Guidance on developing and reporting Forest Reference Levels in accordance with Regulation (EU) 2018/841.
Date: 2018-07-24
Institutions: Directorate-General for Climate Action
Subjects: environmental impact, environmental indicator, environmental monitoring, environmental research, forest conservation, forestry legislation, forestry policy, greenhouse gas, harmonisation of standards, report, research method, research project, user guide

Guidance on developing and 
reporting Forest Reference Levels in 
accordance with  
Regulation (EU) 2018/841  

version 20 July 2018 

LEGAL NOTICE 

The information and views set out in this report are those of the authors and do not necessarily reflect the 
official opinion of the Commission. Neither the Commission nor the authors guarantee the accuracy of the 
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be held responsible for the use which may be made of the information contained therein.” 

Please cite this document as follows: Forsell N, Korosuo A, Federici S, Gusti M, Rincón-Cristóbal J-J, Rüter S, 
Sánchez-Jiménez B, Dore C, Brajterman O and Gardiner J. (2018). Guidance on developing and reporting 
Forest Reference Levels in accordance with Regulation (EU) 2018/841. Available online at: 
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EUROPEAN COMMISSION 

Guidance on developing and 
reporting Forest Reference 
Levels in accordance with 
Regulation (EU) 2018/841  

CONSORTIUM LEADER:  
ICF Consulting Limited (ICF), United Kingdom 

CONSORTIUM MEMBERS: 
International Institute for Applied Systems Analysis (IIASA), Austria 
Aether, United Kingdom 
ICF Consulting Limited (ICF), United Kingdom 

AUTHORS: 
Nicklas Forsell, Anu Korosuo, Sandro Federici, Mykola Gusti, Juan José Rincón Cristóbal, 
Sebastian Rüter, Beatriz Sánchez Jiménez, Chris Dore, Olivia Brajterman, James Gardiner 

2018 

Directorate-General for Climate Action 

EUROPEAN COMMISSION 

Directorate-General for Climate Action 
Directorate C — Climate Strategy, governance and emissions from non-trading sectors 
Unit C3 — Land Use and Finance for Innovation 

Contact: Simon Kay 

E-mail:  CLIMA-LULUCF@ec.europa.eu 

simon.kay@ec.europa.eu 

European Commission 
B-1049 Brussels 

 Guidance on developing and reporting Forest Reference Levels in accordance with 
Regulation (EU) 2018/841 

OVERVIEW 

This  technical  guidance  document  has  been  prepared  for  DG  Climate  Action,  to  support 
the  EU  Member  States  in  complying  with  the  ‘LULUCF  Regulation’,  Regulation  (EU) 
2018/841 of the European Parliament and of the Council of 30 May 2018 on the inclusion 
of greenhouse gas emissions and removals from land use, land use change and forestry 
in the 2030 climate and energy framework, and amending Regulation (EU) No 525/2013 
and  Decision  No  529/2013/EU  (Text  with  EEA  relevance) 1.  In  particular,  the  aim  of  this 
document  is  to  provide  guidance  for  the  Member  States  on  the  establishment  of  Forest 
Reference  Levels  (FRLs)  and  National  Forestry  Accounting  Plans  (NFAPs)  as  required  by 
the LULUCF Regulation.  

The  LULUCF  Regulation  requires  the  Member  States  to  submit  their  NFAPs,  including  a 
proposed  FRL,  to  the  Commission  by  31  December  2018  for  the  period  from  2021  to 
2025,  and  by  30  June  2023  for  the  period  from  2026  to  2030.  While  the  guidance 
provided  in  this  document  is  not  binding  on  the  Member  States,  it  seeks  to  help  the 
Member  States  to  interpret  the  LULUCF  Regulation,  and  provides  examples  of  possible 
technical  approaches  for  preparing  the  FRLs  and  NFAPs.  However,  there  may  exist  a 
number of other approaches to set the FRL in line with the LULUCF Regulation. 

The structure of this technical guidance document is illustrated in Figure 1. The document 
is  organized  into  three  sections,  accompanied  by  three  Annexes.  Section  1  provides  an 
introductory  summary  of  the  state  of  the  forest-related  accounting  rules,  and  gives  an 
overview of the key differences between the FRL approach under the LULUCF Regulation 
and  the  previous  approach  under  the  Kyoto  Protocol  (KP).  Section  2 details  a  step-wise 
methodology for the construction of robust and transparent FRLs by Member States. The 
steps in the methodology have been developed by a group of thematic experts, based on 
discussions  with  DG  Climate  Action  and  Joint  Research  Centre  of  the  European 
Commission (JRC), as well as in workshops with experts from the Member States. These 
steps  seek  to  portray  a  wide  array  of  different  solutions  for  developing  the  FRL  to  take 
into account the large variation in the natural conditions and forest sector characteristics 
across  the  EU  Member  States.  Section  3  provides  a  detailed  analysis of  the  criteria  and 
guidance  for  determining  the  FRL,  as  set  out  in  Annex  IV.A  of  the  LULUCF  Regulation, 
and  a  suggested  table  of  contents  for  the  submission  of  the  NFAPs,  taking into  account 
the requirements as set out in Annex IV.B of the LULUCF Regulation. 

In  the  annexes  to  this  technical  guidance  document,  we  provide  a  checklist  for  the 
proposed  step-wise  approach,  as  well  as  an  illustrative  handbook  of  the  different  steps 
for  the  development  of  the  FRL.  In  addition,  we  provide  suggestions  and  examples  of 
tables that the Member States may consider to use in their reporting of the NFAPs.  

1 Available online at: http://europa.eu/!cQ33UG 

5 

 Guidance on developing and reporting Forest Reference Levels in accordance with 
Regulation (EU) 2018/841 

Section 1

Section 2

Section 3

Annexes

• Overview of the 
principles for GHG 
accounting in 
LULUCF sector, the 
current state of 
reporting, and an 
overview of the 
legislative text

• Guidance to 
possible 
approaches to 
develop the FRLs, 
and advice on how 
to ensure 
transparent 
reporting
• Hands-on 
examples on 
different 
calculation steps 
and possible 
methods

• Detailed analysis 
of the criteria for 
the FRL set out in 
the Annex IV of the 
Regulation
• Example table of 
contents for the 
submission of the 
NFAP, in 
accordance with 
the requirements 
of the Annex IV of 
the Regulation.

• Annex I: Checklist 
for the proposed 
step-wise 
approach
• Annex II: 
Handbook for 
establishing FRLs
• Annex III: Filled in 
examples of 
reporting tables as 
suggested in 
section 2
• Annex IV: 
Overview of 
Member States' 
reporting under KP

Figure 1. Structure of this technical guidance document. 

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 Guidance on developing and reporting Forest Reference Levels in accordance with 
Regulation (EU) 2018/841 

TABLE OF CONTENTS 

OVERVIEW ................................................................................................................... 5 

TABLE OF CONTENTS ..................................................................................................... 7 

GLOSSARY ................................................................................................................... 8 

ACRONYMS AND ABBREVIATIONS ................................................................................. 12 

ACKNOWLEDGEMENTS ................................................................................................. 13 

SECTION 1 ................................................................................................................. 14 

1 

INTRODUCTION ................................................................................................... 14 

1.1  What is this technical guidance document for? ................................................ 14 
Introduction to LULUCF in the context of climate change ................................. 15 
1.2 
Previous reporting and accounting under the Kyoto Protocol ............................ 19 
1.3 
LULUCF Regulation...................................................................................... 22 
1.4 

SECTION 2 ................................................................................................................. 29 

2 

POSSIBLE WAYS TO IMPLEMENT THE FRL REQUIREMENTS IN LINE WITH THE LULUCF 
REGULATION REQUIREMENTS ............................................................................... 29 

Stratification .............................................................................................. 32 
2.1 
2.2 
Forest management practices ....................................................................... 38 
2.3  Methodology .............................................................................................. 53 
2.4  Consistency with greenhouse gas inventories ................................................. 70 
2.5 
Projections ................................................................................................. 76 
2.6  Calculate the forest reference level ............................................................... 87 

SECTION 3 ................................................................................................................. 89 

3 

CRITERIA  FOR  THE  FOREST  REFERENCE  LEVEL  AND  THE  CONTENTS  OF  THE 
NATIONAL FORESTRY ACCOUNTING PLAN ............................................................... 89 

3.1  Description of Annex IV criteria for constructing FRLs ...................................... 89 
3.2  Common table of contents for the NFAP ......................................................... 92 
3.3  Where to find advice for Annex IV elements in this document? ......................... 94 

ANNEXES ................................................................................................................... 96 

ANNEX I ..................................................................................................................... 96 

Checklist  of  aspects  to  consider  when  following  the  approach  suggested  in  this 
technical guidance document ................................................................................. 96 

ANNEX II .................................................................................................................. 100 

Handbook for establishing forest reference levels ................................................... 100 

ANNEX III ................................................................................................................ 104 

Filled in example of table for Step 1 ..................................................................... 104 
Filled in examples of tables for Step 2 .................................................................. 105 

ANNEX IV ................................................................................................................. 108 

Overview of implementation of the Kyoto Protocol in the EU Member States .............. 108 

REFERENCES ............................................................................................................ 115 

7 

 
 
 
 
 
 Guidance on developing and reporting Forest Reference Levels in accordance with 
Regulation (EU) 2018/841 

GLOSSARY 

This  glossary  covers  the  terminology  used  in  this  technical  guidance  document.  The 
terms that are specifically defined in the LULUCF Regulation (Regulation (EU) 2018/841) 
are  marked  with  an  asterisk  (*),  and  those  previously  defined  in  the  Decision  No 
529/2013/EU  with  a  plus-sign  (+).  Direct  quotes  of  definitions  as  stated  in  the  LULUCF 
Regulation or the Decision are typed in ”blue italics”.  

Accounting. Rule-based assessment of the impact on GHG emissions and removals that 
take  place  under  a  compliance  period.  The  impact  is  accounted  through  comparison  of 
actual  GHG  emissions  and  removals  from  GHGI  categories  during  a  compliance  period 
with the counterfactual value, following the accounting rules set for the given category.  

Actual  management  practices  (AMP).  The  dataset  describing  the  FMP,  including  the 
specification of when and how each FMP and the associated management activity actually 
were implemented during the RP. 

Afforested  land*.  “Land  use  reported  as  cropland,  grassland,  wetlands,  settlements  or 
other  land,  converted  to  forest  land.”  (Article  2(1))  Note  that  the  process  under  the 
LULUCF Regulation is different from that under the KP, and also that the definition of the 
afforested  land  in  the  context  of  the  LULUCF  Regulation  differs  from  the  definition  of 
afforestation  in  the  IPCC  Guidelines  for  National  Greenhouse  Gas  Inventories  (2006). 
Nevertheless, the accounting of afforested (and deforested) land is understood to refer to 
human-induced  emissions  or  removals  from  land  use  change:  the  LULUCF  Regulation 
states that the “Member States shall account for emissions and removals resulting from 
afforested land and deforested land, as being the total emissions and total removals for 
each  of  the  years.”  (Article  6(1)),  and  emissions  and  removals  are  defined  as 
anthropogenic processes. 

Background  level.  “Average  emissions  caused  by  natural  disturbances  in  the  period 
from 2001 to 2020, excluding statistical outliers.” (Article 10(1)). 

Biomass  available  for  wood  supply  (BAWS).  The  potential  biomass  subject  to 
operational  criteria  as  defined  for  the  FMP.  For  example,  if  a  FMP  is  to  clearcut  spruce 
forests between 80 and 120 years, BAWS would be all spruce forests in between 80 and 
120 years. Please also see Grassi et al. (2017) for more details about this term. 

Carbon  pool*.  “The  whole  or  part  of  a  biogeochemical  feature  or  system  within  the 
territory of a Member State and within which carbon, any precursor to a greenhouse gas 
containing  carbon  or  any  greenhouse  gas  containing  carbon  is  stored.”  (Art  3(1)).  Note 
that  in  order  to  avoid  double-counting  of  traded  wood,  ‘production  approach’  is  to  be 
used.  This  means  that  the  imported  HWP  shall  not  be  accounted  for  by  the  importing 
Member State. (Annex V).  

Carbon stock*. “The mass of carbon stored in a carbon pool.” (Article 3(1)). 

Compliance period (CP). The period 2021–2030, to which the LULUCF Regulation sets 
out the commitments of the Member States for LULUCF, and the rules for the accounting 
of  emissions  and  removals  from  LULUCF  and  for  checking  the  compliance  of  Member 
States with those commitments (Article 1). Note that for accounting purposes, the CP is 
split  in  the  LULUCF  Regulation  into  two  periods:  2021  to  2025,  and  to  2026  to  2030. 
While the overall accounting rules set out in the LULUCF Regulation are the same for the 
whole  CP,  there  are  some  differences  in  the  requirements  of  wetlands  for  the  first  and 
second  CP.  After  each  5-year  period,  the  Commission  will  carry  out  a  comprehensive 
review  of  the  data  (Article  14(2))  and  determine  compliance  with  the  “no  debit” 
commitment of each Member State as set out in Article 4.  

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 Guidance on developing and reporting Forest Reference Levels in accordance with 
Regulation (EU) 2018/841 

Deforested  land*.  “Land  use  reported  as  forest  land  converted  to  cropland,  grassland, 
wetlands, settlements or other land.” (Article 2(1)).  

Dynamic  age-related  forest  characteristics.  The  LULUCF  Regulation  refers  to 
”dynamic  age-related  forest  characteristics”  (Article  8(5)).  In  this  technical  guidance 
document, age-related characteristics are understood to refer to the state of ‘maturity’ of 
the  forest,  which  can  be  characterized  e.g.  with  mean  age  of  a  stand,  its  biomass 
density,  and  age  or  diameter  class  distribution.  “Dynamic”  is  understood  to  refer  to  the 
development  of  these  characteristics  over  time,  such  as  the  movement  of  a  stand  from 
one age or diameter class to another over time. 

Emissions+.  “Anthropogenic  emissions  of  greenhouse  gases  into  the  atmosphere  by 
sources.” This is an opposite process to ‘Removals’. 

Forest*. “An area of land defined by minimum values for area size, tree crown cover or 
an equivalent stocking level, and potential tree height at maturity at the place of growth 
of the trees as specified for each Member State in Annex II [of the LULUCF Regulation]. 
It  includes  areas  with  trees,  including  groups  of  growing,  young  natural  trees,  or 
plantations that have yet to reach the minimum values for tree crown cover or equivalent 
stocking  level  or  minimum  tree  height  as  specified  in  Annex  II,  including  any  area  that 
normally forms part of  the forest area but on which there are temporarily no trees as a 
result  of  human  intervention,  such  as  harvesting,  or  as  a  result  of  natural  causes,  but 
which area can be expected to revert to forest.” (Article 3(1)). 

Forest management+. “Any activity resulting from a system of practices applicable to a 
forest that influences the ecological, economic or social functions of the forest.” 

Forest  management  practice(s)  (FMP).  The  LULUCF  Regulation  text  is  not  explicit 
about  the  definition  of  ‘forest  management  practice’.  In  Article  8(5),  the  term  is  in 
singular  form  (“practice”),  while  Annex  IV.B  asks  to  describe  “practices”.  Please  see 
section 2 of this document for possible interpretations of this term. In the context of this 
technical  guidance  document,  a  FMP  refers  to  a  set  of  management  activities  being 
carried out at different phases of the stand development. FMP can thus be seen as a set 
of  activities  carried  out  and  aimed  at  fulfilling  specific  functions  assigned  to  a  forest 
(production,  protection,  etc.),  including,  e.g.,  the  regeneration  modality,  the  species 
planted,  the  schedule  and  intensity  of  thinning  and  final  cut.  In  the  context  of  this 
document, also “no management” is considered as a possible FMP option.  

Forest reference level (FRL)*. “An estimate, expressed in tonnes of CO2 equivalent per 
year,  of  the  average  annual  net  emissions  or  removals  resulting  from  managed  forest 
land  within  the  territory  of  a  Member  State  in  the  periods  from  2021  to  2025  and  from 
2026 to 2030, based on the criteria set out in this Regulation [2018/841].” (Article 3(1)) 
In accounting terms, the FRL is the counterfactual value of emissions and removals that 
would occur in managed forest land in the absence of any future change in management 
practices compared to the reference period. 

Half-life  value*.  “The  number  of  years  it  takes  for  the  quantity  of  carbon  stored  in  a 
category of harvested wood products to decrease to one half of its initial value.” (Article 
3(1)). 

Harvested wood product (HWP)*. “Any product of wood harvesting that has left a site 
where wood is harvested.” (Article 3(1)). Note that in the accounting for HWP as detailed 
in  Article  9,  the  emissions  and  removals  resulting  from  changes  in  the  carbon  pool  of 
HWP  are  to  be  reflected  according  to  the  Annex  V  approach  for  the  following  HWP 
products: paper, wood panels, sawn wood (see Article 9(1)).  

9 

 
 
 Guidance on developing and reporting Forest Reference Levels in accordance with 
Regulation (EU) 2018/841 

Instantaneous  oxidation*.  “An  accounting  method  that  assumes  that  the  release  into 
the  atmosphere  of  the  entire  quantity  of  carbon  stored  in  harvested  wood  products 
occurs at the time of harvest.” (Article 3(1)). 

Legacy effect. Effect or impact of an action or a disturbance that occurs only after some 
time.  This  is  typical  in  forestry,  where  different  management  decisions  or  disturbances 
during  the  course  of  the  forest  rotation  time  affect  the  future  state  of  the  forests  for 
decades or even hundreds of years after the actual occurrence. 

LULUCF  Regulation.  The  full  name  of  the  Regulation  is  “Regulation  (EU)  2018/841  of 
the  European  Parliament  and  of  the  Council  of  30  May  2018  on  the  inclusion  of 
greenhouse gas emissions and removals from land use, land use change and forestry in 
the  2030  climate  and  energy  framework,  and  amending  Regulation  (EU)  No  525/2013 
and  Decision  No  529/2013/EU  (Text  with  EEA  relevance)”.  The  LULUCF  Regulation  is 
available online at: http://europa.eu/!cQ33UG. 

Managed  cropland*.  “Land  use  reported  as:  cropland  remaining  cropland;  grassland, 
wetland,  settlement  or  other  land,  converted  to  cropland,  or;  cropland  converted  to 
wetland, settlement or other land.” (Article 2(1)a). 

Managed forest land (MFL)*. “Land use reported as forest land remaining forest land.” 
(Article 2(2)a). 

Managed grassland*. “Land use reported as: grassland remaining grassland; cropland, 
wetland,  settlement  or  other  land,  converted  to  grassland,  or;  grassland  converted  to 
wetland, settlement or other land.” (Article 2(1)a). 

Managed  wetland*.  “As  of  2026:  land  use  reported  as:  wetland  remaining  wetland; 
settlement  or  other  land,  converted  to  wetland,  or;  wetland  converted  to  settlement  or 
other  land”  (Article  2(1)b).  Note  that  a  Member  State  may  include  emissions  and 
removals  from  managed  wetland  during  the  period  from  2021  to  2025,  but  it  is  not  a 
requirement in the LULUCF Regulation (Article 2(2)). 

Modelled  management  practices  (MMP).  The  dataset  including  the  quantified  FMPs 
that will be used to by the model to project the FRL. 

Natural  disturbances*.  “Any  non-anthropogenic  events  or  circumstances  that  cause 
significant emissions in forests and the occurrence of which is beyond the control of the 
relevant Member State, and the effects of which the Member State is objectively unable 
to significantly limit, even after their occurrence, on emissions.” (Article 3(1)). 

Precursor  to  a  greenhouse  gas+.  “A  chemical  compound  that  participates  in  the 
chemical  reactions  that  produce  any  of  the  greenhouse  gases  listed  in  Article  3(4)”  (of 
the Decision 529/2013/EU). 

Production  approach.  In  the  accounting  for  HWP,  the  HWP  is  accounted  for  in  the 
producing  country,  and  “the  imported  [HWP],  irrespective  of  their  origin,  shall  not  be 
accounted for by the importing Member State.” (Annex V). 

Reference period (RP). The period from 2000 to 2009. 

Removals+.  “Anthropogenic  removals  of  greenhouse  gases  from  the  atmosphere  by 
sinks.” This is an opposite process to ‘Emissions’. 

Reporting.  In  GHG  accounting  context,  reporting  refers  to  emission  and  removal 
estimates  prepared  annually  by  the  countries.  The  reporting  provides  the  information 
needed  for  accounting  the  impact  of  human  activities  on  the  atmospheric  GHG 
concentration.  Note  that  in  this  document,  we  use  ‘reporting’  also  in  a  more  general 

10 

 
 
 Guidance on developing and reporting Forest Reference Levels in accordance with 
Regulation (EU) 2018/841 

sense  to  refer  to  documentation  and  submissions  of  data  or  estimates  prepared  by  the 
countries. 

Salvage logging+. “Any harvesting activity consisting of recovering timber that can still 
be used, at least in part, from lands affected by natural disturbances.”  

Sink*. “Any process, activity or mechanism that removes a greenhouse gas, an aerosol, 
or  a  precursor  to  a  greenhouse  gas  from  the  atmosphere.”  (Article  3.1).  This  is  an 
opposite process to a ‘source’. 

Solid and energy use of forest biomass. The LULUCF Regulation refers to “solid and 
energy  use  of  forest  biomass”,  but  does  not  provide  a  specific  definition.  In  absence  of 
other  definitions,  it  is  advisable  to  consider  ‘solid  use’  as  the  use  of  forest  biomass  to 
other than energy purposes. For ‘energy use’, it is advisable to follow FAO definition for 
‘wood energy’: “All energy derived from primary and secondary solid, liquid and gaseous 
biofuels derived from forests, woodlands and trees. Wood  energy represents the energy 
produced after combustion of woodfuels, such as fuelwood, charcoal, pellets, briquettes, 
etc., corresponding to the net calorific value (NCV) of the fuel.” (FAO term portal 2018) 
Note,  however,  that  following  the  ‘production  approach’  to  avoid  double-counting  of 
traded wood, imported  HWP  shall not be accounted for by the importing Member State. 
(Annex V)  

Source*.  “Any  process,  activity  or  mechanism  that  releases  a  greenhouse  gas,  an 
aerosol or a precursor to a greenhouse gas into the atmosphere.” (Article 3.1). This is an 
opposite process to a ‘sink’. 

State of the forest. Set of data and information that describe the forest, such as total 
area of Managed Forest Land; as well as stratum-specific variables, e.g. area, increment, 
biomass, age-related information. 

Stratum,  strata.  In  the  context  of  this  technical  guidance  document,  a  stratum  (in 
plural: strata) is a part of forest (distinguished geographically or grouped across different 
geographic locations) homogeneous for all the criteria applied to the stratification process 
(tree  species,  forest  type,  management  system,  ownership,  etc.).  Each  stratum  differs 
from other strata by at least one of the criteria of stratification. 

Sustainable forest management (practice). The preamble of the LULUCF Regulation 
(recital  16)  refers  to  the  principles  of  sustainable  forest  management  as  adopted  in  the 
Ministerial  Conferences  on  the  Protection  of  Forests  in  Europe  (‘Forest  Europe’).  The 
Helsinki  Resolution  H1  (Forest  Europe  1993)  of  Forest  Europe  defines  “sustainable 
management” as: “the stewardship and use of forests and forest lands in a way, and at a 
rate,  that  maintains  their  biodiversity,  productivity,  regeneration  capacity,  vitality  and 
their  potential  to  fulfil,  now  and  in  the  future,  relevant  ecological,  economic  and  social 
functions, at local, national, and global levels, and that does not cause damage to other 
ecosystems”.  Furthermore,  Annex  IV  A.(f)  of  the  LULUCF  Regulation  states  that  “the 
reference level should be consistent with the objective of contributing to the conservation 
of  biodiversity  and  the  sustainable  use  of  natural  resources,  as set  out  in  the  EU  forest 
strategy, Member States’ national forest policies, and the EU biodiversity strategy”. 

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 Guidance on developing and reporting Forest Reference Levels in accordance with 
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ACRONYMS AND ABBREVIATIONS 

Afforestation and reforestation [under the KP] 
AR 
Biomass Available for Wood Supply 
BAWS  
Carbon 
C  
Methane 
CH4 
Centimetre 
cm  
Carbon dioxide 
CO2 
Compliance period 
CP  
Carbon stock change method  
CSC 
Carbon stock change factors 
CSCF   
Dbh 
Diameter at breast height 
DG CLIMA   Directorate General for Climate Action 
DOM   
EFI 
EU 
FAO 
FLrFL   
FMRL   
FMP    
FRL 
GHG    
GHGI   
HFM 
HWP   
IIASA  
IPCC    
IPCC GL  
JRC  
KP  
LULUCF  
MFL 
Mm3 
ND 
NFAP   
NFI  
NIR  
N2O 
PP 
RCP 
RP 
SOM 
SSP 
TBA 
t 
UNFCCC  
YR 

Dead organic matter 
European Forest Institute 
European Union 
Food and Agriculture Organization of the United Nations 
Forest Land Remaining Forest Land 
Forest Management Reference Level 
Forest management practice 
Forest Reference Level 
Greenhouse gas 
Greenhouse gas inventories 
Harvest Fraction of Management 
Harvested wood product(s) 
International Institute for Applied Systems Analysis 
Intergovernmental Panel on Climate Change 
IPCC Guidelines 
Joint Research Centre of the European Commission 
Kyoto Protocol 
Land Use, Land Use Change and Forestry 
Managed Forest Land 
Mega cubic metres (million cubic metres)  
Natural Disturbances 
National Forestry Accounting Plan 
National forest inventory 
National inventory report 
Nitrous oxide 
Projection period 
Representative Concentration Pathways 
Reference period 
Soil organic matter  
Shared Socioeconomic Pathways 
Total Biomass Available 
Tonne 
United Nations Framework Convention on Climate Change 
Year  

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ACKNOWLEDGEMENTS 

This  work  was  conducted  as  a  collaborative  effort  by  IIASA,  ICF,  Aether  and  a  group  of 
thematic experts. IIASA led the preparation of this technical guidance document, and ICF 
coordinated practical arrangements with meetings and a survey for the Member States.  

The authors want to thank DG Climate Action and the JRC for the excellent collaboration 
throughout  the  preparation  of  this  document.  Specifically,  we  would  like  to  show  our 
gratitude to Simon Kay, Valeria Forlin, Silvia Stefanelli, and Christoph Moosmüller at DG 
CLIMA,  and  Giacomo  Grassi,  Roberto  Pilli,  and  Matteo  Vizzarri  at  JRC,  for  their  active 
assistance in the course of preparing this document, and for the insightful comments on 
the text.  

Several  workshops  organized  by  the  EU  Commission,  JRC,  as  well  as  by  the  Member 
States at their own initiative, gave invaluable input and insight to the work. The authors 
would  like  to  express  their  most  sincere  thanks  to  the  organizers  of  these  workshops, 
and  to  all  representatives  of  the  Member  States  for  the  active  participation  and  fruitful 
discussions  in  the  workshops  during  spring  2018.  In  addition,  the  authors  thank  the 
national  experts  within  the  Member  States  for  taking  the  time  and  effort  to  answer  the 
online survey, as well as for sharing their expertise in form of examples for the text and 
the insightful comments on the first version of this document.  

The interpretations and any errors are however purely those of the authors.  

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SECTION 1 

1  INTRODUCTION 

1.1   What is this technical guidance document for? 

In  2018,  a  new  Regulation  of  the  European  Parliament  and  of  the  Council  came  into 
force,  setting  in  place  the  accounting  rules  on  the  inclusion  of  greenhouse  gas  (GHG) 
emissions  and  removals  from  land  use,  land  use  change  and  forestry  (LULUCF)  in  the 
2030 climate and energy framework. The aim of this document is to provide guidance for 
EU  Member  States  on  the  establishment  of  forest  reference  levels  (FRLs)  and  national 
forestry accounting plans (NFAPs) in the context of the Regulation (EU) 2018/841 of the 
European  Parliament and of the  Council  of 30  May 2018  on the inclusion of greenhouse 
gas  emissions  and  removals  from  land  use,  land  use  change  and  forestry  in  the  2030 
climate and energy framework, and amending Regulation (EU) No 525/2013 and Decision 
No  529/2013/EU  (Text  with  EEA  relevance)  (hereafter  referred  to  as  the  ‘LULUCF 
Regulation’). This technical guidance document seeks to provide the best possible advice 
on interpreting the LULUCF Regulation, and developing the FRL and NFAP in compliance 
with  the  LULUCF  Regulation.  This  is  not  a  binding  document.  It  is  at  the  discretion  of 
each Member State to use, or not to use, this document when establishing their national 
FRL and NFAP. In addition to the approaches described in this document, there may exist 
a number of other approaches to set the FRL in line with the LULUCF Regulation.  

In the LULUCF Regulation, GHG emissions and removals from managed forest land (MFL) 
in  each  EU  Member  State  are  accounted  against  a  FRL,  a  country-specific  projected 
baseline of expected forest emissions and removals for the Compliance Period (CP) 2021-
2030. The NFAPs, including a proposed FRL, shall be submitted to the Commission by 31 
December  2018  for  the  period  from  2021  to  2025,  and  by  30  June  2023  for  the  period 
from 2026 to 2030 (Article 8.3). As defined in the LULUCF Regulation, the FRL “shall be 
based on the continuation of sustainable forest management practice, as documented in 
the period from 2000 to 2009 with regard to dynamic age-related forest characteristics in 
national forests, using the best available data” (Article 8(5)). 

This document provides advice and examples on how to prepare the FRL and NFAP, and 
gives  guidance  on  how  to  ensure  comprehensive  and  transparent  reporting.  Given  that 
the  forest  characteristics,  forest  management  practices  (FMPs),  as  well  as  data  and 
models  availability,  vary  substantially  among  the  Member  States,  specific  attention  has 
been  given  to  including  a  variety  of  different  alternative  methods  to  accommodate 
different national circumstances. The goal is that this document helps the Member States 
to  identify  the  set  of  historical  management  activities  implemented  in  the  Reference 
Period  (RP),  and  to  project  the  forest  characteristics  in  the  CP  by  simulating  the 
continuation of historical FMPs over the CP.  

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This technical guidance document is structured as follows:  

  Section 1: Overview of the principles for GHG accounting in forestry, the current 

state of reporting, and an overview of the legislative text. 

  Section 2: Guidance on possible approaches to develop the FRLs, and advice on 
how to ensure transparent reporting. In this section, hands-on examples on 
different calculation steps and possible methods are elaborated as well. 

  Section 3: Detailed analysis of the criteria for the FRL set out in the Annex IV of 
the LULUCF Regulation, to clarify details and provide help to understand the 
requirements of the LULUCF Regulation. This section also illustrates an example 
table of contents for the submission of the NFAP, in accordance with the 
requirements of the Annex IV of the LULUCF Regulation. 

  Further details are given in the Annexes I-IV:  

-  Annex I: Provides a checklist for the proposed step-wise approach 
-  Annex II: Handbook for establishing FRLs. 
-  Annex III: Provides filled in examples of reporting tables as suggested in 

section 2. 

-  Annex IV: Overview of the EU Member States’ reporting of LULUCF under 

Kyoto Protocol. 

This  document  does  not  provide  an  exhaustive  collection  of  all  possible  approaches  to 
preparing the FRLs and NFAPs. Instead, the authors have sought to survey and analyse a 
wide array of possible approaches to develop and report FRLs and NFAPs. Based on this 
information,  this  document  has  been  structured  to  give  an  overview  of  possible 
approaches  for  the  Member  States  to  develop  their  FRLs  and  NFAPs.  In  addition,  this 
document  highlights  and  explains important  parts  of  the  LULUCF  Regulation  so  that  the 
Member States can be confident in that their reporting complies with the requirements as 
set out in the legislative act. 

1.2   Introduction to LULUCF in the context of climate change 

1.2.1   Background  

To limit the increase of the global average temperature, reducing anthropogenic (human-
induced)  net  emissions of  GHGs  is  essential.  In  the  Paris  Agreement  adopted  under  the 
United  Nations  Framework  Convention  on  Climate  Change  (UNFCCC),  the  parties, 
including the EU, agreed to commit themselves to a long-term goal of keeping the global 
temperature increase well below 2°C above pre-industrial levels; and to pursue efforts to 
keep it from exceeding 1.5°C above pre-industrial levels (United Nations 2015). The Paris 
Agreement  replaces  the  approach  taken  under  the  1997  Kyoto  Protocol  (KP),  which  will 
not be continued beyond 2020 (UNFCCC 2018).  

