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European State Forest Association

EUSTAFOR

The European State Forest Association promotes sustainable management of publicly owned forests across the EU.

Lobbying Activity

Meeting with Andrea Vettori (Head of Unit Environment) and European farmers and

19 Nov 2025 · Guidance document on the species protection requirements of the Birds Directive

EUSTAFOR seeks credit for existing sustainable state forest management

26 Sept 2025
Topic — The European Commission is developing a market-based framework to finance biodiversity through nature credits.
Message — EUSTAFOR requests that the credit system rewards existing sustainable forest management instead of only new projects. They seek full inclusion for public forest owners and the integration of current certification standards.123
Why — Public forest managers would secure new revenue streams and avoid expensive, duplicative administrative requirements.45
Impact — Global biodiversity risks harm if reduced logging in credited areas causes increased extraction elsewhere.6
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Meeting with Laia Pinos Mataro (Cabinet of Executive Vice-President Stéphane Séjourné)

16 Sept 2025 · EUSTAFOR positions towards EU policies and instruments, in particular the upcoming revision of the EU Bioeconomy Strategy

EUSTAFOR urges active management to reach 2040 climate targets

10 Sept 2025
Topic — Amending the European Climate Law to establish a climate target for 2040.
Message — EUSTAFOR advocates for active forest management and rejuvenation to maintain carbon sequestration and resilience. They request a recalibration of LULUCF targets using realistic data and updated carbon sink projections. The association also emphasizes the climate benefits of wood products in the bioeconomy.12
Why — This approach would secure the economic role of state forests and prevent industry job losses.3
Impact — Other industrial sectors lose the ability to treat forests as simple offsets for their pollution.45
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State foresters urge EU to recognize forests as critical infrastructure

3 Sept 2025
Topic — The consultation seeks input on an integrated framework for European climate resilience.
Message — EUSTAFOR wants forests recognized as essential infrastructure and managed actively by professionals. They propose reorienting EU funds to support long-term adaptation and site-specific strategies.12
Why — This approach would unlock new EU funding streams for forest infrastructure and management.3
Impact — Groups advocating for passive conservation lose as the focus shifts toward intensive forest management.4
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Meeting with Jessika Roswall (Commissioner) and

13 May 2025 · EU policies relevant for forests

Meeting with Emma Wiesner (Member of the European Parliament, Rapporteur)

13 May 2025 · Skogspolitik

Meeting with Emmanuelle Maire (Head of Unit Environment) and Conféderation Européenne des Propriétaires Forestiers

20 Mar 2025 · Exchange of views on bioeconomy

EUSTAFOR Urges Integrating Sustainable Forestry into EU Water Strategy

4 Mar 2025
Topic — The European Water Resilience Strategy aims to secure water resources across the EU.
Message — Integrate sustainable forestry practices into water management policies to ensure long-term stability. Forest management must remain active to balance healthy ecosystems with regional water resources. Increase financial investment in water-smart forestry practices through dedicated EU funding mechanisms.123
Why — The organization would secure funding and political recognition for active forest management operations.4
Impact — Local communities face reduced water yields if forest expansion occurs without active management.5
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State foresters demand economic trade-off assessments in restoration plans

7 Feb 2025
Topic — The European Commission is standardizing the format for national nature restoration plans.
Message — EUSTAFOR requests that national restoration plans indicate potential trade-offs having serious impacts on land-use. They also recommend a mandatory Policy Impact Assessment to evaluate consequences for the value chain.12
Why — Economic impact assessments help foresters protect commercial interests against new environmental requirements.3
Impact — Global climate goals suffer if restoration is deprioritized due to short-term greenhouse gas increases.4
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Meeting with Ion Codescu (Head of Unit Environment)

23 Jan 2025 · Meeting with EUSTAFOR to discuss on the implementation of the EU Forest Strategy, including the Forest Monitoring proposal.

Meeting with Adam Jarubas (Member of the European Parliament)

12 Dec 2024 · Leśnictwo w pracach Komisji Europejskiej i Parlamentu Europejskiego w rozpoczynającej się kadencjii

Meeting with Taru Haapaniemi (Cabinet of Commissioner Janusz Wojciechowski)

11 Sept 2024 · General discussion about State-owned forests; bio-economy; EUDR; nature restauration law.

EUSTAFOR Urges More Realistic EU Carbon Sink Targets

11 Jul 2024
Topic — Evaluation of EU rules governing greenhouse gas emissions and removals from land and forestry.
Message — EUSTAFOR requests updating LULUCF targets using national data instead of outdated models. They argue that relying on forests to offset industrial emissions is unrealistic given climate risks. The group advocates for active forest management to ensure long-term resilience.123
Why — This would lower compliance pressure on foresters and promote the wood-based bioeconomy.4
Impact — Emitting industrial sectors would face more pressure to reduce their own direct pollution.5
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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

EUSTAFOR Demands Protection of Data Ownership in Forest Monitoring

7 Feb 2024
Topic — The EU is establishing a framework for digitalized and regular monitoring of forest conditions.
Message — EUSTAFOR urges the Commission to respect Member State data ownership and use established international monitoring systems. They recommend using implementing regulations instead of delegated acts to ensure expert involvement throughout the process.123
Why — Restricting map resolution protects commercial operations from public interference and maintains national control.45
Impact — The public loses access to granular data on selective cutting and forest disturbances.6
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Response to Revision of the plant and forest reproductive material legislation

7 Dec 2023

EUSTAFOR is pleased to have the opportunity to give constructive feedback on the proposal for the new Forest Reproductive Material Regulation (FRM). As a representative of 38 State Forest Management Organizations from 26 European countries, EUSTAFOR firmly shares the opinion that active sustainable and multi-functional management of the European forests is crucial to keep them growing, healthy and resilient natural resource against the increasing biotic and abiotic risks linked to climate change. EUSTAFOR recognizes that the availability of certified seeds and planting material is a precondition to improve the quality and resilience of European forests in the long run. Considering the legal proposal, EUSTAFOR cannot support setting up the new legislation in the form of a regulation. It is our opinion that the need for local adaptation to the conditions is more important than full harmonization. EUSTAFOR cannot support empowering the Commission to adopt delegated acts to change crucial parts of the proposal either. EUSTAFOR is in general positive to harmonization of appearance and information in master certificates and labels as well as definitions, as the irregularities in certificates between different countries may cause in some cases misunderstandings. The professional operators and forestry organizations must however be involved in the discussions on this matter to ensure a smooth transition.. A concern of EUSTAFOR is the demand for each Member State to have a contingency plan. We recommend leaving the planning of reserve stock up to the very local level, whilst enabling producers and the free market to balance their stock with the market demand. It is also important to EUSTAFOR members that the FRM will be consistent with the PRM and regulation on production of ornamental plants, so that operators can sell material approved as forest productive material for other purposes as well. finally, EUSTAFOR recognizes that many plants are currently discarded due to weeds and diseases, as there is a lack of (mechanical) plant protection methods. It is our opinion that investments in research and development in these areas would have a greater effect on the availability of suitable plants than a new administrative system. Our points of concern are further elaborated upon in the attached document.
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State Foresters Seek Forest-Specific EU Soil Monitoring Rules

3 Nov 2023
Topic — The Soil Health Law proposal aims to monitor, manage, and restore EU soils sustainably.
Message — EUSTAFOR advocates for land-use-specific measures and monitoring intervals extended to ten years for forests. They oppose the strict one-out-all-out assessment method and new certification requirements.123
Why — This would reduce administrative costs and prevent unnecessary financial burdens from redundant certification.45
Impact — Environmentalists lose a rigorous standard that classifies any failing metric as unhealthy.6
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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

European state foresters urge realistic 2040 EU climate targets

23 Jun 2023
Topic — This consultation gathers stakeholder feedback on establishing a European greenhouse gas reduction target for 2040.
Message — EUSTAFOR calls for realistic 2040 targets for the land-use sector that emphasize forest adaptation. They argue forests should not just offset other sectors' emissions and advocate for a bioeconomy.123
Why — Shifting to a bioeconomy ensures a continued market for their wood products.4
Impact — Other industrial sectors would face higher emission reduction burdens if land-use targets are lowered.5
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Meeting with Janusz Wojciechowski (Commissioner) and

