AUTHORS: Julia Bognar, Krystyna Springer

Increasing carbon removals from forests is a necessity in achieving the EU’s overall climate objective of carbon neutrality by 2050. This is embodied in the EU’s own carbon sink objective for 2030 under the Land Use and Land Use Change and Forestry (LULUF) Regulation.  However, increased demand for woody biomass exacerbated by its inclusion towards increasing renewable energy targets for 2030 under the Renewable Energy Directive (aka RED III) could potentially undermine this goal. The upcoming Forest Monitoring Framework will play a fundamental role in providing greater transparency for monitoring the progress towards meeting the sink objective.  

The European Commission’s impact assessments (EU Commission 2016, EU Commission 2020) highlight the growing importance of the land sector in the climate mitigation effort over time. This is in part due to the EU objective of achieving climate neutrality by 2050 relying on an increase in carbon removals to offset the remaining, hard-to-abate emissions. However, according to the EEA (2022), CO₂e removals have decreased in the past 10 years, mainly as a result of increased harvest rates. Due to the essential role of carbon sinks in meeting its net zero climate target for 2050, the EU has established a target under the LULUCF Regulation to increase its net carbon sink to -310 MtCO₂e by 2030, which recently became law in May 2023, to halt and reverse the trend of a decreasing EU carbon sink. 

As removals and reductions of emissions from agricultural land are projected to play a limited role in the coming years (EEA 2022), forest carbon sinks will be critical to achieving climate targets as it is currently the only¹ sector which is consistently a net carbon sink. To become carbon neutral by 2050, the EU net carbon sink from forests should increase from the current level of about −360 to −450 Mt CO₂ (Pilli et al 2022).  

According to Rockström et al (2023), safe Earth system boundaries to avoid tipping points are heavily dependent on large-scale nature restoration. Both reforestation and protection of existing carbon stocks will be essential: there is consensus within the IPCC report (2019) , that both the restoration of young forests, as well as the conservation and management of mature forests, will be critical to avoiding catastrophic climate change.  

Safeguarding existing carbon stocks and sinks will be heavily dependent on a swift roll-out of robust and ambitious monitoring mechanisms. The relatively short-term timeframe to meet the carbon sink target by 2030 will mean that regular and timely information will be necessary for Member States to demonstrate compliance with the LULUF Regulation.  

However, since the expiration of the Forest Focus Regulation in 2007, there is a lack of harmonised forest reporting requirements in the EU.²  As a result, comparable and consistent information on the status of EU forests is lacking. This presents a risk to the EU’s climate objectives, as robust monitoring will be essential to assess progress towards the carbon sink objective.  

As part of the Forest Strategy for 2030, the Framework for Forest Monitoring aims to develop an EU-wide forest observation framework to provide open access to detailed, accurate, regular, and up-to-date information on the condition and management of EU forests as well as requiring Member States to prepare strategic plans for forests. In addition to improving forest monitoring, the intention is to also facilitate more data-driven decision-making on forests.  

However, the Forest Monitoring Framework will also have to balance diverging demands for forest resources in addition to its carbon sink target. The EU’s updated Renewable Energy Directive has concluded trilogue negotiations with an agreement to raise the EU’s renewable target to 42.5% by 2030. Traditionally, under the RED, a broad range of biomass feedstocks have been classified as renewable, making them eligible for taxpayer support. As a result, the progress that the EU has made towards its renewables target to date has been largely driven by the use of woody biomass for energy generation.³  

Critics of the EU’s renewable energy legislation argue that it could potentially increase pressure on forest resources, and thus jeopardise the critical carbon stocks that are essential to achieving climate neutrality. Many studies have linked the decline in forest carbon sink to the increasing demand for biomass used for energy generation (Boettcher et al 2021; Booth 2022; Norton et al 2019; Searchinger et al 2022; Ceccherini et al 2020; Soimakallio et al 2022). 

In the agreed upon version of REDIII between the institutions, EU lawmakers have attempted to respond to some of the concerns around potential negative impacts from bioenergy generation by strengthening the relevant sustainability criteria for forest biomass. Notably, Member States will be required to assess if the burning of forest biomass for energy is in line with their LULUCF carbon sink targets.

While a stronger link with the LULUCF carbon sink targets at Member State level is welcome, it does not provide direct disincentives for economic operators, where the REDIII could potentially continue to stimulate increasing demand for forest biomass for energy production, further delaying the scaling up of genuine renewables, such as solar or wind. 

As REDIII leaves the Member States in charge of maintaining a balance between the multifunctional demands for forest resources, the EU’s role in managing the potentially conflicting carbon-based energy and carbon sink objectives will be shaped in the coming years (2023-2030) by the proposed Framework for Forest Monitoring and Strategic Plans.  

Fit-for-purpose monitoring and reporting is urgently needed to inform and evaluate policy decisions regarding the multifunctional use of forests in balancing bioeconomy demands with nature conservation commitments, and to understand the capacity of EU forests to deliver against multiple objectives under changing climate conditions. Without real-time data, it will be challenging to verify whether such a balance is feasible.  

The Forest Monitoring Framework will not only verify the coherence of the EU’s climate architecture for forests when it comes to the REDIII and LULUCF Regulation but can also provide support for other forest-related climate and biodiversity policies, such as the Nature Restoration Law, the Carbon Removal Certification Framework, and the 3 Billion Trees Pledge.  

To raise awareness of the importance of the Framework for Forest Monitoring and Strategic Plans, IEEP have prepared brief summaries of relevant policies in which the Framework for Forest Monitoring will be an essential policy measure in the verification of progress towards achieving the EU’s climate objectives related to the role of forests. 

• LULUCF Regulation Forest Monitoring
• NRL & Forest Monitoring
• RED & Forest Monitoring
• CRCF & Forest Monitoring
• 3B Trees Pledge & Forest Monitoring

Photo by Janusz Maniak on Unsplash

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¹ Under LULUCF accounting, grasslands vacillate between being a net source of emissions, and a net sink. Harvested wood products, which are sourced from forests, are a net sink. Croplands, wetlands, and settlements are net sources of emissions. It should also be noted that while forests are a net sink, the sector is also the largest source of LULUCF emissions. 

² Forest Europe does provide a voluntary framework for common strategies regarding sustainable forest management, including monitoring under EUFORGEN. 

³ Biomass accounts for nearly 60% of all renewable energy in the EU, with wood-based sources making up over 60% of EU domestic biomass used for energy purposes. Over a third of the woody biomass input is estimated to be primary³ wood (Camia et al. 2021).