The main anthropogenic driver of the global temperature increase is the accumulation of 
GHGs  in  the  atmosphere.  Processes  that  release  GHGs  into  the  atmosphere,  such  as 
combustion of fuels, are  referred to as ‘sources’.  Processes that  remove  GHGs from the 
atmosphere are called ‘sinks’. The  most important sinks are absorption of carbon in the 
oceans and by biomass on land. The sum of the sources and sinks is referred to as ‘net 
emissions’. Critical anthropogenic GHGs include carbon dioxide (CO2), methane (CH4) and 
nitrous  oxide  (N2O).  In  the  LULUCF  Regulation,  all  GHGs  are  expressed  in  terms  of  CO2 
equivalent (the effect of an equivalent mass of CO2 in the atmosphere on solar radiative 
forcing). 

The  Paris  Agreement  also  calls  for  a  balance  between  anthropogenic  emissions  by 
sources  and  removals  by  sinks  of  GHGs  in  the  second  half  of  the  century.  This  asks  for 
net-zero  emissions,  where  the  amount  of  carbon  absorbed  by  the  sinks  equals  the 

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amount  of  carbon  released  by  the  sources.  Assuming  that  the  use  of  fossil  fuels  and 
other human-induced emissions, such as those from agriculture, will not end completely 
in the coming decades, it will be necessary to achieve and enhance uptake of carbon by 
sinks whenever possible. This is where the LULUCF sector comes into play. 

1.2.2   Specific characteristics of the LULUCF sector 

The LULUCF sector differs from other sectors (e.g. energy and transport) in that human 
actions on the LULUCF sector can at the same time contribute both to emitting GHGs and 
to  removing  them  from  the  atmosphere.  Trees  remove  and  store  carbon  from  the 
atmosphere  when  they  grow,  and  carbon  is  also  stored  in  wood-based  products. 
Conversely,  carbon  is  emitted  to  the  atmosphere  when  wood  decays  to  dead  organic 
matter,  when  it  is  burnt,  or  when  wood-based  products  decay  over  their  life-times.  In 
addition,  forest-related  activities  may  lead  to  emissions  of  other  GHGs:  for  example, 
increase  N2O  emissions. 
drainage  of  wetlands  and  nitrogen 
Consequently,  LULUCF  can  at  the  same  time  act  as  a  source  and  a  sink;  therefore, 
determining  the  final  net  balance  requires  a  careful  assessment  of  the  emissions  and 
removals of GHGs within the sector.  

fertilization  may 

In  the  context  of  the  Paris  Agreement  and  the  sharing  of  efforts  between  countries, 
distinguishing  between  anthropogenic  emissions  and  removals,  and  those  caused  by 
natural  processes  is  key.  Within  the  LULUCF  sector,  and  particularly  within  forestry, 
distinguishing the natural component in the carbon cycle from the component associated 
with  the  impact  of  human  activities  is  not  always  straightforward.  Natural  disturbances 
(NDs), such as wildfires, windthrow, or insect outbreaks, may lead to large emissions or 
reductions  in  the  forest  sinks,  and  their  impact  may  be  reduced  or  amplified  through 
forest management.  

Furthermore, the impact of activities or disturbances on forest land does not occur fully 
within  the  same  year  as  the  occurrence  takes  place.  Forest  harvesting  reduces  the 
carbon sinks temporarily, but may over the long term lead to improved growth of forests 
and consequently, larger sinks. Moreover, because of the long time-span of forest cycles, 
different  management  decisions  over  the  course  of  the  forest  rotation  time  may  affect 
the removals and emissions for decades – or even centuries – after the actual operation, 
such  as  planting  or  thinning,  took  place.  Similarly,  emissions  from  the  decay  of  organic 
matter  are  seen  still  years  after  the  disturbance  creating  the  dead  organic  matter.  This 
extension of impact over time is referred to as ‘legacy effect’. In other words, the future 
emissions  and  removals  in  forests  are  impacted  by  the  long-term  legacy  effects 
associated with age-class dynamics, determined by past activities and NDs. Unlike other 
sectors, in LULUCF and specifically in forestry it is typical that these legacy effects occur 
repeatedly over time in a cyclical fashion. 

1.2.3  Overview of the LULUCF accounting principles 

The GHG emission reduction target of the EU of reducing the GHG emissions by at least 
40%  by  2030  is  set  economy-wide,  i.e.  across  sectors.  To  ensure  reliable  and  efficient 
policies  and  comparison  between  different  sectors,  the  reporting  and  accounting  of  the 
emissions and removals for each sector need to be reliable, robust, and transparent. 

In GHG context, ‘reporting’ refers to the emission and removal estimates prepared by the 
countries.  In  the  context  of  mitigation  targets,  ‘accounting’  refers  to  the  comparison  of 
emissions and removals with the base value, or the counterfactual value. On the LULUCF 
sector,  the  accounting  is  done  through  policy-agreed  accounting  rules,  which  filter  the 
reported estimates with the aim to quantify better the results of mitigation actions (e.g. 
Cowie  et  al.  2007,  Schlamadinger  et  al.  2007,  Grassi  et  al.  2018).  The  LULUCF 
accounting  then  produces  ‘debits’  or  ‘credits’  (i.e.  extra  emissions  or  extra  emission 
reductions,  respectively)  that  count  toward  the  target.  Through  the  debit  and  credit 

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system,  the  aim  is  to  provide  incentives  for  beneficial  actions  and  policies,  and 
disincentives for detrimental actions.  

There  are  different  approaches  for  establishing  the  counterfactual  value  for  the 
accounting of mitigation effects by carbon sinks and sources: 

 

 

In gross-net accounting, the counterfactual value is set at zero. This means 
that the net total (‘net’) of all (‘gross’) emissions and removals occurred in the 
compliance period are accounted for. This approach is used in the LULUCF 
Regulation within Article 6, where the emissions and removals resulting from 
afforested land and deforested land shall be accounted for “as being the total 
emissions and total removals for each of the years in the periods from 2021 to 
2025 and from 2026 to 2030”.  

In net-net accounting, the counterfactual value is set as the emissions of the 
base year or level (net), and is compared with the emissions of the compliance 
period (net). This is the accounting principle in the LULUCF Regulation for 
managed cropland, managed grassland and managed wetland (Article 7), where 
the emissions and removals from these land use classes shall be compared to the 
base period from 2005 to 2009. 

Another example of net-net accounting is when the actual emissions and 
removals in a given year are compared against a projected reference level. This 
approach is used in the LULUCF Regulation for the accounting of MFL (Article 8). 

The  use  of  different  accounting  approaches  reflects  how  the  activities  implemented  in 
different land uses affect the development of carbon sinks and sources within the LULUCF 
sector.  The  gross-net  accounting  used  for  land  use  change  emphasizes  the  more 
profound  change  of  the  characteristics  of  that  land  for  the  future,  which  can  also  be 
linked  to  a  relatively  specific  point  in  time.  Gross-net  accounting  aims  to  give  full 
incentive to reduce emissions or enhance the sinks, while assuming that all the emissions 
and  removals  are  a  direct  consequence  of  human  actions.  In  net-net  accounting,  the 
choice of the RP is emphasized. For land uses where the annual emissions and removals 
change  relatively  little  from  year  to  year  (such  as  cropland  or  grassland,  where  the 
annual biomass production is relatively similar from year to year), the use of a historical 
base  year  is  justified  since  it  allows  to  account  for  efforts  made  for  enhancing  net 
removals of GHG emissions over time.  

For  MFL,  accounting  against  a  reference  level  provides  a  means  of  considering  the  long 
time-horizon  and  legacy  effects  of  past  management  practices  associated  with  forestry. 
This approach was applied under KP reporting for the second commitment period, and it 
is  now  adopted  in  the LULUCF  Regulation.  Note  that  the  requirements  and  scope  of  the 
FRL in the LULUCF Regulation differ partly from the KP; see section 1.4 for more details. 
The FRL for MFL as regulated by the LULUCF Regulation ties the FRL to “continuation of 
sustainable  forest  management  practice,  as  documented  in  the  period  from  2000  to 
2009”  (Article  8(5)).  This  aims  to  provide  a  baseline  to  show  how  the  forest  would 
develop  if  no  changes  to  policies  or  practices  were  put  in  place  (i.e.  the  counterfactual 
value), compared to the RP. The impact of this approach compared to net-net accounting 
against  a  base  year  is  especially  prominent  in  a  situation  where  the  age  structure  of  a 
forest is skewed: if the forests had a relatively large share of trees in a certain age class, 
the total harvest would fluctuate over time purely because there are different amounts of 
trees reaching the harvest age during different periods in time. The use of FRL attempts 
to  make  a  complete  account  of  the  impacts  of  changes  in FMPs,  relative  to  the  practice 
under  a  historical  RP,  and  to  eliminate  the  differences  that  result  purely  from  the  age-
related dynamics. 

In the land use sector it is generally simpler and more accurate to measure the change in 
‘carbon  stock’,  instead  of  the  fluxes  of  emissions  and  removals.  Carbon  stock  refers  to 
“the  mass  of  carbon  stored  in  a  carbon  pool”,  measured  at  a  given  time.  For  example, 
the  net  emissions  caused  by  land  use  change  can  be  estimated  through  comparing  the 

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stock  of  carbon  per  area  unit  before  and  after  the  land  was  converted  (the  so  called 
‘stock-difference’  method).  It  is  important  to  note  that  the  mere  presence  of  carbon 
stocks  will  not  mitigate  climate  change,  if  emissions  from  other  sectors  continue 
increasing.  Instead,  the  net  carbon  sinks  need  to  be  maintained  and  ideally  enhanced. 
This means that the total amount of atmospheric carbon needs to be reduced, and more 
carbon  sequestered  in  lands  and  oceans.  It  follows  that  in  order  for  the  land  use  to 
contribute  positively  to  combating  global  temperature  increase,  it  is  necessary  that  the 
future land-based carbon stock will be larger than the current carbon stock, and that the 
net carbon sinks are enhanced.  

The  GHG  emissions  and  removals  are  estimated  from  different  ‘carbon  pools’.  A  carbon 
pool means “the whole or part of a biochemical feature or system within the territory of a 
Member  State  and  within  which  carbon,  any  precursor  to  a  greenhouse  gas  containing 
carbon or any greenhouse gas containing carbon is stored”. In the LULUCF sector, and in 
forest  land,  the  carbon  pools  considered  include  living  biomass  (above-  and  below 
ground),  dead  organic  matter  (litter  and  dead  wood,  DOM),  soil  organic  matter  (SOM), 
and harvested wood products (HWP).  

In the context of the LULUCF Regulation, the following six pools are considered within the 
Member States (Annex I.B): 

  Above-ground biomass; 

  Below-ground biomass 2; 

  Litter2; 

  Dead wood; 

  Soil organic carbon2; 

  Harvested wood products. 

In  line  with  the  Paris  Agreement,  accounting  of  GHGs  within  the  LULUCF  Regulation 
refers  to  anthropogenic  emissions  by  sources  and  removals  by  sinks.  This  means  that 
NDs may be excluded from the accounting. However, the Member States are expected to 
adopt  active  prevention  measures,  to  reduce  the  risk  associated  with  NDs,  and  to 
strengthen the  resilience of the LULUCF sector (recital 8 in the preamble of the LULUCF 
Regulation.  

On  the  other  hand,  since  HWP  is  an  anthropogenic  pool,  it  is  included  in  the  LULUCF 
Regulation.  This  is  in  line  with  UNFCCC  reporting:  HWP  is  reported  under  the  KP  as  a 
separate  carbon  pool  in  afforested  land  and  in  land  under  forest  management, 
respectively. The accounting of HWP under LULUCF recognizes the fact that when forest 
is harvested and the wood used for material products, the carbon stored in the biomass 
is  not  released  into  the  atmosphere  immediately.  Instead,  the  carbon  continues  to  be 
stored  in  the  products  that  have  different  lifetimes  before  eventually  decaying  or  being 
burnt  for  energy  production.  In  the  LULUCF  Regulation,  the  HWP  that  are  specifically 
accounted  for  are  paper,  wood  panels,  and  sawn  wood  (Article  9).  For  each  of  these 
products,  specific  half-life  values  are  defined,  reflecting  the  number  of  years  it  takes  to 
lose  one-half  of  the  material  currently  in  the  pool,  and  eventually  be  released  into  the 
atmosphere  (IPCC  2006).  This  accounting  attempts  to  promote  enhanced  use  of  wood 
products  with  long  life-cycles,  compared  to  short-lived  products  or  the  combustion  of 
virgin wood directly to energy. The accounting is based on a ‘production approach’, which 
means  that  the  HWP  is  accounted  by  the  producing  country,  while  “imported  [HWP], 
irrespective of their origin, shall not be accounted by the importing Member State”. These 
rules  prevent  double-counting  of  the  internationally  traded  HWP.  In  addition  to  the 

2 These pools may be excluded in the accounts under the LULUCF Regulation, provided that the carbon pool is not a source (Article 5(4)). 

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modelling  of  the  decay  of  HWP  over  time,  the  LULUCF  Regulation  requires  also  a 
comparison  with  instantaneous  oxidation  (which  assumes  that  the  carbon  stored  in  the 
wood biomass is not stored but instead released into atmosphere directly after harvest). 
This  comparison  serves  to  evaluate  the  extent  and  importance  of  the  HWP  pool  in 
relation with the whole LULUCF pool. 

1.3   Previous reporting and accounting under the Kyoto Protocol 

1.3.1  Overview 

The  1997  Kyoto  Protocol  (KP)  established  a  set  of  accounting  and  reporting  rules  for 
assessing the emissions and removals from different sectors (UNFCCC  2018). It will not 
be continued beyond 2020. The LULUCF Regulation is part of the EU efforts towards the 
climate  change  mitigation  targets  of  the  Paris  Agreement,  which  will  replace  KP  after 
2020. Here, we give an overview of the KP system and previous experiences with it, and 
highlight differences between the reporting under KP and the LULUCF Regulation. 

The  KP  accounting  system  was  designed  with  the  aim  accurately  reflecting  the 
atmospheric impacts of additional human actions during an established time period. The 
impacts  of  the  additional  actions  have  generally  been  addressed  through  the  so-called 
net-net  accounting  approach  that  uses  a  reference year  or  level  as  a  comparison  point. 
This method excludes all those emissions and removals that would occur in the absence 
of the additional actions from being credited/debited (i.e. the counterfactual value). 

To achieve such a goal, the accounting rules under the KP deal with: 

  Legacy effect of pre-KP activities; 

 

Impact of NDs; 

  Symmetry of processes, as removals and subsequent emissions, and vice versa, 

from the same C pool, or as tree cover gains and tree cover losses, and vice versa 
in the same land; 

  Non-permanence of CO2 emissions and removals. That is, the CO2 removals and 
subsequent CO2 emissions, and vice versa, are accounted when they actually 
occur. 

Further,  in  case  of  inaccuracy  due  to  lack  of  adequate  data,  KP  allows  for  conservative 
accounting; that is, it attempts to zero out the likelihood of overestimating net benefits. 

1.3.2  Accounting of forest emissions and removals under the KP  

The general assumption in the KP approach is that the reference level corresponds to the 
GHG  emissions and removals of a historical base year, i.e., generally 1990. This means 
that  the  countries  are  considered  accountable  of  all  emissions  and  removals  after  this 
date. Consequently, any deviation with a positive-sign compared to the level of the base 
year (i.e. more emissions/less removals) will be debited, and any negative-sign deviation 
(i.e.  less  emissions/more  removals)  will  be  credited.  However,  in  the  woody  biomass 
pool, previous actions or historical disturbances cause significant variation to the rate of 
carbon  stock  change  through  time,  even  in  the  absence  of  subsequent  actions  or 
disturbances.  This  legacy  effect  means  that  a  historical  level  of  carbon  stock  change  is 
not  an  appropriate  counterfactual  level  for  the  accounting  of  emissions  and  removals 
related to the use of woody biomass. 

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For  reasons  such  as  these,  all  activities  where  the  woody  biomass  carbon  stock  is 
negligible, or otherwise insignificant, use the base year GHG emissions and removals as 
their reference level 3, while: 

  Afforestation sets its reference level at 0 (zero), so that all CO2 removals are 

counted as an additional contribution compared to a scenario without such forest 
(i.e. gross-net accounting). Further, to ensure that subsequent CO2 emissions (e.g. 
associated with harvesting) are also accounted when they actually occur, land 
under afforestation cannot transit to an activity with a different reference level. 
Accounting all CO2 removals and all subsequent CO2 emissions against the 0-
reference level allows to account for the actual change in the long-term average C-
stock, which is also in line with what the impacts of the afforestation activity are on 
the atmosphere. 

  For symmetry, deforestation applies the same reference level and accounting rules 
applied to afforestation; although, deforested land cannot transit to afforestation. 

  Forest management applies a projected reference level (forest management 

reference level, FMRL) in order to zero out the contribution of CO2 removals (and 
emissions) resulting from pre-KP actions or disturbances. Further, in order to 
exclude the impact of the inter-annual variability of NDs 4, the contribution of 
disturbances to the reference level is set as the average that occurred during the 
historical period 1990-2009 (or later). 

1.3.3  Lessons learned under the KP, and expectations for the new 

FRLs  

The concept of a reference level was used within the second commitment period (2013-
2020) of the Kyoto Protocol, during which the Annex l parties were required to establish 
a reference level referred to as FMRL. A total of 38 parties submitted their FMRLs under 
the  KP,  including  all  EU  countries.  There  was  a  wide  variety  of  approaches  used  to 
produce the FMRL, ranging from using the emission estimate from base year 1990, or a 
value of zero, to using model-based projections 5. Most countries applied projected FMRLs 
(including  all  EU  countries),  typically  using  the  data  from  NFI  combined  with  scenario 
analysis or demand projections with partial equilibrium models to estimate the future net 
emissions  from  forest  management.  Several  EU  countries  projected  FMRL  following  a 
common  approach  coordinated  by  the  JRC  and  modelled  by  teams  from  IIASA  and  EFI 
(based on harvest demand projections). An overview of the LULUCF reporting by the EU 
Member  States  under  KP  commitment  period  2  appears  in  Annex  IV.  A  more  thorough 
analysis on the lessons learned under the KP may be found in Grassi et al. (2018). 

For the development of this technical guidance document, an electronic survey was sent 
to  all  Member  States  in  February  2018.  The  aim  of  the  survey  was  to  get  a  better 
understanding  of  the  experiences  from  the  FMRLs  and  of  the  modelling  capacities  and 
data availabilities that the Member States have available now for the FRLs. The response 
rate  was  excellent,  with  27  Member  States  providing  at least  partial  answers  within  the 
given  time  of  two  weeks.  The  responses  provided  an  overview  of  lessons  learned  under 
the  past  FMRL  process  and  expectations  for  the  FRL  development,  as  well  as  more 
detailed questions and comments regarding the technical or conceptual understanding of 
the  LULUCF  Regulation.  These  questions  and  comments  have  been  considered  and 
addressed throughout this document. 

The  survey  results  show  clearly  that,  at  the  time  of  the  development  of  the  FMRLs, 
Member  States  had  varying  institutional  capacities  and  varying  resources  available  to 

3 i.e. cropland management, grazing land management, revegetation, wetlands drainage and rewetting. 
4 Identified as outliers in the normal distribution of emissions from disturbances 
5 See Chapter 2, Box 2.7.3 of the 2013 Revised Supplementary Methods and Good Practice Guidance Arising from the Kyoto Protocol (IPCC 2014) 
for more detail.  

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develop  their  own  national  projections.  Since  then,  the  capacity  within  the  Member 
States  has  improved  and  a  majority  of  Member  States  feel  that  they  are  able  to  apply 
national approaches to the development of their FRL.  

Past experience with the FMRL was seen to have brought insight into what the process of 
setting  a  reference  level  entails,  including  the  projections,  technical  corrections,  as  well 
as  the  review  process.  The  FMRL  development  under  the  KP  also  gave  better 
understanding  of  the  availability  and  characteristics  of  models,  data,  and  personnel 
needed  nationally  to  deliver  the  reference  levels.  A  frequently  occurring  comment 
concerned the difficulty of estimating future policies appropriately in the FMRL under the 
KP, as these estimations were experienced to be difficult to define and were perceived to 
include a high level of uncertainty. As the expectations of future policies will not be part 
of the LULUCF Regulation, this specific problem will be avoided for the FRL.  

Past challenges that are expected to persist in the development of the FRLs include lack 
of  data  and  inconsistencies  between  different  data  sets  and  data  sources.  Estimation  of 
NDs, accounting for HWP, and lack of FMP documentation were also frequently mentioned 
issues where the Member States expected to face challenges for the FRL estimation. The 
survey  answers  also  brought  clearly  forward  the  different  natural  conditions  in  different 
countries:  the  forests  within  the  EU  include  a  wide  variety  of  tree  species  and  forest 
structures  that  are  managed  in  a  variety  of  ways  for  different  purposes.  Within  the  EU, 
forests  range  from  subtropical  Mediterranean  forests  to  boreal  tundra,  and  the  forestry 
focus  varies,  from  highly  industrial  use  of  timber  to  household  firewood  collection. 
is  multifunctional,  considering 
Furthermore,  often 
simultaneously  several  objectives  such  as  water  protection,  recreation,  biodiversity 
protection,  and  timber  production.  In  this  setting,  it  is  obvious  that  a  single  system  to 
categorize and model the forests and their importance in carbon accounting may not be 
meaningful. Instead, there should be flexibility to accommodate the national differences 
in  the  modelling  of  the  FRL  and  LULUCF  sector,  while  ensuring  that  the  reporting  is 
transparent, complete, and based on as consistent, comparable and accurate information 
as possible.  

the  management  of 

forests 

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1.4   LULUCF Regulation  

1.4.1  Background, structure and important dates  

The  LULUCF  Regulation  adopted  in  2018  was  published  in  all  EU  Member  States’ 
languages  in  the  Official  Journal  of  the  European  Union.  It  is  available  online  at: 
http://europa.eu/!cQ33UG.  Here,  we  give  an  overview  of  its  structure  and  the  most 
important aspects with respect to developing the FRLs and NFAPs.  

Figure 2 sets the LULUCF Regulation into context with respect to  other agreements and 
regulations,  both  internationally  and  within  the  EU.  The  linkages  between  different 
processes  and  the  background  for  the  LULUCF  Regulation  are  also  described  in  the 
preamble of the LULUCF Regulation.  

May 2013: Decision No 529/2013/EU and Regulation (EU) No 525/2013 on initial accounting rules 
on GHG emissions and removals, applying from 2013 onwards  

Oct 2014: Council invited the Commission to establish policy target on how to include LULUCF in 
the 2030 greenhouse gas mitigation framework 

Mar 2016: Council reaffirms the target to reduce GHG emissions by 40% by 2030  
July 2016: Commission proposes framework 2021-30, including LULUCF 

Nov 2016: Paris Agreement to limit 
the global temperature increase well 
below 2°C and pursue efforts to keep 
it to 1.5°C entered into force 

Sep 2015: 2030 Agenda for 
sustainable development (including 
to ensure that management of 
forests is sustainable), reaffirmed by 
the Council in Jun 2017 

May 2018: Adoption of the LULUCF Regulation, on the inclusion of GHG emissions and removals 
from LULUCF in the climate and energy framework, amending the 2013 Decision and Regulation  

Figure 2. Overview of the context of the LULUCF Regulation and a selection of agreements that are 
closely related to it.  

The  structure  of  the  LULUCF  Regulation  follows  the  practice  and  presentation  of  a 
publication in the Official Journal of the EU, consisting of a preamble, enacting terms, and 
annexes. Box 1 gives an overview of the contents of each part in the LULUCF Regulation. 
Figure  3  outlines  the  important  dates  related  to  the  submissions  and  possible  technical 
corrections  as  stated  in  the  LULUCF  Regulation.  The  LULUCF  Regulation  requires  the 
Member  States  to  submit  to  the  Commission  their  NFAPs,  including  a  proposed  FRL,  by 
31 December 2018 for the period from 2021 to 2025 and by 30 June 2023 for the period 
from 2026 to 2030. 

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Box 1. Structure of the LULUCF Regulation 

The  LULUCF  Regulation  has  three  parts:  the  preamble,  the  enacting  terms  of  the  Regulation,  and 
annexes. The following gives an overview of the contents of the three parts. 

1.  Preamble 

Title and reference to the adopting institution/body.  

 
  Citations, indicating the legal basis and preparatory acts for the Regulation. 

-  These parts start with ‘Having regard…’, ‘After transmission…’ or ‘Acting in 

accordance…’ 

  Recitals, setting out the reasons for the contents of articles of the Regulation  

-  The recitals are introduced by the word ‘Whereas:’. In the LULUCF Regulation, 
there are 36 numbered recitals that explain the context, background, and main 
concepts for the Regulation. 

2.  Enacting terms  

 

This part constitutes the normative part of the LULUCF Regulation. It is divided into 20 
Articles, which are further subdivided into paragraphs. The LULUCF Regulation 
constitutes of the following: 

  Articles 1-3 describe the subject matter, scope, and definitions used in the Regulation. 
  Article 4 states the commitments for the Members States. 
  Articles 5-9 state the accounting rules for the different land uses as well as for HWP. 
  Article 10 describes the accounting rules for natural disturbances. 
  Articles 11-13 describe the flexibilities available for the Member States. 
  Article 14 details the requirements for a compliance check. 
  Articles 15 and 16 describe the registry and exercise of delegation by the European 

Commission. 

  Article 17 gives an overview of the review process of the submissions. 
  Articles 18 and 19 detail the amendments to Regulation (EU) No 525/2013 and Decision 

No 529/2013/EU that this new LULUCF Regulation imposes. 

 

The final article 20 specifies the entry date and binding nature of the Regulation, as 
directly applicable in all Member States.  

3.  Annexes 

 

The LULUCF Regulation is accompanied by seven annexes, specifying the GHGs and carbon 
pools addressed by the Regulation (Annex I), as well as Member State-specific thresholds 
of forest parameters to be considered for Forest Land (Annex II), base years (Annex III) 
and compensation under Managed Forest Land (MFL) flexibility (Annex VII). The annexes 
also give more detailed instructions on the contents and what to include in the national 
forestry accounting plan (Annex IV), HWP accounting (Annex V), and natural disturbances 
(Annex VI). 

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First compliance period 2021-2025 

31 Dec 2018 

During 2019

31 Dec 2019

31 Oct 2020

•Submission of 

the NFAP, 
including 
proposed FRL

•Technical 

assessment of 
the NFAPs by 
the 
Commission 
and experts 
appointed by 
Member 
States

•Revisions and 

technical 
corrections by 
the Member 
States (where 
necessary)

•Adoption of 

the delegated 
acts

Second compliance period 2026-2030 

30 Jun 2023

During 2023-
2024

•Submission of 

the NFAP, 
including 
proposed FRL

•Technical 

assessment of 
the NFAPs by 
the 
Commission 
and experts 
appointed by 
Member 
States

30 Jun 2024

30 Apr 2025

•Revisions and 

technical 
corrections by 
the Member 
States (where 
necessary)

•Adoption of 

the delegated 
acts

Figure 3. Timeline for the FRLs as defined in the LULUCF Regulation. 

24 

 
 
 
 
 
 
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1.4.2  Key statements in the LULUCF Regulation concerning FRLs 

According to the LULUCF Regulation, there are several requirements for the development 
of the FRL. In particular, related with the methodology, the FRL shall: 

According to Article 8(5) of the LULUCF Regulation: 

 

“be  based  on  the  continuation  of  sustainable  forest  management  practice,  as 
documented in the period from 2000 to 2009 with regard to dynamic age-related 
forest characteristics in national forests” 

  use the “best available data” 

 

 

“take account of the future impact of dynamic age-related forest characteristics” 

“not  unduly  constrain  forest  management  intensity  as  a  core  element  of 
sustainable  forest  management  practice,  with  the  aim  of  maintaining  or 
strengthening long-term carbon sinks” 

According to Annex IV of the LULUCF Regulation: 

 

 

 

 

“be  consistent  with  the  goal  of  achieving  a  balance  between  anthropogenic 
emissions  by  sources  and  removals  by  sinks  of  greenhouse  gases  in  the  second 
half of this  century, including enhancing the potential removals by  ageing forest 
stocks that may otherwise show progressively declining sinks” 

“ensure that the mere presence of carbon stocks is excluded from accounting” 

“ensure a robust and credible accounting system that ensures that emissions and 
removals resulting from biomass use are properly accounted for” 

“include the carbon pool of harvested wood products” 

  assume  “a  constant  ratio  between  solid  and  energy  use  of  forest  biomass  as 

documented in the period from 2000 to 2009” 

 

 

 

 

“be  consistent  with  the  national  projections  of  anthropogenic  greenhouse  gas 
emissions  by  sources  and  removals  by  sinks  reported  under  Regulation  (EU)  No 
525/2013” 

“be consistent with greenhouse gas inventories and relevant historical data” 

“be  based  on  transparent,  complete,  consistent,  comparable  and  accurate 
information” 

“be  able  to  reproduce  historical  data  from  the  National  Greenhouse  Gas 
Inventory” 

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1.4.3  Description of key differences between FRL and FMRL 

Both  of  the  projected  reference  levels,  the  FMRL  under  the  KP  and  the  FRL  under  the 
LULUCF  Regulation,  are  set  to  provide  a  baseline  against  which  the  future  net  forest 
emission can be compared for accounting proposes. The key difference between the two 
methods is that the FMRL included future effects of policies adopted and implemented by 
2009  in  the  business-as-usual  scenario 6,  however  the  FRL,  as  detailed  in  the  LULUCF 
Regulation,  does  not  include  any  reference  to  a  future  scenario.  It  thereby, 
excludes  assumptions  of  forest  management  development  or  expectations  on 
future  demand  for  wood  or  land  use.  Instead,  the  FRL  “shall  be  based  on  the 
continuation  of  sustainable  forest  management  practice,  as  documented  in  the  period 
from  2000  to  2009  with  regard  to  dynamic  age-related  forest  characteristics  in  national 
forests, using the best  available data.” (Article 8(5)). This aims to make the accounting 
of  forest-sector  mitigation  more  transparent,  as  the  FRL  is  based  on  documented 
historical  information  instead  of  assumptions  for  the  future.  This  approach  is  also  more 
similar to the accounting of GHGs on other sectors (Grassi et al. 2018). 

The  FMRL  under  the  KP  was  requested  in  the  Decision  2/CMP.6  of  the  Cancun 
Agreements on Land use, land-use change and forestry (KP 2010), and further refined in 
the  Decision  2/CMP.7  by  the  Conference  of  the  Parties  in  Durban  (KP  2011).  In  the 
footnote 1 to paragraph 4 of the Decision 1/CMP.6 (KP 2010), the FMRL was stated to be 
set transparently, taking into account the following:  

“(a)  removals  or  emissions  from  forest  management  as  shown  in  greenhouse  gas 
inventories and relevant historical data;  

(b) age-class structure;  

(c) forest management activities already undertaken;  

(d) projected forest management activities under a ‘business as usual’ scenario;  

(e)  continuity  with  the  treatment  of  forest  management  in  the  first  commitment 
period;  

(f)  the  need  to  exclude  removals  from  accounting  in  accordance  with  decision 
16/CMP.1, paragraph 1.  

Points  (c),  (d)  and  (e)  above  were  applied  where  relevant.  The  forest  management 
reference  levels  also  took  into  account  the  need  for  consistency  with  the  inclusion  of 
carbon  pools.  Reference  levels  including  and  excluding  ‘force  majeure’  should  be 
provided.” 

The LULUCF Regulation does not provide a similar concise list for aspects to be taken into 
account in the FRL.  In order to compare the list provided under the  KP to requirements 
set  out  in  the  LULUCF  Regulation,  we  compare  the  two  processes  in  Table  1.  Note  that 
here  we  give  only  an  overview  of  the  aspects  related  to  forest  management;  aspects 
such  as  the  considerations  to  area  under  forest  management,  calculation  of  different 
carbon  pools,  or  consideration  of  NDs,  are  covered  in  detail  under  section  2  in  this 
document. 