21 Jun 2023 · to discuss the implementation of the EU Forest Strategy 2030 and several actions embedded therein

State foresters demand long-term climate focus in carbon certification

14 Mar 2023
Topic — The European Commission is developing a regulatory framework for certifying carbon removals.
Message — EUSTAFOR insists that certification must prioritize active forest management over short-term offsets for polluters. They argue that methodologies should recognize existing state efforts and include national experts.12
Why — This ensures state foresters receive financial recognition for their ongoing and historical carbon sequestration efforts.3
Impact — Heavy polluters lose the ability to use forest offsets to avoid reducing fossil fuel emissions.4
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European State Forest Association Urges Flexible Nature Restoration Targets

20 Jul 2022
Topic — An initiative proposing legally binding targets to restore degraded ecosystems across the European Union.
Message — The association requests extending forest monitoring cycles to at least five years. They reject assuming unknown habitats are in poor condition and demand verified field data.123
Why — This would reduce their administrative costs and prevent expenses for restoring forests that might be healthy.4
Impact — Environmental groups lose because less frequent monitoring could allow forest degradation to go undetected.5
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European state foresters demand monitoring rely on national data

6 May 2022
Topic — The initiative creates a framework for monitoring the condition of EU forests.
Message — The association requests using existing national systems and field-level data collection. They insist that reported data must be verified by national authorities and forest managers.12
Why — This approach protects existing national monitoring investments and ensures state foresters retain authority.3
Impact — Relying on national agreements could delay a uniform, real-time European forest monitoring system.4
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EUSTAFOR urges EU to include wood products in carbon certification

2 May 2022
Topic — The European Commission is developing a regulatory framework for certifying sustainable carbon removal solutions.
Message — The organization calls for a holistic approach that recognizes the carbon storage potential of forest-based products. They emphasize that sustainable forest management already contributes to mitigation and warn against unfair additionality requirements. The framework must acknowledge existing synergies with the bio-based circular economy to avoid greenwashing.123
Why — This would allow state forest organizations to maintain harvesting levels while receiving climate credits.4
Impact — The bioeconomy and wood-reliant industries suffer if policies prioritize forest sinks over harvesting.5
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Response to Revision of the Renewable Energy Directive (EU) 2018/2001

17 Nov 2021

As noted in previous consultation inputs by European State Forest Association (EUSTAFOR), we believe that the current criteria in the REDII are robust enough and effective, requiring that the biomass is sourced sustainably and negative impacts on biodiversity are minimized. Their revision risks bringing even more uncertainty to the market and unjustified administrative burden for operators and Members States. Any further limitations (such as limitation related to the cascading use and/or use of whole trees for bioenergy) might cause disruptions in the functioning of EU wood markets. Such limitations could also result in increased EU imports of raw materials, thus displacing the risk of deforestation outside of the EU. Regarding the new RED proposal, EUSTAFOR would like to comment the following aspects: 1. Applying the existing land criteria (e.g., no-go areas) for agricultural biomass also to forest biomass is conceptually wrong. It ignores the fact that almost every tending or harvest operation results in biomass removal from forests, entailing a certain amount of wood suitable only for bioenergy use. This includes management of protected forests as well, that are now by the new proposal of RED classified as highly biodiverse, hence no-go areas. The new RED proposal does not offer any solution for the biomass that will inevitably be delivered through different management operations, and that is only suitable to be used for bioenergy purpose. If left in forests, this biomass can pose high risk in terms of biotic disturbances such as pests and insects’ outbreaks, but also abiotic ones such as forest fires. For example, in the Mediterranean zone, highly biodiverse areas are in high danger of forest fires. If these stands are left unmanaged, the fires will destroy them, including the biodiversity within. These areas have specific management plans, and one of the most important activities is management of the fuels. In addition to roads, paths, or creating specific areas, additional natural infrastructure to break the progress of the fires is needed. This requires reducing the amount of biomass that normally is not suitable for any other use than bioenergy. 2. Alignment of bioenergy policies (support schemes) with the cascading principle of biomass use. EUSTAFOR fully supports strengthening the concept of resource efficiency but not by imposing binding administrative restrictions on the open biomass market. Namely, any rigid application of the biomass cascading principle that neglects other important dynamics, such as local demand risks undermining the efficiency of forest-based value chains and ultimately risks the suboptimization of the value of biomass. EU policies should aim to improve the flow of materials and residues within and between different industries and users in order to allow for a more efficient use of available biomass resources, thereby contributing to “closing the loop” of product lifecycles and reaching the targets for the reduction of waste set out in the EU’s Circular Economy Package, but compulsory rules that limit market access or impose a cap on the use of biomass in certain industry sectors risk reducing the competitiveness of the whole sector and might well hinder technological advances. Finally, we would like to clarify the misunderstanding in terminology that refers to “whole tree concept”. Whole tree harvesting is often misinterpreted as harvesting of the roots and the stem wood. In Europe this is not done. Not all parts of a tree are harvested, e.g., stump harvesting was abandoned and deemed to be an ineffective and unsustainable. In European forestry, stumps, roots and branch tops are leftovers called harvesting or forest residues which accumulate carbon and ensure nutrient cycle in forest soil. Therefore, their removals from forests need careful monitoring and consideration. EUSTAFOR's complete input is attached.
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Response to Land use, land use change and forestry – review of EU rules

8 Nov 2021

EUSTAFOR welcomes the opportunity to discuss and give feedback on the recently proposed amendment of the LULUCF Regulation. Although it has been so far often communicated that in order to achieve the increased 2030 climate target and the climate neutrality by 2050 objective, it will be necessary to sequester more greenhouse gases from the atmosphere, how exactly this will be accomplished still remains very unclear. While EUSTAFOR supports higher climate ambition, any future scenario of strengthening LULUCF in order to be in line with the climate objectives will be beneficial only if the emitting sectors make sufficient efforts to lower their emissions. Otherwise, the sustainability of forests and forest sector will be jeopardized as forests will again be charged with the additional ambition to meet the targets by offsetting emissions from other sectors. EUSTAFOR wishes to underline that unfortunately the carbon farming concept currently being increasingly promoted by the European Commission (including via the new LULUCF Regulation proposal) seems to be still very ambiguous and insufficiently addresses specificities of forests and their management. Our particular attention goes to the following aspects: - Additionality compared to business as usual – sustainable forest management (SFM) should be considered as a nature -based solution that has been already delivering the contribution of the forest land use vis-à-vis climate change mitigation. Its added value needs to be recognized compared to other carbon capture methods which may require either significant technology development, financing or environmental impacts; - Financing – the concept of carbon farming insufficiently addresses the financing of the delivery of carbon (capture) service compared to business as usual scenario. An important aspect of this is ownership type distribution in forest land use across the EU and the need for ensuring fair remuneration of services delivered; - Carbon certification – a new system to certify so-called carbon benefit – is still vague and insufficiently analysed regarding its content criteria, administrative and financial burden, the relationship to the existing sustainability certification schemes in forestry, and legal status. When discussing nature-based carbon capturing solutions, it is highly important to acknowledge all three equally important ways – the so-called three Ss – in which forests help reduce climate change impacts (Sink, Storage and Substitution). Forest area, average forest age and carbon stocks of European forests have increased in recent decades. Consequently, wood supply has been also increasing as a consequence of forest management which aims at reaching an equilibrium of forest ecosystem dynamics. Whether this development will continue in the coming decades is uncertain in a view of the recent EU policy developments that create increased pressure and expectations from forests to refrain from management practice, thus compensate for other sectors. Moreover, recently observed increasing forest damage and disturbances will most probably increase a need for well-designed management interventions. Therefore, overprioritizing sink over the other two aspects risks not only to undermine the ongoing climate change mitigation and adaptation efforts, but also to turn forests into a source of emissions. Such approach will also have a negative impact on the supply of wood products, which are critical to our sustainable growth and bioeconomy. Therefore, well-designed and holistic EU strategies and appropriate incentives are needed more than ever. EUSTAFOR would like to comment on the following other two aspects: - The Impact Assessment accompanying the proposal, and - The Study used as the basis for defining problems behind decreasing sink in the LULUCF sector. EUSTAFOR comments on these two points are attached.
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Response to Restoring sustainable carbon cycles

