The Commission’s ‘deep clean’ looks dangerously like greenwashing
13 May 2026
The European Commission says it wishes to simplify EU climate law while maintaining its commitment to fight climate change. But simplifying targets for the land sector looks more like diluting climate ambition than easing bureaucracy.
On 28 April 2026 – before the public consultation about the future of national climate targets closed – the European Commission quietly signalled a major shift in its climate architecture. Buried in Annex I of its “Regulatory Deep Cleaning Action Plan”, a document framed around cutting red tape, was a line that should alarm everyone who cares about Europe’s forests: the cleaning, “will look into merging the Land Use, Land Use Change and Forestry Regulation [LULUCF] and the Effort Sharing Regulation [ESR] into a single instrument on national climate targets.”
What merging LULUCF and ESR would mean
The LULUCF Regulation keeps a dedicated eye on happenings in Europe's forests and soils. Keeping separate land and economy-wide emissions targets, thereby forcing governments to address what is happening on the ground. National climate targets under both regulations run to 2030, which is precisely why a credible post-2030 architecture matters so much.
Merging the two instruments would mean no more separate target for land, and no more obligation to treat Europe’s declining forest carbon sink as a problem that demands its own solution. Under a merged framework, a country could compensate for a deteriorating forest sink by claiming emission reductions elsewhere – a notorious minefield of carbon-accounting shell games.
Practically, it creates a mechanism for letting industrial logging giants off the hook.
The Commission insists that the manœuvre is all about simplification, not dilution. Ursula von der Leyen claims to maintain the EU’s commitment to climate ambition. But the political logic always follows the same script: industry groups argue that forests are declining because of climate change – drought, pests, fire – and that logging cannot reasonably be constrained further.
That argument does not stand up: 90% of Europe’s tree cover loss is caused by logging.
Fern’s recent briefing, Pulping unfair incentives, details how the pulp and paper industry, one of the heaviest users of European wood, has systematically lobbied against stronger LULUCF targets –while benefiting from subsidies incentivising the high-intensity forestry causing Europe’s carbon sink collapse.
The Commission’s proposed change would reward industrial forest lobbying with the destruction of a dedicated climate framework for land, while Europe’s citizens would receive increased forest destruction, climate instability and unpredictability.
Sweden: the human cost of industrial forestry
Fern’s briefing also outlines the environmental and social harm caused by the largest forestry companies (also FW 311, FW 313). To those can be added another, recently exposed in articles by Swedish outlet Dagens Arbete: In 2023, some 60 Thai migrant workers travelled to Sweden to plant and clear forests for a contractor working on behalf of Svenska kyrkan (the Church of Sweden) and the state-owned company Sveaskog, lured by the promise of wages three times higher than in Thailand. They returned home exhausted and nearly penniless, their passports and bank cards confiscated, having been housed in overcrowded dormitories for which they had to return some of their wages – in cash – each month. Both Svenska kyrkan and Sveaskog hold Forest Stewardship Certificate (FSC) certification, a scheme that explicitly commits companies to fair and safe working conditions.
The editor-in-chief of Dagens Arbete puts the responsibility squarely where it belongs: the companies who recruit from low-wage countries and create conditions where abuse can thrive.
The Swedish National Audit Office flagged these systemic failures back in 2020. Nothing changed. Companies clearly need to be held to higher standards by public authorities.
The Commission’s ‘deep clean’ would leave a stain on Europe’s climate credibility. Erasure of dedicated accountability for the land sector is not a technical adjustment. It is a political choice – and one that the forests will pay for.
Image: Eddgars/Shutterstock
Categories: News, Forest Watch, European forests, LULUCF