6 Appendix II of the Decision 2/CMP.6, see KP 2010.  

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Table 1. Comparison between the scope of the FMRL under the KP (KP 2010, IPCC 2014), and FRL 
as described in the LULUCF Regulation in terms of forest management. The points (e) and (f) in the 
KP  referred  to  internal  consistency  within  the  KP,  and  are  hence  not  included  in  this  comparison 
with the LULUCF Regulation. 

FMRL under the Kyoto Protocol: 

FRL as described in the LULUCF Regulation 

The scope of the FMRL is to account for 
changes in emissions and removals 
associated with Forest Management 
(FM) only, i.e. excluding impact of 
legacy and of natural disturbances 

“land subject to AR after 1990 
transitions to Forest Land after 20 
years under UNFCCC but remains in AR 
under the KP” 

“removals or emissions from forest 
management as shown in greenhouse 
gas inventories and relevant historical 
data” 

“age-class structure” 

“forest management activities already 
undertaken” 

The scope of the FRL is to account for “emissions and 
removals resulting from managed forest land” (Article 
8(1)) 

“Where land use is converted, Member States shall, 20 
years after the date of that conversion, change the 
categorization of forest land, cropland, grassland, 
wetland, settlements and other land from such land 
converted to another type of land to such land remaining 
the same type of land.” (Article 5(3)) 

“Member States shall demonstrate consistency between 
the methods and data used to determine the proposed 
forest reference level in the national forestry accounting 
plan and those used in the reporting for managed forest 
land.” (Article 8(5)) 

“the reference level shall be consistent with greenhouse 
gas inventories and relevant historical data and shall be 
based on transparent, complete, consistent, comparable 
and accurate information. In particular, the model used 
to construct the reference level shall be able to reproduce 
historical data from the National Greenhouse Gas 
Inventory” (Annex IV.A(h)) 

“The forest reference level shall be based on the 
continuation of sustainable forest management practice, 
as documented in the period from 2000 to 2009 with 
regard to dynamic age-related forest characteristics in 
national forests, using the best available data.” (Article 
8(5)) 

“Forest reference levels […] shall take account of the 
future impact of dynamic age-related forest 
characteristics in order not to unduly constrain forest 
management intensity as a core element of sustainable 
forest management practice, with the aim of maintaining 
or strengthening long-term carbon sinks” (Article 8(5)) 

“The forest reference level shall be based on the 
continuation of sustainable forest management practice, 
as documented in the period from 2000 to 2009 with 
regard to dynamic age-related forest characteristics in 
national forests, using the best available data.” (Article 
8(5)) 

“projected forest management 
activities under ‘business as usual’ 
scenario” 

NOTE: no mention of a ‘scenario’ projection in the 
LULUCF Regulation. Instead, the FRL is to be projected 
assuming continuation of the FMPs as in the RP. 

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1.4.4  General concepts about the FRL projections  

This  section  aims  to  clarify  some  general  aspects  about  the  FRL  projections  in  line  with 
the LULUCF Regulation. 

The use of the FRL should allow the impact of changes in FMP relative to a historical RP 
to be fully reflected in the accounts. This allows the accounting of forest mitigation to be 
comparable  to  other  GHG  sectors,  because  all  sectors  implicitly  reflect  the  impact  of 
policy or management changes relative to a base year or period. Therefore, the use of a 
FRL allows comparability of forest credits with other sectors (Grassi et al. 2018).  

The  projection  behind  the  FRL  aims  to  represent  what  would  occur  on  the  MFL  if  the 
historical  management  regime  were  to  be  continued.  Therefore,  the  assumed  future 
impact of policies and markets are not to be included in the FRL estimation, since in all 
other  GHG  sectors  such  impacts  are  accounted  for  as  credits 7  or  debits 8.  The  same 
management practices of the RP, without any rate of variation, are applied during the CP. 
This  ensures  that  the  FRL  is  a  best  possible  estimate  of  the  counterfactual  value  of 
emissions  and  removals  that  would  have  occurred  in  the  absence  of  the  impacts  of 
policies  and  measures  already  in  place,  and  of  any  variation  of  such  policies  and 
measures or of any new policy and measure put in place after the RP. 

However, the FRL has to include the expected natural dynamics in forest carbon stocks in 
the  country,  through  the  combination  of  the  expected  changes  in  forest  characteristics 
(e.g.  biomass  available  for  wood  supply,  net  increment,  etc.)  and  the  “continuation  of 
forest management practice” (Article 8(5)) in the RP. 

Article  5(4)  requires  the  Member  States  to  include  in  their  accounts  any  change  in  the 
carbon  stock  of  above-ground  biomass,  below-ground  biomass,  litter,  dead  wood,  soil 
organic carbon, and  HWP.  However,  “Member States may choose not to include in their 
accounts changes in carbon stocks of carbon pools provided that the carbon pool is not a 
source”.  This  is  however  not  an  option  in  the  land  accounting  category  MFL  for  above-
ground biomass, dead wood and HWP; for these carbon pools, all changes in the carbon 
stocks need to be included in the accounts.  

Even  though,  according  to  Article  8(5),  the  FRL  shall  not  “unduly  constrain  forest 
management  intensity”,  the  FRL  estimation  cannot  contradict  the  first  paragraph  of 
Article 8(5) “The forest reference level shall be based on the continuation of sustainable 
forest management practice, as documented in the period from 2000 to 2009”. This part 
of  the  LULUCF  Regulation  can  be  understood  reflecting  the  need  to  model  the 
development  of  age-related  characteristics  of  the  forests  over  time,  instead  of  fixing 
those  on  the  level  of  the  RP.  Section  2.3  of  this  document  provides  more  detailed 
guidance on how to take this into account in the estimations of the FRL. 

It is important to understand that the FRL is not a constraint on future management, and 
does  not  place  a  limit  or  threshold  that  should  be  met  or  improved  upon  (see  e.g. 
Matthews and Henshall 2018). Instead, the Member States are free to pursue and evolve 
sustainable management practices as they see fit. The purpose of the FRL is to allow the 
consequences to be accounted for in a transparent and reliable manner. 

7 For instance, impacts of a policy in the energy sector leading to credits are those associated to a set of fiscal incentives for the production of 
renewable energy that determine a growth of the renewable energy market, which triggers a decrease in the cost of renewable energy production 
and consequently a progressive increase in the installation of renewable energy plants and in the associated carbon emissions. 
8 For instance, impacts of a policy in the energy sector leading to debits are those associated with the removal of subsidies to fossil fuels that has 
the largest impact in the year in which is applied and a degressive impact in the following years according to the decreasing use of fossil fuels. 

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SECTION 2 

2  POSSIBLE WAYS TO IMPLEMENT THE FRL REQUIREMENTS IN 

LINE WITH THE LULUCF REGULATION REQUIREMENTS 

This section provides guidance for Member States on how to estimate the FRLs requested 
in  Article  8  of  the  LULUCF  Regulation.  A  step-by-step  approach  for  projecting  emissions 
by  sources  and  removals  by  sinks  from  MFL  is  proposed,  and  various  methods  to 
implement each sequential step are described in detail. An overview of key concepts for 
the  development  of  the  FRL  is  recalled  below  in  Box  2.  In  addition,  an  overview  of  the 
suggested  step-wise  approach  is  presented  below  in  Box  3.  The  steps  proposed  in  this 
section  have  been  organized  in  a  structure  that  can  be  used  to  properly  include  the 
reporting of the FRL in the NFAP. 

The  aim  of  this  section  is  to  provide  general  guidance  on  the  development  of  the  FRL 
estimations for the CP, including descriptions of some of the decisions and choices that a 
Member State will need to consider when establishing the FRL. Also, this section provides 
practical suggestions on how to establish the FRL and provides guidance on how to report 
the FRL. The section also includes some approaches and examples of good practices, as 
well as several warnings about ‘not good practice’ examples.  

Within  the  context  of  this  technical  guidance  document,  a  ‘good  practice’  refers  to  an 
advice  that  is  interpreted  as  being  in  line  with  the  LULUCF  Regulation  and  that  aims  to 
help a Member State to fulfil its requirement. As the approaches and examples described 
in this document are not binding to the Member States, it is not mandatory to follow the 
advised  ‘good  practices’.  There  may  exist  a  variety  of  other  approaches  to  prepare  the 
FRL in line with the Regulation and the ultimate choice of the method to calculate the FRL 
will  depend  on  the  national  circumstances,  including  data  availability  and  modelling 
capacity.  Moreover,  while  the  authors  have  sought  to  use  their  best  judgement  in 
providing  the  guidance  for  ‘good’  and  ‘not  good  practices’,  there  may  exist  situations 
where  a  Member  State  chooses  to  implement  a  ‘not  good  practice’  approach.  In  such  a 
case,  it  is  recommended  to  provide  clear  justification  of  why  such  an  approach  was 
chosen, and what effects this choice will have on the FRL. 

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Box 2: Key concepts for the implementation of the FRL 

Compliance  period  (CP).  The  period  2021-2030,  to  which  the  LULUCF  Regulation  sets  out  the 
commitments of the Member States for LULUCF, and the rules for the accounting of emissions and 
removals from LULUCF and for checking the compliance of Member States with those commitments 
(Article 1 of the LULUCF Regulation).  

Dynamic  age-related  forest  characteristics.  The  LULUCF  Regulation  refers  to  ”dynamic  age-
related  forest  characteristics”  (Article  8(5)).  In  this  technical  guidance  document,  age-related 
characteristics  are  understood  to  refer  to  the  state  of  ‘maturity’  of  the  forest,  which  can  be 
characterized  e.g.  with  mean  age  of  a  stand,  its  biomass  density,  and  age  or  diameter  class 
distribution. ‘Dynamic’ is understood to refer to the development of these characteristics over time, 
such as the movement of a stand from one age or diameter class to another over time. 

Forest  Management  Practice  (FMP).  Refers  to  a  set  of  activities  being  carried  out  at  different 
phases of the stand development. FMP can thus be seen as a set of activities carried out and aimed 
at fulfilling specific functions assigned to a forest (production, protection, etc.), including, e.g., the 
regeneration  modality,  the  species  planted,  the  schedule  and  intensity  of  thinning  and  final  cut. 
Examples of activities are soil preparation and thinning, and many of the activities can be used in 
many  FMPs.  In  the  context  of  this  document,  also  ‘no  management’  is  considered  as  a  possible 
FMP. 

Reference period (RP). The period from 2000 to 2009. 

State  of  the  forest.  Set  of  data  and  information  that  describe  the  forest,  such  as  total  area  of 
Managed  Forest  Land;  as  well  as  stratum-specific  variables,  e.g.  area,  increment,  biomass,  age-
related information. 

Stratum.  A  part  of  forest  (distinguished  geographically  or  grouped  across  different  geographic 
locations) homogeneous for all the criteria applied to the stratification process (tree species, forest 
type, management system, ownership, etc.). Each stratum differs from other strata by the value of 
at least one of the criteria of stratification. 

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Box  3.  Overview  of  the  suggested  step-wise  approach  to  implement  FRLs  and 
figure highlighting how the steps are suggested to be carried out sequentially 

Step 1: Stratify the area of MFL, according to country-defined criteria, and apply the stratification 
in a consistent manner over time, including the RP 2000-2009.  

Step  2:  Identify  and  document  the  FMPs  in  each  strata  for  the  2000-2009  period,  based  on 
country-defined and quantifiable operational criteria. 

Step 3: Select the appropriate methodology to project the development of carbon pools based on 
available data (including strata and management practices described in Steps 1 and 2) and national 
circumstances. 

Step  4:  Calibrate  the  selected  methodology  based  on  real  observed  data  and  show  that  the 
methodology is able to reproduce the GHGI estimates. 

Step  5:  Project  the  future  development  of  anthropogenic  forest  GHG  emissions  by  sources  and 
removals by sinks for the CP. 

Step  6:  Calculate  the  FRLs  as  average  of  emissions  and  removals  during  2021-2025  and  2026-
2030.  

As  Step  1  and  2  are  closely  interlinked,  it  is  possible  that  a  Member  State  may  have  to  perform 
these two steps in conjunction with each other. Also, (parts of) these steps may already be built in 
into  the  modelling  frameworks.  Nevertheless,  even  if  a  Member  State  had  an  existing  modelling 
framework  that  is  intended  to  use  for  the  development  of  the  FRL,  it  is  advised  that  the  Member 
State reflects on each of the suggested steps and documents in detail the data sources being used 
and how the model works, to allow for transparency and to accommodate an external review of the 
FRL. 

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2.1  Stratification 

Step 1: Stratify managed forest land  

Stratify the area of managed forest land, according to country-defined criteria, and apply 
the stratification in a consistent manner over time, including the RP 2000-2009. 

This subsection is structured as follows: 

2.1.1 Introduction (p. 32) 

2.1.2 Possible criteria for stratification (p. 33) 

2.1.3 Consistency requirements for stratification criteria (p. 35) 

2.1.4 Documenting the strata (p. 36) 

2.1.5 Additional data (p. 37) 

2.1.1  Introduction 

In this technical guidance document, we propose to start the preparation of the FRL with 
stratification, in other words dividing the MFL into classes. The strata defined in the first 
step will then be used as a basis for defining the FMPs in Step 2. 

A  Stratum  (in  the  context  of  this  document)  is  a  part  of  forest  (distinguished 
geographically or grouped across different geographic locations) homogeneous for all the 
criteria  applied  to  the  stratification  process  (tree  species,  forest  type,  management 
system,  ownership,  etc.).  Each  stratum  differs  from  other  strata  by  at  least  one  of  the 
criteria of stratification. 

Stratification is not an explicit requirement in the LULUCF Regulation. On the other hand, 
the  FRL  “shall  be  based  on  transparent,  complete,  consistent,  comparable  and  accurate 
information”  (Annex  IV.A(h)  of  the  LULUCF  Regulation).  Clear  documentation  of  the 
stratification  (division  of  the  MFL  into  classes)  helps  to  make  the  description  of  the 
forests more structured and thus more transparent and easier for reviewing. 

Stratification  also  serves  to  enhance  the  reporting  and  make  it  easier  to  understand  – 
even for those not  familiar with the specific national circumstances.  The Member States 
are hence advised to use a stratification principle that is deemed suitable to describe the 
forests  and  FMPs  in  the  respective  countries,  instead  of  adopting  a  general  rule  set  for 
stratification. The purpose of the stratification in Step 1 is to document clearly the basis 
for the allocation of the FMPs on the MFL. 

The  basis  and  level  of  detail  for  the  stratification  are  likely  to  depend  strongly  on  the 
national  circumstances  and  the  FMPs  applied  in  the  country.  FMPs  applied  in  forests 
primarily  used  for  wood  production  differ  from  the  practices  applied  in  forests  primarily 
serving  other  purposes,  such  as  water  protection  or  recreation.  The  FMPs  may  differ 
between forests on plains and forests on steep slopes, for different tree species mixtures, 
growing  conditions,  etc.  State  and  private  forest  owners  may  have  different  FMPs  in 
forests  that  are  similar  in  other  characteristics.  With  stratification,  such  differences  can 
be  taken  into  account  by  the  Member  State.  In  other  words,  stratification  of  the  MFL 
serves to provide a basis for distinguishing different types of FMPs.  

The  LULUCF  Regulation  also  explicitly  requests  the  Member  States  to  “demonstrate 
consistency  between  the  methods  and  data  used  to  determine  the  proposed  forest 
reference  level  in  the  national  forestry  accounting  plan  and  those  used  in  the  reporting 
for  managed  forest  land.”  (Article  8(5)).  This  means  that  where  applicable,  it  is  good 
practice  to  use  the  same  principles  for  the  stratification  as  those  used  in  the  GHG 

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inventory  (GHGI)  or  national  forest  inventory  (NFI)  (if  the  NFI  forms  the  basis  for 
reporting  for  managed  forest  land).  However,  when  deemed  appropriate  and  justifiable, 
the  stratification  for  the  FRL  may  differ  from  the  stratification  used in,  for  example,  the 
NFI, and may sometimes be partly already implemented in the forest model. 

2.1.2  Possible criteria for stratification 

Countries  may  use  different  criteria  to  stratify  MFL,  typically  including  some  of  the 
following examples: 

  Bio-physical context 

-  Geographic part of the country (e.g. North and South) 
-  Topography (e.g. plain and mountainous, flat terrain and slope) 
-  Bio-geophysical site conditions (e.g. site index) 

  Administrative/legal context 

-  Administrative boundaries (region, province, municipality, etc.) 
-  Ownership (private, public) 

  Function and characteristics of forest stands 

-  Functions/objective assigned to forest (timber production, water quality 
protection, maintenance of habitats, recreation, conservation etc.) 
-  Forest management/ silvicultural system (coppice forest vs. high forest, 

clearcut vs. shelterwood, even-aged forestry, etc.) 

-  Tree species composition/mixture (forest categories and types, prevailing 

tree species, mixtures, etc.) 

-  Quality of timber produced (sawlogs, pulpwood, firewood)  
-  Vulnerability to external disturbances (fire, windstorms, insect outbreaks, 

etc.) 

-  Accessibility (e.g. roads, remote forests) 

Examples  of  possible  (but  not  limited  to)  stratification  of  MFL  in  some  Member 
States  are  presented  in  the  boxes  below.  Note  that  these  are  examples  presented 
previously  in  the  literature,  and  do  not  necessarily  represent  the  approach  that  will  be 
selected by the Member States for the preparation of the FRL. 

Box 4: Example of stratification for Finland 

For the GHG estimations in the National Inventory Report (NIR), Finland has used stratification by 
region  (south/north)  and  soil  type  (mineral/organic).  To  cover  the  peculiarities  of  forest 
management  in  the  country  in  more  detail  (Yrjölä,  2002),  stratification  is  also  possible  along  the 
following criteria: 

  Southern Finland and Northern Finland 

  Different tree species (pine, spruce, silver birch, downy birch, larch, aspen) 

  Site classes (OMT - rich, MT - medium, VT - rather poor and CT - poor forest site types and 

peat soil) 

  Main function of forests (timber production, reindeer husbandry, protection, recreation) 

 

Forest owner  

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Box 5: Example of stratification for Sweden 

In earlier analysis of the forests in Sweden, the following criteria have been used to distinguish the 
area used for different FMPs (Skogsstyrelsen, 2015): 

  Geographic region (a total of 12 regions are being used, each covering a set of counties) 

 

Forest ownership (non-industrial private owners, other owners (including government, 
municipalities, church, forest companies)) 

  Main function of forest (production forest, voluntarily set-aside forests, formally protected 

nature reserves) 

 

Forest type, characterized by tree species (Scots pine, Norway spruce, Lodgepole pine, 
Birch, Other), soil moisture and site index 

Box 6: Example of stratification for Croatia  

According  to  description  of  forests  and  forest  management  in  Croatia  (Law  on  forests,  2014; 
Ordinance  on  forest  management,  2015;  NIR,  2017)  managed  forest  area  in  the  country  can  be 
stratified by the following criteria: 

  Main function of forests (commercial, protective, special purpose) 

  MFL category (high forests, plantations, forest cultures, plantations, coppices, maquia, 

shrub, garigue, scrub) 

  Management type (e.g. even aged or uneven aged) 

 

 

 

 

Tree species 

Terrain topography 

Level of fire vulnerability 

Forest owner 

Box 7: Example of stratification for France  

In France, the following criteria have been used to stratify the forests in order to distinguish the 
area used for different FMPs (Colin et al. 2016): 

  Cultivated poplar stands, other stands 

-  Further stratification for cultivated poplar stands based on: 

•  Clone group 

•  Region 

-  Further stratification for other stands based on: 

• 

• 

Forest cover type 

tree species 

•  Ownership category 

•  Biogeographical region 

An example of stratification based on the criteria listed in Box 5 for Sweden is presented 
in Figure 4. 

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Figure 4. An example of stratification following the criteria presented in Box 5. 

2.1.3  Consistency requirements for stratification criteria 

The  criteria  used  for  stratification  are  to  remain  the  same  in  the  modelling  of 
historical  and  projected  emissions  and  removals.  The  number  of  strata  is 
constrained  by  available  data  and  method  (model)  requirements  used  for  estimation  of 
FRL.  

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We suggest preparing a list of data necessary for the method chosen for FRL estimation, 
then checking which detailing of stratification still can satisfy the data demand. The level 
of  detail  needed  for  the  stratification  depends  on  the  method  chosen  for  the  FRL 
estimation, as well as on the available data.  

According  to  Article  8(5)  of  the  LULUCF  Regulation,  “The  forest  reference  level  shall  be 
based on the continuation of sustainable forest management practice, as documented in 
the period from 2000 to 2009”. This implies that the FRL is based on the continuation of 
(documented) sustainable FMPs in the historical RP, and the FMPs considered in the FRL 
are  not  projected  to  change  during  the  CP.  Similarly,  once  the  strata  are  defined  and 
FMPs associated to each stratum, they are expected to not change over the CP.  

Thus,  a  stratum  is  a  coherent  unit  within  which  the  FMP  does  not  change  over 
time.  Hence,  it  is  not  good  practice  to  stratify  the  MFL  by  criteria  that  may  change 
relatively  fast  over  time  (e.g.  age  class  or  harvest  volume).  The  FRL  is  based  on  the 
continuation of (documented) sustainable FMPs as in the period 2000-2009. This in turn 
means  that  once  the  strata  are  defined  and  created,  and  FMPs  associated  to  each 
stratum, these are expected to not change over the CP. However, the forest within each 
stratum can be divided further into units for modelling purposes (e.g. the model may be 
based on age classes). The modelling assumptions are discussed in detail in Step 3 (see 
section  2.3)  and  assumptions  to  be  taken  for  the  projection  of  the  FRL  are  further 
discussed in section 2.5. 

It is good practice that the construction of FRL reflects as close as possible any 
stratification  already  used  in  the  national  GHGI  or  the  NFI.  This  facilitates 
demonstrating  that  the  model  used  to  construct  the  FRL  is  able  to  reproduce  historical 
data  from  the  GHGI.  It  is  recommended  that  any  deviation  from  this  good  practice  is 
documented and justified by the Member State.  

It  is  also  good  practice  to  provide  a  description  of  the  forest  definition  used  for  the 
construction of FRL and explain whether it differs from that used in the national GHGI.  

2.1.4  Documenting the strata 

It is good practice to document the following information for each stratum:  

  Area during the RP 2000-2009.  

  Development  of  age-related  forest  characteristics  during  the  RP  (e.g.,  area  of 
forest stands in each age class, average above-ground and below-ground biomass 
in each age class, basal area, average diameter in each age class, increments in 
each  age  class  etc.;  for  uneven-aged  forest  the  respective  information  concerns 
the  whole  forest  instead  of  age  classes)  depending  on  data  requirements  of  the 
method used for FRL estimation. 

  The  forest  age-related  characteristics  for  the  year  which  is  the  closest  to  the 
starting year of modelling, i.e., 2009, or is representative for the starting year of 
modelling. 

  Species composition. 

  Additional  forest  characteristics  relevant  to  the  criteria  of  the  stratification  and 

method used for FRL estimation. 

It is important to quantitatively define those forest characteristics which are used in the 
method  selected  by  a  Member  State  for  FRL  estimation.  The  purpose  of  the 
documentation  is  to  comply  with  the  requirement  of  “transparent,  complete,  consistent, 
comparable and accurate information” (Annex IV.A(h)) and to allow for proper reviewing 
of the FRL estimation by designated experts. The forest characteristics can be presented 
in  a  table  or  a  set  of  tables.  Sources  of  information  used  for  description  of  the  forest 
characteristics are also to be documented. An example of possible table for documenting 

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information sources used for determining forest characteristics in each stratum is Table 2 
(a filled in example of Table 2 is presented in Annex III of this document).  

Table 2: Example of a table in which Member States may document data sources used as a basis 
for  stratification  of  MFL.  See  Annex  III  of  this  document  for  an  example  of  how  the  table  can  be 
filled in. Member States may add additional sources of information to the table so that it accurately 
reflects the national circumstances.  

Forest characteristics 

Data references 

ID  where 

Stratum 
characteristics 
reference are relevant 

the 
and 

Aboveground biomass 

Belowground biomass 

Area 

Species  composition,  species  X, 
…n 

…. 

2.1.5  Additional data 

If  a  Member  State  does  not  have  all  data  necessary  for  documenting  the  forest 
characteristics  (e.g.,  based  on  NFI  or  other  research  and  monitoring),  other  published 
data  may  be  used.  Box  8  gives  an  overview  of  possible  data  sources  that  may  be 
considered.  Furthermore,  some  of  the  data,  e.g.  forest  age  related  increments,  can  be 
approximated using forest growth models (e.g. Schelhaas et al., 2018).  

Box 8: Examples of possible data sources for complementing national data  

Forest cover maps (JRC; Hansen et al., 2013), 

 
  Maps  of  forest  biomass  (Barredo  et  al.,  2012;  Gallaun  et  al.,  2010;  Kindermann  et  al., 

2008; Thurner et al., 2014), 

  Maps of tree species (Brus et al., 2011; JRC; Mauri et al., 2017), 
  Maps of wood production (Verkerk et al., 2015), 
  Spatial data on logging residues (Di Fulvio et al., 2016), 
  Biomass expansion factors (Zianis et al. 2005).  

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2.2  Forest management practices 

Step 2: Description of forest management practices 

Identify  and  describe  the  FMPs  in  each  strata  for  2000-2009  based  on  country-defined 
operational criteria and quantifiable data.  

This subsection is structured as follows: 

2.2.1 Introduction (p. 38) 

2.2.2 What is a forest management practice? (p. 38) 

2.2.3 Description of forest management practices (p. 39) 

2.2.4 Documentation of forest management practices (p. 41) 

2.2.5 Implementation of forest management practices (p. 45) 

2.2.6 Possible data sources for documenting forest management practices (p. 49) 

2.2.7 Sustainability of forest management practices (p. 50) 

2.2.8 Adaptation of forest management practices to statistical harvest levels (p. 51) 

2.2.1  Introduction 

In  this  Step,  the  FMPs  applied  in  the  period  from  2000  to  2009  are  described  for  each 
stratum (see Step 1 – section 2.1) through country-defined and quantifiable operational 
criteria.  Both  the  qualitative  and  quantitative  aspects  of  each  FMPs  are  to  be 
documented.  In  addition,  it  should  be  demonstrated  how  these  definitions  have  been 
implemented and applied consistently over time for the estimation of the FRL. 

The  justification  for  this  Step  stems  from  Article  8(5)  of  the  LULUCF  Regulation,  which 
states that the FRL “shall be based on the continuation of sustainable forest management 
practice,  as  documented  in  the  period  from  2000  to  2009”.  As  the  continuation  of 
sustainable  management  practice  forms  the  basis  for  the  FRL,  it  is  important  that 
Member States provide a transparent documentation of the FMPs that were applied in the 
period from 2000 to 2009.  

Although Article 8(5) refers to “practice” in the singular, it is interpreted that depending 
on  the  understanding  and  justification  of  this  term  provided  by  the  Member  State,  the 
overall  FMP  within  the  Member  State  can  also  be  considered  to  consist  of  several 
different  practices,  depending  on,  for  example,  the  stratification  of  forests  to 
accommodate  national  circumstances.  Nevertheless,  the  documentation  needs  to  use 
quantitative criteria, to show that the FRL is “based on transparent, complete, consistent, 
comparable  and  accurate  information”,  as  required  by  Annex  IV.A(h)  of  the  LULUCF 
Regulation.  

It is good practice to describe how large a share of the national forests was covered by a 
given FMP in the period from 2000 to 2009. It is also good practice that Member States 
document explicitly the data sources which have been used to identify and specify each 
FMP. 

2.2.2  What is a forest management practice? 

In the context of this document, a forest management practice (FMP) refers to a set 
of  management  activities  (i.e.  silvicultural/forestry  operations)  being  carried  out  at 
different phases of the stand development.  

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A  FMP  can  thus  be  referred  to  a  set  of  management  activities  carried  out  and  aimed  at 
fulfilling  specific  functions  assigned  to  a  forest  (production,  protection,  etc.),  including, 
for  example,  the  regeneration  modality,  the  species  planted,  the  schedule  and  intensity 
of  thinning  and  final  cut.  Examples  of  activities  are  soil  preparation  and  thinning,  and 
more than one activity can be used in different FMPs.  

Through these activities, the FMP describes the management throughout the full cycle of 
the stand development in qualitative and quantitative terms. An FMP describes the origin 
and development of a forest stand and includes specification of, for example:  

  The origin (by seed or vegetative, such as suckers or coppice) of the stand. 

  The first activity being carried out (i.e. soil preparation) to the last activity of the 

cycle (i.e. final cut). 

  When trees are harvested (e.g. specific age or dimension). 

  Description of the main methods of removing trees. Are all trees removed in one 
final harvest (e.g. a clearcut), or are trees harvested through selective cutting? 

  Description if stumps are being harvested or not. 

 

‘No management’ is also a possible FMP. 

The  outcomes  of  FMPs  are  dependent  on  the  environment,  the  growing  conditions  and 
tree  species  (hence,  FMPs  are  linked  to specific  strata  to  reflect  how  the  forest  is  being 
managed and the outcome of such managements). A qualitatively similar practice used in 
one part of the EU can in quantitative terms be different in another environment.  

One  way  to  think  of  a  FMP  is  a  comparison  to  a  toolbox:  it  includes  many  tools 
(activities),  used  in  different  phases  of  the  stand  development.  These  tools  or  activities 
are  not  unique  to  a  single  FMP  and  they  can  be  used  in  many  FMPs,  even  in  different 
stages of development (e.g. an activity example is clearcut that could be done in FMP 1 
at 50 years and in FMP 2 at 120 years). 

2.2.3  Description of forest management practices 

It is good practice that the Member States describe in detail the FMPs applied in 
the MFL in the period from 2000 to 2009. In this subsection, we provide examples of 
possible descriptions of FMPs, and discuss aspects that are considered as good practice to 
include in  the  FMP  description.  It  may,  however,  not  be  necessary  to  provide  all  details 
as showcased here; the appropriate level of detail in the FMP description depends on the 
national  circumstances,  including  data  and  model  availability,  as  well  as  on  the  chosen 
modelling approach.  

To demonstrate that the FRL is based on “transparent, complete, consistent, comparable 
and  accurate  information”  (Annex  IV  of  the  LULUCF  Regulation),  it  is  good  practice  to 
describe each FMP in terms of qualitative and quantitative aspects. Such aspects may 
be considered in the following terms: 

  Qualitative  aspects:  The  qualitative  information  concerning  the  FMP  describes 
what is being done: which activities or operations are carried out for that specific 
FMP at different phases of the stand development. 

  Quantitative  aspects:  The  quantitative  information  concerning  each  FMP 

describes when and how each activity or operation is carried out.  

It  is  good  practice  to  provide  the  qualitative  documentation  of  each  FMP  so  that  it 
describes the management activities throughout the full cycle of the stand development, 
starting from the first activity being carried out (e.g. soil preparation) to the last activity 
of the cycle (e.g. end-of-rotation cutting). 

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To  the  extent  possible,  it  is  good  practice  to  define  when  each  management  activity  is 
being  carried  out  (i.e.  the  quantitative  aspects  of  the  FMP)  based  on  age-related 
characteristics of a stand. This term can also be understood as the state of ‘maturity’ of 
the  forest.  This  links  the  description  of  the  practices  to  the  requirement  in  the  LULUCF 
Regulation  to  “take  account  of  the  future  impact  of  dynamic  age-related  forest 
characteristics”  (Article  8(5)),  and  contributes  to  providing  a  transparent  basis  on 
showing that the FMP projected for the future is truly “continuation of sustainable forest 
management practice” (Article 8(5)) as documented in the RP, and not a change in FMP. 
The  definition  of  when  each  activity  is  being  carried  may  also  be  linked  to  variables 
describing the state of the forest (see Box 9).  