7 Oct 2021

In the first place, EUSTAFOR wishes to underline that unfortunately the carbon farming concept currently being increasingly promoted by the European Commission seems to be still very ambiguous and insufficiently addresses specificities of forests and their management. Our particular attention goes to the following aspects: - Additionality compared to business as usual – sustainable forest management (SFM) should be considered as a nature -based solution that has been already delivering the contribution of the forest land use vis-à-vis climate change mitigation. Its added value needs to be recognized compared to other carbon capture methods which may require either significant technology development, financing or environmental impacts; - Financing – the concept of carbon farming insufficiently addresses the financing of the delivery of carbon (capture) service compared to business as usual scenario. An important aspect of this is ownership type distribution in forest land use across the EU; - Carbon certification – a new system to certify so-called carbon benefit – is still vague and insufficiently analysed regarding its administrative and financial burden, the relationship to the existing sustainability certification schemes in forestry, and legal status. Almost all up-to date policies proposed by the European Commission to implement the objectives of the EU Green Deal propagate reduction in harvests as the key measure to reach the goals for climate neutrality, whereas the substitution effect of forest-based products is overlooked. Such simplified concept depicts forests with an infinite carbon storage and carbon sink capacity, while ignoring basic forest growth and forest life cycle principles, and the fact that climate change is also negatively affecting forest ecosystems and thus reducing their potential for climate change mitigation. Namely, if forests are used only as carbon sinks, their storage capacity will eventually be filled, and they can no longer act as sinks. In such scenario even the carbon that was sequestered and stored in trees will be eventually released in result of aging and ultimate decomposition of trees. Instead, a holistic view of the C-balance of the entire forest-wood chain, which also includes storage and substitution effects through the use of wood, would be more appropriate. Using a holistic approach, it has been proven that timber use can contribute the same amount to emission reductions as building up forest C-pools through forest growth. In addition, climate change is having a significant visible impact on forests. The JRC PESETA IV final report shows that in recent years, in the EU and UK, two-thirds of the total biomass, was found to be potentially vulnerable to natural disturbances. The Intergovernmental Panel on Climate Change concluded that “Sustainable forest management can help to manage some of these vulnerabilities, while in some cases, it can increase and maintain forest sinks through harvest, transfer of carbon to wood products and their use to store carbon and substitute emissions-intensive construction materials”. Therefore, managing forests and producing wood products is beneficial for both, the sink and the storage. This is a well-known fact and a reason behind why countries report not only the development of carbon storage and carbon sinks in forests in the international GHG monitoring but also the development of the carbon storage of wood products. As noted in the Roadmap, at the moment there are insufficient incentives to create a competitive industrial market for capturing, recycling, and storing carbon in forest ecosystems. In that regard, EUSTAFOR would like to emphasize the importance of further developing the potential of the bio- based circular economy that is of central importance in combating climate change and safeguarding ecosystem resilience. EUSTAFOR's full contribution to the consultation with all references is available in the attached document.
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Response to European Bioeconomy Policy: Stocktaking and future developments

31 Aug 2021

EUSTAFOR welcomes the Commission's initiative to discuss the main opportunities and challenges of the bioeconomy in relation to the adopted European Green Deal. While initiatives presented so far under the European Green Deal have mainly focused on the environmental pillar of sustainable development, the potential of changing the EU economic system towards a bio-based circular economy continues to be underestimated. Therefore, the Bioeconomy Strategy has the unique opportunity to boost the other two equally important pillars – the social and the economic – thereby ensuring a necessary equilibrium among all three pillars of sustainable development in the future-fit carbon neutral Europe. The bio- and circular economies constitute the next economic development and are of central importance in combating climate change and safeguarding ecosystem resilience. While recognizing the full value of ecosystem services, the bioeconomy promotes economic development and the creation of new jobs, especially in rural and remote areas of Europe. European forests, their products, and services, are integral to achieving the goals set out by the Bioeconomy Strategy and the European strategic long-term vision for a prosperous, modern, competitive and climate-neutral economy by 2050. Sustainable Forest Management (SFM) practices applied in EU forests clearly show that the ecological functions of ecosystems can be maintained in actively managed forests alongside the provision of biomass, timber, non-wood products, and other ecosystem services, while still contributing to climate change mitigation and adaptation. In order to maximize the potential of forests to deliver these multiple services, they must be actively and professionally managed. In that regard, the EU should, including within the bioeconomy, further promote the pan-European concept of SFM and work to strengthen the application of sustainable forest management practices, increasing cooperation between all countries in the European region. EUSTAFOR's full input to this consultation is attached.
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Meeting with Jorge Pinto Antunes (Cabinet of Commissioner Janusz Wojciechowski) and European farmers and

25 Jun 2021 · Forest strategy

Response to Guidance on REDII forest biomass sustainability criteria

28 Apr 2021

EUSTAFOR would like to address the following important aspects of this initiative: Point (5): The risk-based assessment should also take account of any relevant infringement rulings of the Court of Justice of the European Union or on-going infringement procedures launched by the Commission, which are reflected in the publically available infringements database of the Commission. While EUSTAFOR fully supports the relevance of already ruled cases of the Court of Justice, taking into account the ongoing infringements which have not been concluded by ruling seem to be problematic and suggests this to be removed from the text. Point (6), EUSTAFOR suggests slightly different wording (please see the attached file) Point (8), EUSTAFOR suggests slightly different wording (please see the attached file) Point (9), EUSTAFOR suggests slightly different wording (please see the attached file) General comment on Definitions: EUSTAFOR suggests using forest terms and definitions, as defined by the FAO. Comment applies to using this terminology throughout the whole document. For example, “natural forest” is not a concept defined in any internationally recognized forest resources monitoring, assessment and reporting system. Therefore, to avoid misinterpretation and secure coherent implementation, the definitions used in the document have to be verified, making sure they are internationally agreed and used in existing reporting. Under Definitions and throughout the whole document, wording ‘harvesting criteria at national or sub-national level’ should be replaced with sustainability criteria for forest biomass, to remain consistent with the original objective of the REDII. Harvesting criteria are something that is embedded in national forest legislations and management plan, and these go well beyond sustainability of biomass only. General comment is that some of the provisions are way to specific and too detailed, they don’t take into account the possible national (regional and local) circumstances, and related legislation. For example, under the Article 3, 1 (b) (ii): forest regeneration, by demonstrating that the applicable laws require natural or artificial regeneration, or a combination of both, aiming at the establishment of a new forest in the same area and within at least five years after the harvesting. EUSTAFOR strongly advises to move away from giving a certain timeframe for this activity because there are national provisions in place for this that take into account local circumstances. Instead, this document should give enough flexibility to MS to follow their own national provisions. Same comment can be applied for the Article 4, 1(b) (iv) when referring to minimizing clear-cuts, which in a first place does not explains what minimizing means and can be left to interpretation. Clear-cutting systems are silviculture methods used for alternation of generation, applied only in certain circumstances, when it is the most efficient system required by certain forest types, and therefore cannot be regulated on such high level, as it is the EU. General comment on forest biomass definition: more clarity could be needed, whether for example trees planted on agricultural land, including short rotation energy plantations are intended to fall within the scope of the Implementing Regulation, which may not be defined as forest by national law and thus not covered by regeneration requirements; Article 3, 1 (b) (ii): demonstration of no short term nor temporary effects on biodiversity may be problematic at the regeneration phase, the solution could be either removing the link to “biodiversity degradation” here, or a wording that reflects longer term, plannable objectives and general principles of protecting biodiversity as expressed also at 1 (b) (iv);
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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 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 Helena Braun (Cabinet of Executive Vice-President Frans Timmermans)

