, and for recycling carbon from biomass, waste and directly from air to replace fossil carbon in the production of the fuels, materials and food of the future” and would seek clarification on how such approach will encompass and support the storage (carbon storage in wood products) and substitution benefits above mentioned. Furthermore, CEPF stresses that while addressing synergies and potential trade-offs with other climate, environmental and social priorities, such as biodiversity, adaptation, clean water and air, and carbon leakage, the sourcing area should be duly considered. European forest management has very high environmental standards and sustaining the provision of locally sustainably sourced materials will be of key importance to avoid leakage. According to CEPF, important clarifications are needed prior to developing the range of options, in particular the concept of “nature-based solutions” or “climate friendly practices”. Such concepts must be properly defined and commonly understood. To this aim, the voice of those who are responsible for taking care of forests daily should be duly considered. About the EU Carbon Farming’s initiative, CEPF would have very much welcome to be associated more closely to its developments. As far as CEPF is aware, the information available so far regarding this initiative do not address the forest sector very closely and is rather focused on agricultural and agroforestry activities However and as mentioned in the roadmap, to realise the potential of carbon farming, direct incentives for forest owners and the promotion of new green business model for climate friendly practices are foreseen. In addition, as the new EU Forest Strategy for 2030 and LULUCF mention the carbon farming initiative as a tool to develop the concept of payment for ecosystem services, the role of sustainable forest management and the forest sector should be further considered. Forest owners are open to look into options to develop revenues from other ecosystem services than wood supply provided that these remain voluntary and are adapted to local circumstances. Finally, such initiative to encourage carbon removals and storage should not be seen as the only way to support forests contribution to the EU carbon neutrality objective. As mentioned above, support to the use of wood-based material is as important from a climate-smart perspective. That is why new forest-related policies must not limit the economic development of forests and jobs creation but should continue to provide support to private forest owners in achieving their multifunctional role in contributing to climate change mitigation and adaptation, by supporting them to develop and consolidate the sustainable management of their forests
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Response to European Bioeconomy Policy: Stocktaking and future developments

30 Aug 2021

The Confederation of European Forest Owners (CEPF) welcomes the European Commission’s initiative to take stock of the progress of the Bioeconomy Strategy and its action plan. We would like to highlight the importance of the Bioeconomy Strategy’s holistic approach which we regard as essential prerequisite to fully exploit the potentials of the bioeconomy. Our feedback focuses on how EU forests contribute to the deployment of a sustainable bioeconomy as well as to the need for coherence and synergies between the Bioeconomy Strategy and other EU policy developments, in particular the European Green Deal. How are EU forests contributing to the deployment of a sustainable European bioeconomy? Forests and wooded land account for around 43.5 per cent of the EU's land area. European forests provide a multitude of ecosystem services including the provision of sustainable raw materials used for construction, furniture, pulp and paper, packaging, energy but also for textile, chemicals etc… which all contribute to and are a basic precondition for a growing EU Bioeconomy. The EU forest and forest-based sector offers key solutions for achieving the 2050 carbon neutrality goal by contributing to climate change mitigation in three essential ways: carbon sequestration, carbon storage in trees and wood products, and carbon substitution by providing raw material as a substitute for fossil-based and other carbon intensive material and energy. Releasing this potential, including via contributing to the development of a bioeconomy could lead to a win-win situation for society in combating climate change and for forest owners to continue to manage their forests in a sustainable way so as to provide all benefits expected by society. What should the review on the European Bioeconomy Strategy and its action plan take into account? We would like to express our regret about the way bioeconomy has been addressed under the European Green Deal. According to European Forest Owners, the role and benefits of bioeconomy towards achieving EU objectives have not been sufficiently acknowledged and encouraged by Green Deal implementation. One example is the recently published new EU Forest Strategy which has caused concerns among forest owners, as it is approaching bioeconomy more on the risks side rather than opportunities side. A concrete example for this is the definition of the cascading principle within the EU Forest Strategy. In our opinion, cascading should not mean giving priority to long lived products and minimise short lived products and energy production. Instead, in order to promote a sustainable bioeconomy, all uses of wood are needed and should be embraced, in consistency with already adopted European legislation and agreed targets, while incorporating high-value technology and innovation. The Commission should take in account that carbon sequestration, storage and substitution does not have the same capacity in aeternum and it is not extensive and accumulative. It is compulsory to have a sustainable forest management to prevent fires and floods provoked by biomass accumulation and massive afforestation without active management. Overall, it is of high importance to recall and explain again all the benefits of bioeconomy for society. The forest sector alone provides millions of jobs and contributes to the livelihoods of millions of private forest owners. It is also necessary to ensure a stronger recognition and concrete actions to support bioeconomy benefits in ongoing legislative developments including: - The EU Biodiversity Strategy to 2030 - The implementation of the EU Taxonomy Regulation - The new EU Forest Strategy - The revision of the RED II - The revision of the LULUCF Regulation - The implementation of ‘Farm to Fork’ Strategy
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Meeting with Helena Braun (Cabinet of Executive Vice-President Frans Timmermans) and European farmers and

2 Jul 2021 · European Green Deal and the next EU Forest Strategy

Meeting with Camilla Bursi (Cabinet of Commissioner Virginijus Sinkevičius) and European farmers and

2 Jul 2021 · European Green Deal and the next EU Forest Strategy

Meeting with Francisco Barros Castro (Cabinet of Commissioner Elisa Ferreira)

28 Jun 2021 · The new EU Forest Strategy

Meeting with Jorge Pinto Antunes (Cabinet of Commissioner Janusz Wojciechowski) and European farmers and

25 Jun 2021 · Forest strategy

Meeting with Laure Chapuis (Cabinet of Commissioner Kadri Simson), Peeter Kadarik (Cabinet of Commissioner Kadri Simson)