Box  9:  Examples  of  variables  that  may  be  used  to  define  when  and  how  each 
activity or operation is carried out 

Examples of variables describing the state of the forest: 

Total area of MFL 

 
  Stratum-specific variables: 

-  Area of stratum 
-  Mean age 
-  Mean biomass volume 
-  Number of seedlings/trees 
-  Basal area 
-  Crown cover 
-  Mean diameter 
-  Volume class of the growing stock 
-  Stocking level 

Examples of age-related characteristics that describe the maturity of the stand: 

  Mean age of the stand 
  Mean diameter of the stand 
  Mean volume of growing stock 

Examples of operations characterizing FMP, linking the state of the forest and the timing of the 
operation: 

 
 
 

Pre-commercial thinning when the stand is 10-15 years old 

Pre-commercial thinning when trees reach the diameter class (Dbh) of 10-15 cm 
Thinning when the basal area exceeds 18 m2/ha and the age exceeds 30 years 

It is not good practice to define when each activity is being carried out based on 
assumptions  or  projected  sources  of  information  such  as  future  wood  price 
development, interest rates, net present value estimates, or expected demand for wood 
for energy and material purposes. See Figure 5 for an overview of good practice and not-
good practice examples of criteria that may be used to define when each activity is being 
carried out.  

When  documenting  the  FMPs,  it  is  good  practice  to  describe  as  closely  as  possible  the 
management  practices  that  actually  took  place  during  RP,  and  not  the 
management  that  was  expected,  what  was  legally  allowed  during  the  RP,  or  the  best 
possible  management  of  the  forest  would  have  been.  The  aim  is  indeed  to  describe  as 
accurately  and  precisely  to  correspond  to  the  management  practices  that  were  actually 
carried  out  during  the  RP.  This  information  will  then  be  the  basis  to  model  the 

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continuation of management practices documented in the RP in the period from 2021 to 
2030. 

When  documenting  the  FMPs  in  a  Member  State,  it  is  not  good  practice  to  distinguish 
different  FMPs  (or  management  activities)  only  based  on  a  criterion  that  has  a  large 
annual  variability  (i.e.  rotation).  As  an  example,  it  is  not  considered  good  practice  to 
define one FMP (FMP 1) for which the final cut takes place when the trees are 81 to 82 
years  old,  a  second  practice  (FMP  2)  for  which  the  final  cut  takes  place  when  the  trees 
are 83 to 84 years old, a third practice (FMP 3) for which the final cut takes place when 
the  trees  are  85  to  86  years  old,  and  so  forth.  A  single  FMP  may  instead  cover  a  wider 
range of criteria for it to encompass and cover such annual fluctuations.  

Figure 5: Good practice and not good practice example of criteria that may be used to define when 
a management activity within a FMP is being carried out. 

2.2.4  Documentation of forest management practices 

Since  the  documentation  of  current  FMPs  should  reflect  the  country’s  circumstances 
appropriately,  a  large  degree  of  flexibility  can  be  applied  to  the  documentation,  as  long 
as  (i)  the  criteria/values  (or  similar  indicators)  used  are  transparently  documented  and 
their  rationale  illustrated,  and  (ii)  the  same  FMPs  are  applied  consistently  when 
projecting the FRL (see Step 5 – section 2.5). 

Here, we give two alternative examples on how to document FMPs: describing the FMPs 
through  forestry  activities  (Alternative  1),  and  describing  the  FMPs  by  biomass  removal 
percentage within an age or diameter class (Alternative 2). 

2.2.4.1  Alternative 1: Describe FMPs by management activities  

As a first step, it is suggested to provide a qualitative description of the FMPs as applied 
during the RP. In this step, the aim is to describe each FMP in terms of the associated set 

41 

 
 
 
 
 
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of  management  activities  (i.e.  silvicultural/forestry  operations)  to  be  carried  out.  One 
alternative  approach  to  document  the  qualitative  information  of  the  management 
practices is shown in Table 3.  

It should be noted that Table 3 is only an example of how the qualitative aspects of the 
FMPs can be documented and Member States are free to adopt the table as they see fit 
to fully reflect the country’s circumstances. 

Table  3:  Example  of  how  Member  States  may  describe  the  qualitative  aspects  of  the  FMPs  as 
applied in the Member State during the RP. See Annex III of this document for an example of how 
the table can be filled in. 

Forest Management Practice 

Index  Name of 
Practice 

Short Description of Practice 

Data source 
for practice 

FMP 1 

FMP 2 

FMP 3 

FMP 4 

Pine 
clearcutting  

Even aged pine forest with long rotation and 
regenerated by clearcut 

NFI 

Spruce 
clearcutting 

Even aged spruce forest regenerated by clearcutting  NFI 

Pine uniform 
shelterwood 

Even aged pine forest regenerated with consecutive 
cuttings applied on the whole area  

Close-to-
nature forest 

Forest with close to nature management and 
minimal intervention 

… 

… 

… 

NFI 

NFI 

… 

After  the  qualitative  description  of  each  FMP  has  been  defined,  it  is  good  practice  to 
document  the  specific  characteristics  of  each  FMP.  In  such  tables,  it  is  good  practice  to 
provide quantitative information about each FMP, thereby defining when each activity is 
being carried out.  

It  is  good  practice  that  the  description  documents:  (i)  how  is  each  activity  performed, 
and  (ii)  when  is  each  activity  being  carried  out.  It  is  good  practice  to  document  the 
characteristics  of  each  management  practice  as  precisely  as  possible  to  facilitate  the 
modelling  of  the  management  practices  and  to  clarify  the  difference  between  the 
management  practices.  It  is  important  that  Member  States  also  provide  quantitative 
information for all activity criteria so that they can be modelled and applied to estimate 
the projection of the FRL.  

One  alternative  approach  to  document  the  quantitative  information  of  the  management 
practices is shown in Table 4 and Table 5. These two tables show an example of how the 
FMPs  can  be  documented  according  to  two  broad  categories  of  management:  the 
management  practices  based  on  clear-felling  (even-aged  forest)  (see  Table  4),  and  the 
management practices without clear-felling (uneven-aged forest) (see Table 5). Member 
States  should  note  that  Table  4  and  Table  5  are  only  examples  of  how  Member  States 
may  document  the  quantitative  aspects  of  the  FMPs.  Member  States  are  free  to  adapt 
Table 4 and Table 5 as they see fit to fully reflect country specific circumstances. 

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Table  4:  Example  of  how  to  quantify  each  FMP  in  terms  of  its  management  activities 
(silvicultural/forestry  operations).  In  this  table  only  the  FMPs  that  include  a  final  harvest  of  the 
forest  is  described.  The  same  Index  and  name  of  FMPs  as  set  out in  in Table  3  are  applied.  Each 
activity  (i.e.  silvicultural/forestry  operation)  should  be  defined  and  reported  in  terms  of  two 
aspects: I) the criteria for when the operation is carried out (e.g. at a specific minimum age, time 
interval,  or  a  specific  diameter  class  (Dbh));  II)  the  percentage  of  living  biomass  removed.  See 
Annex III of this document for a detailed example of how the table can be filled in. 

Forest 
management 
practice 

Silvicultural operations with final harvesting 

Pre-
commercial 
thinning 

First 
commercial 
thinning 

Second 
commercial 
thinning 

Final cutting 

Index 

Name  of 
Practice 

Age 
(yrs)  or 
Dbh 
(cm) 

% 
biomass 
harvest 

Age 
(yrs) 
or  Dbh 
(cm) 

% 
biomass 
removals 

Age 
(yrs)  or 
Dbh 
(cm) 

% 
biomass 
removals 

Age 
(yrs)  or 
Dbh 
(cm) 

% 
biomass 
removals 

FMP1 

Pine 
clearcutting 
long 

>10 

15% 

>20 

15% 

N.A. 

N.A. 

120 - 
140 

95% 

FMP2 

Spruce 
clearcutting  >10 

15% 

>20 

15% 

N.A. 

N.A. 

80-100  95% 

FMP3 

Pine 
uniform 
shelterwood 

N.A. 

N.A. 

>20 

15% 

>30 

15% 

80-120  95% 

… 

… 

… 

… 

… 

… 

… 

… 

… 

… 

Table  5:  Example  of  how  to  quantify  each  national  FMP  in  terms  of  its  description  of  its 
management activities (silvicultural/forestry operations). In this table, only the FMPs without final 
harvesting of the forest is described. The same Index and name of FMPs as set out in in Table 3 are 
applied. See Annex III of this document for a detailed example of how the table can be filled in. 

Forest management practice 

Silvicultural operations without final 
harvesting 

Index 

Name of practice 

Years between two 
subsequent 
operations  

% biomass removals 

FMP 4 

Single tree selection 

15-20 

… 

… 

… 

15% 

… 

After the qualitative and quantitative aspects of each FMPs have been documented, it is 
good  practice  to  document  the  use  of  FMPs  according  to  the  stratification  of  the  forest 
land, as developed in Step 1 (see section 2.1).  

One  example  of  how  this  can  be  documented  is  shown  in  Table  6.  The  main  aim  of 
documenting  the  use  of  management  practices  in  different  strata  is  to  clarify  in  which 
stratum  the  management  practices  are  being  implemented  and  to  provide  clear 
indications about the difference between strata in term of how they are being managed. 

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Table 6: Example of how to document the percentage distribution of FMPs for each stratum of the 
country.  Member  States  are  encouraged  to  amend  the  table  according  to  the  number  of  strata 
defined  in  Step  1  (see  section  2.1),  and  the  number  of  FMPs  as  defined  in  Table  3.  For  each 
stratum, the sum over the percentage distribution of FMPs should sum up to 100% and should be 
indicated in the row called Sum Total (%). See Annex III of this document for a detailed example 
of how the table can be filled in. 

Sum 
Total 
(%)  

100% 

100% 

100% 

100% 

… 

Stratification of MFL 

% distribution of FMPs 

Strata 
categorization 
level I 

Strata 
categorization 
level II 

… 

FMP 
Index 
1 

FMP 
Index 
2 

FMP 
Index 
3 

FMP 
Index 
4 

… 

85% 

75% 

0% 

0% 

… 

0% 

0% 

0% 

0% 

100%  0% 

82% 

0% 

… 

… 

15% 

25% 

0% 

0% 

… 

… 

Type I  
(e.g. Private 
commercial 
forest owners) 

Type II  
(e.g. State 
owned forest) 

Type I  
(e.g. Pine) 

Type II  
(e.g. Spruce) 

Type III 
(e.g. Birch) 

Type IV 
(e.g. Aspen) 

Type I  
(e.g. Pine) 

Type II  
(e.g. Spruce) 

Type III 
(e.g. Birch) 

Type IV 
(e.g. Aspen) 

2.2.4.2  Alternative 2: Describe FMPs by biomass removals in forest age or 

diameter classes 

A  second  alternative  for  describing  the  FMPs  is  to  define  the  biomass  removal  as  a 
function of the age and state of the forest (e.g. age class, diameter class). This is slightly 
different  from  Alternative  1,  in  which  the  FMP  are  mainly  documented  according  to  the 
biomass  removal  for  each  specific  management  activity.  In  Alternative  2,  the  biomass 
removal  (e.g.  the  %  removal  of  the  growing  stock)  is  not  defined  according  to  each 
specific activity, but directly as a function of the age and state of the forest. As such, the 
difference between Alternative 1 and Alternative 2 is only in terms of how the FMPs are 
documented. 

Similarly  to  Alternative  1,  it  is  good  practice  to  document  both  the  qualitative  and  the 
quantitative  information  of  the  each  FMP.  Alternative  2  is  largely  based  on  well-
established and available references of the descriptions of the FMPs,  while Alternative 1 
may be better suited for situations where earlier documentation is poor or does not exist. 

Table  7  gives  a  possible  example  of  how  to  document  the  qualitative  description  of  the 
FMPs.  Compared  to  Alternative  1,  this  example  relies  heavily  on  other  documentation, 
and only provides overall principles of the FMPs. To ensure transparent documentation of 
the  practices,  careful  and  complete  references  to  published  documentation  are  here 
essential. 

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Table 7: Example of a qualitative description of FMP, following Alternative 2. 

Forest management practice 

Index 

Short description of practice 

FMPspruce 

FMPspruce consists of soil preparation 
through scarification, planting of seedlings, 
pre-commercial thinning of young stands, 
one to three thinnings over the rotation 
period, and a final harvest through 
clearcutting. The harvest schedule and 
biomass removals in harvests are regulated 
by Forest Law (please provide reference 
here), and guidelines for good FMP. 

Determination  of 
biomass removal rates 

the 

actual 

The biomass removals used in the FRL 
are based on observations of actual 
harvests in the period 2000-2009. The 
biomass removal as a % of growing 
stock is determined through calculating 
harvest probability for a given age class 
using the method described in (please 
provide reference here). 

… 

… 

… 

Table  8  provides  an  example  of  the  quantitative  details  to  document  the  FMPs  within 
Alternative 2. The rationale behind this description of FMPs is to identify as accurately as 
possible the characteristics of FMPs that affect the emissions and removals of GHGs from 
the  forests.  In  this  respect,  it  is  good  practice  that  the  stratification  of  the  forests  (see 
Step  1  –  section  2.1)  includes  at  a  minimum  differentiation  between  tree  species  or 
species  groups,  and  geographic  regions  in  cases  where  it  has  a  clear  impact  on  forest 
growth.  Given  that  the  FRL  shall  “take  account  of  the  future  impact  of  dynamic  age-
related  forest  characteristics”  (Article  8(5)),  it  is  good  practice  to  define  the  harvest 
removals  based  on  age-related  characteristics  such  as  age  or  diameter  classes,  seeking 
to provide as accurate and complete information on the FMPs as possible. 

Table  8:  Example  of  how  to  quantify  each  national  FMP  in  terms  of  the  percentage  of  biomass 
removal of the total growing stock in a certain age or diameter class, following Alternative 2. 

Biomass removal as a % of growing stock within each age or diameter class 

Age  
(or Dbh) 
class 

Index 
FMPspruce 

… 

0-20 

21-40 

41-60 

61-80 

81-100 

… 

50% 

… 

20% 

… 

35% 

… 

0% 

… 

45% 

… 

… 

… 

2.2.5  Implementation of forest management practices 

Some  models  used  for  the  projection  of  the  FRL  may  require  that  each  management 
activity  takes  place  at  a  specific  timing  of  a  criterion  (i.e.  final  clearcutting  takes  place 
when the stand is 85 years old) instead of a range for a criterion (e.g. final clearcutting 
takes place when the stand is 80-100 years old). As such, the timing of when an activity 
is to be carried out may have to be set according to a single static value (or a criterion). 
Depending  on  the  model  being  used  to  project  the  FRL,  a  number  of  quantifiable 
variables  may  have  to  be  defined  for  each  FMP  in  terms  of  when  and  how  each 
associated management activities are being carried out (see section 2.2.3).  

For simplicity, the dataset including the specification of when and how each FMP and the 
associated management activity actually were implemented during the RP will be referred 

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to as the actual management practice. The dataset including the quantified FMPs that 
will be used to by the model to project the FRL are hereafter referred to as the modelled 
management practices.  

If such a static value is selected for a FMP, it is good practice that Member States do so 
based on the range during which the activity was implemented during the RP.  

Figure 6. Three examples of historical trends in the timing of a management activity for an FMP. In 
this example ‘Rotation period’ refer to the age at which the final clearcutting takes place. The solid 
line shows the historical values as documented for the period from 2000 to 2009 that follow a trend 
over  time.  Continuation  of  such  trends  in  the  CP  is  not  considered  good  practice.  Instead,  the 
shaded  area  shows  the  minimal  and  maximal  range  of  the  operation  criteria  as  observed  for  the 
period from 2000 to 2009.  

When  deciding  upon  the  definition  of  the  exact  criteria  for  when  an  activity  is  to  be 
carried  out,  it  is  good  practice  that  the  minimum  and  maximum  values  of  when 
the activity was carried out during the RP set the boundary conditions for when 
the activity is to be carried out during the CP.  

In other words, the static value for when the management activity (silvicultural/forestry 
operation) does take place is to be selected by the Member State, but it is to be within 
the  observed  range  during the  RP  and  thereby  not  to  deviate  from  the  historical  values 
as observed. 

This  implies  that  even  if  a  trend  in  when  an  activity  is  carried  could  be  observed  and 
documented  during  the  period  from  2000  to  2009  (e.g.  that  the  final  clearcutting  is 
taking  place  earlier  in  2009  than  in  2000),  it  is  good  practice  not  to  project  such 
trends to continue during the CP and to confirm this in the documentation.  

Following  this  same  logic,  also  situations  where  the  praxis  is  to  systematically  change 
from one tree species to another after final felling, may be considered as a trend, and is 
not  to  be  continued  during  the  CP.  In  this  case,  a  change in tree  species  would  also  be 
considered  a  change  in  FMP  and  as  such  not  to  be  included  in  the  FRL:  as  discussed  in 

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section  2.2.3,  FMP  describes  the  management  activities  throughout  the  full  cycle  of  the 
stand  development,  starting  from  the  first  activity  being  carried  out  (e.g.  soil 
preparation) to the last activity of the cycle (e.g. end-of-rotation cutting). Box 10 gives a 
more detailed example of a situation where tree species are changing during the RP. 

Because of the inter-annual variability, it is considered to be good practice to define the 
FMPs  based  on  data  across  a  period  of  time,  instead  of  a  single  year  as  for  other  GHG 
categories. That is, if a quantifiable variable used to describe when a FMP is carried out 
(for example rotation period) varies during the RP and no clear trend can be established, 
then the average value for the RP would normally be used to quantify the FMP (see top 
example in Figure 6). However, if the quantifiable variable follows a trend or changes its 
value  abruptly  during  the  RP,  then  it  could  be  justified  that  (and  documented  why)  the 
latest  value  is  applied  to  characterize  the  FMP  (see  middle  and  bottom  examples  in 
Figure 6).  

Consequently, it is good practice that each FMP characteristic is quantified according to a 
single and static value (or criterion), not by a trend nor by a rate of change.  

Further  guidance  on  verifying  the  consistency  between  the  actual  management  practice 
and the modelled management practices is provided in section 2.4.2. 

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Box 10. Example of a systematic change in tree species 

Figure 7 shows an example of a situation where one tree species is systematically replaced by 
another  in  the  RP.  In  this  illustrative  example,  conifers  were  systematically  replaced  by 
broadleaved  trees.  In  2000,  the  share  of  broadleaved  trees  was  only  10%,  while  90%  of  the 
area was covered by conifers. Over the RP, the broadleaved trees replaced conifers, and in the 
end of the RP in 2009, 55% of the area was covered by broadleaved trees. 

In this situation, it is good practice to model the tree species shares as those in the end of the 
RP, i.e. 55% broadleaved trees and 45% conifers (assuming that the MS starts the projection of 
the FRL as of 2010). A further change in tree species would be considered a change in FMP and 
as  such  not  to  be  included  in  the  FMP.  Therefore,  “continuation  of  the  sustainable  forest 
management  practice  […]  with  regard  to  age-related  forest  characteristics  in  national  forests, 
using the best available data” (Article 8(5)) is understood to refer to a possibility to project age-
related  effects,  such  as  periodic  harvests  and  regeneration  of  a  given  stratum.  However,  a 
change in stratum is not considered to comply with continuation of FMP as referred to in Article 
8(5).  

In other words, it is interpreted that it is good practice that the FRL project age-related effects 
within  a  stand  (change  in  age  structure 9),  but  not  good  practice  to  project  a  change  in  tree 
species, change in management and change in area 10 (see section 2.3.2). 

Figure  7.  Example  of  systematic  change  in  tree  species  under  the  RP,  where  conifers  have 
systematically been replaced by broadleaved trees under the RP. In the end of the RP, the share 
of broadleaved trees was 55% and the share of conifers 45%. It is good practice to assume this 
state of the forest to prevail during the CP, instead of further change in the coverage of the tree 
species. 

9 It is important to point out that the references to age, age class, and age structure should be understood as the state of ‘maturity’ of the forest. 
In the case of even-aged forest, the age of the stratum could be used. However, in case of uneven-aged forest, it will correspond to the current 
average “size” of the forest, and it is described by parameters different than age (e.g. mean diameter, volume classes of growing stock, etc.). 
10 With the possible only exception of conversions to/from forest (See section 2.5.3). 

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2.2.6  Possible data sources for documenting forest management 

practices 

Numerous  Member  States  have  long  time  series  of  information  concerning  the  state  of 
their forest from the NFIs. NFI usually provides data concerning the state of the forest at 
a  given  time,  and  a  comparison  of  NFI  plots  from  two  different  points  can  be  used  to 
derive information on yields and removals. All such information may be already used for 
GHG reporting, and hence considered also as input data for the construction of the FRL. 
For example, information on the FMPs that were applied in the period from 2000 to 2009 
can be derived through a comparison of permanent inventory plots between years. 

NFI data commonly has the disadvantage that it does not provide information about the 
management  purposes,  but  only  that  a  specific  management  practice  has  taken  place. 
For  the  purpose  of  defining  the  FMPs  and  filling  in  the  Table  3  to  Table  8,  this  is  not  a 
problem  as  the  FMPs  should  be  defined  according  to  the  management  that  took  place. 
Other  data  sources  than  NFI  may  of  course  also  be  used  to  define  the  FMPs,  such  as 
forest  laws  and  other  legal  documents,  forest  management  guidelines,  and  forest 
management  plans,  provided  that  it  is  shown  that  these  sources  describe  the  actual 
management practices, instead of only the theoretically allowed practice. For example, if 
there is a forest management plan adopted by the owner of a stand, and it can be shown 
that  the  owner  is  strictly  implementing  the  plan,  then  the  practices  foreseen  within  the 
management plan may be used to define the FMPs for the stand.  

When documenting the FMPs, it is good practice that Member States only use data 
sources from the period 2000 to 2009, as required in the LULUCF Regulation. This is 
the case as the Article 8(5) states that “The forest reference level shall be based on the 
continuation  of  sustainable  forest  management  practice,  as  documented  in  the  period 
from 2000 to 2009”.  

A  challenge  when  applying  NFI  data  to  document  the  FMPs  may  be  that  the  inventory 
period  may  not  match  with  the  requirement  of  using  data  that  was  documented  in  the 
period  from  2000  to  2009.  In  many  EU  Member  States,  the  inventories  take  place  over 
several years, and the inventory periods may  not be  compatible with the RP  of 2000 to 
2009.  For  instance,  as  illustrated  in  Figure  8,  a  Member  State  may  perform  the  forest 
inventories  based  on  a  five-year  cycle,  meaning  that  each  year  1/5  of  the  sample  plots 
are measured. Furthermore, in this example, the total estimates as reported in the year 
2005 are based on the inventories carried out during the period 2003 to 2007.  

8
9
9
1

9
9
9
1

0
0
0
2

1
0
0
2

2
0
0
2

3
0
0
2

4
0
0
2

5
0
0
2

6
0
0
2

7
0
0
2

8
0
0
2

9
0
0
2

0
1
0
2

1
1
0
2

Figure 8. Example of an NFI where the inventory follows a running five-year average, reported in 
year X. In this example, the NFI as reported in the year 2000 is based on inventories carried out 
during the period 1998 to 2002. 

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In  this  example,  it  would  be  good  practice  that  only  the  sample  plots  measured  in  the 
time period from 2000 to 2009 (shaded in blue) would be used for the documentation of 
the FMPs. In other words, it would be the reported total estimates for the period of 2002 
to 2007 that would be used for documenting the FMPs. 

However,  it  is  likely  that  most  Member  States  do  not  have  such  detailed  inventory 
information  available  of  their  forests,  and  in  some  cases  the  NFI  period  may  be 
completely  outside  the  RP.  If  data  sources  outside  the  period  from  2000  to  2009 
are used, it is good practice to document and justify this deviation. Also, if this is 
the case, it is good practice to reflect on how choosing data outside the RP represents the 
conditions under the RP, and to document an assessment of the impact of this deviation 
on the FRL. 

The  use  of  all  available  data  sources  on  FMPs  to  construct  the  time  series  of 
management  practices  is  certainly  good  practice  as  it  integrates  all  available 
information.  It  is  good  practice  to  document  which  data  sources  have  been  used  to 
specify the FMPs and justify why these sources have been used. 

In  the  worst  case,  no  information  may  be  available  or  suitable  for  the  description  of 
specific  FMPs.  In  such  cases,  expert  judgement  may  be  carried  out  on  the  basis  of 
knowledge gained concerning country specific FMPs that are being carried out. While the 
judgement  by  experienced  experts  may  be  essentially  of  good  quality,  it  is  difficult  to 
verify.  This  is  why  expert  judgement  should  be  the  last  alternative  as  an  approach.  If 
expert judgement is carried out, it is highly recommended that the “elicitation protocol” 
from the IPCC Guidelines for expert judgment is being followed. 11 

2.2.7  Sustainability of forest management practices 

It is important to understand that the purpose of the FRL is to reflect in the accounts the 
impact  of  changes  in  FMP  relative  to  a  historical  RP;  the  FRL  is  not  a  sustainability  or 
best-management  benchmark,  and  thus  is  not  a  benchmark  of  the  quality  of  forest 
management  in  a  Member  State.  Nevertheless,  as  noted  in  section  3.1,  Member  States 
are  encouraged  to  provide  in  the  NFAP  information  on  how  sustainable  forest 
management policies and practices evolved, and to describe how these have been taken 
into account in the modelling of the FRL. 

According  to  the  LULUCF  Regulation,  the  FRL  “shall  be  based  on  the  continuation  of 
sustainable  forest  management  practice,  as  documented  in  the  period  from  2000  to 
2009”  (Article  8(5)).  The  preamble  (recital  16)  of  the  LULUCF  Regulation  refers  to  the 
principles of sustainable forest management as adopted in the Ministerial Conferences on 
the Protection of Forests in Europe (‘Forest Europe’). According to Forest Europe, a forest 
management  is  defined  sustainable  if  it  maintains  “(forest)  biodiversity,  productivity, 
regeneration  capacity,  vitality  and  (forest)  potential  to  fulfil,  now  and  in  the  future, 
relevant  ecological,  economic  and  social  functions,  at  local,  national,  and  global  levels, 
and  does  not  cause  damage  to  other  ecosystems”.  Forest  Europe’s  most  recent  report 
shows the advanced progress of adoption of sustainable national forest programs across 
its  member  countries,  that  in  general  show  consistent  adoption  of  sustainable 
practices (Forest Europe 2015). 

Nonetheless,  it  is  good  practice  that  a  Member  State  documents  in  a 
transparent  manner  how  the  principles  of  sustainable  FMP  are  being  applied 
within  their  country.  Documentation  that  clarifies  and  highlights  what  is  defined  in 
practice  as  sustainable  forest  management,  and  how  such  principles  are  being  enforced 

11 See IPCC 2006 (Volume 1, Annex 2.1) for further guidance 

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through  means  such  as  national  regulations,  forest  certification  and  endorsements  of 
specific criteria and principles, would fulfil this recommendation. 

In  exceptional  circumstances,  a  Member  State  might  signal  that  a  (part  of)  FMP 
documented  for  part  or  the  whole  of  the  2000-2009  RP  does  not  fulfill  the  criteria  of 
being sustainable. In principle, this does not present a problem for the estimation of the 
FRL;  improvements  (indeed,  any  change)  in  current  FMP  should  be  reflected  in  the 
accounting  against  an  FRL  (that  assumes  a  continuation  of  the  RP  practices). 
However,  in  exceptional  circumstances  it  might  arise  that  the  Article  8(5)  condition  of 
“continuation of sustainable forest management practice” invalidates the FRL modelling. 
In such a rare circumstance, it is good practice that the Member State:  

  Fully documents (in accordance with section 2.2.4) and consequently justifies why 
the  previous  FMP  infringed  sustainable  FMP  during  the  RP  2000-2009,  with 
reference to Forest Europe.  

  Documents the (subsequently) adopted sustainable FMP (again in accordance with 
section 2.2.4) that replaced the previous non-sustainable FMP, including the date 
from  which  it  was  adopted  and  has  been  applied,  and  justifying  why  the 
replacement FMP provided an improvement in terms of sustainability. 

  Documents  the  expected  impact  of  the  practice  change,  where  applicable 
quantifiably,  with  respect  to  the  key  criteria  and  principles  listed  in  Annex  IV  of 
Regulation 2018/841. 

Note that there can be other, methodologically consistent ways of resolving such issues, 
instead of adopting a revised set of sustainable FMPs (for example, stratification, or use 
of the flexibility in selecting the value of a variable within the RP (see section 2.2.5)). It 
is  good  practice  therefore  to  evaluate  these  options  in  priority;  only  in  exceptional 
circumstances,  and  when  all  the  above-mentioned  aspects  have  been  transparently 
documented  and  justified,  should  a  replacement  (adopted)  FMP  be  considered  for  the 
projection of the FRL.  

2.2.8  Adaptation of forest management practices to statistical 

harvest levels 

To  complement  NFI  data  and  to  acquire  missing  information  (e.g.  thresholds  for 
operational  criteria  as  defined  in  Table  4  and  Table  5)  modelling  exercises  may  also  be 
employed.  As  it  is  good  practice  to  describe  the  FMPs  as  closely  as  possible  to  the 
management practices that actually took place during RP, such approaches may also be 
used to refine the quantitative aspects of the FMPs have been defined and documented.  

A  first  example  of  such  an  approach  is  to  derive  the  average  threshold  (or  distribution 
function)  for  when  a  management  activity  is  carried  out  (e.g.  age  to  perform  the  final 
cutting) through combining the historical harvest levels with the age structure 12. Through 
combining such data sources, information can be derived to assist the specification of the 
specific criteria of each FMP.  

A  second  example  of  such  an  approach is  based  on  obtaining  harvest  rates  by  stratum, 
FMP  and  age-class  during  the  RP  in  line  with  the  documented  practices  and  the  actual 
statistics  of  harvest  at  national  level.  If  only  total  harvest  (or  aggregated  harvest)  is 
available,  it  is  suggested  to  disaggregate  that  data  by  stratum  and  age-class  based  on 
bibliographical information describing the FMP regarding theoretical harvest 13 by area for 
each stratum and age-class.  

12 An example of such an approach is described in Grassi and Pilli 2017.  
13 By theoretical harvest it is understood the amount of harvest documented in the forest management plans or legal texts. 

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Using  this  information  and  the  areas  in  the  RP,  a  theoretical  harvest  based  on 
documented  practices  can  be  estimated  and  compared  with  the  statistical  harvest.  This 
ratio  between  the  estimated  and  the  statistical  harvest  can  be  used  improve  upon  the 
parameterization of the FMPs. 

The suggested procedure is as follows: 

1.  Obtain the total statistical harvest for each year of the RP (TSHRP). 

2.  Using the FMPs as defined and documented in Step 2 (see section 2.2), estimate a 

theoretical harvest by area for each stratum and age (THbARP). 

3.  Multiply  the  area  of  each  stratum  in  the  RP  (ARP)  by  the  theoretical  harvest  by 

area (THbARP) to obtain a theoretical total harvest (TTHRP). 

4.  Verify  the  difference  between  the  theoretical  total  harvest  (TTHRP)  and  the 

statistical harvest (TSHRP). 

5.  Adapt  the  parameterization  of  the  FMPs  so  that  the  theoretical  total  harvest 

(TTHRP) matches the statistical harvest (TSHRP). 

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2.3  Methodology 

Step 3: Selection of appropriate methodology 

Select  the  appropriate  methodology  to  project  future  development  of  anthropogenic 
forest  GHG  emissions  by  sources  and  removals  by  sinks  based  on  available  data  and 
national circumstances.  

This subsection is structured as follows: 

2.3.1 Introduction (p. 53) 

2.3.2 Fixed parameters and dynamic variables (p. 54) 

2.3.3 Requirements for the selected methodology (p. 56) 

2.3.4 Modelling carbon pools in forest (p. 57) 

2.3.5 Modelling the development of the harvested wood products (p. 63) 

2.3.6 Modelling the development of natural disturbances (p. 67) 

2.3.7 Modelling frameworks (p. 69) 

2.3.8 Documenting the methodology used (p. 69) 

2.3.1  Introduction 

This  part  of  the  technical  guidance  document  provides  information  on  how  to  select  the 
appropriate  methodology  or  modelling  framework  for  projecting  the  development  of 
carbon stocks in the carbon pools in the CP. The objective is to use this methodology to 
project  continuation  of  the  sustainable  FMPs  of  the  RP  regarding  dynamic  age-related 
forest characteristics in national forests, using the best available data. 