16 Mar 2021 · Discussion on the preparation of the new EU Forest Strategy

Meeting with Janusz Wojciechowski (Commissioner) and

3 Feb 2021 · New EU Forest Strategy.

Response to Climate change mitigation and adaptation taxonomy

18 Dec 2020

EUSTAFOR wishes to share the following contribution to this consultation: Inclusion of forestry into the scope of the EU Taxonomy must be done in full respect of the subsidiarity principle to avoid contradictions with the existing forest laws of MS. Existing definition and principles of SFM must be used. 1. European forests are a diverse resource. This determines the great variety of management approaches, e.g. species selection or the choice of management techniques. The EU’s approach to the sustainability of forests needs to follow the principle of “no one size fits all.” The EU Taxonomy must be built on the definition of SFM of the FOREST EUROPE, transposed to national forest law. 2. The entirety of a forest’s life and production cycles has to be addressed. The classification of forest activities must be reconsidered to ensure consistency with definitions applied in MS’ forest legislation. EUSTAFOR disagrees with dividing the holistic SFM into individual measures to be verified according to narrowly defined sustainability criteria. This could be counterproductive for the health, vitality, productivity, and resilience of forests. 3. Only well-defined and well-understood concepts should be used. EUSTAFOR considers the use of concepts that lack clear definitions and/or a common understanding to be inappropriate. Thus, referring to concepts such as additionality, improved FM, closer-to-nature forestry, nature-based solutions, etc., is premature and should be avoided. 4. “Additionality” and “improved” forest management cannot be accepted without a prior state-of-the-art assessment. Legal provisions and management guidelines developed by MS are compulsory for state forests. SFM is much broader than “managing forests with a purpose to contributing to climate change mitigation demonstrated through climate benefit analysis.” The improved management of forests can only be proposed following prior assessment of a current baseline. The additionality concept needs to be thoroughly analyzed in order not to discriminate against certain ownership types. 5. Proposed technical screening criteria are unnecessarily complex and burdensome. The two sets of technical screening criteria create a complicated framework which will discourage forest owners from investing in their assets. The requirement of an environmental impact assessment is superfluous and burdensome for activities that are not related to land-use change. EUSTAFOR is highly concerned that these proposals will increase the already existing regulatory burdens. To avoid this, a risk-based approach, similar to the one enshrined in RED II, should be applied. 6. Considerations of social issues cannot be promoted over those of business planning and governance. Forest management and afforestation plans are the “item count” of forest owners. Their elaboration strictly follows national laws on sustainable forestry and spatial planning. Public consultations are sufficiently covered. EUSTAFOR recommends that EU law does not interfere with existing national provisions that regulate these aspects. 7. Climate benefit analyses should be based on a wide scope of forest products. EUSTAFOR is concerned about how carbon flows are being calculated for the “harvesting of timber products.” They appear to deliberately calculate the negative impact of harvesting and soli disturbance, while ignoring the positive impact of “product substitution” in which timber replaces carbon-heavy products such as concrete and steel. 8. The SFM applied in state forestry clearly show that ecological functions of forest ecosystems and biodiversity can be maintained in managed forests. The segregation of “conservation forestry” as a separate activity is superfluous and lacks justification. 9. There is a misconception concerning the use of whole tree stems for bioenergy. There is a lack of evidence to confirm this. EUSTAFOR disagrees on incorporating this concept into EU Taxonomy as going against market rules
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Response to EU Forest Strategy

4 Dec 2020

The European State Forest Association (EUSTAFOR) represents 35 members from 25 European countries who carry out sustainable forest management (SFM) on a daily basis. In that regard, the following recommendations are made as their input to the ongoing debate on the key objectives of the FS post-2020 (full text attached): 1. The EU needs a straightforward forest land use strategy in order to solve existing and potential conflicts between forests and all other land uses, stakeholders and interest groups/sectors based on a balanced spatial planning at a landscape level. 2. Means to further develop forest resources, including forest area expansion should be embraced by the FS post-2020. This can be only done through effective and thoroughly planned afforestation, reforestation and rehabilitation of forests damaged by biotic and non-biotic agents. 3. The FS post-2020 should provide a platform for effective technical, scientific and policy cooperation and experience exchange, as well as necessary policy means and adequate funding for Forest Adaptation, Health & Resilience. 4. The role of forests and the forest-based sector in mitigating climate change should be promoted in the FS post-2020 through: - Sequestration as a long-term goal and the role of wood in storing carbon and substituting for fossil-based products. - A robust and coherent methodology for the measurement of carbon sequestration and emission levels in forestry, to include land type, silviculture practices and species attributes. It should embrace full LCA for both wood production and woodland protection. Impact assessment, financial (state aid) support frameworks for climate mitigation and adaptation measures. 5. European forests as home for biodiversity and nature - at a scale that cannot be offered by any other land use – should be promoted by the FS post-2020. Sustainable forest management is not only compatible with the conservation of biodiversity but, in most cases, actively contributes to its maintenance and enhancement. 6. Challenges to the license to operate due to a growing lack of acceptance of the harvesting process and the use of wood is one of the emerging issues to be addressed in the FS post-2020. 7. The FS post-2020 should address the value-based framework for ecosystem services and show a clearly defined direction in relation to competing forestry objectives with data to demonstrate the necessity for each. 8. The FS post-2020 should highlight the benefits of developing a credible forest information system on forests, SFM and its multiple benefits. 9. While developing its policies to face the challenges of climate change, biodiversity, the bioeconomy, rural development, renewable energies or social benefits such as recreation - which combine very ambitious expectations of our forests - the EU should also give substantial attention to the financial aspects which will allow forest managers and owners to deliver on these essential services. 10. The FS post-2020 should be an EU framework which promotes the pan-European concept of SFM. It should work towards strengthening the application of SFM practices both globally towards halting deforestation and forest degradation as well as through strengthened cooperation with other countries in the pan-European region. 11. The FS post-2020 should provide a consistent structure for the EU, Member States and relevant stakeholders to cooperate on forests and their sustainable management at EU level and to work out EU contributions to pan-European and international processes. To conclude, EUSTAFOR calls on the European Commission, taking into account the recent Council conclusions, to develop a strong, self-standing, coherent, and holistic EU Forest Strategy post-2020. The Strategy should serve as a central policy instrument to support and promote SFM, making clear references to the equal relevance of its three pillars – economic, environmental and social.
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Response to Protecting biodiversity: nature restoration targets

2 Dec 2020

EUSTAFOR, acting as a voice of European state forest management organizations at EU and pan-European levels, wishes to share the following contribution to this roadmap consultation: Restoration commitment requires properly defined objectives: From a forest manager’s perspective, the restoration objectives, especially those in old-growth forests and primary forests, must be precise and based on sound scientific knowledge and previously agreed definitions. Any such objectives and activities should build upon a thorough assessment of the current status and trends based on an agreed methodology within the EU. Various available sources of data need to be used, especially is important that data reported by the MS are verified and cross-checked with relevant actors at national level, including forest owners and managers. Specific causes of forest ecosystem degradation must be identified, examined and well understood. Whether in the context of global or EU circumstances, these causes differ significantly. For instance, the degradation of forests due to industrial emissions, urbanization, infrastructure development or farming should be distinguished from the ongoing decomposition of forest stands caused by climate change-induced biotic and non-biotic causes, including prolonged droughts, storms and forest fires, followed by the massive occurrence of pests and diseases. Just as there are different causes of forest degradation, so there are different management approaches needed to cope with them. Recovery from biotic and abiotic calamities is embedded within Sustainable Forest Management (SFM) practices and regulated by forest legislation already in place. No “one size fits all” solutions: Sustainable and multifunctional forest management of all state-owned forests in the EU is based on detailed and thorough forest management planning which strictly follows SFM principles. Forests managed by EUSTAFOR members span three major biogeographic zones with different species, growth rates and management traditions. The resulting variations create a wide range of options for the SFM across EUSTAFOR members. EUSTAFOR, therefore, emphasizes that there can be no “one size fits all” solution in the forestry sector. Instead, there is a need to respond to a wide variety of contexts and promote an approach which takes into account these different regional characteristics. Such an approach should also be reflected in the EU Nature Restoration Plan. Holistic approach: Managing forests sustainably means to manage and use them in such a way that their biodiversity, productivity, regeneration capacity, and vitality are maintained while leaving all interconnected ecosystems intact, so that future generations will benefit from forests as much as, and possibly even more than, we do now. Sustainability means a proper balance all three pillars: environmental, social and economic. According to the latest study from the Thünen Institute any implementation of dedicated measures of the EU Biodiversity Strategy for 2030 will reduce roundwood production in EU, which creates a risk of biodiversity loss in non-EU countries. The danger in ‘off-shoring’ a greater percentage of the EU’s timber supply requirements from outside the EU, where the EU has far less control on the standards being applied, would be a counterproductive move. EUSTAFOR believes that self-sufficiency of wood products in the EU, by maximizing the flow of sustainably managed timber supply from within the EU, that can be guaranteed under SFM principles, should have greater emphasis and be better supported. EUSTAFOR believes that a well-designed EU Nature Restoration Plan could play a major role in upscaling positive European experiences to a global level. Such a plan should be reliable and achievable and, thus, not overburden forest managers. SFM is not only compatible with the conservation of biodiversity but, in most cases, actively contributes to to to its maintenance and enhancement.
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Response to Land use, land use change and forestry – review of EU rules