21 Jun 2021 · - To discuss about European Forest Owners hopes and worries regarding the EU Forest Strategy.

Response to Guidance on REDII forest biomass sustainability criteria

28 Apr 2021

CEPF points out the fact that forest biomass is the most important renewable energy source in the EU27 (Eurostat) and the effective utilization of sustainably managed forests in the EU will be in future very important to fulfill the aims of the Green Deal and the Paris climate agreement. CEPF welcomes the operational guidelines suggested by the Commission which are key to implement RED II sustainability criteria. CEFPF acknowledges the time pressure which the Commission is working with when looking ahead for July 2021, the start of the RED II implementation. However, on certain aspects the implementation guideline goes beyond the Directive’s competence and could therefore raise issues regarding Member States competences. We would emphasize the minimizing additional administrative burdens on forest owners and ensuring stable framework conditions for necessary investments in the bioenergy sector in order to meet the ambitious energy and climate goals. During 2020 the RED II BIO project report was under public consultation. It contained an analysis of national level compliance for EU MS and some other countries. We regret that this report was not published in time to provide stakeholders background information which would help assessing this guidance text. The regulations should stick to the same definition for forest biomass as the Directive it is meant explain. The regulation differentiates between “primary biomass from forests” and “secondary biomass from forests” while the directive uses “forest biomass” and “residue”. The regulation refers to in art 3 to four different forest categories: primary forests, natural forests, semi-natural forests, plantation forests. Only the last 3 are defined. It is not clear where these specific definitions come from. If it is expected that all forest can be classified in these types, the requirement in art 3 para 1.b.ii will be limiting for forest regeneration. We recommend using FAO definitions forest types. Please avoid mixing up “plantation forests” with “planted forests”. The implementation regulations should stick to the five sustainability requirements set in point (a) of Article 29 (6) of Directive (EU) 2018/2001. Especially we have trouble with art 3, para 1.b.ii and art 3 para 1.b.iv. See attachment for rationale and suggestion. The article 29, 6 a ii of the RED II refers to “forest regeneration of harvested areas” and relates only to the re-establishment of a forest stand by natural or artificial means following the removal of the previous stand by felling or as a result of natural causes, including fire or storm. Adding the requirement above in para 1.b.ii is adding a biodiversity angle, which is not the intention in the directive. The article 29, para 6.a.iv of the RED II refers to “maintenance of soil quality and biodiversity with minimizing negative impacts”. Adding regulation of the removal of stumps, roots, deadwood and where appropriate, needles or leaves to this regulation is too detailed. For both points the above-mentioned provisions of the guidance are going very much deeper level than in the RED II regulation text and is jeopardizing the role of Member States to explain and show how RED II requirements are covered by national legislation. Such details are rather subject to practices and operational guidelines. We would therefore suggest deleting these detailed level texts. It is unclear what “clear-cuts are minized” under art 4 1.b.iv. means (the amount, the area, the size, the responsibility to define what “minimization” means). This minimization and falling of the A-level assessment may paralyze the harvesting operations where bioenergy collection is a side product. We are concerned that this is a result of the toxification of the renewable energy debate (JRC report).
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Meeting with Camilla Bursi (Cabinet of Commissioner Virginijus Sinkevičius) and European farmers and

28 Apr 2021 · to discuss the Preparation of the EU Forest Strategy

Meeting with Jorge Pinto Antunes (Cabinet of Commissioner Janusz Wojciechowski) and European agri-cooperatives and

28 Apr 2021 · to discuss the preparation of the EU Forest Strategy.

Meeting with Janusz Wojciechowski (Commissioner) and

3 Feb 2021 · New EU Forest Strategy.

Response to Climate change mitigation and adaptation taxonomy

17 Dec 2020

Sustainable Forest Management principles (Forest Europe) guide forestry practices in EU. Sustainability criteria for forest biomass have already been defined in EU legislation (Renewable Energy Directive). Forestry is sustainable. There are systems in place at national and local level to verify it. Unfortunately, the proposed delegated act does not consider it. We very much would want to welcome this proposal, but not with the conditions that discard the core of the forest sector –Sustainable Forest Management. Delegated act should not be used as a tool to shift away from the Member State competence on forestry. It has been a common consensus for decades that the competence on forest management belongs to Member States. The solution for better coherence of policies would be working together with the Member States and sectors involved. In addition, delegated act should not be used to introduce new concepts to EU legislation. Indeed, as it comes to forestry, the draft delegated goes beyond the Better Regulation principle that “the delegated act cannot change the essential elements of the law”. The delegated act framework is therefore not appropriate and correct to define new, detailed sustainable forest management criteria. CEPF is concerned that the Commission is working with too much ambition and too little time to make legislative proposals. The delegated act would have deserved more transparency and would deserve more time for impacted stakeholders to be listened to. Forests are the first link in long value chains and networks of forest-based industries. CEPF has been promoting the RED II risk-based approach when establishing criteria for forests’ sustainability in Taxonomy Regulation. The reason is that we need a coherent approach, unattached from the end-use of wood when it comes to sustainability. Forest owners do not separate sustainable forest management planning and activities towards different end-uses. The different levels of ambition in criteria for different purposes could change the demand in wood markets and thus have an impact in forest owners’ management practices. CEPF would like to express strong concerns about how the process for this delegated act has been carried out. The lack of sectoral involvement can be seen in the complex criteria, complexity which will exclude most of the 16 million private forest owners to contributing to the climate change mitigation and adaptation via taxonomy system. Luckily some lessons were learnt from this first process and the Commission has invited stakeholders to work on the second batch of criteria via platform on sustainable finance. Uncertainty in definitions makes the evaluation of the delegated act difficult. In the forest related chapters, the delegated act refers to “improved forest management”, “close-to-nature forestry”, “stakeholder consultation for forest management plan” and “afforestation plan”. There is no forest owner who would agree to this without prior knowledge on the definition of these concepts. The delegated act proposes an extremely detailed forest management plan to be submitted and audited. This is not acceptable as the management planning choices belong to forest owners. In addition, such planning is regulated in different ways at national level and can’t be required in a harmonized way at EU level. This delegated act seems to shrink forest owners to reporting units who serve the cause of the financing sector. We have not seen an impact assessment for this delegated act from the sector´s point of view. Since the Sustainable Finance Action Plan was published, we have been asking at several occasion how this will directly and concretely help or impact forest owners to contribute to climate actions. Unfortunately, no answer was provided to this question. We don’t know either who will be reporting on the complex forest related criteria. This is a weak point of the delegated act – it is lacking reality of the actions on the field.
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Response to Access to Justice in Environmental matters