The objective is to estimate future development of the MFL carbon pools in the CP in line 
with the stratification developed in the Steps 1 (see section 2.1) and the FMPs as defined 
in  Step  2  (see  section  2.2).  It  is  important  to  point  out  that  the  set  of  strata  and  FMPs 
must consider all the variables needed in the methodology for the estimation of the FRL 
projections selected in Step 3 (see section 2.3). 

Finally, it is important to point out that although a unique methodology could be used for 
all  strata  and  FMP,  a  Member  State  may  use  different  methodologies  to  project  the 
different strata and FMP, so that it can take into account the differences in management 
practices  and  forest  composition.  For  example,  a  forest  model  could  be  used  for  the 
commercial forest  whilst other strata (e.g. protected national parks) could be estimated 
based  on  a  completely  different  methodology.  As  changes  between  strata/FMP  are  not 
allowed  (see  section  2.5),  the  use  of  different  methodologies  presents  no  further 
problems, meanwhile the methodologies results are consistent with the ones presented in 
the GHGIs (see Step 4 below). 

It  should  be  mentioned  that  the  natural  disturbances  estimation  requires  special 
consideration,  and  detailed  information  on  the  possible  approaches  on  considering  the 
NDs  in  the  FRL  estimation  is  included  in  this  section  (see  2.3.6).  Additionally,  further 
information on the treatment of the HWP pool is also provided in this section (see 2.3.5). 

For  the  estimation  of  the  FRL,  two  sets  of  input  data  are  foreseen  to  be  required  by  a 
model for projecting the FRL for the CP: 

a)  Data  describing  the  state  of  the  forest  for  each  stratum  (e.g.  area,  increment, 

biomass volume).  

b)  Description of the FMPs in 2000-2009 for each stratum.  

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According to the LULUCF Regulation, the methodology used for projecting the FRL needs 
to  model  “continuation  of  sustainable  forest  management  practice  […]  with  regard  to 
dynamic  age-related  forest  characteristics”  (Article  8(5)).  To  comply  with  this,  in  most 
cases,  the  methodology  will  need  to  take  into  account  the  stratification  previously 
introduced in Step 1 (see section 2.1), the FMPs introduced in Step 2 (see section 2.2), 
and the age-structure development of the forest. 

2.3.2  Fixed parameters and dynamic variables 

The  LULUCF  Regulation  lays  out  rules  and  criteria  that  need  to  be  taken  into  account 
when  choosing  methodology  and  data  for  the  estimation  of  the  FRL.  Most  importantly, 
the  projections  need  to  be  made  with  attention  to  the  terms  used  in  Article  8(5): 
“continuation  of  sustainable  forest  management  practice”,  which  implies  that  some 
parameters describing the FMPs need to be  fixed to the RP level in the projections  over 
the CP, while “regard to dynamic age-related forest characteristics” implies that the age 
structure of the forest should be allowed to evolve over the CP.  

For  this  reason,  all  aspects  directly  related  to  the  description  of  the  FMP  (e.g.  which 
management activities are included in an FMP, when and how each activity is carried out) 
and the criteria used to stratify the MFL (e.g. geographic part of the country, ownership, 
tree  species)  need  to  remain  constant  throughout  the  CP.  A  change  in  these  aspects 
would indicate a change in the FMP during the CP, and is not to be included in the FRL.  

In other words, it is good practice that all information and descriptions regarding 
the  FMPs  remain  unchanged  throughout  the  CP,  and  are  considered  as  fixed 
parameters.  It  is  important  to  note  that  only  the  FMPs  that  were  implemented  in  the 
period from 2000 to 2009 are to be applied in the CP for the estimation of the FRL (see 
section 2.2.3 for more details). 

Additionally, it is good practice that the area  of land allocated to each stratum and FMP 
remains  constant  from  the  starting  year  of  the  projection  onwards  (thereby  not 
extrapolating any possible trends observed historically into the future) 14
.. Any deviation in 
terms of area allocation would be considered as a change in management, and is as such 
not good practice to include in the projection of the FRL. It is important to note that just 
because the area of land dedicated to a stratum or FMP remains constant does not imply 
that the age-related characteristics of the forest within the strata remains constant 15. 

it 

the  other  hand, 

On 
is  good  practice  that  the  dynamic  age-related 
characteristics 16  of  the  forest  do  not  remain  fixed  throughout  the  CP,  meaning 
that the age structure of the forest is modelled to develop over time. This allows to “not 
unduly  constrain  forest  management  intensity  as  a  core  element  of  sustainable  forest 
management practice” (Article 8(5)). For example, the total annual area of clearcuts may 
vary between years and also differ between the RP and CP. As a consequence, the total 
harvest  volume  may  vary  between  years  in  the  CP  (i.e.  it  is  dynamic),  and  may  also 
differ from the total harvest volume during the RP.  

Therefore,  it  is  good  practice  that  the  selected  model  takes  into  account  the  age 
(‘maturity’)  distribution  within  each  stratum  (usually  age  or  diameter  class  distribution) 
in  a  way  that  allows  for  age  structure  to  change  over  time.  Here,  by  ‘age  structure’  we 
mean  the  area  of  forest  in  each  age  class.  This  means  that  while  the  total  area  of  land 
allocated  to  a  certain  stratum-FMP  combination  remains  fixed14,  the  area  of  each  age 

14 With the possible only exception of conversions to/from forest (See section 2.5.3). 
15 The  area of land dedicated to a specific age  class or diameter class does not  have to remain constant from the starting year of the 
projection onward.  
16 It is important to point out that the references to age, age class, age structure should be understood as the state of ‘maturity’ of the forest. In 
the case of even-aged forest, the age of the stratum could be used. However, in case of uneven-aged forest, it will correspond to the current 
average “size” of the forest, and it is described by parameters different than age (e.g. mean diameter, volume classes of growing stock, etc.). 

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class  within  a  stratum-FMP  combination  may  change  over  time  (i.e.  forest  hectares  will 
move  from  one  to  another  age  class,  while  the  stratum-FMP  description  does  not 
change). 

However,  the  parametrization  of  the  model  with  regards  to  the  characteristic  of  each 
combination  of  stratum,  FMP  and  age  class  (e.g.  growth  or  mortality  functions)  should 
not be changed in the projections.  

Therefore, all parameters related to the amount of wood harvest obtained by performing 
a specific management activity within a FMP (i.e. implementing an option covered by an 
FMP) are to remain constant throughout the CP 17. That is, the outcome of performing  a 
specific  management  activity is  fixed  for  each  specific  combination  of  stratum,  FMP  and 
age  class.  However,  as  the  age  structure  of  the  forest  may  change  over  time  (to  take 
into account the age dynamic characteristics), the total volume of wood harvested is not 
fixed in the CP. 

Table 9 summarizes the main variables and parameters needed for the modelling of the 
GHG emissions and removals, and indicates the parameters to be fixed over the CP, and 
variables that are modelled to develop over time. 

Table 9. Types of data according to the methodology. 

Input data 

Fixed parameters in 
the CP 

Dynamic variables in the 
CP 

Final output 

FMP 

FMP 

Silvicultural/forestry 
operations 

Silvicultural/forestry 
operations 

Harvest (% of 
biomass) 

Harvest (% of 
biomass) 

How each operation is 
carried out 

How each operation 
is carried out 

State of forest 

Total area of the 
stratum-FMP 

Total area of the 
stratum-FMP14 

Area harvested 

Age structure within a 
stratum-FMP  

Age structure within a 
stratum-FMP 

Parameterization of 
the model for each 
stratum-FMP-age-
class 18 

Parameterization of 
the model for each 
stratum-FMP-age-
class 

Total volume of wood 
harvested 

Variations in living 
biomass, soil organic 
carbon and dead organic 
matter pools 

17 With the possible only exception for models that account for climate change (see section 2.5.2).  
18 This includes aspects such as growth, mortality and yield functions.  

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2.3.3  Requirements for the selected methodology 

The methodology as selected by the Member State needs to be able to: 

  Apply fixed parameters. 

  Estimate the evolution of the dynamic variables. 

  Estimate the C pool variations. 

  Estimate the changes in the HWP pool. 

So, it is good practice that the methodology be able to estimate the dynamic data, based 
on input data: 

  The age structure. 

  The total wood harvested. 

Finally,  based  on  fixed  and  dynamic  data,  it is  good  practice  that  the  methodology  also 
be able to estimate: 

  The C pool variations. 

  The changes in the HWP pool. 

Hereafter,  we  provide  a  proposal  for  a  subdivision  of  the  previous  estimation  procedure 
into what we will be refer to as ‘modules’: 

  Age structure module: models the development of age-related characteristics16 

over time and the dynamics of areas within a stratum/FMP. 

  Harvest module: models the total volume of wood harvested. 

  C  pool  variation  module:  would  use  the  outputs  of  the  previous  models 
(dynamic  variables)  and  the  fixed  variables  to  estimate  the  variations  in  the 
carbon pools. 

  HWP  module:  would  use  the  total  volume  of  wood  harvested  to  estimate  the 

variations in the HWP pool. 

Figure 9 shows the structure of the FRL methodology: 

Figure 9. Methodology structure.  

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2.3.4  Modelling carbon pools in forest 

As  explained  in  the  previous  section,  the  methodology  could  use  three  modules  for 
estimating  the  dynamic  variables  and,  therefore,  the  variations  in  the  C  pools  of  the 
forest.  The  characteristics  of  each  of  these  modules  will  be  described  in  more  detail  in 
this section. 

2.3.4.1  Age-structure module  

This  module  is  aimed  to  predict  the  next  year  age-structure  of  forest,  based  on  the 
information of the current year age-structure and FMPs. 

Figure 10. Age-structure module description. 

For  age-classes  based  on  years,  the  module  only  needs  to  move  forward  in  time  the 
areas from one class to another based on the number of years projected and the possible 
losses. It is good practice that Member States use all available data sources to define the 
age  distribution  within  each  age  class,  and  to  document  which  data  sources  have  been 
used. In case where the age distribution within each age class is not known, it could be 
justifiable to assume that the distribution is uniform (i.e. the area of  forest is the same 
for all ages included in the age-class, e.g. if 40 kha are allocated in the age class “21-40 
y”, then it is assumed that 2 kha are 21 years, 2 kha are 22 kha…). However, given that 
assumptions  concerning  age-classes  may  influence  the  FRL,  such  a  choice  needs  to  be 
justified and clearly documented by the Member State (see Step 1 and 2 in sections 2.1-
2.2). 

However, if the age  classes are based  on volumes  or Dbh, the age-structure model has 
to  be  able  to  estimate  the  yearly  amount  of  increase  of  those  variables  to  model  the 
changes between age classes over the years. 

In  order  to  model  these  changes  of  area,  the  Member  State  could  use  a  forest 
management  probability  matrix  that  matches  the  development  of  volume  in  each  age 
class during the RP, thereby describing the forest management as was applied during the 
RP. As already explained, this forest management probability matrix has to be developed 
for each stratum-FMPs combination, as defined in Steps 1 and 2 (see section 2.1-2.2). 

The basic idea behind this approach is that a country would use inventory data and the 
matrix  approach  to  calibrate  historical  harvest  to  the  management  actually taking  place 
in the inventory plots. Once calibrated, it is good practice that the same parametrization 
is applied to the CP. 

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Box  11.  Examples  of  changes  in  the  age  structure  distribution  estimated  by 
the age-structure module 

Areas by strata/FMP/age class for year i 

Strata/FMP 
Pine 
commercial/FMP1 

Pine 
conservation/FMP2 

Mixed 
centre/FMP3 

Forest 

0-20 y 

60 
0-30 y 

10 
0-50 m3/ha 

Mixed 
south/FMP4 

forest 

30 
0-50 m3/ha 

Eucalyptus 
plantation/FMP5 

60 
0-10 y 

Age classes/Area (kha) 
40-60 y 
20-40 y 

50 
30-70 y 

30 
50-150 
m3/ha 
30 
50-100 
m3/ha 
50 
10-20 y 

80 
70-100 y 

60 
150-250 
m3/ha 
25 
100-200 
m3/ha 
40 

>60 y 

20 
>100 y 

20 
>250 m3/ha 

20 
>200 m3/ha 

20 

20 

30 

Total 

210 
Total 

120 
Total 

105 
Total 

170 
Total 

50 

Combined with the activities of the FMP by strata/FMP/age class 

Strata/FMP 
Pine commercial/FMP1 

Pine conservation/FMP2 

Mixed Forest centre/FMP3 

Mixed forest south/FMP4 

Eucalyptus plantation/FMP5 

Age classes 

0-20 y 
No cut 
0-30 y 
No cut 
0-50 m3/ha 
No cut 
0-50 m3/ha 
No cut 
0-10 y 
No cut 

20-40 y 
No cut 
30-70 y 
No cut 
50-150 m3/ha 
No cut 
50-100 m3/ha 
No cut 
10-20 y 
Cut (at 20y) 

40-60 y 
No cut 
70-100 y 
No cut 
150-250 m3/ha 
Thinning (10%) 
100-200 m3/ha 
Thinning (5%) 

>60 y 
Cut (30%) 
>100 y 
No cut 
>250 m3/ha 
Thinning (20%) 
>200 m3/ha 
Thinning (15%) 

Note: More detailed information in the activities composing a FMP has to be given (this only focus on harvest, but it is not 
the only variable) 

Produce the areas by strata/FMP/age class for the year i+1 

0-20 y 

20-40 y 

Age classes/Area (kha) 
40-60 y 

Strata/FMP 
Pine 
commercial/FMP1 

Pine 
conservation/FMP2 

Mixed 
centre/FMP3 

Forest 

62 
0-30 y 

5 
0-50 m3/ha 

Mixed 
south/FMP4 

forest 

28 
0-50 m3/ha 

Eucalyptus 
plantation/FMP5 

55 
0-10 y 

51 
30-70 y 

30 
50-150 
m3/ha 
29 
50-100 
m3/ha 
52 
10-20 y 

76 
70-100 y 

60 
150-250 
m3/ha 
27 
100-200 
m3/ha 
42 

>60 y 

21 
>100 y 

25 
>250 m3/ha 

21 
>200 m3/ha 

21 

22 

28 

Total 

210 
Total 

120 
Total 

105 
Total 

170 
Total 

50 

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2.3.4.2  Harvest module  

The aim of this module is to estimate the total volume of wood harvested, based on the 
current year age-structure (dynamic) and the FMP (fixed). It has to take into account all 
kinds  of  harvesting  practices  in the  country  as  documented  in  Step  2  (see  section  2.2), 
including both clearcutting and thinning. 

Figure 11: Harvest module description. 

According to Article 8(5), the FRL shall not “unduly constrain future forest management 
intensity”. 

There are several alternatives for the implementation of this concept as shown in Box 12. 

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Box 12. Alternatives for the harvest module  

The  following  three  alternatives  may  be  considered  for  calculating  the  harvest  for  each 
combination of strata, FMP and age-class 19. 

Alternative 1: Maintain the ‘harvest to biomass available for wood supply’ ratio  

This alternative, included as part of the JRC approach (Grassi and Pilli 2017, Grassi et al. 2018), 
is based on maintaining the ratio between the harvest and the amount of biomass available for 
wood supply in MFL (for both final felling and thinning) constant over time. 

  Step  a:  Calculate  the  ‘biomass  available  for  wood  supply’  in  the  RP  (BAWSRP,  e.g. 
biomass within 80 and 140 years if clear-cutting or 20% of total biomass for silvicultural 
operations without final harvesting). 

  Step b: Document the harvest amount during the RP (HRP). 
  Step c: Estimate the Harvest Fraction of Management (HFMRP) during RP as: HFMRP= HRP 
/ BAWSRP. HFMRP is a proxy that expresses the impact of all constraints on the harvest 
during RP. 

  Step d: Estimate the future biomass available for wood supply (BAWSCP) by applying the 
same FMP of the RP to the expected age-related evolution of forest characteristics (e.g., 
biomass and increment). 

  Step e: Set future harvest (HCP) as: HFMRP x BAWSCP. 

This  approach  may  help  in  overcoming  the  situation  where  no  precise  information  on  specific 
FMP are available during the RP. 

Alternative 2: Maintain the ‘harvest to biomass’ ratio 

This is a more general alternative based on the previous Alternative 1. It uses the same step-
by-step  method  but  replaces  the  biomass  available  for  wood  supply  (BAWSRP  and  BAWSCP)  by 
the total biomass (TBARP and TBACP) 20. The steps for this alternative then become: 

  Step a: Calculate the total biomass in the RP (TBARP). 
  Step b: Document the harvest amount during the RP (HRP). 
  Step c: Estimate the Harvest Fraction of Management (HFMRP) during RP as: HFMRP= HRP 
/  TBARP.  HFMRP  is  a  proxy  that  expresses  the  impact  of  all  constraints  on  the  harvest 
during RP. 

  Step d: Estimate the future biomass available for wood supply (TBACP) by applying the 
same FMP of the RP to the expected age-related evolution of forest characteristics (e.g., 
biomass and increment). 

  Step e: Set future harvest (HCP) as: HFMRP x TBACP. 

Alternative 3: Maintain the harvest amount 

This alternative is to be considered as a last resort in cases where there is a lack of modelling 
capability  to  assess  the  relation  between  harvest  and  wood  available.  The  procedure  is  to 
document the harvest amount during the RP (HRP) and use it for the CP (HCP). It is important to 
point  out  that this  alternative does  not  consider  any  information  on  the  evolution  of the  forest 
and  just  assume  the  continuation  of  the  current  harvest  and,  therefore,  is  not  in  line  with  the 
LULUCF Regulation. 

19 If a country does not have statistics on harvest at such a level of disaggregation (strata/FMP/age class), the approach as presented in section 
2.2.8 could be applied. 
20 A further generalization of this approach based on areas instead of wood available will not be in line with the LULUCF Regulation as it 
would  not  take  into  account  the  age-structure  dynamics.  So,  it  is  not  a  good  practice  to  base  the  estimations  on  areas  in  this  harvest 
module. 

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2.3.4.3  Carbon pool variation module 

The  aim  of  this  module  is  to  estimate  the  variation  in  all  C  forest  pools  (above-ground 
biomass, below-ground biomass, dead wood, litter and soil organic carbon) based on the 
fixed data and the information estimated by the previous modules (dynamic data). 

Figure 12: C pools variation module description. 

The  results  of  this  module  have  to  be  consistent  with  the  estimations  in  the  GHGI. 
Additionally, it is  good practice  that  the input data  (i.e.  wood  density,  emission  factors) 
are  consistent  with  those  of  the  GHGIs.  So,  this  module  would  probably  use  a 
methodology similar to the one used in the national GHGI. 

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Box 13. Alternative of modelling for countries using stock-difference method  

This  modelling  takes  into  account  jointly  the  effect  of  harvest  and  the  C  pool  variations  at 
stratum/FMP/age  class  level.  Nevertheless,  a  model  for  the  age-structure  is  still  needed  to 
complement this approach. 

This  approach  is  focused  on  the  EU  Member  States  that  apply  the  Stock-Difference  Method 
(usually  known  as  carbon  stock  change  method,  CSC)  of  the  2006  IPCC  Guidelines  for  the 
estimation  of  their  national  GHGIs.  This  method  of  assessing  carbon  stock  changes  is  applied 
where carbon stocks in relevant pools are measured at two points in time (e.g. measurements 
of the NFIs). 

If based on NFI measurements, and if the NFI is reliable, this method is able, usually with low 
uncertainty  to  estimate  the  net  change  of  carbon  in  a  pool.  However,  it  does  not  provide 
information  on  potential gains  or  on  the  amount  and  type of  the  losses,  which  are  key  for  the 
developing of sound projections. In addition, the information of these gains and losses may not 
be available, which impairs the use of other approaches based on gains and losses. 

The  aim  of  this  approach  is  to  estimate  the  projected  FRL  based  on  the  information  currently 
used  in  the  GHGI  in  a  simple  way  such  that  it  is  able  to  both  be  perfectly  consistent  with  the 
GHG results, and take into consideration the FMP of 2000-2009 and the variations in the forest 
structure. 

The NFI inventory data, eventually combined with other data, may deliver activity data (usually 
the areas) and carbon stock change factors (CSCF) 21 for different forest classes (temporal and 
spatial as well as for other characteristics). A forest inventory can thereby provide data on the 
areas  of  forests  classified  by  a  number  of  parameters  (i.e.  it  can  provide  information  by 
stratum). 

At  GHGI  level,  it  is  common  to  use  a  single  country  specific  CSCF  (or  a  small  set  of  CSCFs), 
based on repeatedly measured NFI data for a historical year or time period. However, using the 
raw data of the NFI, it is also possible to derive different CSCFs by forest stratum and age class 
using  the  same  approach 22.  The  CSCF  per  area  unit  for  a  single  stratum  and  age  reflects  the 
impact of the forest management on this stratum regarding net emissions or removals per unit 
of area.  

So, the CSCFs of each stratum based on 2000-2009 data should reflect the FMP in those years. 
These CSCFs could be combined with the best available data for describing the areas and their 
combination will provide the C pool variations in the CP. 

The procedure will be the following: 

1.  Calculate the areas evolution using the age-structure module. 

2.  Calculate the CSCFs for each stratum/FMP/age class based on the NFI information that 

was used for the GHGI using RP (2000-2009) data. 

3.  Estimate the projections multiplying the RP CSCFs by the projected areas. 

2.3.4.4  The ‘fall-back’ approach 

This is a really simplified approach aimed to provide an estimation method in the absence 
of data to properly model the FRL. It can only be applied if the Member State can clearly 
demonstrate and document the complete lack of the minimum of data needed to model 
the  forest  dynamics.  It  is  important  to  point  out  that  here  we  refer  to  the  lack  of  input 
data, not of a model or a modelling framework. If a country has no model available but 
has available data, this approach is not an option and it is deemed good practice to either 
develop  or  obtain  a  suitable  model  for  estimating  the  FRL  (see  section  2.3.7  for  an 
overview of existing modelling frameworks that may be utilised). 

21 By CSCF, in this context, we refer to C variations in each pool by unit (usually ha). 
22 Strata in the FRL estimations and the categorization used in the GHG Inventory could differ (e.g. forest types vs. regions). However, as both 
classifications are based on the NFI data, the aggregated results should be equal. 

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For  the  carbon  pool  that  the  approach  is  selected  to  be  applied  for  (i.e.  above-below 
ground biomass, litter, dead-organic matter, or soil organic carbon), the approach would 
assume the continuation of historical GHG emissions and removals as observed in the RP. 
Therefore,  the  FRL  will  be  calculated  as  the  average  of  emissions  and  removals  for  the 
pool in the RP as included in the most up-to-date GHGI (i.e. the 2018 submission). 

2.3.5  Modelling the development of the harvested wood products  

This  section  provides  information  on  how  to  implement  the  calculation  framework  for 
estimating  emissions  and  removals  of  CO2  from  HWP  on  the  basis  of  changes  of  the 
carbon  pool  and  contains  some  background  information  on  the  assumption  of 
instantaneous oxidation.  

Box 14. Overview of key steps for estimating the carbon pool in HWP 

Phase  I:  Collect  time  series  of  HWP  activity  data  comprising  the  defined  HWP  default  categories 
‘sawnwood’, ‘wood-based panels’ and ‘paper and paperboard’ as well as harvest data to 
allocate HWP to domestic forests.  

Phase  II:  Calculate  HWP  originating  from  the  domestic  forest  land  category  ‘Forest  Land 

remaining Forest Land’ (FLrFL). 

a)  Estimate  the  share  of  HWP  originating  from  domestic  forests  by  means  of  relevant 

feedstock categories. 

b)  Allocate HWP from domestic forests to the land use category ‘Forest Land remaining 

Forest Land’. 

c)  Calculate the annual carbon inflow to the HWP pool. 

Phase III: Implement the HWP estimation method in line with the requirements (cf. Figure 13). 

2.3.5.1  Estimating the carbon pool in HWP 

In  order  to  implement  the  requirements  for  estimating  emissions  and  removals 
associated  with  HWP  as  set  out  in  the  LULUCF  Regulation  and  in  line  with  the 
requirements of the relevant IPCC guidelines, countries need to fulfil the following three 
phases. 

I. 

Collect  activity  data  for  the  defined  HWP  categories  from  relevant  production  and 
trade  statistics,  reflecting  the  national  circumstances  and  assort  data  time  series  for 
further  data  processing  accordingly,  e.g.  in  a  spreadsheet  programme.  Following 
elements  need  to  be  considered  in  relation  to  the  collection  of  the  required  activity 
data: 

I.1.  HWP categories 

I.1.1.  Activity data that could be used with the default method to estimate HWP 
contribution (i.e. first order decay function) as defined in Annex V of  the 
LULUCF Regulation. 

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These  estimates  on  the  basis  of  the  change  of  the  carbon  pool  in  HWP 
shall include (a) paper (b) wood panels and (c) sawnwood. The FAO  and 
IPCC  guidelines  provide  internationally  agreed  definitions  of  these 
aggregated  wood  product  commodities  and  further  specify  their  included 
subcategories. Detailed guidance can be found in section 2.8.1.1 of IPCC 
(2014).  For  calculating  the  carbon  content  of  those  commodities,  the 
relevant carbon conversion factors are provided in Table 2.8.1  of  section 
2.8.3.1 IPCC (2014) 23. 

In  the  case  that  countries  want  to  apply  country-specific  activity  data, 
section  2.8.4.1  of  IPCC  (2014)  further  specifies  the  possible  sets  of  data 
or sources which would be in line also with the LULUCF Regulation. 

These  data  comprise  HWP  item  data  following  the  international  HS 
nomenclature  and  classification  system  (i.e.  the  categories  ‘sawnwood’, 
‘wood-based panels’ and ‘paper and paperboard’) 

“These  data  could  be  available  from  country-specific  statistics  containing 
further  disaggregated  items  of  the  subcategories  as  specified  in  Table 
2.8.2.  Examples  would  be  coated  particle  board,  fibreboard  with  specific 
density  or  surface,  or  coniferous  sawnwood  made  from  specific  tree 
species  (e.g. 
item  data  using 
appropriate carbon conversion factors e.g. based on information on wood 
densities can contribute to considerably improve the accuracy of the HWP 
estimations.” (IPCC 2014). 

larch).  Introducing  disaggregated 

The  type  of  activity  data  that  could  be  combined  with  the  default  first 
order  decay  function  (Annex  V  of  the  LULUCF  Regulation)  could  be 
derived from either: 

  National statistical offices in the case of the above mentioned country-
specific HWP item data following the international HS nomenclature, 
or 

 

International statistics, e.g. FAOSTAT (which supposed to be 
consistent with data from national sources). 

I.1.2.  Activity data that would require also country-specific methods to estimate 

the emissions and removals of CO2 from HWP 

Other  country-specific  activity  data  which  do  not  follow  the  international 
HS nomenclature and classification system could be either: 

  Finished HWP that are further processed from the above mentioned 

categories, or  

  Data on buildings with different wooden construction components 

(made of those defined commodities). 

Both  type  of  data  would  require  the  application  of  also  country-specific 
methodologies as set out in section 2.8.4.2 of IPCC (2014) and could not 
be combined with the first order decay function as referred to in Annex V 
of the LULUCF Regulation. 

I.2.  Data for allocating HWP to ‘Forest Land remaining Forest Land’ (FLrFL)  

In order to allocate the HWP to the originating forest land category ‘Forest Land 
remaining  Forest  Land’  as  set  out  in  the  LULUCF  Regulation,  further  data  on 
harvest amounts originating from those lands is needed to estimate the share of 
HWP  removed  thereof.  Following  IPCC  (2014)  this  includes  the  feedstock 

23 The same information is expected to be included in Table 12.2 of section 12.5.2 of the IPCC 2019 Refinement. 

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commodities  ‘industrial  roundwood’  and  ‘wood  pulp’.  It  is  suggested  to  also 
include  ‘recovered  paper’  as  feedstock  commodity  for  the  HWP  category  ‘paper 
and  paperboard’  when  estimating  emissions  and  removals  from  HWP  applying 
the ‘production’ approach23. 

I.3.  Time series 

To fulfil the requirements of  IPCC  for  estimating the initial  carbon stock both in 
the  annual  reporting  as  well  as  in  calculating  the  HWP  contribution  to  the 
projected FRL, the activity data time series needs to comprise the years starting 
in 1990. Further information is provided in section 2.8.3 of IPCC (2014). 

II. 

Calculate  the  annual  carbon  inflow  to  the  HWP  pool  following  the  ‘production’ 
approach as set out in the LULUCF Regulation 

According  to  the  LULUCF  Regulation,  only  carbon  in  HWP  originating  from  domestic 
forests  (‘Forest  Land  remaining  Forest  Land’)  is  to  be  considered  in  the  FRL 
estimates 24. In consequence, the times series of data reflecting the annual production 
of HWP commodities as described in I.1 need to be allocated to the relevant domestic 
forest land category. This comprises three intermediate steps: 

STEP a: Estimate the share of carbon in HWP coming from domestic forests. For this 
purpose,  calculate  the  share  of  the  relevant  HWP  feedstock  categories  ‘industrial 
roundwood’,  ‘wood  pulp’  and  if  applicable  ‘recovered  paper’  being  used  (i.e. 
consumed)  for  manufacturing  the  relevant  HWP  categories  ‘sawnwood’,  ‘wood-based 
panels’  and  ‘paper  and  paperboard’  and  at  the  same  time  originating  from  domestic 
forests.  

STEP  b:  Estimate  the  annual  fraction  of  feedstock  for  the  HWP  categories 
‘sawnwood’,  ‘wood-based  panels’  and  ‘paper  and  paperboard’  originating  from  the 
particular land category ‘Forest Land remaining Forest Land’24. It is important to note, 
that  in  line  with  the  requirements  of  the  LULUCF  Regulation,  harvested  wood 
originating  from  Deforested  Land  is  to  be  treated  on  the  basis  of  ‘instantaneous 
oxidation’.  In  the  case  that  the  data  used  for  this purpose  (e.g.  harvest  amounts  as 
considered  for  previous  steps)  deviate  from  harvest  amounts  as  contained  in 
production statistics such as FAOSTAT, please explain the differences and the relation 
between those sets of data. 

STEP c: In order to obtain the annual fractions of HWP which originate from domestic 
harvest  and  the  relevant  land  category  to  be  considered  in  the  FRL,  combine  the 
information obtained from steps a and b. 

Further  methodological  guidance  with  relevant  equations  is  provided  in  section 
2.8.1.2 of IPCC (2014) 25. 

III. 

Implementation of the default first order decay function 

In  a  next  step,  the  calculated  annual  carbon  inflow  is  to  be  used  for  estimating  the 
annual  carbon  stock  and  its  changes  over  time  by  means  of  the  first  order  decay 
function  as  set  out  in  Annex  V  of  the  LULUCF  Regulation.  The  following  Figure  9 
provides  an  example  with  relevant  formulae  on  how  to  implement  this  equation 
consistent with IPCC (2014) in a spreadsheet model (e.g. Microsoft Excel). 

24 NOTE: “In the case that it is not possible to differentiate between the harvest from Lands subject to Afforestation and the FM, it is conservative 
and in line with good practice to assume that all HWP entering the accounting framework originate from FM.” (IPCC 2014). 
25 Similar information is expected to be included in section 12.5.2.1 (“Compilation of activity data for the ‘production’ approach”) of the IPCC 
2019 Refinement.  

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1

2

3

4

5

6

7

8

9

10

11

12

13

14

A

years

1990
1991
1992
1993
1994
1995
1996
…

B
half-life (hl)

C

35

decay constant k =LN(2)/C1
 term 'e -k ' of Eq. 12.2 =EXP(-C2)
term '[(1 ‒ e-k)/k]' of Eq. 12.2 =(1-EXP(-C2))/C2

D

Inflow

HWPj  carbon stock

stock-change

100,00 =AVERAGE(B7:B11)/C2
101,00 =$C$3*C7+$C$4*B7
150,00 =$C$3*C8+$C$4*B8
103,00 =$C$3*C9+$C$4*B9

95,00 =$C$3*C10+$C$4*B10
105,00 =$C$3*C11+$C$4*B11
100,00 =$C$3*C12+$C$4*B12

… …

=C8-C7
=C9-C8
=C10-C9
=C11-C10
=C12-C11
=C13-C12
=C14-C13
…

The  initial  carbon  stock  for  the  year  1990  is  calculated  in  cell  C7  as  suggested  in  IPCC  (2014).  The  FOD 
function used for calculating the carbon stock for the start of each subsequent year is implemented in cells 
C8:C13. Based on the development of the carbon stock of the particular HWP category, the stock-changes 
(i.e. carbon pool changes are calculated in the cells of column D). 