26 Nov 2020

As stated in the Roadmap, to achieve the increased 2030 climate target and the climate neutrality by 2050 objective, it will be necessary to sequester more greenhouse gases from the atmosphere. EUSTAFOR believes that, especially with the ongoing negative climate change impact on forests, this will only be possible with a proactive approach, applying sustainable forest management (SFM) practices that improve the ability of forests to maintain and enhance carbon sinks and stocks, including by transferring carbon to wood products and by substitution of the carbon intensive products and energy. EUSTAFOR strongly emphasizes three equally important ways the so-called three Ss – in which forests help reduce climate change impacts: • Sink - Carbon sequestration; • Storage - Carbon storage in living trees and long-term carbon storage in forest products; • Substitution - A sustainable alternative for fossil fuels and fossil-based high energy consuming materials. Even though the Roadmap points out that, due to different cost related issues, farmers and foresters do not take sufficient climate action, EUSTAFOR’s newest compilation of good practices in different aspects of climate mitigation and adaptation entitled European forests: Tackling climate change shows quite the opposite situation in state forests. As the case studies have shown, forests have a role to play, both in climate mitigation and adaptation. Restoring disturbed forests by establishing adapted, and species-rich forest stands that minimize the climate change induced risks in the future is one of the best examples. Forests are being adapted through implementing preventive measures to make them less prone to climate change induced damaging agents (biotic and abiotic) and at the same time protecting people and infrastructure from fires, floods and other weather disasters. Todays’ forest management planning strategies to make forests fit for future climate imply using new approaches such as mapping forest carbon potential or modelling species suitability based on site conditions. All this makes possible to increase forest sink and produce sustainable wood products that store carbon and substitute other emission intensive materials, including fossil fuels. Indeed, all these activities generate a significant and increasing financial burden. Therefore, EUSTAFOR fully supports the initiative’s aim to create stronger policy incentives that realize the EU’s potential to reduce land emissions, enhance substitution of fossil-based materials and enhance land-based sinks in the land use sector. Due to its diversified membership and its need to stay consistent with diverse Member States’ positions on this topic, EUSTAFOR cannot be at this moment in support of any of options offered by the Roadmap. All three options presented in the Roadmap are very general. However, EUSTAFOR’s general comment is that any future scenario of strengthening LULUCF in order to be in line with the 2030 Climate Target Plan will be beneficial only if the emitting sectors make sufficient efforts to lower their emissions. Otherwise, the sustainability of forests and forest sector will be jeopardized as forests will again be charged with the additional ambition to meet the renewed 2030 Climate Targets by offsetting emissions from other sectors. EUSTAFOR underscores the following five policy recommendations: • Lower the EU’s total greenhouse gas emissions (GHG) through the sustainable increase of forest resources. • Promote the use of wood to boost the bio-based circular economy. • Support the active and professional management of forests to make them climate fit. • Mobilize additional resources and financial incentives for the adaptation of EU forests and the restoration of forests damaged by climate change. • Reflect a holistic picture of the forest life and management cycles in the new EU policy planning on climate change mitigation and adaptation.
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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 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 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

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

21 Sept 2020

As announced in this initiative summary, under the European Green Deal the Commission has committed to stronger action on climate change and will assess how the EU’s greenhouse gas emissions could be responsibly reduced by at least 50-55% by 2030. The review will: • assess how far EU renewable energy rules (Directive 2018/2001/EU) can contribute to a higher EU climate ambition, • explore how to accelerate the transition to a more integrated energy system as outlined in the energy system integration & hydrogen strategies. In this regard, the European State Forest Association (EUSTAFOR) would like to address the following two important aspects of this initiative: • the importance of renewable biomass as a source of bioenergy, and • the announced possible revision of the REDII and the sustainability criteria for bioenergy therein Forests and the forest-based sector play a significant role in mitigating climate change through decarbonizing the European economy, enabling the transition to a bioeconomy, increasing the renewable energy share of the EU’s total energy consumption, fostering energy efficiency and promoting the efficient use of natural resources. To maximize their potential to regulate climate, forests must be actively and professionally managed to make them “climate-fit” thus productive. Sustainable forest management improves the ability of forests to maintain and enhance carbon sinks and stocks, including by transferring carbon to wood products and substituting for fossil and other energy-intensive materials. Furthermore, forests and forest products function as a cornerstone of Europe’s bioeconomy. They have a long history of providing a sustainable alternative to fossil-based materials and fossil energy, helping decouple economic growth from resource depletion and adverse environmental impacts. Climate change is having a significant and visible impact on forests. EUSTAFOR’s members report that in 2018-2019, over 36 million m³ of wood have been lost and recovery will require additional workforce and funding of up to 800 million EUR, presenting both logistical and financial challenges for many state forest organizations. Wood biomass from sanitary cuts made necessary by biotic and non-biotic calamities meets very limited demands from wood-based industries other than bioenergy. In EUSTAFOR’s view, the EU must support European forest owners and managers in combating the anticipated and most likely increasing, the aforementioned climate change-induced impacts in order to nurture climate-fit and resilient forests. The EU’s renewable energy and industrial policies must enable affordable market conditions for the efficient use of renewable and climate-friendly raw materials, enhancing investments in forests as a natural asset. In addition to directly increasing the availability of renewables, the use of biomass for bioenergy contributes to the development of markets for low-value forestry residues. This, in turn, contributes towards keeping forestry viable which indirectly supports all other SFM measures, including climate change adaptation and mitigation. EUSTAFOR shares the view that the best practical way to include forests and forest management into the overall climate and energy framework is to use the risk-based approach for forest biomass as has already been set out in the REDII. This would avoid confusion, legal uncertainty, and subsequent restrictions to investments in the forestry sector. EUSTAFOR believes that amending the existing articles, including the announced potential changes to the sustainability and GHG gas emission savings criteria for bioenergy (Article 29-31), before the Regulation is even implemented and before national renewable energy progress reports are published and ready to be assessed, would be counterproductive. Such actions would simply diminish previous efforts and potentially slow down the process before it was even given a chance to prove its fitness.
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Response to EU Strategy on Adaptation to Climate Change

30 Jun 2020

The European State Forest Association (EUSTAFOR) welcomes the European Commission’s initiative to develop an ambitious EU Strategy on adaptation to climate change, as announced in the European Green Deal. We would like to address the following three components, relevant for the upcoming Strategy: • The importance of forests and the role of sustainable forest management (SFM) for climate change mitigation, • The negative effects of climate change on forests, • The role of SFM in adapting forests to climate change, thus making them healthy and resilient to the above-mentioned negative climate change effects. All the above elements are equally important and should be well-balanced to ensure the optimal contribution from forests to solving the climate problem. In order to maximize the potential of forests to regulate climate, they must be actively and professionally managed to make them “climate-fit.” SFM improves the ability of forests to maintain and enhance carbon sinks and stocks, including by transferring carbon to wood products and substituting fossil and other energy-intensive materials. Furthermore, forests and forest products function as a cornerstone of Europe’s bioeconomy. EUSTAFOR wishes to express its concern that the current proposal for the Climate Law does not do enough to promote the phasing out of the use of fossil energy and materials. It is overly focused on the no net emissions target, without defining it precisely. This may lead to the unsatisfactory elimination of fossil energy and products in the economic system, while pushing expectations to compensate them by forest carbon sinks too high. Such a simplified approach may also lead to new demands for setting aside forest lands, which is a risky climate strategy considering that old and unmanaged forests are more vulnerable to storms, pests and diseases, fires and other calamities. Already now, climate change is having a significant visible impact on forests. The JRC PESETA IV final report shows that in recent years, in the EU and UK, two-thirds of the total biomass, was found to be potentially vulnerable to natural disturbances. Nearly half of that amount (46%) is threatened by windstorms, followed by forest fires (29%) and insect outbreaks (25%). A case in point is the recent severe damage of 1,2 million hectares of European state forests resulting from extreme weather and climate events, followed by pests and diseases, throughout Europe. EUSTAFOR’s members report that in 2018-2019, over 36 million m³ of wood have been lost and recovery will require additional workforce and funding of up to 800 million EUR. The key responsibility of the EU to support European state forest organizations in combating the biotic and abiotic climate change-induced impacts on European forests and nurturing climate-fit forests which are able to resist the anticipated, and most likely increasing, aforementioned impacts. This requires active, climate-smart forest management by professional foresters in close cooperation with scientists, climate change modellers, the private sector, and other stakeholder groups, in contrast to a protectionist approach which just sees forests as a standing carbon sink, increasing the risk of natural disturbances and calamities. Moreover, European multifunctional forests must provide a wide scope of other ecosystem services, including regulating ground and surface water flows, protecting micro-climates and infrastructure, as well as offering recreational and aesthetic values to society. Considering the crucial role forests and SFM play not only for climate change mitigation and adaptation, but also for human health, the economy, and biodiversity, EU policies and actions in this area can be most effective and provide the most added value. The interventions should be identified within the framework of the EU Forest Strategy, including by the proper involvement of experts from MS and relevant stakeholders.
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Meeting with Catherine Geslain-Laneelle (Cabinet of Commissioner Janusz Wojciechowski), Jorge Pinto Antunes (Cabinet of Commissioner Janusz Wojciechowski), Magdalena Majerczyk (Cabinet of Commissioner Janusz Wojciechowski)