8 Dec 2020

The general principles of the Aarhus Convention (AC) are important. However, CEPF has not found support in the AC’s background papers or any primary source of law for the interpretation persistently put forward by the Aarhus Convention Compliance Committee (ACCC) which implies a right for basically anyone or any group, that identifies themselves as being a stakeholder, to take part in administrative processes, judicial reviews as well as court proceedings in almost all matters with a possible environmental aspect at both national and EU levels. The Proposal made, if validated, would give anyone, even those without actual environmental concerns, the possibility of attacking and preventing operations which would be contrary to their own interests without taking into account the general interest. The scope the Proposal clearly contains redefinitions and re-interpretations far beyond the original scope of the AC as it aims to extend it to apply to other acts than those under environmental law as well as to acts of general scope. It is also suggested that existing deadlines are too short for procedures under the Aarhus Regulation. This suggestion would leave the field open for law fare on small scale forest owners, from any groups that operate according to their convictions. This was not the original intention of the AC. The views put forward by the ACCC does not reflect minimum standard set up by the AC nor its scope. CEPF calls for a more balanced and objective approach which clarifies the wide possibilities for the Member States to implement the standards of the AC adjusted to their national administrative and legal system. In the Proposal, the ACCC has shown an unreasonable far-reaching interpretation of the obligations laid down by the AC. Based on its role and composition, the ACCC continuously strives to extend the scope of the AC beyond what was intended. The Proposal would, in addition to socioeconomic costs, lead to far reaching and negative consequences for individuals and small enterprises. This development can also be negative for the intent of the AC, and above all, negative for crucial overall goals such as mitigation climate change, shift towards bioeconomy and sustainable jobs’ creation. The Proposal shows no evidence of how the environment would benefit from the proposed amendments. The Proposal clearly lack in analysing the overall effect of the proposed amendments. As example, members of the Federation of Swedish Farmers have experienced the development of a very extensive access to court proceedings for NGOs due to the AC, the Swedish environmental Code, other relevant Swedish legislation as well as precedential court decisions. The consequences of this are unforeseeable delays and large costs for lawsuits for individuals and small enterprises. This also affects the initiative and the standard procedure of enforcement which is the competent authorising authorities’ responsibility. That initiative is transferred to NGOs, which have no responsibilities or liabilities. Their priorities are not an act of balance with the broader societal interest in focus. CEPF calls for a discussion on how to implement the AC in a more balanced manner where/if it is needed to strengthen the public, without putting important development for the society’s efficient functioning, individual’s ownership rights or small enterprises such as forest and investments economic predictability at risk. CEPF strongly request a thorough analysis of the consequences for these parties as well as the society as such. CEPF also calls for a thorough due diligence of the participants, work and aims of the ACCC. The very broad interpretation of the AC which is developing in terms of the current misinterpretation of Article 9 (9:2-3), is not in line with the original intentions. The consequences will be unforeseeable delays and large costs for lawsuits for individuals and very small enterprises. It thereby leads to an unwanted “juridification” of policy.
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Response to EU Forest Strategy

2 Dec 2020

CEPF would like to provide the following comments on behalf of the 16 million European forest owners who we represent 1. Elements that we support - The recognition of the need for a comprehensive strategy to ensure that forests are addressed in a consistent manner across the different policies - The EUFS will build on Sustainable Forest Management (SFM) - The EUFS will foster on adaptation of forests to climate change and on strengthening their resilience to face future challenges - The strong economic dimension that the EUFS will have to have - The fact that the EUFS will have to lay the foundations for innovation and promotion of new products that replace fossil-based materials and effectively contribute to a new climate neutral society - The highlight that will be given on training, skills and jobs - The need to foster innovative financial incentives - The need to improve forest monitoring and the role that the EUFS should play 2. Our views on the key objectives announced: afforestation, restoration and preservation The scope of these objectives is too limited and does not reflect the whole picture of the many challenges for EU forests nor the full potential of services forest already provide for the society. Such scope is not enough to secure a consistent approach between the EU’s domestic policies that the roadmap calls for and is missing consideration and support to dynamic SFM framework. It also does not seem compatible with the strong economic dimension, including the development of circular bioeconomy, that the EUFS will have to have. Regarding the restoration and preservation obj, the purpose and rationale should be clarified. 3. Important elements that we are missing The EUFS should be the key tool to make forest impacting policies work in the same direction. It should create an enabling framework conditions that does not hamper the implementation of sustainable forest management at national level which is a national competence. The Roadmap is ambitious and it has many objectives. However, the legal basis for so many miscellaneous objectives is unclear. In the “problem that the initiative aims to tackle”, the roadmap does not mention directly forests as the producer of wood, which is the most climate friendly raw material. We believe that SFM in Europe should build on the work of Forest Europe. Therefore a reference to Forest Europe SFM definition, criteria and principles should be added. The roadmap does not highlight the importance to maintain and strenghthen motivation of forest owners and managers to manage their forests furthermore. It also does not address the need to work and progress on implementing payment of ecosystem services (PES) especially in the field of climate protection and when SFM is subject to policy restrictions. Finally risk management should be incorporated in the management of forest areas. 4. Important clarifications that we need - We have strong concerns about the call “to foresee measures to avoid or correct unsustainable practices » which implies that forests are not sustainably managed. Clear definition of “unsustainable practices” based on sound information should be provided before making such call - We do not understand the call “to strive to decrease the loss of forest coverage” given that EU forest coverage has been increasing for decades - A definition of “last remaining primary and old growth forests who may need strict protection” should be provided 5. We support the views of European Parliament and Member States We are calling the Commission to build on Council conclusions European Parliament Resolution which are are calling to take a holistic approach to address forests and their multifunctionality, to build on SFM as defined under Forest Europe and to respect the distribution of competences between the EU and Member States From forest owners views, it is important that SFM and forests multifunctionality are the main guiding principles of the new EUFS
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Meeting with Florika Fink-Hooijer (Director-General Environment)

2 Dec 2020 · EU Forest and Biodiversity Strategy

European forest owners urge voluntary approach to nature restoration

1 Dec 2020
Topic — The European Commission is proposing legally binding targets to restore nature and biodiversity.
Message — The organization insists that restoration projects must be voluntary and require the prior consent of forest owners. They also demand that any targets be accompanied by guaranteed financing and implemented at the national level.123
Why — This shifts conservation costs to the EU and preserves private property rights.4
Impact — EU regulators lose the authority to mandate uniform conservation measures across all member states.56
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European forest owners demand priority for wood product substitution

26 Nov 2020
Topic — Review of EU rules on land use, land use change and forestry.
Message — The organization prioritizes substitution, sequestration, and storage in climate policy. They want wood products used to replace fossil fuels. Forestry should remain a separate accounting sector.12
Why — This allows owners to profit from investments and prevents raw material supply lockdowns.3
Impact — Industrial polluters lose the ability to use forests to offset their carbon emissions.4
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Meeting with Jorge Pinto Antunes (Cabinet of Commissioner Janusz Wojciechowski) and European farmers and

25 Nov 2020 · Meeting with forest stakeholders on the review of the Forest Strategy

Meeting with Helena Braun (Cabinet of Executive Vice-President Frans Timmermans) and European farmers and

