WWF response to the draft EU Forest Strategy

Posted on June, 29 2021

The Commission must listen to EU citizens and adopt a strategy that works for nature, climate and people
EU forests are home to an incredible variety of biodiversity, play a critical role in climate mitigation, and contribute greatly to people’s wellbeing. But they are threatened by multiple and growing pressures.

Today, almost all of Europe’s natural forests have been replaced by forests managed to varying degrees of intensity. Even in forests protected under EU nature legislation, biodiversity is in decline and their ability to absorb carbon from the atmosphere is decreasing.

To reverse this trend, we need an EU Forest Strategy that builds on the European Green Deal and international commitments, supports the EU Biodiversity Strategy, secures the health and resilience of Europe’s forests and adopts strong governance mechanisms. 

From the recent petitions on the disastrous consequences of forest biomass subsidies under the Renewable Energy Directive to the mass protests in Poland and Romania, EU citizens have shown their concern and their desire to see forests spared from destruction and degradation.

"The draft EU Forest Strategy is a sign that the European Commission has listened and is taking a crucial step in the right direction", said Sabien Leemans, Senior Biodiversity Policy Officer at WWF European Policy Office.

"EU forests are under immense pressure and people all over Europe are speaking up about the need to protect and restore them," she continued. "We are appalled by the criticism of the strategy from the forest industry [1]. This clearly shows that the forest sector has not yet fully grasped the urgent need to divert from business as usual and to transform to a long-term sustainable sector."

We call on the Commission to withstand industry pressure and adopt a forest strategy that works for nature, climate, as well as current and future generations.

In particular, the Commission should defend the following commitments in the draft EU Forest Strategy: 
  • A swift change to closer to nature and multi-functional forest management, avoiding destructive practices like whole-tree harvesting (removal of stumps and roots), and supporting management practices that are beneficial for biodiversity and climate resilience, like maintaining sufficient quantities of deadwood, creating and maintaining mixed-species uneven-aged forests and set-aside areas in production forests. 
  • The reinforcement of the sustainable forest management framework through the definition of indicators and thresholds relating to ecosystem health, biodiversity and climate change, to be included in the future legislative proposal on EU forest planning and monitoring. 
  • The focus on re- and afforestation of biodiverse forests in urban and peri-urban areas and agricultural areas, through agroforestry and alongside rivers to establish ecological corridors. 
  • The recognition that forest owners and managers should be rewarded for the provision of ecosystem services provided by their forests and the commitment to address possible hurdles posed by current EU legislation and State Aid guidelines.
  • The adoption of a robust, EU-wide monitoring framework both through remote sensing and in situ data, to monitor the actual status and health of the different forest ecosystems and most importantly the fact that the Commission will put forward a legislative proposal for EU Forest Monitoring and Planning framework.
  • The adoption of strong and more transparent governance and the creation of an EU expert group with broad stakeholder representation, including NGOs and civil society, to discuss EU forest initiatives, a legal duty since the Aarhus convention. 
  • The reaffirmation of the commitment to strictly protect all primary and old-growth forests and to ensure no deterioration until the strict protection regime is applied.
  • The recognition that forest ecosystems, other than primary and old-growth forests, will also need to contribute to the target of strictly protecting at least 10% of the EU land area. 
  • The reaffirmation that the Commission will propose a legally binding instrument for ecosystem restoration that will include targets for restoring forest ecosystems. 
However, the draft EU forest strategy also falls short on certain elements. In particular, the Commission should stop blindly incentivising the bio-economy [2], which leads to intensive forest management and increased harvesting, as this goes against the EU’s climate and biodiversity objectives. 

Points in the draft EU Forest Strategy that need to be improved: 
  • Revise the Renewable Energy Directive (RED) and the Land Use, Land Use Change and Forestry (LULUCF) Regulation: The RED needs to end incentives for burning trees for energy, something that can increase emissions for decades compared to fossil fuels and risks promoting unsustainable land-use practices, distorting markets and undermining the principle of cascading use. The LULUCF Regulation meanwhile needs new targets to encourage carbon sequestration in biodiverse and hence climate-resilient forests through ecosystem restoration. 
  • We see significant risks in relation to the carbon farming and carbon removal certification initiative. Indeed, the Commission’s apparent plans to finance payments for ecosystem services through a market mechanism based on companies buying certified carbon credits seems profoundly misguided. Carbon offsets in the land-use sector, which are difficult to measure and not necessarily stable or permanent, should not be treated as directly (tonne-for-tonne) equivalent to fossil fuel emissions in other sectors. Support for forest restoration and other nature-based climate solutions should be financed primarily through national support schemes, the Common Agricultural Policy, revenues from the Emission Trading System, or other levies on greenhouse gas-emitting companies.
  • The Strategy aims to incentivise the forest bioeconomy including through long-lived wood production and quantify the climate benefits of wood construction products to supposedly help turn the construction sector from a source of greenhouse gas emissions into a carbon sink. WWF is deeply worried about such statements. Carbon stocks in biodiverse and hence climate-resilient natural forests must be built for climate mitigation purposes, but also for restoring ecosystems and reversing the collapse of biodiversity, and neither of these objectives will be achieved if forest logging is further intensified. EU forests (mainly in central and northern Europe) are already under very high pressure for production with an increase of harvesting levels. 

For further information:

Sabien Leemans
Senior Biodiversity Policy Officer
Bartosz Brzezinski
Communications Officer for Biodiversity & Agriculture
Tel. +32 484 28 15 10

Notes to editors

[1] http://www.forestindustries.se/news/news/2021/06/forest-strategy/
[2] Using renewable biological resources from land and sea, like crops, forests, fish, animals and micro-organisms to produce food, materials and energy (European Commission)
The European Commission is expected to adopt the new EU Forest Strategy on 14 July.
© Victor Daggberg