29 Jun 2020 · Biodiversity Strategy 2030 and future Forest Strategy

Response to Climate change mitigation and adaptation taxonomy

20 Apr 2020

EUSTAFOR shares the view that forests, sustainable forest management (SFM) and forest-based products have great potential to contribute to the climate mitigation and adaptation objectives and the climate neutrality objective enshrined in the EU Green Deal. EUSTAFOR welcomes the fact that forestry and SFM are subject to the EU Taxonomy. However, the way in which the latter embraces SFM requires further examination by the Commission and the Member States, with due consideration of the opinions of forest owners and managers. As explained in our official statement “Let’s Build a Future-Fit Europe Together” (December 2019 ( ), EUSTAFOR wishes to reiterate that European forests must be actively and professionally managed in order to maximize their input to the objectives of the EU Green Deal. For this reason, the concept of SFM must be defined and implemented in such a way that a balance among the environmental, social and economic functions of European forests is ensured. The definition and principles of SFM have been developed and internationally agreed by European governments and the European Union under the Forest Europe process (Helsinki Resolution 1 of 1993 ( )). Subsequently, these political commitments were introduced into modern forest legislation of MS and into the EU Forest Strategy. Such an approach fully respected different national and regional bio-geographical circumstances that are crucial in forestry since our sector is, and should be, guided in the future by the rule: “No one size fits all.” Consequently, the EU Taxonomy must be built on a clear and unambiguous reference to Forest Europe’s definition of SFM and its principles as well as its various implementation tools. EUSTAFOR would like to recall that the Council of the European Union has already stated ( ) that, although the EU has a variety of forest-related policies, the Treaty on the Functioning of the European Union does not refer to a common EU forest policy, that the responsibility for forests lies with the Member States, and that all forest-related decisions and policies in the EU must respect the principle of subsidiarity and Member States’ competence in this field. EUSTAFOR strongly believes that the Commission and the Members States should jointly develop the technical screening criteria for the EU Taxonomy based on sound forest research and the strong field expertise of forest managers, in order to make them feasible and reliable. Moreover, the technical screening criteria should build upon a one-off system of non-single end-use specific criteria ( ) for forest functions and products which, in future, could also be used by other sectors, as appropriate. The risk-based approach for the sustainability of forest biomass of RED II provides a good point of departure. The EU Forest Strategy should be the right framework to further refine and advance these criteria, including by examining whether and how to embrace concepts, such as “closer-to nature” management within SFM. EUSTAFOR underlines that the future sustainability system of the EU Taxonomy will have a significant impact on the level of investments in forestry/SFM and, therefore, on the economic viability of the sector. Regretfully, the TEG report gives insufficient attention to the role of forests as a source of renewable raw material and green employment as pillars of a bio-based circular economy, which are necessary to achieve Europe’s climate neutrality objectives 2050. Forestry is a complex and comprehensive system characterized by an overall guiding principle of durability and continuity of forest cover and a long life/production cycle. The EU Taxonomy and its technical screening criteria must respect these principles. Departing from this commonly agreed and already implemented understanding could lead to an incoherent use and application of sustainable forest management in the future and, thus, will seriously impede achieving the objectives of the Sustainable Finance Action Plan.
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Response to 2030 Climate Target Plan

8 Apr 2020

EUSTAFOR welcomes the European Commission’s initiative to develop a Communication for setting the climate target for 2030, within the objective of climate neutrality by 2050. As stated in the Roadmap, the EU’s land use sector (agriculture land, forests and other natural land) is presently a net sink of CO2, meaning that it removes more CO2 from the atmosphere than it releases GHGs. It is estimated that EU forests and the forest- based sector currently contribute to the overall climate mitigation by absorbing about 13% of the EU’s total emissions . EUSTAFOR notes the fact that the potential risk of carbon leakage is acknowledged by the Roadmap. Forests and forest products function as a cornerstone of Europe’s bioeconomy. They have a long history of providing a sustainable alternative to fossil-based materials and fossil energy, helping decouple economic growth from resource depletion and adverse environmental impacts. Sustainable forest management (SFM) improves the ability of forests to maintain and enhance carbon sinks and stocks, including by transferring carbon to wood products . In order to maximize the potential of forests to regulate climate, they must be actively and professionally managed to make them “climate-fit”. SFM aimed at providing biomass, timber, non-wood resources and other ecosystem functions and services, can lower GHG emissions and can contribute to adaptation. Therefore, State Forest Management Organizations with their knowledge and expertise, can actively contribute to the initiative of assessing how to increase the absorptions of CO2 emissions over time, including in its natural forest sinks and the role of biomass-based products and nature-based solutions. This should be done within the framework of the EU Forest Strategy, including by the proper involvement of experts from the Member States and stakeholders through the Standing Forestry Committee and the Civil Dialogue Group on Forestry and Cork. EUSTAFOR shares a view that the best practical way to include forests and forest management into overall climate and energy framework, including the upcoming sustainable finance framework would be/was to use the risk-based approach for forest biomass as applied in the Renewable Energy Directive (recast) which properly covers sustainability concerns in forestry and which was adopted by all respective EU institutions and Member States. This would avoid confusion, legal uncertainty and subsequent restrictions to investments in the forestry sector. The objective of this initiative is to propose an increased climate target for 2030 to prepare the EU for the transition towards climate neutrality by 2050, including through an amendment of the recently proposed European Climate Law. EUSTAFOR wishes to express its concern that the current proposal for the Climate Law is not enough focused on phasing out fossil use. It is very focused on no net emissions without exactly defining what that means. It might mean that we will still have lots of fossil energy and products in the system, expected to be compensated by the forest carbon sink. That might also lead to new demands for setting aside forest lands, which is a risky climate strategy considering storms, insects, fires. Climate change has a significant impact on forests. A case in point is the recent severe damage in 1,2 million hectares of European forests resulting from extreme weather and climate events, followed by pests and diseases, throughout Europe. Our members report that over 36 million m3 of wood have been lost and recovery will require additional workforce and funding of up to 800 million EUR, presenting both logistical and financial challenges for many state forest organizations. Well-designed EU strategies and financial instruments are needed more than ever! Only healthy and thriving forests can efficiently provide climate-related services.
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Response to Minimising the risk of deforestation and forest degradation associated with products placed on the EU market

4 Mar 2020

The European State Forest Association (EUSTAFOR) welcomes the Commission Communication from July 2019 that tackles deforestation and forest degradation – reducing the impact of products placed on the EU market. The protection of World’s forests and reversing of negative trends in deforestation and forest degradation globally has been a topic of international forest policy debate since at least the Rio Earth Summit in 1990. Following the global debate, the pan-European forest policy dialogue was established first as the Ministerial Conference on the Protection of Forests in Europe (MCPFE), currently known as the FOREST EUROPE process. This process resulted in defining the concept of Sustainable Forest Management (SFM) and its principles (Helsinki Resolution H1 of 1993). A number of policy instruments, such as Criteria and Indicators for SFM, Pan European Operational Level Guidelines and National Forest Programmes have been developed to enable effective implementation of SFM concept. All EU Members States are signatories to FOREST EUROPE commitments and successfully implemented the pan-European commitments into their national and/or regional forestry legislation. Their modern laws which ensure sustainable development of forest resources and their multifunctional use as well as effective governance systems in place resulted in significant increase of forest resources in Europe over recent decades, both in quantity and quality. This is confirmed in international and national statistics. Furthermore, high standards of sustainable forest management practice, largely applied in European state forests, are confirmed by voluntary forest certification systems. State forests are very often subject to double or multiple certification, which is even better proof of high sylvicultural standards in use. EU, represented by the European Commission is a signatory of FOREST EUROPE commitments as well. Thanks to that fact the EU Forestry Strategy was adopted as early as 1998 in order to serve as a guiding policy tool for effective coordination of the EU forest-related policies, having SFM and subsidiarity among its main principles. Furthermore, the EU developed its Timber Regulation to prevent illegal logging and related trade in as well as the FLEGT Action Plan for the economic interaction with non-EU timber producing countries, as well as other policies or legislation, including most recent RED II and its risk-based approach to forest biomass sustainability. Such a legal and policy setting well proved its efficiency and effectiveness while fully respecting subsidiarity as a main guiding principle to tackle forests in the EU. EUSTAFOR represents an opinion that this common heritage of the EU and its Member States in implementing SFM should be further promoted in the international policy debate on stepping up action against global deforestation and degradation of world’s forests. The EU Forest Strategy should serve as an efficient framework to formulate EU positions and sure ensure efficient participation of relevant stakeholders. The Forest Strategy should also be a platform to examine any future regulatory and non-regulatory policy options, such as mandatory labelling, voluntary commitments and labelling, due diligence, verification schemes, etc., to be developed with an aim to minimize the impact of products placed on the EU market on world’s forests, should not duplicate and disintegrate existing forest sustainability schemes but rather refer to and make use of them. Voluntary certification systems must remain voluntary market-tools and should not be indirectly imposed by EU legislation.
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Response to Illegal logging – evaluation of EU rules (fitness check)