Figure  13:  Example  for  implementing  the  first  order  decay  function  in  a  spreadsheet  (e.g.  MS 
Excel).  

2.3.5.2  Assuming ‘instantaneous oxidation’ 

The  criterion  d)  of  Annex  IV  of  the  LULUCF  Regulation  for  calculating  emissions  and 
removals of CO2 from HWP as part of the FRL requires a comparison “between assuming 
instantaneous oxidation and applying the first-order decay function”. Furthermore, Annex 
V  of  the  LULUCF  Regulation  defines  that  also  “HWP  from  solid  waste  disposal  sites  and 
HWP  that  were  harvested  for  energy  purposes  shall  be  accounted  for  on  the  basis  of 
instantaneous oxidation”. 

The assumption of ‘instantaneous oxidation’ is based on the notion that the carbon pool 
in HWP is stable (i.e. carbon inflow to the HWP pool equals carbon outflow from the HWP 
pool).  In  consequence,  the  assumption  of  ‘instantaneous  oxidation’  corresponds  to  an 
estimate of no changes in HWP carbon stocks, with the result that emission and removals 
of  CO2  from  HWP  are  zero  (cf.  also  IPCC  2006).  Mathematically,  this  equals  the 
assumption that all carbon in the biomass harvested is oxidized in the removal year (i.e. 
year of harvest). It is important to note that the assumption of ‘instantaneous oxidation’ 
only relates to the HWP pool; carbon losses from the above ground biomass carbon pool 
in the forest (e.g. through harvest) are still included in the forest carbon pool estimates.  

Following  calculated  example  assuming  a  gain/loss  method  for  implementing  the  forest 
carbon  pool  estimates  illustrates  the  assumption  of  ‘instantaneous  oxidation’  to  be 
applied to the HWP pool only:  

1.  Forest C-pool above ground biomass 

C-pool Inflow (i.e. forest growth) = -100  

C-pool Outflow (i.e. harvest) = +90 

Emissions and removals from above ground biomass carbon pool = -10 

2.  HWP C-pool 

C-pool Inflow = -35 (example) 

C-pool Outflow = +35 

Emissions and removals from HWP carbon pool = 0 

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As a result of the assumption that all carbon in the biomass harvested is oxidized in the 
removal  year  (i.e.  in  the  year  of  harvest)  (cf.  inter  alia  IPCC  1997),  in  the  above 
example, no additional emissions and removals are to be added to the +90 (harvest).  

In  consequence  of  applying  ‘instantaneous  oxidation’,  only  emissions  and  removals 
associated with the use of harvested wood as material are to be estimated in the context 
of  the  LULUCF  Regulation.  Emissions  associated  with  the  use  of  wood  for  energy 
purposes are implicitly included in the forest carbon pool estimates. 

Further  detailed  information  on  the  assumption  of  instantaneous  oxidation  which  is 
described consistently with relation to the carbon pool in HWP is provided in IPCC (1997) 
and IPCC (2014). 

2.3.6  Modelling the development of natural disturbances  

In  the  LULUCF  Regulation,  NDs  are  defined  as  “any  non-anthropogenic  events  or 
circumstances that cause significant  emissions in forests and the occurrence of which is 
beyond  the  control  of  the  relevant  Member  State,  and  the  effects  of  which  the  Member 
State  is  objectively  unable  to  significantly  limit,  even  after  their  occurrence,  on 
emissions” (Article 3(1.9)). 

NDs,  such  as  wildfires,  insect  and  disease  infestations,  extreme  weather  events  and 
geological disturbances are recognized to result in emissions that are beyond the control 
of the Member States (recital 20 of the LULUCF Regulation preamble). Consequently, the 
LULUCF  Regulation  provides  a  possibility  to  exclude  emissions  resulting  from  NDs  that 
exceed the average emissions caused by NDs in the period from 2001 to 2020 26. 

The (voluntary) exclusion of the NDs from the Member States’ accounts is done through 
including a ‘background level’ in the FRL (Article 10).  The background  level is a level of 
annual  disturbances  based  on  average  historical  occurrences,  and  calculated  as  “the 
average  emissions  caused  by  natural  disturbances  in  the  period  from  2001  to  2020, 
excluding statistical outliers” (Article 10). At the end of each five-year CP, the emissions 
caused by NDs that exceed this background level (with a margin of a probability of 95%) 
may  be  excluded  from  the  accounts.  The  calculation  and  use  of  the  background  level is 
further specified in Annex VI of the LULUCF Regulation. 

If a Member State chooses to use this ND provision, the background level will be included 
in the FRL and the emissions from NDs are implicitly excluded from accounting up to the 
background level. This means that if a Member State uses this provision, the projection 
of the FRL must exclude any further assumptions of the effect of the ND (e.g. stochastic 
modelling  of  storms  and  their  effects  on  forest)  in  the  FRL  and  only  consider  the 
background level of emissions from NDs. 

If  the  ND  provision  is  used,  the  Member  State  is  required  to  submit  information  on  the 
background level and the methodologies used to the Commission (Article 10.2(a)). Also, 
the Member State “shall exclude from accounting until 2030 all subsequent removals on 
the land affected by natural disturbances” (Article 10(2)).  

Note  that  in  the  context  of  LULUCF  accounting,  ‘removal’  refers  to  anthropogenic 
removals of carbon from the atmosphere; that is, it should not be mixed with harvesting 
of wood from logging sites. Article 10(2) means therefore that if a land is affected by a 
ND and this emission is excluded from the accounts, management of  this land after the 
ND (e.g. replanting) may not be considered to contribute to GHG removals until 2030. It 
is  also  important  to  note  that,  as  defined  in  Annex  VI  of  the  LULUCF  Regulation, 

26  This  approach  is  consistent  with  the  principles  and  approaches  described  in  IPCC  2014  (section  2.3.9.6,  “Guidance  on  the 
development of the background level and margin”). 

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emissions  resulting  from  harvesting  and  salvage  logging  that  took  place  after  the  ND 
shall not be excluded from the accounts (Annex VI.4(a)). In addition, emissions from 
prescribed  burning  or  deforestation  after  the  ND  shall  not  be  excluded  (Annex  VI.4(b)-
(c)).  

Annex VI of the LULUCF Regulation provides details for how the background level of NDs 
is to be calculated and documented. The main aspects are recalled in Box 15.  

Box 15. Calculation of background levels for natural disturbances 

Background level definition 

The  background  level  of  NDs  is  calculated  as  the  average  of  the  2001-2020  time  series, 
excluding statistical outliers (years with abnormal levels of emissions). 

Information to be provided regarding the calculation of the background level 

(a)  Historical levels of emissions caused by NDs 

(b)  The type(s) of ND included in the estimation 

(c)  Total  annual  emissions  for  those  ND  types  for  the  period  from  2001  to  2020, listed  by 

land accounting categories 

(d)  A  demonstration  of  the  time  series  consistency  in  all  relevant  parameters,  including 
minimum  area,  emissions  estimation  methodologies,  coverages  of  carbon  pools  and 
gases.  

How to identify a statistical outlier? 

(a)  Calculate the arithmetic average value and the standard deviation for the full time series 

2001-2020. 

(b)  Exclude  all  years  for  which  the  annual  emissions  are  outside  twice  the  standard 

deviation. 

(c)  Calculate  the  arithmetic  average  value  and  standard  deviation  again,  excluding  the 

years identified in point (b).  

(d)  Repeat point (b) and (c) until no outliers can be identified. 

If a Member State pursues Article 10(2) to exclude emissions exceeding the background 
level,  the  following  information  will  need  to  be  provided  (Annex  VI.5  of  the  LULUCF 
Regulation): 

(a) Identification  of  all  land  areas  affected  by  NDs  in  that  particular  year,  including 

their geographical location, the period and types of NDs 

(b) Evidence  that  no  deforestation  has  occurred  during  the  rest  of  the  CP  on  lands 

excluded from accounting because of NDs 

(c) A description of verifiable methods and criteria to be used to identify deforestation 

after the CP 

(d) Where feasible, a description of measures taken to prevent or limit the impact of 

NDs that occurred 

(e) Where feasible, a description of measures taken to rehabilitate the lands affected 

by NDs 

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2.3.7  Modelling frameworks  

A  number  of  existing  modelling  frameworks  may  be  used  by  countries  to  estimate  the 
FRL.  Box  16  provides  some  examples  of  modelling  frameworks  that  are  available  and 
may  be  employed  to  project  the  development  of  forests.  An  overview  of  a  number  of 
these modelling frameworks can be found in Schelhaas et al. (2017). However, this is not 
an exhaustive list, and new systems may be developed to project the FRLs.  

Box  16.  Examples  of  modelling  frameworks  to  project  the  development  of 
forests 

  G4M – The Global Forest Model (Kindermann et al. 2008; Gusti 2010) 
http://webarchive.iiasa.ac.at/Research/FOR/globiom/forestry.html  

 

EFISCEN – The European Forest Information Scenario model (Verkerk et al. 2014) 
http://www.efi.int/portal/  

  CBM-CFS3 - Carbon Budget Model of the Canadian Forest Sector (Pilli et al. 2013) 

http://www.nrcan.gc.ca/forests/climate-change/carbon-accounting/13107  

 

 

 

EFDM - The European Forest Dynamics Model (Packalen et al. 2014) 

YASSO model (for SOC) (Liski et al. 2005) 
http://en.ilmatieteenlaitos.fi/yasso  

FVS - Forest Vegetation Simulator  
https://www.fs.fed.us/fvs/  

  CASMOFOR – Carbon Sequestration Model for Forestations 

www.scientia.hu/casmofor  

To  increase  reliability  of  the  estimation,  a  Member  State  may  use  projections  of  more 
than one model, especially in case if Member State does not have country specific model 
(Boettcher et al., 2012). 

A  number  of  national  forest  system  models  also  exist  that  may  be  utilized  within  the 
context  of  the  FRL,  such  as  CALDIS  (Ledermann  et  al.,  2017),  FOHOW  (Schwarzbauer 
and Stern, 2010), CARBWARE (NIR Ireland, 2018), Heureka (Wikström et al. 2011), SF-
GTM and MELA (FMRL Finland, 2011), and CARBINE and RECONCILE (NIR UK, 2018). 

It is important to point out that these models are designed to provide the best estimates 
of the future development of the forest. However, FRL  estimations are constrained by a 
number  of  mandatory  requirements  included  in  the  LULUCF  Regulation.  Therefore,  it  is 
responsibility of the country to make sure that those constraints (e.g. FMP practices from 
2000-2009, lack of changes in the total area of a stratum/FMP) are properly included in 
the model, so the results are in line with the LULUCF Regulation. 

2.3.8  Documenting the methodology used  

According  to  the  LULUCF  Regulation,  the  FRL  “shall  be  based  on  transparent,  complete, 
consistent, comparable and accurate information” (Annex IV.A(h)). It is good practice for 
Member  States  to  extensively  document  the  method  that  has  been  applied  for  the 
projection  of  the  FRL  in  order  to  provide  the  needed  transparency  for  the  reviewing 
process.  

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2.4  Consistency with greenhouse gas inventories 

Step 4: Calibration and consistency with greenhouse gas inventory estimates 

Calibrate  the  selected  methodology  based  on  real  observed  data  and  show  that  the 
methodology is able to reproduce historical data from the national GHGI. 

This subsection is structured as follows: 

2.4.1 Introduction (p. 70) 

2.4.2 First phase: consistency of the management practices (p. 71) 

2.4.3 Second phase: consistency of the emissions and removals estimates (p. 72) 

2.4.4 Third phase: consistency of the time series (p. 74) 

2.4.1  Introduction 

In this step, it is shown that the methodology as selected in Step 3 (see section 2.3) is 
able  to  reproduce  the  existing  and  documented  historical  data  as  reported  in  the  latest 
publicly available national GHGI for MFL. 27 Historical data here refers to the period 2000-
20XX;  where  20XX  is  the  latest  inventory  year  available  in  the  national  GHGI  at 
time  the  FRL  is  constructed.  It  is  suggested  that  Member  States  document  that  the 
methodology  is  able  to  reproduce  historical  data  through  the  use  of  the  set  of  tables 
provided in Table 10. 

The calibration step has two separate and concurrent goals: 

1.  to verify that the model is able to reproduce historical GHG estimates. This means 
that, given the set of equations and parameters that compose the model and the 
set  of  input  data  for  FMPs,  the  model  produces  output-values  of  GHG  estimates 
that are actually consistent with those reported for the historical time period. 

Differences between historical data and the model-outputs may be explained: 

i. 

ii. 

in 

errors 

the  model 

parametrization 
as 
(Errorsmodel/parameter)  –  e.g.  the  function  for  calculating  the  biomass 
increment  does  not  calculate  correctly  the  increment  actually  occurred  in 
the historical period – or 

formulation 

and/or 

as inconsistencies between the input dataset and actual variables in the RP 
(Errorsmanagement_dataset) – e.g. forests of type X are assumed to be subject to 
a thinning at age 20 (with intensity Y) and 40 (with intensity Z) and a final 
harvest at age 60, although thinning actually occurs in average only  once 
between age 20 and 40 (with intensity within the range Y-Z) and the final 
harvest not always occurs -and usually not exactly at the established age-; 

i.e. Estimatemodelled = Estimatehistorical + Errorsmodel/parameter + Errorsmanagement_dataset 

To exclude the second source of errors, the calibration step needs also: 

2.  to  verify  that  the  set  of  management  practices  used  as  input into  the  model  are 

consistent with those actually applied in the RP. 

To  achieve  both  goals,  a  4-phase  serial  procedure  for  the  calibration  process  is 
hereafter proposed. 

27 As publically available by the time of submission of the FRL. 

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2.4.2  First phase: consistency of the management practices 

In the first phase, the datasets of actual management practices 28 in the RP (AMPRP), 
as  compiled  at  Step  2  (see  section  2.2.5),  and  modelled  management  practices 
(MMPPP)  to  be  applied  as  input  data  in  the  Projection  Period  (PP)  to  project  the  FRL,  as 
compiled at Step 2 (see section 2.2.5), are checked to verify their mutual consistency. 

Such  checking  may  be  done  at  the  national  level  of  e.g.  total  harvest,  or  at  level  of 
harvest allocated at each stratum, depending on the features of the applied model. 

The  guidance  in  Box  17  applies  to  quantitative  variables  of  management  practices  (e.g. 
the  age  at  which  the  final  clearcutting takes  place,  harvested  wood  over  the  total  wood 
available  for  harvest).  However,  non-quantitative  variables,  if  any,  impact  the 
quantitative  variables  and  therefore  are  indirectly  checked  (e.g.  it  is  a  management 
practice  to  salvage  log  all  wood  in  all  forests  impacted  by  disturbances),  the  impact  of 
such  management  practice  can  be  identified  in  the  variable  “harvested  wood  over  the 
total wood available for harvest” and accordingly verified. 

Box  17:  Description  of  the  two  proposed  alternatives  for  verifying  mutual 
consistency  between  the  set  of  actual  management  practices  (AMPRP)  and 
modelled management practices (MMPPP) 

Alternative A:  

In cases where AMPRP shows a variability in the management practices across RP (e.g. “harvested 
wood  over  the  total  wood  available  for  harvest”)  without  a  clear  trend,  the  central  value  of  the 
distribution of AMPRP is used as MMPPP, and the following conditions should be met: 

• 

• 

the MMPPP should be either the mean or the median 29 value, or a value comprised between 
those two, of the distribution built. This aims at identifying the MMPPP as the central value 
of AMPRP; 

the outliers in the distribution of actual management practices should have been excluded 
from the calculation of its central value.  

Alternative B:  

In cases where AMPRP shows a variability in the management practices across RP (e.g. “harvested 
wood  over  the  total  wood  available  for  harvest”)  with  a  clear  trend,  the  latest  value  of  the 
distribution of AMPRP is used as MMPPP, and the following conditions should be met: 

• 
• 

the MMPPP is the latest value of AMPRP; 

the MMPPP is not a rate of change observed between the latest value and any other value of 
the AMPRP. Indeed, any change projected in the future implies a change in BAU conditions 
that have caused that change and therefore a deviation from historical BAU conditions, and 
such deviation is the subject of the accounting mechanism (which means that its impact on 
accounting cannot be zeroed through its inclusion in the FRL). 

Note that it may occur that data on actual management may not be suitable (robust) to 
ensure  that  the  model  may  correctly  reproduce  historical  estimates.  However,  any  gap-

28 The modelled management practice are the FMPs with quantitative values that specifies each management practice associated with the FMP. 
For instance, assuming that an FMP includes a final clearcutting, the timing of when the clearcutting take place may vary each year across the RP 
2000-2009. The modelled management practice is the FMP with a single value specifying when the final clearcutting takes place to be used to 
project the FRL. Another example is the management practice “harvested wood over the total wood available for harvest” which value varies each 
year across the RP 2000-2009; the modelled management practice is the single value of “harvested wood over the total wood available for 
harvest” that represents such variable in the RP. See section 2.2.5 for further details. Two alternatives for verifying the consistency between the 
actual and modelled management practices are provided in Box 16. 
29 Given that the RP is a relatively short period, the set of available data will likely be an incomplete distribution of values. In case of incomplete 
distributions, the median is a better estimator of the "typical" value of a variable than the mean since it is not skewed so much by extremely large 
or small values typical of incomplete distributions. Furthermore, the median always has equal probability to be either over or under the true value 
(although it does not necessary represent the value that minimizes the error). 

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filling  of  information  should  be  done  after  the  second  phase  is  carried  out  with  the 
information available (without any gap-filling). 

2.4.3  Second phase: consistency of the emissions and removals 

estimates  

the  actual  management  practices 
After  verifying  mutual  consistency  between 
implemented  in  the  RP  (AMPRP)  and  the  modelled  management  practices  applied  for 
projecting the FRL (MMPPP), the second phase is to be performed.  

The  main  aim  of  the  second  phase  is  to  verify  the  consistency  between  historical  data 
(2000-20XX),  as  reported  in  the  national  GHGI,  and  model  projected  estimates  for  the 
same historical period. 

When verifying the ability of the model to reproduce historical GHG estimates, the set of 
actual  management  practices  (AMP)  across  for  the  RP  and  the  subsequent 
historical  period  (i.e.  2000-2009  and  2010-20XX)  is  to  be  used  instead  of  the 
modelled management practice (MMP). The verification is to be done in this manner 
regardless  of  whether  alternative  A  or  B  was  used  in  the  first  phase  to  verify  the 
consistency between AMP and MMP (see Box 16). For the state of forest and age-related 
information, the data to be used by the model to project the historical period 2000-20XX 
are  either  the  closest  to  20XX,  if  the  model  is  capable  to  project  backward,  or  those 
closest to the beginning of the RP. See Figure 14. 

The FRL is the projection of forest C stocks according to historical management practices. 
Where forest C stocks vary because of: 

• 

• 

the legacy effect of management activities and disturbances that occurred before 
the first year of the time period for which the projection is made; 

the management practices and disturbances that will occur in the time period for 
which  the  projection  is made,  under  the  assumption  that the  same  management 
practices as those applied in the historical period will apply. 

Because  the  verification  of  outputs  may  only  be  done  for  historical  periods,  the  model 
used  for  projecting  the  FRL  must  produce  estimates  for  the  same  historical  period.  The 
historical  data  on  forest  area  and  C  stocks  (i.e.  the  state  of  forest  &  age-related 
information),  as  stratified  according  to  relevant  variables  that  determine  the  C  stock 
gains and losses, used by the model to project the historical period 2000-20XX are either 
the  latest  (if  the  model  is  capable  to  project  backward),  or  those  closest  to  the  year 
2000. 

Verification consists in the comparison of model’s outputs and actual data as reported in 
the national GHGI: 

Ideally, two variables are to be verified: gains and losses; 

 
  Pools  to  be  verified  are  all  those  for  which  a  non-zero  net  change  is  included  in 
the FRL. Ideally the biomass pools are verified in isolation; although also other C 
pools  i.e.  dead  organic  matter,  soil  organic  matter  and  HWP  may  be  verified  in 
isolation.  In  any  case,  the  verification  is  also  performed  at  level  of  total  GHG 
emissions and removals; 

  These will be verified at the level of aggregation at which they are projected (e.g. 

fuelwood vs industrial roundwood); 

  Both the level and the trend need to be verified: 

-  For verifying the level, the sum of the time series of historical data should 
be compared with the sum of model’s outputs. The verification is positive if 

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they  are  one  within  one  standard  deviation  (i.e.  the  68%  confidence 
interval 30) of the other, otherwise the model’s outputs need to be refined. 

•  Other  statistical  tests  may  be  applied;  to  evaluate  the  similarity  of 
the precisions of the two datasets (e.g. the Fisher's test) or the bias 
(as  the  Student’s  t-test,  the  Cochran  t-test,  the  Anova  test); 
although  the  shortness  of  time  series  may  impair  the  validity  of 
such tests. 

-  For verifying the trend (this test is done before the impact of disturbances 

is replaced by its background level of emissions): 

• 

• 

the  inter-annual  variability  within  the  projected  time  series  should 
not be larger than that reported in the GHGI; 

the direction of the trend should be the same, i.e. same highs and 
lows, same trendline when applying moving averages 31. 

If the model results for the verification do not match the above-listed requirements, it is 
recommended to: 

 

 

first assess if information on historical management can be gap-filled to enhance 
the consistency of model’s outputs with historical estimates. In cases where such 
gap-filling  does  not  enhance  the  quality  of  model’s  outputs  making  them  match 
the above-listed requirements, 

then revise the model applied or use an alternative model. 

A procedure of gap-filling of information on the management practices applied in 
the RP should: 

  First  provide  the  information  needed  for  gap-filling.  This  could  be  done  for 
similarities  with  management  activities  of  the  following  period  if  information 
needed is available for the period following RP; or by using expert judgement. 

  Second provide information to support the validity of the use of such information. 

  Third  describe  the  impact  on  the  model’s  outputs  for  the  historical  period  of  the 

information applied for gap-filling. 

  Fourth describe the impact on the model’s outputs for the projected period of the 

information applied for gap-filling. 

The verification is done with historical data of the period 2000-20XX. 

30 This is consistent with the IPCC approach to define “likely” confidence in the likelihood of an outcome or result 
31 E.g. 3 or 5 years rolling average. 

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Figure 14: An overview of the process of reproducing the historical estimates as documented in the 
latest national GHGIs for MFL. 

2.4.4  Third phase : consistency of the time series 

This  phase  is  applied  to  check  if  the  entire  time  series  of  estimates  (i.e.  historical 
estimates and projected estimates) is consistent and where inconsistencies are found, to 
adjust the projected estimates. 

An inconsistency in the time series is quantified as follows: 

  Step I. apply an iterative process to the entire time series: historical period and 
projected  period,  to  exclude  outliers  (if  any)  that  are  larger  than  the  mean  plus 
two times the standard deviation in each successive iteration. From the remaining 
values  of  the  time  series,  calculate  a  new  dataset  of  the  interannual  rate  of 
change (e.g. (Estimate2016 - Estimate2015) / Estimate2015); 

  Step  II.  calculate  the  average  value  and  the  standard  deviation  of  the  new 

dataset; 

  Step  III.  identify  an  inconsistency  in  the  time  series  between  the  last  historical 
year and the first projected year that are not  affected by NDs, if the  interannual 
rate of change is larger than the average value plus twice the standard deviation. 

In cases where no inconsistency is found, this phase does not apply. 

In cases where an inconsistency is found, one of the techniques provided in section 5.3.3 
of  volume  1  of  the  2006  IPCC  Guidelines,  should  be  applied  to  ensure  time  series 
consistency.  

The  aim  of  these  techniques  is  to  ensure  that  no  any  inconsistencies  occur  in  the  time 
series. That means that any differences between subsequent years  should not be larger 
than the observed variability in the time series of historical data. Further, trends should 
have consistent behaviour across time.  

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In  cases where the two trends show a consistent behaviour across time, an adjustment 
factor of the projected estimates can be calculated by comparing the overlap between a 
set  of  annual  estimates  composed  from  as  many  years  as  possible  (this  is  because 
comparing  only  single  years  will  likely  lead  to  bias  and  make  it  impossible  to  evaluate 
trends).  The  following  equation  taken  from  Volume  1  of  the  2006  IPCC  Guidelines 
(equation 5.1) applies: 

Where: 

𝑛𝑛

𝑦𝑦0 = 𝑥𝑥0 ∗ �

1
(𝑛𝑛 − 𝑚𝑚 + 1)

∗ �
𝑖𝑖=𝑚𝑚

𝑦𝑦𝑖𝑖
𝑥𝑥𝑖𝑖

�

 = the recalculated emission or removal estimate computed using the overlap method; 

𝑦𝑦0

 = the estimate developed using the previously used method; 

 and 

 are the estimates prepared using the new and previously used methods during 

𝑥𝑥0
the period of overlap, as denoted by years m through n. 
𝑦𝑦𝑖𝑖
Table 10: Suggested set of tables (one for the three variables: Biomass gains, Biomass losses, Net 
GHG  emissions/removals)  to  document  that  model  estimates  for  the  CP  are  within  the  estimated 
range of variability of the GHGI estimates. 

𝑥𝑥𝑖𝑖

Model estimate of either 
-  Biomass gains 
-  Biomass losses 
-  Net GHG 

emission/removals  

GHGI estimates for 
the same variable 

68% confidence 
interval of GHG 
estimates 

Year 

2000 

2001 

2002 

2003 

2004 

2005 

2006 

2007 

2008 

2009 

2010 

2011 

2012 

2013 

2014 

2015 

2016 

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2.5  Projections 

Step 5: Projection of emissions and removals 

Project  the  future  development  of  anthropogenic  forest  GHG  emissions  by  sources  and 
removals by sinks for the CP.  

This subsection is structured as follows: 

2.5.1 Introduction (p. 76) 

2.5.2 Assumptions concerning climate change (p. 77) 

2.5.3 Assumptions concerning area development of managed forest land (p. 78) 

2.5.4 Starting year for the projection of the FRL (p. 80) 

2.5.5 Assumptions concerning the period from 2010 to 2020 (p. 82) 

2.5.6 Assumptions concerning harvested wood products (p. 84) 

2.5.7 Possible problems with the projections and how to address them (p. 86) 

2.5.1  Introduction 

In  this  step,  the  methodology  as  selected  in  Step  3  (see  section  2.3)  and  calibrated  in 
Step  4  (see  section  2.4)  is  used  to  project  the  future  development  of  anthropogenic 
forest GHG emissions by sources and removals by sinks for the CP. That is, the modelling 
framework  applied  by  a  Member  State  is  in  this  Step  used  to  project  the  FRL  for  the 
periods 2021-2025 and 2026-2030 (see Figure 15).  

In  this  part  of  the  technical  guidance  document  we  will  focus  on  key  assumptions  that 
need to be taken for carrying out this particular task. 

Figure 15: Overview of how the various steps fit together in relation to a timeline of the reference 
and CPs. In this figure, the red dot at 2010 illustrates the default starting years for the projections 
(See section 2.5.4 for further details).  

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2.5.2  Assumptions concerning climate change 

2.5.2.1  Overview 

Estimates  of  the  FRL  may  be  affected  by  changes  in  future  climatic  conditions  such  as 
changes in precipitation, temperature, and CO2 and nitrogen deposition feedbacks. These 
changes  may  have  a  direct  impact  on  aspects  such  as  forest  growth,  mortality  and 
biomass decomposition rates, thereby influencing the projection of emissions by sources 
and removals by sinks from MFL.  

Depending on the modelling framework as selected in Step 3 (see section 2.3), different 
assumptions  may  be  made  concerning  future  climatic  conditions  and  the  related  carbon 
impacts for the projection of the FRL.  

Box  18  shows  two  distinct  alternatives  proposed  for  dealing  with  climate  change  during 
the CP. 

Box 18. Consideration of climate change during the CP 

Alternative 1: No consideration to future climate effects  

For  the  projection  of  the  FRL,  use  the  same  climatic  conditions  as  for  a  historical  time  period 
(depending on data availability) for which the climatic conditions are known. If this alternative is 
selected  and  applied  by  a  Member  State,  it  is  simply  assumed  that  the  climatic  conditions  will 
not change during the CP (i.e. constant over time). 

It  is  good  practice  that  a  Member  State  selects  to  apply  this  alternative  if  the  modelling 
framework  selected  in  Step  3  (See  section  2.3)  to  project  the  FRL  is  not  able  to  consider 
changes in climatic conditions. This alternative may also be selected if the modelling framework 
selected  in  Step  3  is  able  to  consider  changes  in  climatic  conditions,  but  the  uncertainty 
associated with the climate change modelling is deemed too high.  

Alternative 2: Projection of the assumed future climatic conditions  

This alternative is for Member States that consider a change to future climatic conditions while 
projecting  the  FRL.  By  this  alternative,  it  is  assumed  that  the  future  climatic  conditions  are 
known  and  the  impacts  of  the  related  changes  are  taken  into  account  in  the  projection  of  the 
FRL.  If  the  methodology  selected  in  Step  3  is  able  to  model  future  changes  in  climatic 
conditions,  a  Member  State  may  select  to  apply  this  alternative  and  take  such  changes  into 
account in the projection of the FRL.  

For  this  alternative,  country-specific  climate  projections  may  be  applied,  including  downscaled 
climatic  conditions  for  the  SSP-RCP  scenarios  (Moss  et  al.  2010).  National  estimates  of  the 
historical trend in climatic conditions may also be applied to project the FRL. A simple example 
of  such  an  approach  would  be  to  calculate  a  geographically  explicit  historical  trend  in  climatic 
conditions, and assume that the same trend will continue during the CP. 

Given  that  the  FRL  for  the  CP  shall  be  based  on  “the  continuation  of  sustainable  forest 
management  practice,  as  documented  in  the  period  from  2000  to  2009  with  regard  to 
dynamic age-related forest characteristics in national forests” (Article 8(5)), it is not good 
practice  to  adapt  or  modify  the  quantifiable  information  that  define  when  and  how  a 
management  practice  is  carried  in  the  CP  based  on  changes  in  climatic  conditions. 
Change  in  climatic  conditions  may  for  example  impact  site  specific  growing  conditions 
and related emission factors, but the management activities for each FMP, as defined and 
documented in Step 2 for the RP, are to be consistently applied from the starting year of 
the projection onward (see section 2.5.5). 

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2.5.2.2  Documentation and technical corrections 

It is good practice that a Member State clearly specifies, documents and justifies which of 
the two alternatives is applied for climate change assumptions in the projection of FRL for 
the CP. 

If Alternative 2 is selected by a Member State, it is good practice to  document in detail 
which  assumptions  and  projections  for  future  climatic  conditions  are  being  applied,  and 
where the data for the projection can be found. In addition, if Alternative 2 is selected to 
be  applied,  it  is  good  practice  that  a  Member  State  documents  the  potential  impact  on 
the FRL of selecting Alternative 2 instead of Alternative 1. 

If a Member State selects to apply Alternative 2, it is good practice to submit a technical 
correction  to  correct  for  any  potential  differences  between  the  projected  and  actual 
climatic  conditions  during  the  CP.  As  long  as  methodological  consistency  is  fulfilled,  a 
technical correction may be applied by a Member State based on the climatic conditions 
that actually took place during the CP instead of the projected climatic conditions applied 
for the calculation of the FRL.  

Estimating  and  applying  when  necessary  such  a  technical  correction  would  remove  any 
erroneous  estimates  of  carbon  balance  development  simply  caused  by  differences 
between  the  projected  climatic  conditions  and  the  climatic  conditions  that  actually 
occurred. 

2.5.3  Assumptions concerning area development of managed 

forest land 

2.5.3.1  Overview 

The area of MFL may change during the CP due to two related processes: 

  Afforestation, where ‘land converted to forest land’, as reported in the GHGIs, has 
reached the  end  of the 20-year  conversion period 32 and  starts being reported as 
MFL. 

  Deforestation,  where  MFL  is  converted  other  land  uses  and  starts  being  reported 

as ‘forest land converted to other land uses’ (as reported in the GHGIs).  