25 Nov 2020 · Exchange of views on the upcoming EU Forest Strategy

Meeting with Agne Razmislaviciute-Palioniene (Cabinet of Commissioner Virginijus Sinkevičius) and European farmers and

25 Nov 2020 · Exchange of views on the upcoming EU Forest Strategy

Meeting with Wolfgang Burtscher (Director-General Agriculture and Rural Development)

22 Sept 2020 · CEPF to present itself and its views on the future EU forest strategy

Response to Revision of the Renewable Energy Directive (EU) 2018/2001

18 Sept 2020

The Confederation of European Forest Owners (CEPF) welcomes the EC initiative to possibly review the EU renewable energy rules in order to contribute to higher climate ambition as part of the European Green Deal and in support to the objectives of the EU Climate Law and 2030 Climate Target Plan. We do want to note some remarks and concerns regarding the content of the options described in the inception impact assessment and their possible impacts on the use of forest-based renewable energy. The production and use of renewable forest-based energy have important local and regional level impacts in the recovery of the rural areas after the COVID-19, economically as well as socially. 88 % of bioenergy plants are small and medium scale plants located across EU. We support the option to explore the possibility for a higher target in share of renewable energy consumption. All forms of renewable energy sources should contribute to the 2050 EU climate ambitions and should be supported. Climate Target 2050 cannot be reached without phasing out fossil fuels. The energy derived from biomass answers today to almost 60 % out of the total renewable energy production in EU and projections show that bioenergy wil contribute to the achivement of the the EU 2050 climate neutrality objective. Regarding the Option 4 we do not find it reasonable to amend the articles 29-31 in the REDII at this point of policy development. The implementing guidelines for REDII are almost finalized and the implementation of the REDII is just beginning. Possible amendments of these rules should only be considered after the implementation of the current regulation has been in place and evaluation results are available. We also emphasize the importance of stable policy environment in order to engage the stakeholders in implementation. Regarding the sentence: "The risk of unintended incentives for using unsustainable biomass will be assessed and minimised through appropriate safeguards.", the terminology “unsustainable biomass” is worth being clarified. The REDII regulation and its articles 29-31 are especially developed to ensure that the biomass used for energy purposes is sustainable. Also, as indicated above, CEPF is of the views that this regulatory system should be implemented before considering possible changes. Lastly, CEPF would like to remind that bioenergy developments can support forest owners in sustainably managing their forests through providing them an opportunity to get a revenue from management operations on co-products or low-quality wood. These management operations are essential to produce high value timber. EU policy framework stability and predictability regarding bioenergy developments is therefore important for the forest-based sector as a whole.
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Response to Long term vision for rural areas

9 Sept 2020

The Confederation of European Forest Owners (CEPF) welcomes the European Commission initiative to design a long-term vision for rural areas. As important feature of rural areas, sustainably managed European forests are of great consequence to achieve the goals of this initiative. In this view, CEPF is convinced that that forest owners can be key enablers of the success of the Commission announced long-term vision for rural areas. More than 40% of EU’s land area is covered with forests and other woodlands, with a major share located in rural areas. CEPF therefore believes that forests, the multiple socio-economic and environmental benefits they provide, and the people responsible for their management should be at the core of the design of the long-term vision. CEPF underlines that the long-term vision should acknowledge the essential role of those who are “behind the forest”, managing it and contributing to life and dynamism in rural areas. Custodian of 60% of European forest heritage, European forest owners (most of them family forest owners) are committed to sustainable forestry. As rural areas are expected to answer to many policy priorities laid out in the EU Green Deal, a coherent approach is essential. In this context, CEPF welcomes the approach to strive towards complementarity and coordination of the different policies under the European Green deal. CEPF strongly supports the achievement of a holistic vision of rural areas under the long-term vision, including a coherent and holistic approach of the EU forest-related policies through the new EU Forest Strategy. EU forest-related policies and the long-term vision for rural areas must reflect that rural areas are prone to natural hazards impacts and that sustainably managed forests contribute to increase resilience of rural livelihood and landscape features. Healthy and resilient forests and their owners will contribute to the improvement and support of resilient of rural areas and will also contribute to provide numerous goods and ecosystems services expected by society. As they grow, EU forests deliver on, among others, biodiversity, drinking water, carbon sequestration, wood and non-wood forest products or recreational and spiritual spaces. In this, EU forests in rural areas have a long-term role to play in the achievement of UN SDGs or EU climate neutrality goals. The many EU-forest related-policies should support appropriately these through coherent aims, appropriate funding sources and good scientific knowledge base. Lastly and specifically, following the impacts of Covid-19 on the EU economy, the European forestry sector can contribute to our recovery, in particular in rural areas. For this, CEPF highlights the crucial of role that the EU Bioeconomy Strategy should play in the long-term vision as the essential tool to tackle the specific issue of rural poverty and land abandonment. Economically viable European forests provide the largest non-food renewable resource for a sustainable bioeconomy and around 5 million jobs in forestry and related industries. Supporting this contribution will provide further innovations, jobs and value creation to sustain living rural areas. CEPF looks forward engaging with the European Commission on this important initiative
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Meeting with Helena Braun (Cabinet of Executive Vice-President Frans Timmermans)