26 Feb 2020

As a representative of 36 State Forest Management Organizations which, together, manage 1/3 of Europe’s forests, we would like to share the experiences of our members regarding the present EU rules on illegal logging, specifically the EU Timber Regulation (EUTR) as part of the FLEGT Action plan. In 2015 EUSTAFOR organized an internal discussion with its membersregarding the EUTR that brought the following conclusions: -The greatest impact of the EUTR is on wood and wood-based products imported from outside the EU rather than on domestic producers. The implementation of EUTR provisions generates additional costs and red tape rather than immediate benefits. Positive results might occur in the countries who are exporters to the EU, but an overall benefit is hard to assess because similar legislation is not equally applied worldwide. -When the EU TR came into force, the majority of European SFMOs already had fully operational “Due Diligence Systems” (DDS) in place. The latter were developed on an internal basis without the help of monitoring organizations. In most cases, the set of rules for DDS originated from national legislation and internal procedures were developed long before the EUTR entered into force. -Some gaps (which were also acknowledged by the Commission report from 2016 on the effectiveness of the EUTR) were still present, e.g. the interpretation of the provisions of the EU TR and their enforcement by different national competent authorities. -The main concern was the increase in bureaucracy and administrative costs. The general opinion was that it could have been more effective to enforce existing forest laws instead of enacting complex new EU regulations. When buying timber or timber products from the market, there is generally a long chain of custody, involving a large number of traders, and resulting in the collection of a large number of documents. In the case where stolen wood has been retrieved, there is no procedure (in accordance with EUTR) for placing the recovered volume on the market. -The EUTR does not take into consideration some important non-timber forest products, such as cork. Illegally harvested cork, which is often imported from non-EU countries, could be a relevant issue to tackle while further developing the Commission’s implementation guidance document. The product scope of the EU TR was addressed on several occasions. In April 2018, as part of the Public consultation on the product scope, EUSTAFOR expressed its positive opinion on the proposal to widen the product scope of the EUTR, in line with the 8 June 2017 resolution of the Civil Dialogue Group on Forestry and Cork. In their open letter to the European Commission, European forest-based industries called for extending the scope to ensure that wood-based products sold on the European market are safe from illegal logging regardless of their origin. Several wood-based products are not yet included in the scope of the EUTR. Millions of euros worth of wood-based products are, therefore, still entering the European market without any assurance of their legality. It needs to be underlined, however, that the focus of the EUTR is limited to legality only and thus not cover sustainability issues. This is a result of a political compromise achieved by the MS and the Commission and should not be changed unless a new compromise is achieved by those parties.The latest Commission report on the EUTR, covering the period March 2015 to February 2017, reveals steady progress in the four years since it was introduced. Continuous efforts are needed to ensure a uniform and effective application of the EU TR across countries. Uneven implementation can potentially result in negative impacts in terms of both the effectiveness of the legislation and ensuring a level playing field for market operators. Despite the limitations, EUSTAFOR shares the opinion that the EUTR is one of the key measures available to help prevent illegal logging and deforestation.
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Response to Climate Law

6 Feb 2020

European multifunctional forests and forest-based products should be at the core of the EU climate change agenda. Sustainable forest management can help to diversify the energy supply, lower greenhouse gas emissions and create jobs and growth in rural areas. Moreover, as forest ecosystems provide important habitats for fauna and flora as well as other vital environmental services, they are instrumental in the conservation of biodiversity. European forests are a steadily growing and improving resource. The most recent Forest Europe Report shows that the total area of forests in Europe has increased to 215 million hectares over the last 25 years and continues to expand every year by 0,4 %. State forest management organizations have provided leadership in sustainable forest management in Europe. According to recent statistics, forests managed by EUSTAFOR’s members are growing at an annual rate of 200 million cubic meters. Of this, 60-70 % is harvested to supply wood-based industries and the bioenergy sector, while the remainder accumulates as growing stock. This currently unused growth reserve can be utilized in the future. At the same time, forests are seriously affected by climate change. Global warming causes an increased amount of forest fires and leads to an extension of areas affected by wild fires. Forest fires not only represent a serious danger for the climate, environment and biodiversity, but also a serious threat for human beings and rural areas. Forest sector contributes to climate change mitigation by replacing fossil-based materials and energy by woody biomass, while making sure forests continue growing and providing their multiple services. Moreover, developing markets for forestry residues will make climate adaptation measures, such as regular thinnings, economically more attractive for forest owners with a positive long-term impact on viability and health of forests. Wood is a sustainable and renewable resource to move beyond fossil fuels and build a vibrant bioeconomy. Every cubic meter of wood used to substitute for other non-renewable building materials reduces CO2 emissions to the atmosphere by an average of 1,9 tons of CO2. Wood used in construction materials stores carbon for an average period of 80 years. Increased use of wood in construction and more advanced use of wood in emerging sectors can create new markets and new forest-based value chains while at the same time fight climate change. Bioenergy currently represents 60 % of the EU’s total consumption of renewables and its share is expected to grow by 2030. Constantly developing forest resources justify the statement that there is significant potential for the increased sustainable mobilization of forest biomass in Europe. The sustainable management of state forests thus needs to fulfill multiple objectives and provide various products and services to the public. Although there are potential synergies between climate change mitigation and adaptation and the other services provided by European state forests, it must also be acknowledged that there will be certain necessary trade-offs between the different services which forests can provide. Future climate policy design will consequently need to find a balance between these different societal demands. EUSTAFOR shares the opinion that that sustainable and multi-purpose forest management must be recognized by EU policies as an important part of the global solution for climate change mitigation. Future policy design, targets and implementation details must allow European forests and the forestry sector to realize their full potential. To this end, the permanence of sustainable management of resilient and steadily enlarging forests should be promoted over the permanence of carbon stocks.
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Response to EU 2030 Biodiversity Strategy

