EU Member State positions could have a profoundly negative impact on forests

29 June 2022

EU Member State positions could have a profoundly negative impact on forests

Overnight, EU energy and environment ministers agreed on their positions on two files that are crucial for the fate of EU forests: the revision of the Renewable Energy Directive (RED) and the Land Use, Land-Use Change and Forestry Regulation (LULUCF).

Their positions are worrying with potentially profound and long-term negative consequences for the EU’s forests and the climate crisis.


The position adopted on RED by the EU Council on energy is a sad surrender to the irresponsible interests of the biomass industry. The many billions of euros of taxpayers’ money squandered by Member States on incentivising the forest destruction and atmospheric pollution that goes hand-in-hand with biomass burning, would be much better deployed rewarding foresters transitioning to close-to-nature forestry practices, helping EU citizens insulate their homes, and supporting energy providers to invest in renewables that actually reduce carbon dioxide emissions.

This Directive is meant to set safe boundaries for bioenergy, but the Council position blows a huge hole in them, allowing Member States to increase imports of wood, logging in European forests, and burning of biomass. All of which will compromise the EU’s climate targets. When forests are cut and burned, less carbon dioxide is sequestered and more is sent up into the atmosphere,said Martin Pigeon, Fern’s bioenergy campaigner.

The Council’s position weakens the Commission’s legislative proposal in several ways:

  • it no longer excludes primary and old growth forests from the “sustainability criteria”, which allows the extraction of biomass for energy
  • it weakens the introduction of the cascading principle, which allows for prioritising material uses over energy uses
  • it doubles the power threshold under which energy installations do not have to respect the above-mentioned sustainability criteria from 5 megawatts (MW) to 10MW

Equally worrying, Member States are proposing to exempt biomass installations from environmental impact assessments and include them in the fast-track approval procedures for renewables that was suggested as part of the May 2022 REPowerEU Communication, which offers options on phasing out the EU’s reliance on Russian fossil fuels. The Commission had initially excluded biomass installations from the fast-track procedure. Such a move would worsen the existing, already destructive impacts of the biomass industry in Europe and abroad.

This worrying outcome reflects the strong pressure from a number of countries who are highly reliant on bioenergy, such as Sweden, Finland, Estonia, Latvia and Lithuania. Poland, Hungary, Czechia and Romania, who are looking for cheap and convenient replacements to feed their coal-fired power plants, also supported this position.

Only the Netherlands and Denmark actively opposed, while Germany and Belgium, whose position also acknowledged the pitfalls of heavy bioenergy reliance, looked the other way and prioritised other issues in the file.

Since 2009, the RED has incentivised burning wood for energy to achieve the EU’s renewable energy targets and about 55 per cent of the EU wood harvest is getting burned today, while it was just above 40 per cent in 2005. During that time period, the carbon sucking power of forests has reduced by 28 per cent. According to the Commission’s Joint Research Centre, about 32 per cent of EU's total renewable energy (itself approximately 20 per cent of the EU’s energy mix) most likely originates from forest biomass. Financial subsidies to bioenergy cost more than 20 billion Euros a year to EU taxpayers.

It is wrong to subsidise the increased burning of wood. Not only has it cost forests, the climate, biodiversity and air quality, but it has also impacted other wood using sectors, as the incentives increase the price of wood for all users.

We urge the Members of the European Parliament to refuse this cowardly abandonment of the public interest and, like the Members of the Environment Committee already did in May, exclude unprocessed wood from these incentives and restrict these to biomass feedstocks that do not worsen the climate and biodiversity crisis,” Pigeon added.

The European Parliament is set to adopt its final position mid-September.


The LULUCF Regulation sets the climate ambition and accounting rules for the land and forest sector.

The EU's land climate policies have been marred by low ambition for years. This text does not help reverse it. Instead, it offers multiple escape routes – from setting easier targets to offering shortcuts to reach the target, called flexibilities – allowing recalcitrant Member States to avoid making the urgent changes that are needed to help us achieve higher carbon reduction targets.

This is the legislative equivalent of putting a sticking plaster on a burn. It covers up the problem but doesn't end the pain," said Kelsey Perlman, Fern’s forest and climate campaigner.

Member States kept the target of -310 Million tonnes (Mt) of carbon dioxide sequestration in the LULUCF sector by 2030, that was proposed by the Commission and recently endorsed by the European Parliament. This is well below the civil society ask of -600Mt, but nonetheless is in stark contrast to the 2018 LULUCF Regulation that incentivised forest management that would lead to forests removing less carbon. Many forests in Member States – such as Estonia - are logging so intensively that they are emitting more carbon dioxide that they absorb.

But Member States have also agreed on the insertion of more “flexibilities” into legislation which will allow them to write off underachievement in one country with overachievement in another so that, on paper at least, they would look like they had ‘achieved’ their targets. Such flexibilities risk significantly undermining the overall -310Mt target and go much beyond what was suggested by the Commission and the European Parliament.

One concern is linked with natural disturbances, as forest destruction due to a storm or a bark beetle outbreak could either be ignored in the accounting or offset with available flexibilities. In European forests, 35 million cubic meters of wood have been damaged annually by natural disturbances between 1950 to 2000, according to this study. This would roughly correspond to 35Mt of carbon dioxide that could have been erased per year.

As European forests are increasingly suffering from climate change, it is very worrying that Member States would rather look away from the impacts of the climate breakdown on the EU land sink, rather than acknowledge it. Dodging a problem will not make it go away,” added Perlman. 

Another flexibility concerns “banking credits”: Member States would like to use up to 71Mt of offsetting credits to be able to comply with their 2030 sequestration target. The use of those credits, if it gets the Union to the 310Mt target, would grant access to a another “bonus” flexibility allowing Member States to compensate for the emissions of carbon dioxide stemming from past non-environmentally friendly land use practices on organic soils. This “bonus” could be as large as 50Mt.

Member States also want to be much more lenient in the way their targets are set. They propose to move from yearly targets from 2026-2030 to a single binding one in the year 2030. This would mean less penalties if they miss their targets.

Finally, the Council is calling on the Commission to explore other avenues to cheat the climate by including Bioenergy with Carbon Capture and Storage (BECCS) in the Regulation, despite the fact that many scientists have highlighted feasibility constraints that would make it unlikely to ever work, at least not on the scale foreseen.

The amount of flexibilities and cheat codes Member States have creatively come up with to help them underachieve their carbon sequestration targets is dizzying. But pretending to store carbon on paper won’t do any help in fighting the climate breakdown,” added Perlman.

The European Parliament and the Council will now need to compromise on their positions. Fern calls on the Parliament to stand strong to ensure the integrity of the LULUCF sequestration target.  

Categories: Press Releases, Bioenergy, European forests

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