There  are  two  distinct  alternatives  proposed  to  project  the  area  of  MFL  during  the  CP, 
shown in Box 19.  

2.5.3.2  Documentation and technical correction 

It is good practice that Member States document and justify which of these alternatives 
they have applied for the projection of the MFL. As the two processes of afforestation and 
deforestation both affect the area of MFL and the carbon impacts, it is important that two 
processes are dealt with in a consistent manner. It is therefore not good practice that a 
Member  State  applies  one  of  the  above  described  alternatives  for  afforestation  and  a 
different alternative for deforestation. 

It can be noted that Alternative 2 requires that a Member State applies a methodological 
framework  to  project  the  FRL  that  over  time  considers  area  gains  and  area  losses. 
Furthermore, the framework needs to consider the geographically explicit change of land 

32 The conversion period is normally 20 years (Article 5(3)). However, as stated in Article 6(2), a 30-year conversion period may be used ”if duly 
justified based on the IPCC Guidelines”.  

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and the corresponding updates of the area allocated to strata and FMPs. In such a case, 
it  is  good  practice  that  area  gains  and  area  losses  are  allocated  to  strata  and  FMPs 
according  to  2000-2009  data,  and  that  Member  States  clearly  document  and justify  the 
selected approach. 

For  both  alternatives,  it  is  good  practice  to  perform  and  submit  a  technical 
correction  based  on  the  area  development  and  changes  to  strata  that  actually  took 
place during the CP, instead of the area development initially applied for the  calculation 
of  the  FRL.  Such  a  technical  correction  removes  any  erroneous  estimates  of  carbon 
development simply caused by differences between the assumed area development and 
the  area  development  that  actually  took  place  during  the  CP.  This  technical  correction 
has  to  be  done  ensuring  methodological  consistency  between  the  method  used  for 
calculating the FRL and the technical correction. 

In  conclusion,  as  long  as  a  Member  State  applies  a  technical  correction,  the 
outcome of applying Alternative 1 or Alternative 2 are expected to be the same. 

Box 19. Assumptions concerning the development of MFL area during the CP 

Two  distinct  alternatives  are  proposed  for  modelling  the  development  of  MFL  area  over  time. 
Independently  of  the  alternative  selected  for  the  development  of  MFL,  it  is  good  practice  to 
estimate  and  apply  a  technical  correction  to  remove  any  erroneous  estimates  of  carbon 
development  caused  by  differences  between  the  assumed  area  development  and  the  area 
development that actually took place during the CP. 

Alternative 1: Assume constant area of managed forest land  

For this alternative it is assumed that the area of MFL aggregated remains constant over time. 
In  other  words,  the  area  of  land  allocated  to each  stratum  remains  constant  from  the  starting 
year  of  the  projection  (thereby  not  extrapolating  into  the  future  any  possible  trends  observed 
during  the  RP)  and  no  significant  yearly  changes  are  considered  in  the  projection  of  the  FRL. 
The stratification of the MFL (and the area of land allocated to each stratum) as documented for 
the year of start of the projection is thereby to remain constant throughout the CP. 

Alternative 2: Assume dynamic development of managed forest land 

In this alternative, changes in future area development of MFL are modelled in the projection of 
the FRL. 

For  this  alternative,  it  is  good  practice  to  estimate  area  gains  (land  entering  to  the  MFL 
category) based on the historical and documented area of land classified as ‘land converted to 
forest’ as reported in the GHGIs. Based on this data source and the default 20-years transition 
period,  the  area  gains  for  a  specific  year  can  be  calculated  as  the  area  of  ‘land  converted  to 
forest’  that  reached  the  end  of  the  20-year  transition  period.  In  other  words,  the  area  of  land 
that entered into the category ‘land converted to forest’ in the year 2000 provides the estimate 
of  area  gains  for  the  year  2020  (as  this  is  when  the  20-years  transition  period  will  end).  The 
area gains may be allocated to strata according to historical or geographic explicit data sources. 
To  summarize,  the  area  of  land  under  ‘land  converted  to  forest’  during  the  period  of  2000  to 
2010 and documented in the GHGIs becomes the area gains for the period of 2020 to 2030. 

To  estimate  area  losses,  it  is  good  practice  that  a  Member  State  uses  the  average  of  the 
historical and documented area of ‘forest land converted to other land-uses’ for the period from 
2000  until  2016  as  reported  in  the  GHGIs.  In  other  words,  it  is  good  practice  that  a  Member 
State  calculates the  yearly  average  of  ‘forest  land converted to other land-uses’  for  the  period 
from 2000 to 2016, and apply this yearly average from the starting year of the projection of the 
FRL.  

When  applying  this  alternative,  it  is  important  to  calculate  the  area  of  MFL  for  each  individual 
year  during  the  CP  using  the  annual  projection  of  area  gains  and  area  losses.  In  other  words, 
the projected area of MFL should be calculated for each individual year by adding the estimated 
gains in area and subtracting the expected losses in area. 

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2.5.4  Starting year for the projection of the FRL 

2.5.4.1  Overview 

As a default, it is good practice that Member States start the projection of the FRL as of 
2010  or  earlier. Consequently,  2010  will  be  the  first  year  that  the  modelling  framework 
projects the development of the MFL (i.e. the total volume of wood harvested as of 2010 
will be estimated and is an output of the modelling framework).  

It is good practice that the projection is initialized for a year as close as possible to 2010. 
It  is  important  that  the  starting  year  is  selected  so  that  all  relevant  data  sources  are 
available  for  the  modelling  framework  and  provide  a  consistent  representation  of  the 
status of the MFL. However, a Member State may select a different starting year for the 
projection of the FRL if this is shown to be appropriate and justifiable. If the projection is 
started after 2010, it is good practice to clearly document and justify why this is done.  

It is good practice that the Member State verifies that the modelling framework is able to 
reproduce  historical  data  from  the  national  GHGI  in  the  period  from  2000  to  the  latest 
year  documented  in  the  latest  publically  available  GHGI.  Such  an  evaluation  should  be 
performed  based  on  the  real  observed  management  of  the  forest  (see  section  2.4.2) 
during the period after 2009 instead of a continuation of the FMPs in 2000-2009. In other 
words,  it  is  good  practice  that  a  Member  State  shows  that  the  selected  modelling 
framework  is  able  to  reproduce  the  latest  national  GHGI  through  the  use  of  the  latest 
available data. 

2.5.4.2  Data sources to be used 

In terms of data sources to be used for the projection of the FRL, the LULUCF Regulation 
states that the FRL shall be developed “using the best available data” (Article 8(5)) and 
shall  be  “transparent,  complete,  consistent,  comparable  and  accurate  information” 
(Annex IV.A(h) of the LULUCF Regulation). Therefore, the data sources used should be in 
line with the good practices of IPCC (2006 IPCC GL, volume 1, chapter 1, section 1.4).  

Data describing the state of the forest (e.g. total area of MFL; information by stratum 
such  as  area,  increment,  biomass,  age  related  information  and  area  allocated  to  each 
FMP) have to be used for the projection of the FRL. Depending on the starting year of the 
projection,  either  earlier  data  from  the  RP  (i.e.  data  up  to  2009)  or  the  latest  available 
data (at the time of FRL setting, e.g. up to 2016) can be applied for the projection of the 
FRL.  

It  is  good  practice  to  use  the  best  available  data  sources  to  define  the  state  of  the 
forest  as  of  the  starting  year  of  the  projection  of  the  FRL.  For  example,  if  2010  is  the 
start  year  of  the  projection, it is  good  practice  to  use  data  from  the  latest  NFI  or  latest 
publically available GHGI (i.e. GHGI 2018) to define the state of the forest (2010), rather 
than the reported data that was available at the starting year of the projection (i.e. GHGI 
2010-2011).  

2.5.4.3  Documentation and technical correction 

In  terms  of  documentation,  it  is  good  practice  that  Member  States  document  for  which 
year  the  projection  of  the  FRL  starts,  and  which  starting  year  is  selected  for  the 
projection of the FRL.  

If  the  projection  is  selected  to  be  started  after  2010,  it  is  good  practice  that  Member 
States  justify  why  they  have  selected  to  use  that  specific  year  (e.g.  why  more  recent 
data is considered more reliable and applied for the projection of the FRL). 

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It  is  of  particular  importance  and  good  practice  that  a  Member  State  transparently 
documents  what  data  sources  are  applied  to  define  the  state  of  the  forest,  as  of  the 
starting  year  of  the  FRL  projection.  Furthermore,  independently  of  the  starting  year  of 
the projection, it is good practice that a homogenous and consistent set of data sources 
be applied, to provide a logical and rational representation of the state of the  forest for 
that year. 

If  the  projection  is  started  as  of  2010,  or  earlier,  it  is  not  good  practice  that  a  Member 
State applies a technical correction to alter the starting year of the projection of the FRL. 
However, if the projection starts after 2010, a technical correction may be applied, if this 
allows for the consideration of best available data describing the state of the forest (e.g. 
increment, biomass) or the age-related forest characteristics of the forest. 

Independently  of  the  starting  year  of  the  projection,  a  technical  correction  may  be 
applied  (as  described  in  Art  8(11)  before  the  compliance  check)  by  a  Member  State  to 
correct for differences between the actual and projected state of the MFL up to the start 
of  the  CP  (i.e.  2021).  As  long  as  methodological  consistency  is  fulfilled,  a  technical 
correction may be applied by a Member State based on the observed state of the MFL as 
of  the  start  of  the  CP  instead  of  the  projected  state  of  the  forest  as  applied  for  the 
calculation of the FRL.  

A  technical  correction  thereby  allows  a  Member  State  to  utilize  NFIs  carried  out  after 
2016/2017  to  improve  the  description  of  the  age-related  forest  characteristics  at  the 
start of the CP. 

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2.5.5  Assumptions concerning the period from 2010 to 2020 

2.5.5.1  Overview 

For the projection of the FRL, assumptions have to be made concerning the development 
of the MFL in the period from 2010 to 2020.  

In terms of the stratification of MFL, the approach for stratifying the area of MFL as 
developed in Step 1 should be applied consistently for the RP 2000 to 2009, 2010 
to 2020, and for the projection of the FRL for the period of 2021-2025 and 2026-2030. 

It is important to note that it is good practice that the criteria used for the stratification 
remain  constant  in  the  modelling  of  historical  and  projected  emissions  by  sources  and 
removals by sinks. This means that the same approach for stratifying the area of MFL is 
to be applied independently of the selected starting year of the projection of the FRL and 
throughout the CP.  

Furthermore,  it  is  good  practice  that  the  area  of  land  allocated  to  each  stratum 
remains  constant  from  the  starting  year  of  the  projection  (thereby  not 
extrapolating  into  the  future  any  possible  trends  observed  during  the  RP) 33.  In  other 
words,  the  stratification  of  the  MFL  (and  the  area  of  land  allocated  to  each  stratum)  as 
documented for the  year of start  of the projection is to remain constant throughout the 
CP.  However,  while  the  total  area  of  land  allocated  to  a  certain  stratum  remains 
constant33, are of each class within a stratum may change over time (see section 2.3.2). 

This  implies  that  during  the  CP,  only  the  overall  state  of  the  forest  will  adapt  to  the 
implementation of the FMPs, which in turn will adapt to aspects such as the age dynamics 
of the forest. 

In  terms  of  the  FMPs,  it  is  good  practice  that  the  set  of  the  FMPs  as  defined  and 
documented in Step 2 for the RP are consistently applied from the starting year 
of  the  projection  onwards.  It  is  important  to  note  that  only  the  descriptions  of  the 
FMPs  that  were  implemented  in the  period  from  2000  to  2009  are  to  be  applied  for  the 
estimation of the FRL.  

Therefore, the country-defined operational criteria (i.e. the quantification of the FMPs) for 
the period of 2000-2009 are also to be applied to project the FRL. Independently of the 
starting year of the projection, the same FMPs should be enforced from the starting year 
of the projection of the FRL for the CP. 

Given  that  the  FRL  shall  be  projected  based  on  a  continuation  of  FMP,  it  is  good 
practice  that  the  areas  allocated  to  the  each  FMP  remain  constant  from  the 
starting  year  of  the  projection  of  the  FRL  through  the  CP.  Even if  a  trend  of  area 
being converted from one FMP to another FMP could be observed and documented during 
the RP, it is not good practice to continue such a trend during the CP.  

This implies  that if  the  stratification  as  documented  in  Step  1  (see  section  2.1)  and  the 
FMP  as  documented  in  Step  2  (see  section  2.2)  are  species  specific,  then  including  a 
conversion  from  one  tree  species  to  another  species  in  the  CP  estimates  (e.g.  planting 
broadleaf trees after the final clearcutting of coniferous) would not be good practice. 

33 The only foreseen exemption from this good practice is if the area of MFL is assumed to develop over time (see section 2.5.3). If this 
is the case, then it is good practice to allocate area gains and area losses to strata’s as documented during the RP. 

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2.5.5.2  Documentation and technical correction 

In  terms  of  documentation,  it  is  good  practice  that  Member  States  document  what 
assumptions are made for the period 2010 to 2020.  

Given  that  the  FRL  for  the  CP  shall  be  based  on  “the  continuation  of  sustainable  forest 
management  practice,  as  documented  in  the  period  from  2000  to  2009  with  regard  to 
dynamic age-related forest characteristics in national forests” (Article 8(5)), it is not good 
practice  to  perform  a  technical  correction  of  the  FRL,  based  on  the  FMPs  that  actually 
were carried out during the CP instead of the FMPs as documented in Step 2 (see section 
2.2).  

The  definition  of  when  each  management  activity  is  carried  out,  as  documented  in  the 
period from 2000 to 2009, is to be consistently applied throughout the CP. It is therefore 
not  good  practice  to  perform  a  technical  correction  of  the  operational criteria  describing 
when an activity is carried out.  

As an example, if a management activity has been specified to be carried out at a specific 
age-related  characteristic  of  the  forest  (e.g.  the  first  pre-commercial  thinning  is  carried 
out  when  trees  reach  the  diameter  class  (Dbh)  of  10-15  cm),  this  value  cannot  be 
changed through a technical correction (e.g. the first pre-commercial thinning is carried 
out when trees reach the diameter class (Dbh) of 5-9 cm). 

Furthermore,  it  would  not  be  good  practice  to  perform  a  technical  correction  of  the 
operational  criteria  describing  when  a  management  activity  is  carried  out,  based  on 
updated information concerning such aspects as wood price development, interest rates, 
net present value estimates, and demand of wood for energy and material purposes.  

This  is  the  case  as  the  operational  criteria  are  to  be  defined,  to  the  extent  possible, 
according to the age-related characteristics of the national forests, not to projected data 
sources. 

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2.5.6  Assumptions concerning harvested wood products 

2.5.6.1  Overview 

As set out in criterion e) of Annex IV.A of the LULUCF Regulation, for calculating the HWP 
contribution to the FRL, “a constant ratio between solid and energy use of forest biomass 
as documented in the period from 2000 to 2009 shall be assumed”.  

Independent  from  potentially  available  information  on  developments  and/or  changes  in 
the  consumption  or  production  patterns  of  the  relevant  HWP  commodities,  the  above 
criterion  for  setting  the  FRL  implies  that  the  proportion  of  harvest  manufactured  to  the 
defined  semi-finished  wood  products  representing  the  material  or  solid  use  of  HWP 
remain  unchanged  as  well  as  the  HWP  composition  of  their  production  during  the  RP 
2000-2009. 

In  order  to  implement  the  projection  for  HWP  in  the  FRL,  the  starting  basis  for  the 
calculations  consists  of  the  projected  harvest  amounts  that  have  been  estimated 
following  the  methodology  as  set  out  in  the  previous  steps  (Step  3  -  section  2.3.5  and 
Step 5 – sections 2.5.4 to 2.5.5). Similar to an example as described in section 2.8.5 of 
IPCC  (2014),  the  following  steps  need  to  be  implemented  for  calculating  the  projected 
carbon  Inflow  to  the  HWP  pool  in  line  with  this  requirement  and  consistent  with  the 
relevant IPCC guidance on HWP: 

1.  STEP  I:  Calculation  of  the  rates  of  change  of  the  projected  harvest  as  compared  to 

the average of the historic harvest within the period 2000 to 2009. 

Numeric example: 

(i)  Average historic harvest for the years 2000-2009: 50 Mm³ yr-1 

(ii)  Projected harvest (in Mm³ yr-1): in 2021=52, in 2022=53, in 2023=55… 

(iii)  Rates of change as compared to historic average: in 2021=4%, in 2022=6%, in 

2023=10% 

2.  STEP II: Application of these annual change rates to the  same time  period average 
(i.e. 2000-2009) of historic carbon inflow to the HWP pool, which has been calculated 
from  HWP  production,  in  order  to  project  the  future  carbon  inflow  to  the  HWP  pool 
(reflecting the material or solid wood use). 

Numeric example: 

(i)  Average production of sawnwood for the years 2000-2009: 10 Mm³ yr-1 

(ii)  Projected production of sawnwood (in Mm³ yr-1): in 2021=10.4, in 2022=10.6, 

in 2023=11 … 

As a result, it is assumed that the same average proportion of harvested timber used 
as  feedstock  for  the  subsequent  production  of  the  defined  HWP  categories  (i.e. 
sawnwood,  wood-based  panels  and  paper  and  paperboard,  reflecting  in  the  solid 
wood  use)  in  the  defined  time  period  2000-2009  will  also  apply  in  the  projection 
period.  

3.  STEP  III:  Estimate  future  emissions  and  removals  from  HWP  applying  the  methods 

as set out earlier in Step 3 (See section 2.3.5).  

In  the  case  that  additional  information  on  timber  assortments  and  their  respective 
use for the subsequent manufacture of the defined HWP default categories (i.e. semi-
finished wood products) is being used for an alternative approach, countries need to 
ensure consistency with the requirement to maintain the same proportion of harvest 
manufactured to the defined semi-finished wood products in their projection as in the 

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period  2000  –  2009.  It  is  furthermore  good  practice  that  Member  States  document 
the applied methods and justify why such an alternative has been applied. 

For projecting the future development of emissions and removals, the annual carbon 
inflow  to  the  HWP  pool  is  calculated  from  1990  onwards  including  the  latest  activity 
data  derived  from  the  relevant  statistics  (not  later  than  from  2020).  This  is  to  be 
implemented  independently  of  the  selected  starting  year  of  the  projection  (see 
section 2.5.4), as the carbon stock in the HWP pool is to be estimated on the basis of 
separate  activity  data  (see  section  2.3.5).  Subsequent  to  available  statistical  data, 
the  projected  production  of  the  relevant  HWP  commodities  as  derived  from  Step  II 
are to be used to continually estimate the future carbon inflow to the HWP pool. 

2.5.6.2  Documentation and technical correction 

In terms of documentation, it is good practice to document how the projected emissions 
and removals from the HWP pool have been implemented. This includes a description of 
what data sources both for HWP activity data (default categories) and projected harvest 
amounts  for  implementing  the  Steps  described  above  have  been  applied  as  well  as  a 
description of how the described Steps above have been implemented. In the case that a 
technical correction following the descriptions under section 2.5.2-2.5.5 is conducted with 
a  subsequent  change  of  the  projected  harvest  amounts  as  modelled  following  the 
methodological  guidance  provided  under  section  2.3.5,  it  is  good  practice  to  also 
recalculate the projected emissions and removals from the HWP pool as part of the FRL. 

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2.5.7  Possible problems with the projections and how to address 

them 

Box  20  gives  an  overview  of  possible  problems  that  the  Member  States  may  encounter 
when projecting the FRL, and proposes solutions for addressing them.  

Box 20: Possible problems with the FRL projections and how to address them. 

Problem: The projection only matches a 
single time point in the GHGI, not the overall 
GHGI. 

Solution: Calibrate the projection ignoring 
outliers (see also section 2.4.3). 

Problem: The trend of the GHGI is not 
consistent with the trend of the projection. 

Solution: Refine the model (see also section 
2.4.3). 

Problem: The initial projection is on a 
different overall level from the GHGI. 

Solution: Calibrate the projection to be in 
line with the overall level of the GHGI 
(shown with dashed line). See also section 
2.4.4. 

Problem: The projected inter-annual 
variability is much larger than the inter-annual 
variability in the GHGI. 

Solution: Refine the model. See also section 
2.5. 

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2.6  Calculate the forest reference level 

Step 6: Calculate the forest reference level 

Calculate  the  FRL  as  average  of  emissions  and  removals  during  2021-2025  and  2026-
2030.  

Once  the  GHG  emissions  and  removals  have  been  calculated,  the  5-year  average  of 
projected values is taken as FRL values for the periods 2021-2025 and 2026-2030. Once 
the FRL has been calculated it cannot be modified. However, technical corrections to the 
FRL  may  subsequently  be  applied,  to  ensure  methodological  consistency  with  the 
estimates of actual GHG emissions and removals. 

In particular: 

  Biomass C stock gains need to be corrected in cases where the increment is 

calculated by using: 

-  Climate-related variables; in such a case the same set of climate data (i.e. 
those  during  the  CP)  will  be  applied  to  the  estimates  of  actual  increment 
and to recalculate the projected increment (see section 2.5.2). 

-  Direct  measurements  (e.g.  NFI)  or  empiric  relations  (e.g.  yield  curves); 
where  the  functions  ‘increments-other  variable’ 34  have  been  used  to 
project  the  increment  and  such  functions  have  a  different  trajectory  with 
the new data collected during the CP. Note however, that the correction is 
to  be  applied  only  if  the  relations  increment-other  variable  has  not  been 
impacted  by  changes  in  management.  For  instance,  a  yield  curve  age-
increment is applied to  estimate the increment of  forest type X. The yield 
curve has been built according to the usual management practice that e.g. 
includes  a  thinning  at  age  40.  During  the  CP  the  management  practice  of 
forest type X has been changed e.g. no thinning at age 40. In such a case 
the  change  in  management  practices  impacts  the  relations  age-increment 
so that a technical correction of the FRL is not to be implemented. 

  Biomass  C  stock  losses,  need  to  be  corrected  only  if  parameters  (e.g.  biomass 

expansion factors, allometric functions) applied are recalculated.  

  C  stocks  inputs  to  and  outputs  from  non-biomass  pools  need  to  be  corrected  in 
case  of  corrections  implemented  in  the  biomass  pools.  Further,  those  are 
corrected also if any parameters or empirical or functional functions that has been 
applied  for  calculating  the  FRL  is  subsequently  revised  (e.g.  decay  factors  or 
mortality  rates),  although  only  if  changes  in  management  practices  have  not 
impacted those parameters or functions. 

  non-CO2  emissions  from  C  pools  need  to  be  corrected  only  if  any  parameters 

applied is revised (e.g. C:N ratio). 

  Technical  corrections  for  changes  in  activity  data,  as  roundwood  harvested, 
fuelwood  collected,  losses  due  to  other  disturbances,  or  areas  is  applied  only  if 
those  data  are  recalculated  in  the  national  GHGI  for  the  historical  period  i.e. 
2000-2009  (or  2000-20XX).  An  exception  is  made  for  the  total  area  of  MFL  in 
Alternative 2 of Step 5 (see section 2.5.3 and box 18). 

34 Likely age or biomass density dependent increment curves 

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Once  a  technical  correction  has  been  calculated  and  applied,  the  calibration  of  the 
corrected FRL needs to be performed again, as it was done for the FRL, to ensure that no 
inconsistencies in the time series originated from the recalculation. 

If  a  technical  correction  is  to  be  applied,  it  is  good  practice  to  justify  and  transparently 
document the updates as implemented. 

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SECTION 3 

3  CRITERIA FOR THE FOREST REFERENCE LEVEL AND THE 

CONTENTS OF THE NATIONAL FORESTRY ACCOUNTING PLAN 

3.1  Description of Annex IV criteria for constructing FRLs 

As  described  in  section  1,  the  LULUCF  Regulation  consists  of  a  preamble  describing  the 
context  and  background,  of  enacting  terms  with  the  different  articles  of  the  Regulation, 
and  of  seven  annexes  that  give  further  detail  as  to  how  to  comply  with  the  LULUCF 
Regulation.  

Annex  IV.A  of the LULUCF Regulation defines criteria for determining the FRL.  Here,  we 
present these  criteria as stated in the LULUCF Regulation, and give guidance on how to 
interpret or address the different criteria. The following statements should be considered 
as interpretations of the authors of this document, and not as exhaustive explanations.  

As stated Annex IV.A of the LULUCF Regulation, a “Member State’s forest reference level 
shall be determined in accordance with the following criteria”: 

“(a) the reference level shall be consistent with the goal of achieving a balance 
between  anthropogenic  emissions  by  sources  and  removals  by  sinks  of 
greenhouse  gases  in  the  second  half  of  this  century,  including  enhancing  the 
potential  removals  by  ageing  forest  stocks  that  may  otherwise  show 
progressively declining sinks;” 

This notion links the LULUCF Regulation to the Paris Agreement that the EU and Member 
States  have  ratified,  and  encourages  the  Member  States  to  reflect  on  the  long-term 
development of the forest sinks, also beyond the CP. This criterion can be understood to 
imply that a momentary change in harvest volume because of forest age structure can be 
justified, if it leads to enhancing potential removals by forest increment in the long term. 
Note, however, that the above cannot contradict the first paragraph of Article 8(5) “The 
forest  reference  level  (FRL)  shall  be  based  on  the  continuation  of  sustainable  forest 
management  practice,  as  documented  in  the  period  from  2000  to  2009”.  It  is  good 
practice  to  discuss  the  long-term  implications  of  the  FMPs  estimated  in  the  FRL  in 
qualitative (and if possible, quantitative) terms, in relation to the objective of enhancing 
the long-term LULUCF sinks.  

This criterion thereby refers also to Article 13 of the LULUCF Regulation (Managed forest 
land flexibility), which details the conditions on which a Member State may  compensate 
emissions from the LULUCF sector that incur during the CP, including long term strategy. 

“(b) the reference level shall ensure that the mere presence of carbon stocks is 
excluded from accounting;”  

This  criterion  is  compatible  with  the  KP  Decision  16/CMP.1  (KP  2005),  where  this  same 
principle  was  affirmed.  It  reflects  the  objective  of  enhancing  the  carbon  stocks  and  the 
net carbon  sinks where possible, instead of  only preserving existing carbon  stocks.  It is 
understood that a pre-existing carbon stock in terrestrial vegetation such as a forest on a 
given  area  of  land  does  not  contribute  towards  the  reduction  of  atmospheric  carbon. 
Therefore,  it  is  appropriate  for  the  FRL  to  support  accounting  for  net  changes  in  forest 
carbon stocks, rather than accounting for total existing carbon stocks in forests.  

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“(c) the reference level should ensure  a robust and credible  accounting system 
that  ensures  that  emissions  and  removals  resulting  from  biomass  use  are 
properly accounted for;” 

This  criterion  reflects  the  need  to  provide  trustworthy  accounting.  Note  also  that 
combustion of wood is excluded from the energy sector accounting on the basis that it is 
instead  accounted  for  in  the  LULUCF  sector,  hence  underlining  the  needs  to  properly 
account for biomass used within the LULUCF.  

“(d)  the  reference  level  shall  include  the  carbon  pool  of  harvested  wood 
products,  thereby  providing  a  comparison  between  assuming  instantaneous 
oxidation and applying the first-order decay function and half-life values;”  

This criterion asks to provide explicitly an assessment of the size of the HWP carbon pool. 
This would in most Member States result in two different FRL estimates provided by the 
Member  State:  one  assuming  instantaneous  oxidation  (where  no  carbon  is  stored  in 
HWP, and that pool is essentially zero), and an FRL where carbon storage within HWP is 
accounted for.  

It is good practice to explicitly state the difference between the estimates, for example:  

“The  forest  reference  level  for  [country]  is  XX  tons  CO2  eq,  in  which  the  HWP  pool 
constitutes  of xy tons CO2 eq. If instantaneous oxidation of HWP was  assumed, the FRL 
would be YY tons CO2 eq.” 35 

See  more  guidance  on  how  to  fulfil  this  criterion  under  section  2.3.5  of  this  document, 
and Annex V of the LULUCF Regulation. 

“(e)  a  constant  ratio  between  solid  and  energy  use  of  forest  biomass  as 
documented in the period from 2000 to 2009 shall be assumed;”  

See more guidance on how to fulfil this criterion under section 2.5.6 of this document. 

“(f)  the  reference  level  should  be  consistent  with  the  objective  of  contributing 
to the conservation of biodiversity and the sustainable use of natural resources, 
as set out in the EU forest strategy, Member States' national forest policies, and 
the EU biodiversity strategy;”  

This  criterion  ties  the  FRL  projections  to  the  concept  of  sustainable  use  of  natural 
resources.  That  is,  the  FRL  should  be  based  on  the  continuation  of  sustainable  FMP  in 
2000-2009 (Article 8(5)). It is good practice to confirm that the FMPs upon which the FRL 
is  constructed  are  consistent  with  the  objective  of  contributing  to  the  conservation  of 
biodiversity and other criteria for sustainable use  of natural resources, as set  out in the 
EU  forest  strategy,  Member  States’  national  forest  policies,  and  the  EU  biodiversity 
strategy.  

It  is  recognised  that  the  conservation  or  enhancement  of  forest  carbon  stocks  and  net 
carbon sinks comprise just one objective of sustainable forest management. The pursuit 
of  wider  sustainable  management  objectives  may  have  positive  and/or  negative 
consequences for the development of forest carbon stocks and net carbon sinks that may 
vary  over  time.  The  Member  States  are  encouraged  to  provide  commentary  on  how 
sustainable  forest  management  policies  and  practices  are  evolving,  where  relevant,  and 
to describe how sustainable use of natural resources has been taken into account in the 
modelling of the FRL. In this way, the consistency between the modelling of the FRL and 
historical and evolving sustainable FMPs may be demonstrated. More guidance on how to 

35 The relation between the FRL and HWP pools will be: YY + xy = XX.  

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consider sustainability and continuation of forest management is given in section 2.2.7 of 
this document. 

“(g)  the  reference  level  shall  be  consistent  with  the  national  projections  of 
anthropogenic  greenhouse  gas  emissions  by  sources  and  removals  by  sinks 
reported under Regulation (EU) No 525/2013;” 

This criterion ties the FRL submitted within the LULUCF Regulation (EU) 2018/841 to the 
overall policies and requirements as set out earlier in Regulation (EU) No 525/2013. See 
section 2.4 for how to ensure consistency with the GHGIs.  

“(h) the reference level shall be consistent with greenhouse gas inventories and 
relevant historical data and shall be based on transparent, complete, consistent, 
comparable and accurate information. In particular, the model used to construct 
the  reference  level  shall  be  able  to  reproduce  historical  data  from  the  National 
Greenhouse Gas Inventory.” 

This criterion is addressed in detail under section 2.4 of this document. 

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3.2  Common table of contents for the NFAP 

Annex  IV  B.  of  the  LULUCF  Regulation  sets  out  the  key  elements  that  the  national 
forestry accounting plans shall contain. Based on the elements (a) to (e), it is suggested 
that  Member  States  develop  their  NFAP  according  to  the  following  common  table  of 
contents.  This  table  has  been  developed  to  accommodate  the  need  to  document  each 
Step  of  the  suggested  approach  to  implement  the  FRL  requirements  in  line  with  the 
LULUCF Regulation. 

Chapter 1: General introduction 

1.1: General description of the forest reference level for [the Member State] 

1.2: Consideration to the criteria as set in Annex IV of the LULUCF Regulation 36 

Chapter 2: Preamble for the forest reference level 

2.1: Carbon pools and greenhouse gases included in the forest reference level 

2.2: Demonstration of consistency between the carbon pools included in the 
forest reference level 

2.3: Description of the long-term forest strategy 

2.3.1: Overall description of the forests and forest management in [the 
Member State] and the adopted national policies 

2.3.2: Description of future harvesting rates under different policy 
scenarios 

Chapter 3: Description of the modelling approach 

3.1: Description of the general approach as applied for estimating the forest 
reference level 

3.2: Documentation of data sources as applied for estimating the forest 
reference level 

3.2.1: Documentation of stratification of the managed forest land  

3.2.2: Documentation of sustainable forest management practices as 
applied in the estimation of the forest reference level 

3.3: Detailed description of the modelling framework as applied in the 
estimation of the forest reference level 

Chapter 4: Forest reference level 

4.1: Forest reference level and detailed description of the development of the 
carbon pools  

4.2: Consistency between the forest reference level and the latest national 
inventory report 

4.3: Calculated carbon pools and greenhouse gases for the forest reference 
level 

References 

36 Under this heading, we suggest to reflect on the criteria of Annex IV A. (see section 3.1 on p. 99), and to include an equivalence table such as 
the one suggested in Table 11, to reflect on Annex IV B.  