28 Aug 2020 · EU biodiversity and forest policies

Response to EU Strategy on Adaptation to Climate Change

29 Jun 2020

The Confederation of European Forest Owners (CEPF) welcomes the EC initiative to propose a new and more ambitious EU Adaptation Strategy as part of the European Green Deal and in support to the objectives of the EU Climate Law. Under on-going changing climatic conditions, forests suffer from extreme weathers. It is projected that the occurrence and scale of natural disturbances, biotic or abiotic, will further increase, and it is thus essential to organise the paths towards stimulating forest health and resilience. Climate change already influences the life and work of forest owners in Europe, who report significantly increased pressures on forest ecosystems. Building up the resilience of European forests to climate change is a key feature of the policy considerations on climate change adaptation, as reflected in the Blueprint. In this view, we see the consideration of including in the Strategy actions that would provide more support to the resilience of forests and other ecosystems as a step in the right direction. Increased resilience of EU forests through their adaptation to climate change must be suitable to local conditions and consider all available tools (e.g. biological diversity and genetic resilience, risk management and prevention, restoration of forests degraded by natural disasters, or forest management plans). The future Adaptation Strategy should promote a flexible and dynamic approach of resilience. The long-term nature of forestry implies that selection of tree species should be forward-looking: they must remain adapted to site and climatic conditions foreseen by climate modelling. To meet a holistic approach of multifunctional forestry, species should also continue to produce the products and services for which they are valued. CEPF believes that the EU Adaptation Strategy should be greatly oriented towards improving the knowledge of the scope and scale of climate change impacts on European forests, as well as to increase knowledge on ways to tackle, to prevent and to better adapt forests to these changes. Better access to knowledge with up-to-date scientific research, operational and user-friendly tools, and long-term data series, taking into consideration existing best examples of forest monitoring at regional level as well as improved outreach, trainings and exchange of good practices will be needed to secure active involvement and participation of forest owners. In addition, European forests today carry a great climate mitigation potential that provides major climate benefits. Management of EU forests in a sustainable and active way contributes to enhanced absorption of CO2 from the atmosphere and at the same time provide renewable and climate-friendly raw material which store carbon and can substitute fossil-based materials and fuels. Thus, it will be important to create synergies between climate change mitigation, adaptation needs and the EU climate neutrality goal. Reaching the objectives of the Strategy will require concrete and appropriate funding sources and opportunities provided in an unbureaucratic way. Other financial instruments to manage exposure to risk in forests should be explored and assessed, such as more concrete opportunities and utilization of forest insurances in the EU, including of greater areas, so to decrease exposure to risk in risk prone areas. Finally, CEPF supports further and reinforced mainstreaming of adaptation considerations in EU policies and instruments. Adaptation is key to maintain our forest, thus, opportunities should not be prevented by limitations on forest management. CEPF also sees the need to establish a firm reference in the Strategy with the new EU Forest Strategy, which should act as the main policy framework for forest issues. CEPF believes the above-mentioned issues should be considered when developing action and policies required for EU adaptation to climate change and is looking forward to contributing to the next steps of the process.
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Response to Climate change mitigation and adaptation taxonomy

17 Apr 2020

CEPF welcomes the fact that the sustainable finance initiative recognizes the significant contributions provided by the forest sector to the overall objective of a carbon neutral Europe. To strengthen these contributions, investments are indeed needed in order to achieve not only the climate change mitigation and adaptation objectives, but also to maintain other forest functions and to respond to other growing expectations from society addressed to European forests. Thanks to Sustainable Forest Management (SFM), as stated by the IPCC experts, the forest and forest-based sectors can replace the fossil carbon by a circular bioeconomy and substitute the fossil based and fossil intensive materials and energy. The impact assessment of the delegated acts following the TEG report is therefore crucial to achieve maximum climate benefit from the forestry sector. Objectives and policy option: The roadmap rightly reminds the need to develop the initiative in line with the requirement of art 14 of the Taxonomy Regulation, including the requirement to assess the alignment of the technical criteria with existing legislation. CEPF is of the views that the criteria set in the final TEG report are not in line with existing legislation, in particular the recast of the Renewable Energy Directive (RED II). As noted in the EU Forest Strategy, forest management lies within the competence of Member States and e.g. therefore it was agreed in the REDII to include the sustainability criteria for forestry to the Directive by respecting the national legislations and their implementation with respective monitoring and enforcement systems in place. A similar kind of approach should be applied also in the taxonomy. The evaluation of alignment with article 14 of the Taxonomy Regulation is therefore a very important exercise to carry out. Economic impacts: CEPF believes that the likely economic impacts of the future Delegated Act should address carefully the possible impact of the criteria on forest management activities who have already undertaken important investments. Further investments to these activities may be needed to keep developing EU’s circular bioeconomy and rural areas and ensure the supply of sustainable wood. Therefore, the security and continuity of investments should be secured. Also, the criteria set in the future delegated act should be not only practically feasible but economically feasible to ensure this future supply. The criteria proposed in the TEG may put this supply at risks. The above is even more important, given the extremely complicated situation that many sectors, including the forest sector, are going through due to COVID 19. Social impacts: It is essential that future criteria do not hamper the developments of sectors which are essential to achieve the EU 2050 carbon neutrality goal, such as the forest and forest-based sectors, since this would have a significant impact on the EU society. CEPF is of the views that the criteria set by the TEG report may put at risk investments in active and sustainable forest management of EU forests, which is essential to deliver benefits to society, including carbon storage in wood products and substitution of fossil fuels. Evaluation of impacts CEPF is the views that the evaluation should build on concrete and variable facts and data. To address both social and economic impacts of the future delegated act on the forest sector, CEPF calls the Commission to rely on expertise from the forest sector. CEPF regrets that the TEG did not rely on such expertise which has led to shortcomings and misconceptions related to forests and forestry in the final TEG report. CEPF hopes that experts from the forest sector will be part of the members of the platform on sustainable finance. Public consultation: Regarding future public consultation, CEPF is looking forward to providing inputs on the draft delegated act once it will be published and ahead of its expected adoption in Q4.
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Meeting with Jorge Pinto Antunes (Cabinet of Commissioner Janusz Wojciechowski)

8 Apr 2020 · The ongoing preparation of the EU Biodiversity Strategy to 2030

Response to Minimising the risk of deforestation and forest degradation associated with products placed on the EU market

4 Mar 2020

The Confederation of European Forest Owners (CEPF) has welcomed the European Commission’s Communication aiming at addressing global deforestation published in July 2019. European Forest Owners support the EU in taking actions to tackle this issue. To prevent future forest losses through among others, fire’s outbreaks and other disasters, deforestation and its causes, including socio-economic challenges, must be addressed and appropriate support for those unique tropical rainforests should be provided. CEPF would like to highlight that from its European perspective a reliable legal framework is a prerequisite to prevent deforestation. One key element of legal reliability are secure ownership and tenure rights that allow the respective owners to invest and sustain their forests in the long term. Other important elements are decent standards of living, the insurance of legislation and governance enforcement and the fight against corruption. About the possible instruments listed in the inception impact assessment text, CEPF would like to remind about the existing forest certification systems. Forest certification is a voluntary, market-based tool to promote sustainable forest management. In Europe, an estimated 60 percent of forests are certified via either the Programme for the Endorsement of Forest Certification (PEFC) or the Forest Stewardship Council (FSC) , or both. Since the 1990’s, forest certification has been increasingly applied also in private forestry and has had a positive impact on sustainable forest management in private forests. CEPF is of the views that these existing certification systems should be considered by the European Commission when assessing non-regulatory policy options aiming at minimising the EU’s contribution to deforestation, since both these schemes have proven their effectiveness and positive results over the last decades.
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Response to Climate Law