20 Jan 2020

EUSTAFOR welcomes the European Commission’s initiative to develop the EU Biodiversity Strategy to 2030, within the framework of the implementation of the European Green Deal, and would like to draw attention to the following aspects: •Progressing climate change makes significant impact, not only in the condition of species and habitats, but also on other features of ecosystems. To effectively tackle these challenges, a policy instrument is needed at the EU level, which consists of realistic objectives and feasible measures to reach these objectives, supported by sound financing to enable implementation. EUSTAFOR supports the development of EU biodiversity strategy towards 2030, however, a discussion on either renewed or new targets for it should be based on a sound analysis of the achievements so far and a thorough analysis of the state of biodiversity in different land uses. •The implementation of conservation measures and the enhancement of biodiversity in state forests is a part of regular sustainable forest management practice ensured by the long-term planning approaches envisaged in the forest management plans. Therefore, better integration of biodiversity objectives with all other aspects of forest management within the holistic and robust concept of sustainable and multipurpose forest management is necessary. The EU Forest Strategy is the appropriate policy instrument to ensure that biodiversity related aspects of forestry are well covered and balanced with all other aspects and functions. •SFMOs, as large scale managers, are primary actors to implement nature conservation measures, such as Natura 2000 directives, in state forests. EUSTAFOR has published a compilation of relevant good practices derived from its members that is available under the following link. Therefore, we share the confidence that the European Commission will well take into the consideration expertise of land managers, especially, those in public forests, and as EUSTAFOR we are willing and available to provide inputs, comments and the field expertise of our members. •On the other hand, state forest managers are open for discussions to identify those areas that need to be improved. For example, EUSTAFOR looks towards the Roadmap objective to restore damaged ecosystems but in a first place, these specific cases have to be identified and the damage causes examined and well understood. At the same time, generalization and inappropriate comparison of not comparable situations at EU, pan-European and global level should be avoided since it may lead eventually to drawing up unrealistic goals. Regional differences, including environmental limitations have to be acknowledged. •The negative impacts of climate change on biodiversity are accurately recognized within the Roadmap and that the Strategy will also contribute to global and EU efforts to mitigate and adapt to climate change. European forests are confronted with significant losses due to the climate change and natural disturbances like forest fires, storms, or related pests and diseases. These damages directly have a negative impact on the health and resilience of forests that affect, among others, biodiversity. European forests must be actively and professionally managed, thus resilient, in order to maximize their potential to regulate climate, prevent soil, wind and water erosion, protect infrastructure, ground water cycles and protect biodiversity, •EUSTAFOR welcomes the note in the Roadmap on the fact that EU has already in place an extensive legal and policy framework aimed to protect, restore and sustainably manage its natural habitats, species and ecosystems. EUSTAFOR and its members strongly advocate for an improvement in the implementation of the current policy framework at both national and local levels. •As state forests in many cases are not eligible for public support, either from EU or MS budget, EUSTAFOR supports raising this issue as one of the problems to be tackled.
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Response to Strategy for long-term EU greenhouse gas emissions reductions

10 Aug 2018

EUSTAFOR's feedback to the Roadmap “Strategy for long-term EU greenhouse gas emissions reductions”: Forests cover more than 40 percent of the EU’s land area. They provide the European bioeconomy with renewable materials as well as other ecosystem services. Their role is therefore crucial to fulfil the ambitions of the Paris Agreement and Sustainable Development Goals. Thus, they can contribute to the objectives of the EU related policies especially in relation to climate and energy and to green growth and employment stability, particularly in rural areas. Forests are essential for reaching the balance between GHG emissions and removals, as they provide for the removals and they also provide for renewable raw materials, which combined with substitution of non-renewable materials and energy as well as with efficient production processes, can strongly contribute to the Paris Agreement ambitions. Sustainable forest management is already addressed with a long-term perspective manner through forest management plans, and resilience of forest ecosystems is a top concern for state forest managers in Europe. With surprise we have noticed the exclusion of the forestry sector from the list of interventions at the stakeholders’ high level event organized by the European Commission on 10-11 July 2018. Even though one session was dedicated to the role and use of natural resources, there was no room for comments or questions given to forests and forest management, and, therefore, we are deeply disappointed that forest managers could not share their views, especially with reference to the need of climate change adaptation measures in forestry. In conclusion, we hope that there will be better consideration of the forestry sector in the context of the initiative “Strategy for long-term EU greenhouse gas emissions reductions” in the future. The European State Forest Association (EUSTAFOR) represents European State Forest Management Organizations, which often are the single largest forest managers in Member States. The common aim of EUSTAFOR members is to manage forests with a view to meet societal needs in environmentally sound way, while ensuring the economic sustainability.
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Response to Multiannual Financial Framework - CAP Strategic Plans

2 Aug 2018

The European State Forest Association (EUSTAFOR) represents European State Forest Management Organizations, which often are the single largest forest managers in Member States. The common aim of EUSTAFOR members is to manage forests with a view to meet societal needs in environmentally sound way, while ensuring the economic sustainability. The official position of EUSTAFOR in the future CAP is presented in the attached position paper: Sustainable Forestry for Rural Livelihoods – EUSTAFOR’s seven recommendations to further enhance rural development policy post-2020 – for people, climate and the economy From a first look, the proposed bottom-up approach in the future CAP could be the right approach to address specific issues, such as forestry measures, but it still remains unclear to what level of flexibility the proposed indicators will be applied to the Member States. Moreover, and as one Strategic Plan per Member State has been planned, it is also unclear how regional rural development policy will be addressed in this context. A first understanding is that while the specific objectives would be promising for the consideration of forestry in the new CAP, especially with regards the listed objectives, a closer look at the indicators proposed to assess progress towards those objectives may not guarantee that in each Member State forestry measures will be given priority and, in consequence, included into a strategic plan. Moreover, these indicators do not specifically go in a direction of supporting multifunctional and sustainable forest management, as the only explicit reference to sustainable forest management planning is reported as a result indicator of the objective (f) contribute to the protection of biodiversity, enhance ecosystem services and preserve habitats and landscapes in terms of “Share of forest land under management commitments to support forest protection and management.” Such approach does not seem to bring any specific benefit to state forests which are usually already under management commitments. Such provisions somehow conflict with what is stated in Recitals, for example that “Forestry measures should contribute to the implementation of the Union Forest Strategy” – which we strongly support - while confirming worries with regards to climate policy where forests are seen as a short-term stock rather than a long-term sink and a source of renewable materials and energy. For example, for the specific objective (d) contribute to climate change mitigation and adaptation, as well as sustainable energy forests are mentioned with regards to bioenergy production, carbon storage, as well as afforestation, while Sustainable Forest Management is not considered as a climate mitigation action and specific references to adaptation needs in forestry; for the specific objective (e) foster sustainable development and efficient management of natural resources such as water, soil and air, forests (40% of European lands) are not considered as crucial for clean water and air; for the specific objective (f) contribute to the protection of biodiversity, enhance ecosystem services and preserve habitats and landscapes while Sustainable Forest Management and Natura 2000 are taken into consideration, the result should, nevertheless, be oriented towards better support for the existing protected areas rather than measuring increases in their extension; For the specific objective (h) promote employment, growth, social inclusion and local development in rural areas, including bio-economy and sustainable forestry, the bioeconomy is taken into account, but there is no specific mention of the role of the forest-based sector for the development of rural areas. In conclusion, with regards the CAP Strategic Plans, many of its objectives - especially d), e), f) and h) and b) - can be relevant to forestry, however it is not given that forestry measures will be addressed in the Member States.
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Response to Evaluation of the EU Biodiversity Strategy to 2020

16 Jul 2018

European State Forest Association (EUSTAFOR) represents 33 European State Forest Management Organizations, which often are the single largest forest managers in Member States. The common aim of EUSTAFOR members is to manage forests with a view to meet societal needs in environmentally sound way, while ensuring the economic sustainability. And, as state forests in many cases are not eligible for public support, either from EU or MS budgets, for the implementation of biodiversity and Natura 2000 related measures, the economic viability is mostly relying on wood sales as a main primary product derived from forest management. The implementation of conservation measures and the enhancement of biodiversity in state forests is a part of regular forest management ensured by the long-term planning approaches envisaged in the forest management plans. All these measures are carried out by forest managers, which should be recognized as the key actors in the implementation of the EU Biodiversity Strategy, and not as whatever stakeholder, if the aim is to achieve sound results. Therefore, we share the confidence that the evaluation process will well take into the consideration of land managers, especially, those in public forests, and as EUSTAFOR we are willing and available to provide inputs, comments and the field expertise of our members, as well as to assist the European Commission during the evaluation process. We support the ambitions expressed in the roadmap in terms of “evaluation questions”. In these regards, it is important that the assessment of the coherence with other policies at EU and Member State (MS) level is well taken into account, especially with regards forest-related policies and the EU Forest Strategy. The latter sets the general framework for coordination of forest-related policies at EU level. Still, with regards the coherence with other EU policies, we are surprised that there is no mention of the EU Bioeconomy Strategy which is of strategic importance for the sustainability of the sector and for climate change mitigation, and should be seen in synergy with the EU Biodiversity Strategy, which should aim at improving the quality of the ecosystems rather than to set aside land for multiple benefits, as well other policy initiatives as the ones related to climate change adaptation and mitigation. Finally, we do support the intention to address the relevance of the EU Biodiversity Strategy and its actual benefits to the European citizen, as well as its costs and challenges. EUSTAFOR Position Paper on the Fitness Check of the Birds and Habitats Directives and Their Implementation in State Forests is available at this link: https://www.eustafor.eu/uploads/EUSTAFOR-Position-Paper-Natura-2000-20160708.pdf
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Meeting with Peter Wehrheim (Cabinet of Commissioner Phil Hogan)

7 May 2018 · Future Rural development policy & forests