5 Feb 2020

Climate change is one of the biggest challenges in this millennium and the paths towards reaching the carbon neutrality objective are therefore essential to organise. In this respect, the Confederation of European Forest Owners (CEPF) welcomes the European Commission initiative to propose a European Climate law. The EU forest sector is one of the most essential actors to achieve this aim. Sustainable and active forest management provides three main climate benefits: CO2 sequestration in resilient, growing forests; carbon storage in wood products; and substitution with a renewable and climate-friendly raw material which replaces fossil-based materials and fuels. Continuous management of EU forest in a sustainable and active way and creation of more forests (afforestation) within the EU will contribute to enhancing the absorption of CO2 from the atmosphere. At the same time, replacing fossil-based products and energy with wood will contribute to reduce the release of CO2 emissions to the atmosphere, while ensuring that forests continue to grow and provide many other services. The reorientation towards a fossil free circular bio-based economy, moving away from the fossil-based economy, is indispensable. The forest-based sector actors, including European forest owners, are ready to become the most competitive, innovative and sustainable provider of net-zero carbon solution for a climate neutral Europe. In the EU, since the last decades, we have witnessed a steady growth of the forest area, growing wood stock and carbon stock. Natural forest expansion following structural changes in agriculture, afforestation, an increase of forest areas actively managed, wider use of modern forest management practices, and harvesting levels lower than the annual increment are among the reasons for this increase. Over the last years, we have also witnessed a growing number of natural disturbances which have dramatically affected EU forests and are projected to further increase (e.g. fires, droughts, floods, storms, insects’ outbreaks etc…). A solution to counteract this most serious threat on EU forests, is sustainable forest management which creates synergies between climate change mitigation and adaptation needs. Therefore, regarding EU forests, the new EU Climate Law should be closely linked to the future New EU Climate Adaptation strategy in order to adapt forest management practices to make forests more resilient to changing climatic conditions and to have higher carbon sequestration and as a result to provide more raw material to substitute carbon intensive material and energy. The future EU Climate Law should also highlight the role of Research and Innovation policy which is a key enabler to allow the forest sector to continue to deliver on the many societal expectations, including climate change mitigation. More information about the R&I priorities identified by the Forest-based sector is available in the Strategic Research Agenda of the Forest-based sector Technology Platform (FTP). European forest owners are of the views that the future EU climate law should acknowledge the crucial role of forest management and wood in achieving 2050 carbon neutrality goal. To this aim, it should build on the holistic concept of sustainable forestry and multifunctional forests in order to link the climate change mitigation benefit with the other ecosystem services that forests can provide thanks to the involvement of local actors in rural areas. Thus, a strong reference should be established with the EU Forest Strategy post-2020, which should ensure consistency between forest-related policies. This will allow to take an integrated approach since the Green Deal is an opportunity to use and consolidate the full, long term contribution of EU forests to climate change mitigation but also to several other Sustainable Development Goals. CEPF is looking forward to further collaborate and contribute to the next steps of those processes.
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Meeting with Catherine Geslain-Laneelle (Cabinet of Commissioner Janusz Wojciechowski)

22 Jan 2020 · Le secteur forestier dans le Green Deal

European forest owners urge national-led approach to biodiversity strategy

17 Jan 2020
Topic — This consultation outlines EU plans to restore ecosystems and curtail biodiversity loss.
Message — Measures should be decided at the national level to respect local specificities. They call for improving existing laws before adding new protected areas or legislation. Targets must remain realistic to ensure they can be practically implemented.12
Why — A decentralized approach allows forest owners to avoid burdensome new EU regulations.3
Impact — Environmental groups lose the prospect of uniform, legally binding EU-wide conservation targets.4
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Response to Review of Agricultural Block Exemption Regulation

22 Feb 2019

The Confederation of European Forest Owners (CEPF) welcomes the European Commission initiative to review the Agricultural State aid Guidelines and the Agricultural Block Exemption Regulation (ABER). CEPF considers that consistency and continuity between the CAP Strategic Plans regulation and future State aids Guidelines are essential for the forest sector, which is known for long-term actions and over-generational thinking. CEPF also considers important to ensure appropriate national flexibility to enhance viability of EU rural areas and ensure the sustainable management of European forests. More than 40% of EU’s land area is covered with forests of which approximately 60% are privately owned. European forests represent more than half of the designated Natura 2000 areas. Forests sequester CO2 from the atmosphere as they grow and deliver multiple goods and ecosystem services such as biodiversity, soil protection, drinking water, non-wood forest products and recreational spaces. At the same time, forests are a sustainable source of timber, pulp, paper and energy, providing the largest non-food renewable resource for a sustainable bioeconomy, growth in rural areas and around 4 million jobs in forestry and related industries. Forest resources, including growing stock and the size of forests have been significantly increasing during last decades in Europe. Thus, forest sector and active sustainable forest management contribute significantly to the achievement of the EU rural development, environmental, climate and bioeconomy policy targets. Investments in active and sustainable forest management are one of the prerequisites for the development of healthy and viable forest resources and a basis for the development of the sector. The current State aids Guidelines follow closely the Rural Development regulation 2014-2020. As the delivery model and the structure of the Commission proposal for a CAP Strategic Plans regulation differs significantly from it, with the removal of EU level eligibility criteria for support and increased Member States flexibility to define national eligibility conditions and measures, the reviewed State aids Guidelines should be adapted to the new legal framework. Given this new approach, State aid Guidelines framework should allow enough flexibility for Member States to define appropriate forestry support schemes and eligible forestry measures according to their national context. Moreover, State aid Guidelines should not set stricter limit to eligible support schemes and measures than the CAP Strategic Plans regulation. This may place forest owners in unequal positions depending on their home country. This would also be against a coherent policy between EU funded support schemes and national funded schemes. CEPF welcomes the opportunity to contribute to further steps of the review and reminds that it is of utmost importance that European forest owners are considered as main partners, and not only as stakeholders, when it comes to reviewing State aids Guidelines and ABER.
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European forest owners demand partnership in CAP biodiversity review

6 Dec 2018
Topic — An evaluation of how the Common Agricultural Policy affects habitats and biodiversity.
Message — CEPF wants the evaluation to prioritize cost-effectiveness and long-term forest dynamics. They request that external factors like climate change be considered when measuring performance. The group also demands that forest owners be treated as primary partners in the process.123
Why — This allows owners to justify funding through climate-related services like carbon storage.4
Impact — Environmental groups lose the ability to hold owners accountable for declining biodiversity trends.5
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Forest owners urge active management over 'carbon museums'

10 Aug 2018
Topic — The EU is developing a long-term strategy for reducing greenhouse gas emissions.
Message — Forest owners request active management and using wood to replace fossil-based products. They want the land-use sector kept separate without mandatory targets for carbon sinks.123
Why — Active management and market incentives protect revenue streams while avoiding new regulatory burdens.45
Impact — Environmental groups lose if the policy shifts away from passive forest conservation for biodiversity.6
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Response to Multiannual Financial Framework - CAP Strategic Plans

3 Aug 2018

The Confederation of European Forest Owners (CEPF) welcomes the European Commission proposal for a regulation on Common Agricultural Policy (CAP) Strategic Plans COM(2018) 392 final. CEPF highlights the essential role of forestry in achieving both EU and global objectives on climate, environment, bioeconomy, jobs and growth. The EU Forest Strategy stresses that CAP plays a crucial role in enhancing the contribution of forestry to reach these objectives. More than 40% of EU’s land area is covered with forests of which approximately 60% are privately owned. Forests sequester CO2 from the atmosphere as they grow and deliver multiple goods and ecosystem services such as biodiversity, soil protection, drinking water, non-wood forest products and recreational spaces. At the same time, forests are a sustainable source of timber, pulp, paper and energy, providing the largest non-food renewable resource for a sustainable bioeconomy, growth in rural areas and around 4 million jobs in forestry and related industries. Investments in active and sustainable forest management will contribute to the achievement of CAP objectives. Therefore, CEPF welcomes the recognition of the role of forestry in EU specific CAP objectives, the continued presence of forestry measures under the Rural Development, and the reference to the EU Forest Strategy and the LULUCF regulation. Moreover, CEPF underlines the importance of strengthening the interlinkage between bioeconomy and sustainable forest management in the context of CAP post-2020. The EU-grown sustainable biomass is the first enabler of an EU bioeconomy and can further boost the vitality of the entire value-chain. It promotes the further development of rural areas and offers new business opportunities. CEPF supports the greater emphasis on research, innovation, technology and digitalization and calls for a more prominent role of forestry in the European CAP Network. Regarding the development indicators, CEPF highlights the importance of acknowledging changes in trends that are bound to the dynamic and long-term processes in nature. European forest owners have a crucial role as managers of forest resources, not only on tackling challenges related to social and economic sustainability but also on challenges related to environment and the impact of climate change on the resilience and vitality of forests. Therefore, CEPF highlights the link between active sustainable management and long-term climate goals to be achieved via resilient forests and increased CO2 sequestration, carbon storage and substitution of fossil-based materials. CEPF takes note that the proposal strengthens focus on environmental issues. Promoting and supporting the implementation of sustainable forest management in the EU is key to address biodiversity and is consistent with the UN SDGs. Thus, CEPF highlights that forest owners, as managers of forest resources, and their associations should remain eligible to receive financial support for their efforts to strengthen sustainable forestry and ecosystem services provided by forests. Measures within rural development programs should not only cover costs of those activities but also provide income for forest owners. Regarding the application, administration and verification of progress toward the target processes, CEPF supports further increased simplification. Furthermore, a real simplification for beneficiaries should not only be addressed at EU level but also at national level. It is crucial that the control and sanction mechanisms respect the proportionality principle. Additionally, reality of small-scale forestry should be better acknowledged. Forest management plans should not be compulsory for small holdings below 20 hectares as the plans unnecessarily increase administrative burden for small-scale forest owners. Consequently, we are convinced that CAP Strategic Plans regulation should continue to support and embrace sustainable forestry.
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Forest owners urge EU to avoid new administrative burdens

18 Jul 2018
Topic — The European Commission is evaluating the effectiveness and coherence of its biodiversity strategy.
Message — CEPF wants the EU to recognize forest owners as main partners rather than just stakeholders. They emphasize that existing laws already safeguard management and warn against new administrative burdens.12
Why — Restricting new regulations would help forest owners avoid costs and maintain operational autonomy.3
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Response to EU implementation of the Aarhus Convention in the area of access to justice in environmental matters

5 Jun 2018

Free access to environmental justice promoted by the Aarhus Convention, aimed to facilitate the defense of the environment by avoiding the unequal conditions in the access to justice between large industrial corporations and a citizen or an NGO with limited means. The general principles of the Aarhus Convention are important, but the very broad interpretation of the Convention, which is currently developing, is not in line with the original intentions and induces unequal conditions in the access to justice. The juridical argumentation to extend the possibilities for some parties to initiate court proceedings regardless the consequences for others has resulted in an unbalanced implementation. Even on matters with very limited environmental impact, such as small-scale forestry, the convention is used as a justification to start a legal process that may cause unnecessary delays and costs for forest owners. As an example, in many member states, there are developments of a very extensive access to court proceedings for environmental NGOs due to i.e. national environmental legislations and precedential court decisions. Above mentioned developments lead to negative consequences for individuals, SMEs, authorities and sustainable development for societies. The unforeseeable delays and large costs for lawsuits for individuals and SMEs might imply that the simple threat of court proceedings result in abandonment of the forest area due to high cost of the judicial process for forest owners. It could also have a negative impact on the possibilities to take decisions that are necessary for climate change mitigation and adaptation as well as sustainable development considering economic, social and environmental aspects. The EU and national legislations must maintain the rule of law also in environmental matters. The Confederation of European Forest Owners (CEPF) acknowledges the importance of the general principles of the Aarhus Convention, but does not support the broad interpretation that any interest group could initiate a lawsuit in almost all matters with a potential environmental aspect. CEPF calls for a more balanced and objective approach which clarifies the wide possibilities for member states to implement the standards of the Convention. To sum up, the interpretation proposed in the Commission Notice risks to hasten a development in the EU of access to justice which, in addition to socioeconomic costs, could lead to far reaching and negative consequences for individuals and SMEs and the society as such. This development could also be contrary to the original purpose of the Aarhus Convention and hinder possibilities to achieve the EU climate and energy goals as well as the UN Sustainable Development Goals.
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Meeting with Tom Tynan (Cabinet of Commissioner Phil Hogan)

24 Apr 2018 · Business discusison

Response to Update of the 2012 Bioeconomy Strategy

19 Mar 2018

The Confederation of European Forest Owners (CEPF) welcomes the European Commission initiative to update the EU Bioeconomy Strategy 2012 and its Action Plan. CEPF highlights the importance of adapting the strategy to better correspond the current political priorities such as the UN Sustainable Development Goals, the Paris Agreement and EU policy developments such as the future Common Agricultural Policy, EU Forest Strategy and the Circular Economy. More than 40% of EU’s land area is covered with forests; a sustainable source of timber, pulp, paper and energy, providing the largest non-food renewable resource for a sustainable bioeconomy, growth in rural areas and around 4 million jobs in forestry and related industries. At the same time, Europe’s forests sequester carbon from the atmosphere as they grow and deliver multiple goods and ecosystem services such as biodiversity, drinking water, non-wood forest products and recreational spaces. Forest owners have crucial role as managers of these natural resources so development of incentives and market-based tools for promoting these values should be developed. Consequently, forestry and the forest-based sector have a crucial role not only tackling challenges related to climate and environment but also challenges related to social and economic sustainability. Therefore, CEPF considers that the scope of the future initiative should address, via proposed systematic approach, not only future proofing food systems but also forest-based sector in Europe. In addition, CEPF agrees that it is highly relevant that the initiative expands beyond research and innovation. However, rather than addressing trade-offs, the initiative should aim at finding synergies between sectors. This exercise should provide a reinforced framework that builds on the EU’s common efforts to accelerate the transition from a fossil-based to a more bio-based economy with the inclusion of renewable raw materials for material and energy sectors. Moreover, as the EU-grown sustainable biomass is the first enabler of an EU bioeconomy and can further boost the vitality of the entire value-chain, the exercise should promote the further development of rural areas and offer new business opportunities along the value chain. Promoting and supporting sustainable biomass production and mobilisation in the EU is key to further developing the bioeconomy, and consistent with worldwide sustainable development based upon renewable resources. Involvement of forest owners in the structures of the bioeconomy initiatives and decision making processes is of utmost importance to strengthen partnerships between different actors of society and enhance public awareness of the sustainable use of biomass resources. To better follow the effects of the bioeconomy strategy and enhance public awareness, socio-economic SMART indicators should be developed to highlight all the aspects of sustainability better. CEPF agrees the importance of strengthening the circular bioeconomy and reminds that in the EU the implementation of existing European and national policies and regulations ensure the sustainability of forest biomass sourcing. This should be taken into account before taking any action on developing a new regulatory framework with additional, unnecessary burdens. Forest owners support the view that existing Sustainable Forest Management (SFM) practices are already well covered by Member State legislations and other additional tools. These practices ensure the sustainability of all forest biomass, irrespective of its end use. The Roadmap describes eight priority areas in which above mentioned issues should be taken into account as the Commission drafts the more detailed actions for the future bioeconomy. Should you have any questions please do not hesitate to contact the CEPF Secretariat.
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Meeting with Tatu Liimatainen (Cabinet of Vice-President Jyrki Katainen)

15 Feb 2018 · Forest and Bioeconomy

Response to Commission Delegated Regulation on the methodology for risk assessments of invasive alien species

21 Dec 2017

The description of the current distribution of the species, referring to Art. 5(1,e) of the IAS Regulation should clearly indicate the specific area (ha, or percentage of EU territory) in which a species is present, could introduce, establish and spread. This information should be complementary to the description of the current distribution of the species in biogeographical regions in which it could potentially enter and form a viable population. This is of importance since assessing the risk of IAS on a biogeographical level does not sufficiently take into account that the EU is a highly heterogeneous and large territory and the adverse impact of species, also in one biogeographical region, can differ significantly. Beyond that, there should be a specification from which size of an area (ha, or percentage of EU territory) a species should be considered as being of Union concern. According to Article 5(1,h), the risk assessment should have regard to the description of known uses for the species and social economic benefits deriving from those uses. Therefore we see it as a necessity to search for all available socio-economic data and if needed to create it. The consideration of available and creatable socio-economic data must be binding. So far the draft requires only a consideration of socio-economic issues in case that these appear “relevant” and are “available”. Moreover, the current draft does not fully consider these requirements for a socio-economic perspective. Actually, the risk assessments are usually undertaken by experts, not having the appropriate economic background and expertise regarding the socio-economic aspects. Therefore, it should be ensured that experts with the appropriate expertise to assess the socio-economic benefits as described under Art. 5(1,h) are appointed. For all species listed under the IAS Regulation and for all species that are undergoing a risk assessment, significant socio-economic benefits have to be taken into consideration and must be assessed within the risk assessments. Furthermore, special attention should be given to species that are widely used and provide significant social and economic benefits to Member States and this has to be reflected by the Annex to the draft Delegated Act. Regarding Article 2(3) of the Delegated Act, the delegated act should be restricted to scientific data and publications, applied in the process of a scientific risk assessment. In cases where there are no peer reviewed scientific publications or where the information provided by such publications is insufficient, risk assessments should not be undertaken or finalised, before appropriate data is available. This is backed by the case law of the Court of Justice (2002, T-70/99 and 1991, C-269/90), which states that a risk assessment must be carried out by scientific experts and be in a scientific process based on scientific data resulting in a scientific advice, meeting the requirements of excellence, independence and transparency ensuring that the regulatory measures adopted by the Community institutions have a proper scientific basis and to ensure that the institutions were in a position to examine carefully and impartially all relevant evidence in a particular case. Beyond that, members of scientific fora have to be independent. This is usually not the case, referring to considerations 234-238 of Case T-70/99, that members of scientific fora are not independent when they are also being employed by Member States. Furthermore, the involvement of land owners and managers into the process, among others identifying positive and negative effects of IAS on the economy has to be taken into consideration.
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Meeting with Christiane Canenbley (Cabinet of Commissioner Phil Hogan)

16 Feb 2017 · Action Plan for enhanced implementation of the Nature Directives

Meeting with Shane Sutherland (Cabinet of Commissioner Phil Hogan)

24 Jan 2017 · Bioeconomy

Meeting with Shane Sutherland (Cabinet of Commissioner Phil Hogan)

25 Apr 2016 · Forestry

Meeting with Shane Sutherland (Cabinet of Commissioner Phil Hogan)

7 Mar 2016 · Sustainable Forestry

Meeting with Shane Sutherland (Cabinet of Commissioner Phil Hogan)

22 Feb 2016 · Forestry and Climate Change

Meeting with Maria Asenius (Cabinet of Vice-President Cecilia Malmström)

13 Oct 2015 · Renewables and bio energy

Meeting with Carlos Moedas (Commissioner) and European farmers and

2 Feb 2015 · Meeting with the European Bioeconomy Alliance on the Bioeconomy Strategy

Meeting with Shane Sutherland (Cabinet of Commissioner Phil Hogan)

12 Jan 2015 · Forestry