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In the NFAP, the Member states are encouraged to include a section (chapter 1.2 in the 
suggested  table  of  contents)  that  explicitly  reflects  on  the  criteria  and  guidance  for  the 
FRL  as  detailed  in  Annex  IV  A.  of  the  Regulation.  In  addition,  the  Member  States  are 
encouraged to include an equivalence table, in the form of a filled-in version of Table 11, 
showing where the different elements of Annex IV B. of the Regulation are found in the 
national submission. The purpose of the equivalence table is to assist the review process, 
and  it  is  therefore  good  practice  to  be  as  specific  as  possible  when  referring  to  the 
different chapters or pages of the NFAP submission. 

Table  11.  Suggested  equivalence  table  to  be  included  in  the  NFAP  (Chapter  1.2,  Consideration  to 
the  criteria  as  set  in  Annex  IV  of  the  LULUCF  Regulation),  where  the  Member  State  may  show 
explicitly where the Annex IV B. elements are documented in the NFAP submission. 

Annex 
IV  B. 
paragraph item 

Elements of the national forestry accounting plan 
according to Annex IV B.  

Chapter  or  page 
number(s) 
in  the 
NFAP 

(a) 

(a) 

(b) 

(b) 

(b) 

(c) 

(c) 

(c) 

(d) 

(e) 

A general description of the determination of the forest 
reference level.  

Description  of  how  the  criteria  in  LULUCF  Regulation 
were taken into account. 

Identification  of  the  carbon  pools  and  greenhouse 
gases which have been included in the forest reference 
level. 

Reasons  for  omitting  a  carbon  pool  from  the  forest 
reference level determination. 

Demonstration  of  the  consistency  between  the  carbon 
pools included in the forest reference level. 

A  description  of  approaches,  methods  and  models, 
including  quantitative 
the 
determination  of  the  forest  reference  level,  consistent 
with  the  most  recently  submitted  national  inventory 
report. 

information,  used 

in 

A  description  of  documentary 
sustainable 
forest  management 
intensity.  

information  on 
and 

practices 

A description of adopted national policies. 

Information  on  how  harvesting  rates  are  expected  to 
develop under different policy scenarios. 

A  description  of  how  the  following  element  was 
considered in the determination of the forest reference 
level: 

(i) 

(ii) 

• 

• 

(iii) 

• 

The area under forest management 

Emissions and removals from forests and 
harvested wood products as shown in greenhouse 
gas inventories and relevant historical data  

Forest characteristics, including: 
-  dynamic age-related forest characteristics 
- 
- 
-  other information on forest management 
activities under ‘business as usual’ 

increments 
rotation length and  

(iv) 

•  Historical and future harvesting rates 

disaggregated between energy and non-energy 
uses 

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3.3  Where to find advice for Annex IV elements in this document?  

Table 12 and Table 13 provide links and references  for where to find more guidance on 
Annex IV criteria and elements in this technical guidance document. 

Table  12.  References  for  where  to  find  advice  on  Annex  IV  A.  criteria  in  this  technical  guidance 
document. 

Criterion in Annex IV A.  

(a) the reference level shall be consistent with the goal of achieving 
a  balance  between  anthropogenic  emissions  by  sources  and 
removals  by  sinks  of  greenhouse  gases  in  the  second  half  of  this 
century, including enhancing the potential removals by ageing forest 
stocks that may otherwise show progressively declining sinks; 

Chapter  in  the  technical 
guidance document 

Sections 1.2.1 and 3.1 

(b) the reference level shall ensure that the mere presence of carbon 
stocks is excluded from accounting; 

Sections 1.2.3 and 3.1 

(c)  the  reference  level  should  ensure  a  robust  and  credible 
accounting  system  that  ensures  that  emissions  and  removals 
resulting from biomass use are properly accounted for; 

Sections 1 and 3.1 

(d)  the  reference  level  shall  include  the  carbon  pool  of  harvested 
wood  products,  thereby  providing  a  comparison  between  assuming 
instantaneous  oxidation  and  applying  the  first-order  decay  function 
and half-life values; 

Sections 2.3.5 and 2.5.6 

(e) a constant ratio between solid and energy use of forest biomass 
as documented in the period from 2000 to 2009 shall be assumed; 

Section 2.5.6 

(f)  the  reference  level  should  be  consistent  with  the  objective  of 
contributing  to  the  conservation  of  biodiversity  and  the  sustainable 
use  of  natural  resources,  as  set  out  in  the  EU  forest  strategy, 
Member  States’  national  forest  policies,  and  the  EU  biodiversity 
strategy; 

Sections 2.2.7 and 3.1 

(g)  the  reference  level  shall  be  consistent  with  the  national 
projections  of  anthropogenic  greenhouse  gas  emissions  by  sources 
and removals by sinks reported under Regulation (EU) No 525/2013; 

Section 2.4 

(h)  the  reference  level  shall  be  consistent  with  greenhouse  gas 
inventories  and  relevant  historical  data  and  shall  be  based  on 
transparent,  complete,  consistent,  comparable  and  accurate 
information. In particular, the model used to construct the reference 
level  shall  be  able  to  reproduce  historical  data  from  the  National 
Greenhouse Gas Inventory. 

Sections  2.1,  2.2,  2.4  and 
2.5 

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Table  13.  References  for where  to  find  advice on  Annex  IV  B.  elements in  this  technical  guidance 
document. 

IV  B. 
Annex 
paragraph item 

Elements of the national forestry accounting plan 
according to Annex IV B.  

Chapter  and  page 
number(s) 
in  the 
technical  guidance 
document 

(a) 

(a) 

(b) 

(b) 

(b) 

(c) 

(c) 

(c) 

(d) 

(e) 

A general description of the determination of the forest 
reference level.  

Sections 1.2.3 and 
1.4 

Description  of  how  the  criteria  in  LULUCF  Regulation 
were taken into account. 

Sections 3.1 and 3.2 

Identification  of  the  carbon  pools  and  greenhouse 
gases which have been included in the forest reference 
level. 

Section 1.2.3 

Reasons  for  omitting  a  carbon  pool  from  the  forest 
reference level determination. 

Sections 1.2.3 and 
1.4 

Demonstration  of  the  consistency  between  the  carbon 
pools included in the forest reference level. 

Section 2.4 

A  description  of  approaches,  methods  and  models, 
including  quantitative 
the 
determination  of  the  forest  reference  level,  consistent 
with  the  most  recently  submitted  national  inventory 
report. 

information,  used 

in 

Section 2 

A  description  of  documentary 
sustainable 
forest  management 
intensity.  

information  on 
and 

practices 

Section 2.2 

A description of adopted national policies. 

Information  on  how  harvesting  rates  are  expected  to 
develop under different policy scenarios. 

A  description  of  how  the  following  element  was 
considered in the determination of the forest reference 
level: 

Not applicable  

Not applicable 

(i) 

(ii) 

• 

• 

(iii) 

• 

The area under forest management 

Emissions and removals from forests and 
harvested wood products as shown in greenhouse 
gas inventories and relevant historical data  

Forest characteristics, including: 
-  dynamic age-related forest characteristics 
- 
- 
-  other information on forest management 
activities under ‘business as usual’ 

increments 
rotation length and  

Sections 2.1.4, 2.2.5, 
2.3.2 and 2.5.3 

Sections 2.1.4, 2.3, 
2.4 and 2.5 

Sections 2.1, 2.2, 2.3 
and 2.5  

(iv) 

•  Historical and future harvesting rates 

Section 2.5.6 

disaggregated between energy and non-energy 
uses 

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ANNEXES 

ANNEX I 

Checklist of  aspects to consider  when following the  approach suggested in this 
technical guidance document 

In  this  annex  we  provide  a  series  of  checklists  for  preparing  the  FRL.  The  checklists  as 
detailed below follows the stepwise approach for estimating the FRL as suggested in this 
document. For each Step, a list of key items to be document and specified is provided.  

These  checklists  are  intended  as  an  internal  tool  for  the  national  teams  for  helping  to 
structure the work. These lists are not meant to be included in the NFAPs. 

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Step 1: Stratify the area of MFL, according to country-defined criteria, and apply the stratification 
in a consistent manner over time, including the RP 2000-2009. 

Document how the area of Managed Forest Land is considered in the determination 
of the FRL (Annex IV B.) of the LULUCF Regulation) 

Document how large a share of the national forests was covered by a given FMP in 
the period from 2000 to 2009 

Document each criterion used for the stratification of the MFL. 

Document data sources used to perform the stratification. 

Document and justify any deviation between the stratification for the FRL and any 
stratification already used in the GHGI or NFI. 

Document the sources of information used to determine the forest characteristics for 
each stratum (see Table 2 for an example of this can be documented). 

Document the forest definition used for the construction of FRL and explain whether 
it differs from that used in the national GHGI. 

☐ 

☐ 

☐ 
☐ 

☐ 

☐ 

☐ 

Step  2:  Identify  and  document  the  FMPs  in  each  strata  for  2000-2009  based  on  country-defined 
operational criteria and quantifiable data. 

Document the sources of information used to identify and specify the FMPs. 

Describe in qualitative terms each FMP as applied during the RP (see Table 3 for an 
example of how this can be documented). 

Describe in quantitative terms each FMP as applied during the RP (see Table 4 and 
Table 5 for examples of how this can be documented). 

Document the use of FMPs according to the stratification of the forest land (see Table 
6 for an example of how this can be documented).  

Verify that the documentation of the FMPs include specifications about: (i) how each 
management activity is performed, and (ii) when is each management activity being 
carried out. 

Check that the above descriptions of FMPs and forest characteristics include a 
description of the following forest characteristics (Annex IV B.): 

- dynamic age-related forest characteristics 

- increments 

- rotation length 

- other information on forest management activities  

Confirm that any trends in when an management activity is carried as observed 
during the period from 2000 to 2009 are not projected to continue during the CP 

Document and confirm that only data sources from the period 2000 to 2009 are 
being used to define the FMPs.  

If data sources outside the period from 2000 to 2009 are used, document and justify 
this deviation. 

Also, document an assessment of the impact of this deviation on the FRL. 

Document how the principles of sustainable FMPs are being applied within the 
country. 

Document the use of the FMPs in each strata of the MFL (see Table 6 for an example 
of this can be documented). 

☐ 

☐ 

☐ 

☐ 

☐ 

☐ 
☐ 
☐ 
☐ 

☐ 

☐ 

☐ 

☐ 

☐ 

☐ 

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Step 3: Select the appropriate methodology to project the development of carbon pools based on 
available data and national circumstances. 

Document the methodology as selected to project to the development of carbon 
pools. 

Document the ‘Age structure module’ 

Document the ‘Harvest module’ 

Document the ‘C pool variation module’ 

Document how natural disturbances have been estimated in the projection of the 
FRL, including data sources as applied. 

Document how the HWP pool has been estimated in the projection of the FRL, 
including data sources as applied. 

☐ 

☐ 
☐ 
☐ 

☐ 

☐ 

Step  4:  Calibrate  the  selected  methodology  based  on  real  observed  data  and  show  that  the 
methodology is able to reproduce the GHGI estimates. 

Document the model estimates of Biomass gains, Biomass losses, and Net GHG 
emissions/removals from the year 2000 until the starting year of the projection of 
the FRL. 

Document the emissions and removals from forests and HWP as shown in GHGIs and 
relevant historical data (Annex IV (B)), from the year 2000 until the starting year of 
the projection of the FRL. 

☐ 

☐ 

Step 5: Select the appropriate methodology to project the development of carbon pools based on 
available data and national circumstances. 

Specify the assumptions taken concerning climate change and documentation of data 
sources applied. 

If a projection of future climate conditions are used (Alternative 2 in Box 17), 
document: 

- Assumptions and projections for future climatic conditions as applied 

- Document the potential impact on the FRL by not considering the future climate 
effect (i.e. applying Alternative 1 instead of Alternative 2 (see Box 17)) 

Specify and justify the assumptions taken concerning the area development of MFL 
and documentation of data sources as applied. 

Specify the assumptions taken concerning the area development of MFL and 
documentation of data sources as applied. 

Document and justify the selected starting year for the projection of the FRL. 

Document and justify the assumptions taken concerning the period from 2010 to 
2020. 

Specify the data sources used to describe the State of the forest as of the starting 
year of the projection of the FRL. 

Confirm that area of land allocated to each stratum remains constant from the 
starting year of the projection 

Confirm that the FMPs as defined and documented in Step 2 for the RP are 
consistently applied from the starting year of the projection onwards. 

Describe the historical and future harvesting rates disaggregated between energy 
and non-energy uses. (Annex IV B.) 

☐ 

☐ 

☐ 

☐ 

☐ 

☐ 

☐ 

☐ 

☐ 

☐ 

☐ 

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Step  6:  Calculate  the  FRLs  as  average  of  emissions  and  removals  during  2021-2025  and  2026-
2030. 

Document the 5-year average of projected values for the periods 2021-2025 and 
2026-2030. 

☐ 

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ANNEX II 

Handbook for establishing forest reference levels 

A total of six steps are envisioned to be taken for the implementations of the FRLs. The 
sequence  in  which  these  steps  are  expected  to  be  implemented  and  performed  is 
visualized in Figure 16. It is important to note that while some of these steps are to be 
performed sequentially (i.e. Step 5 is only to be performed after Step 4), there are also 
some steps that can be performed at the same time. As an example, Step 1 and Step 2 
may very well be performed simultaneously as the selection of the stratification is highly 
interlinked to the identification of the FMPs.  

Figure 16: An overview of the step by step process that is envisioned to be taken to establish the 
FRL and how the steps are suggested to be carried out sequentially.  

In  this  handbook  we  highlight  and  list  the  key  aspects  to  consider  during  the 
implementation  of  each  of  these  steps.  The  main  aim  of  this  description  is  to  provide 
additional  information  concerning  how  these  steps  fit  together  and  the  flow  of 
information that follows. For detailed description about each step we refer to section 2 of 
this document. 

Step 1: Stratification 

•  Main aim of this Step is to define and document the stratification of MFL. 

•  The stratification of forest land serves to distinguish different types of FMPs. 

• 

• 

It is important that the stratification covers the entire area of MFL. 

It  is  good  practice  that  the  criteria  used  for  the  stratification  remain  constant  in 
the  modelling  of  historical  and  projected  emissions  by  sources  and  removals  by 
sinks. 

•  The  number  of  strata  and  their  definition  are  to  be  selected  in  consideration  of 
available data and methodological (model) requirements for estimating the FRL. 

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Step 2: Description of forest management practices 

• 

In this Step, the FMPs that were applied in the period from 2000 to 2009 are to be 
documented through country-defined and quantifiable operational criteria. 

•  For each stratum identified in Step 1, the FMPs that took place in the stratum are 

to be documented. 

•  The  focus  is  to  document  and  describe  in  detail  the  management  practices  that 
actually  took  place  during  the  RP,  i.e.  not  the  management  practices  that  were 
expected to take place or that were legally allowed to take place 

•  The  information  collected  and  document  in  this  Step  will  serve  as  input  to  the 
methodology developed to project the FRL in Step 3, thereby forming the basis to 
model the continuation of FMPs during the CP.  

Step 3: Select the appropriate methodology 

• 

In  this  Step,  the  methodology  used  to  estimate  the  FRL  are  to  be  selected, 
calibrated and documented.  

•  The  objective  is  to  select  a  method  that  can  estimate  future  development  of  the 
MFL carbon pools in the CP, in line with the stratification as selected in Step 1 and 
the FMPs documented in Step 2.  

• 

It  is  important  to  note  that  the  Member  States  can  use  different  methods  for 
different strata, to take into account differences in management practices, forest 
composition, and tree species. 

Step 4: Calibration and consistency with greenhouse gas inventory estimates 

• 

• 

• 

In this Step, the methodology as selected in Step 3 is calibrated based on the real 
observed data, including the data concerning each strata and FMP as collected in 
Step 1 and 2.  

It  should  be  shown  that  the  methodology  as  selected  in  Step  3  is  able  to 
reproduce  the  existing  and  documented  data  as  reported  in  the  latest  national 
GHGIs for MFL. 

It  should  be  shown  that  the  modelling  framework  is  able  to  reproduce  historical 
GHGI estimates from the year 2000 until the latest inventory year available in the 
national  GHGI  at  the  time  the  FRL  is  constructed.  Figure  17  provides  an 
illustration  of  how  this  can  be  done  sequentially  for  each  year  that  is  being 
assessed.  

101 

 
 
 
 Guidance on developing and reporting Forest Reference Levels in accordance with 
Regulation (EU) 2018/841 

Figure 17: An overview of the process of reproducing the historical estimates as documented in the 
latest national GHGI for MFL. 

Step 5: Projection of emissions and removals  

• 

In this Step, the methodology as selected and calibrated in Step 4 would be used 
to  project  the  future  development  of  anthropogenic  forest  GHG  emissions  by 
sources and removals by sinks for the CP. 

•  Key  input  to  the  methodological  framework  includes  the  data  concerning  each 

strata and FMP as collected in Step 1 and 2.  

•  Key  output  from  the  methodological  framework  is  the  projection  of  emissions  by 
sources  and  removals  by  sinks  from  the  starting  year  of  the  projections  until 
2025.  

Figure 18: Overview of how the various Steps that are to be implemented fit together in terms of a 
timeline.  In  this  figure,  the  red  dots  at  2010  illustrate  the  preferred  staring  years  for  the 
projections.  

102 

 
 
 
 
 Guidance on developing and reporting Forest Reference Levels in accordance with 
Regulation (EU) 2018/841 

Step 6: Calculate the forest reference level  

•  Based  on  the  yearly  estimates  of  GHG  emissions  and  removals  for  MFL  that  has 
been  developed  in  Step  5,  the  5-year  average  of  projected  values  can  be 
calculated based on the FRL values for the periods 2021 - 2025 and 2026 - 2030. 

•  The calculations of the average estimates should be fully performed based on the 

estimates as developed within Step 5. 

Possible problems with the projection and how to address them 

Problem: The projection only matches a 
single time point in the GHGI, not the overall 
GHGI. 

Solution:  Calibrate  the  projection  ignoring 
outliers (see also section 2.4.3).  

Problem: The trend of the GHGI is not 
consistent with the trend of the projection. 

Solution:  Refine  the  model  (see  also  section 
2.4.3). 

Problem: The initial projection is on a 
different overall level from the GHGI. 

Solution: Calibrate the projection to be in 
line with the overall level of the GHGI 
(shown with dashed line). See also section 
2.4.4. 

Problem: The projected inter-annual 
variability is much larger than the inter-annual 
variability in the GHGI. 

Solution: Refine the model. See also section 
2.5. 

103 

 
 
 
 
 
 
 
 
 
 
 
 Guidance on developing and reporting Forest Reference Levels in accordance with 
Regulation (EU) 2018/841 

ANNEX III 

Filled in example of table for Step 1 

In this annex to the technical guidance document, we illustrate how a Member State may 
document  information  sources  for  forest  characteristics  in  strata  through  the  use  of 
tables. The tables below only serve as examples and a Member State is of course free to 
select another way of documenting the information sources. 

Table 14: Filled in example of Table 2. 

Forest characteristics 

Data references 

Stratum  ID  where 
characteristics 
reference are relevant 

the 
and 

Aboveground biomass 

 NFI, 2009 

 All 

Belowground biomass 

1)  Floodplain forests  

Krejza et al., 2017 

1-9 

2)  All other forests 

Zianis et al., 2005 

10-250 

Area of strata 

 NFI, 2009 

 All 

Species composition 

1)  State forests  

NFI, 2009 

1, 5, 15, 25, 30-250 

2)  Private forests 

Brus et al., 2011 

2-4, 6-14, 16-24, 26-29 

References for the Table 14: 

Brus, D.J., Hengeveld G.M., Walvoort D.J.J., Goedhart P.W., Heidema A.H., Nabuurs G.J., 
Gunia  K.  (2011)  Statistical  mapping  of  tree  species  over  Europe.  European  Journal  of 
Forest Research 131 (1): 145–157 

Krejza  J.,  Světlík  J.,  Bednář  P.  (2017)  Allometric  relationship  and  biomass  expansion 
factors  (BEFs)  for  above-  and  below-ground  biomass  prediction  and  stem  volume 
estimation  for  ash  (Fraxinus  excelsior  L.)  and  oak  (Quercus  robur  L.).  Trees,  31  (4): 
1303-1316 

NFI (2009) National Forest Inventory. 

Zianis  D.,  Muukkonen  P.,  Mäkipää  R.,  Mencuccini  M.  (2005)  Biomass  and  stem  volume 
equations for tree species in Europe. Silva Fennica Monographs 4, 63 pp. 

104 

 
 
  
  
  
  
 
 
 
 
 
 Guidance on developing and reporting Forest Reference Levels in accordance with 
Regulation (EU) 2018/841 

Filled in examples of tables for Step 2 

In this subsection we illustrate how Member State may document their FMPs through the 
use of Table 3 to Table 6. The table below only serve as examples and a Member State is 
of course free to select to document their nationally specific FMPs in other ways. 

Table 15: Filled in example of Table 3.  

Forest Management Practice 

Index 

Name of Practice 

Short Description of Practice 

FMP 1 

Pine clearcutting long 

FMP 2 

Pine clearcutting short 

FMP 3 

Pine uniform shelterwood 

FMP 4 

Pine non uniform shelterwood  

FMP 5 

Spruce clearcutting 

FMP 6 

Spruce non uniform shelterwood 

FMP 7 

Spruce close to nature 

FMP 8 

Beech timber shelterwood 

FMP 9 

Beech close to nature 

FMP 10 

Oak timber provision 

FMP 11 

Mixed forests with selective 
systems 

FMP 12 

Oak coppice 

FMP 13 

Chestnut timber coppice 

FMP 14 

Eucalyptus pulpwood 

FMP 15 

FMP 16 

FMP 17 

No intervention  
Nature conservation and 
biodiversity protection without 
management 
Nature conservation and 
biodiversity protection with 
management 

FMP 18 

Soil protection 

FMP 19  Water purification 

FMP 20 

Close to Nature Forest 

Even aged pine forest with long rotation and 
regenerated by clearcut 
Even aged pine forest with short rotation and 
regenerated by clearcut 
Even aged pine forest regenerated with 
consecutive cuttings applied on the whole 
area  
Even aged pine forest regenerated with 
consecutive cuttings applied on groups, 
strips or different spatial patterns 
Even aged spruce forest regenerated by 
clearcutting  
Even aged spruce forest regenerated with 
consecutive cuttings applied on groups, 
strips or different spatial patterns 
Spruce forest with close to nature cuttings 
and natural regeneration (e.g. group 
selection) 
Even aged beech forest managed to produce 
timber and regenerated with consecutive 
cuttings 

Beech forest with close to nature cutting and 
natural regeneration (e.g. group selection, 
single tree selection)  

Oak forest with long rotation and 
regenerated by clearcut or shelterwood 
Forest with mixed tree species and uneven 
aged management (e.g. group selection, 
single tree selection) 
Oak coppice with short rotation cycle for 
firewood production 
Chestnut coppice with standards for timber  

Eucalyptus plantation for pulpwood 
production with short rotation cutting cycle 

Forest without active management 

Forest without management and aimed to 
protect and preserve biodiversity 

Forest with management oriented to 
biodiversity protection and preservation 

Forest with management oriented to soil 
protection 
Forest with management oriented to water 
purification 
Forest with close to nature management and 
minimal intervention 

105 

 
 
Table 16: Filled in example of Table 4. 

Forest management practice 

Index 

Name of practice 

FMP 1 

FMP 2 

FMP 3 

FMP 4 

FMP 5 

FMP 6 

FMP 8 

Pine clearcutting long 

Pine clearcutting short 

Pine uniform shelterwood 

Pine non uniform shelterwood 

Spruce clearcutting 

Spruce non uniform shelterwood 

Beech timber shelterwood 

FMP 10 

Oak timber provision 

FMP 12 

Oak coppice 

FMP 13 

Chestnut timber coppice 

FMP 14 

Eucalyptus pulpwood 

FMP 15 

FMP 16 

No intervention 
Nature conservation and biodiversity protection 
without management 

FMP 18 

Soil protection 

Water purification 
FMP 19 
*percentage of standing biomass at the time of intervention 

Silvicultural operations with final harvesting 

Pre-commercial 
thinning 

First commercial 
thinning 

Second commercial 
thinning 

Final cutting 

Age (yrs) 
or Dbh 
(cm.) 

% 
biomass 
harvest* 

Age (yrs) 
or Dbh 
(cm.) 

% 
biomass 
removals
* 

Age (yrs) 
or Dbh 
(cm.) 

% 
biomass 
removals
* 

Age (yrs) 
or Dbh 
(cm.) 

% 
biomass 
removals* 

>10 

>10 

N.A. 

N.A. 

>10 

N.A. 

N.A. 

N.A. 

N.A. 

>10 

N.A. 

N.A. 

N.A. 

N.A. 

N.A. 

15% 

15% 

N.A. 

N.A. 

15% 

N.A. 

N.A. 

N.A. 

N.A. 

15% 

N.A. 

N.A. 

N.A. 

N.A. 

N.A. 

>20 

>20 

>20 

>20 

>20 

>20 

>20 

>20 

N.A. 

N.A. 

N.A. 

N.A. 

N.A. 

N.A. 

N.A. 

15% 

15% 

15% 

15% 

15% 

15% 

15% 

20% 

N.A. 

N.A. 

N.A. 

N.A. 

N.A. 

N.A. 

N.A. 

N.A. 

N.A. 

>30 

>30 

N.A. 

>30 

>30 

N.A. 

N.A. 

N.A. 

N.A. 

N.A. 

N.A. 

N.A. 

N.A. 

N.A. 

N.A. 

15% 

15% 

N.A. 

15% 

15% 

N.A. 

N.A. 

N.A. 

N.A. 

N.A. 

N.A. 

N.A. 

N.A. 

120 - 140 

60 - 80 

80-120 

80-120 

80-100 

80-120 

80-120 

80-120 

20-30 

30-40 

12-20 

N.A. 

N.A. 

100-120 

100-120 

95% 

95% 

95% 

95% 

95% 

95% 

95% 

95% 

90% 

85% 

95% 

N.A. 

N.A. 

70% 

70% 

 
 
Table 17: Filled in example of Table 5 

Forest management practice 

Silvicultural operations without final 
harvesting 

Index 

Name of practice 

Years between 
operation (yrs.) 

% biomass removals 

FMP 20  Single tree selection 

15-20 

FMP 21  Single tree selection and thinning 

15-20 

FMP 22   Group selection 

20-25 

15% 

25% 

25% 

Table 18: Filled in example of Table 6 

Stratification of MFL 

% distribution of forest management 
practices 

Ownership 
type 

Private 
commercial 
forest 
owners 

State 
owned 
forest 

Main 
tree 
species 

Pine 

Spruce 

Birch 

Aspen 

Pine 

Spruce 

Birch 

Aspen 

Productivity 
class 

FMP 
Index 1 

FMP 
Index 2 

FMP 
Index 3 

FMP 
Index 4 

… 

 I 

 II 

 I 

 II 

 I 

 II 

 I 

 II 

 I 

 II 

 I 

 II 

 I 

 II 

 I 

 II 

12% 

16% 

88% 

82% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

51% 

41% 

44% 

54% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

5% 

5% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

Sum 
Total 
(%) 

100% 

100% 

100% 

100% 

100% 

100% 

100% 

100% 

100% 

100% 

100% 

100% 

100% 

100% 

100% 

100% 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 Guidance on developing and reporting Forest Reference Levels in accordance with 
Regulation (EU) 2018/841 

ANNEX IV 

Overview of implementation of the Kyoto Protocol in the EU Member States 

Table 19, Table 20 and Table 21 give an overview of the reporting of LULUCF activities by 
the Member States under KP second commitment period. 

Table  19.  Voluntary  KP-LULUCF  activities  elected  by  Member  States  in  the  second  commitment 
period, and accounting timing selected. 

Member State 

Art 3.4 elected activities  

Accounting frequency 

Austria 

Belgium 

Bulgaria 

Croatia 

Cyprus 

Czech Republic 

Denmark 

Estonia 

Finland 

France 

Germany 

Greece 

Hungary 

Ireland 

Italy 

Latvia 

Lithuania 

Luxemburg 

Malta 

Netherlands 

Poland 

Portugal 

Romania 

Slovakia 

Slovenia 

Spain 

Sweden 

--- 

--- 

--- 

--- 

--- 

--- 

CM, GM 

--- 

--- 

--- 

CM, GM 

--- 

--- 

CM,GM 

CM, GM 

--- 

--- 

--- 

--- 

--- 

--- 

CM, GM 

RV 

--- 

--- 

CM 

--- 

United Kingdom 

Iceland 

CM, GM, WDR 

RV 

end of CP 

end of CP 

end of CP 

end of CP 

end of CP 

end of CP 

annual 

end of CP 

end of CP 

end of CP 

end of CP 

end of CP 

annual 

end of CP 

end of CP 

end of CP 

end of CP 

end of CP 

end of CP 

end of CP 

end of CP 

end of CP 

end of CP 

end of CP 

end of CP 

end of CP 

end of CP 

end of CP 

end of CP 

108 

 
 
Table 20. C pools for which estimates have been reported under each of the KP-LULUCF activities. 

CHANGE IN CARBON POOL REPORTED 

GREENHOUSE GAS SOURCES REPORTED 

Member State 

AGB 

BGB 

Litter 

Dead 
wood  

Soil  

HWP 

Fertilization 

Drained, 
rewetted 
and other 
soils 

Nitrogen 
mineralization 
in mineral 
soils 

Indirect 
N2O 
emissions 
from 
managed 
soil 

 Biomass burning 

Min 

Org 

N2O 

CH4  N2O 

N2O 

N2O 

CO2 

CH4 

N2O 

Afforestation/Reforestation 

Austria 

Belgium 

Bulgaria 

Croatia 

Cyprus 

Czech Republic 

Denmark 

Estonia 

Finland 

France 

Germany 

Greece 

Hungary 

Ireland 

Italy 

Latvia 

Lithuania 

Luxemburg 

Malta 

Netherlands 

Poland 

R 

R 

R 

R 

R 

R 

R 

R 

R 

R 

R 

R 

R 

R 

R 

R 

R 

NR 

R 

R 

R 

R 

IE 

R 

R 

R 

R 

R 

R 

R 

R 

R 

R 

R 

R 

R 

R 

NR 

R 

R 

R 

R 

R 

R 

R 

R 

R 

IE 

R 

R 

NR 

NR 

R 

R 

R 

R 

R 

NR 

NR 

R 

R 

R 

NO 

NO 

R 

R 

R 

IE 

R 

R 

NR 

NR 

R 

R 

R 

NO 

R 

NR 

R 

R 

R 

R 

R 

R 

R 

R 

R 

R 

R 

R 

NR 

NR 

NO 

R 

NO 

R 

R 

NR 

R 

R 

NO 

NO 

NO 

NO 

R 

R 

R 

R 

IE 

R 

NO 

NO 

R 

NO 

R 

R 

NO 

NO 

R 

R 

R 

R 

R 

NO 

R 

R 

R 

R 

IE 

NO 

IE 

R 

R 

NO 

IE 

IO 

NO 

IE 

NO 

NO 

NO 

NO 

NO 

NO 

IE 

NO 

R 

NO 

NO 

NO 

IE 

IE 

NO 

NO 

NO 

NO 

NO 

NO 

NO 

NO 

NO 

NO 

NO 

NO 

NO 

NO 

NO 

NO 

NO 

R 

NE 

R 

R 

NE 

R 

NO 

NO 

NO,R  NO,R 

NO 

NO 

R 

NO 

NO 

R 

NO 

NO 

R 

R 

NO 

NO 

NE 

NO 

R 

R 

NO 

NO 

NE 

NO 

R 

R 

NO 

NO 

NO 

NO 

NO 

R 

R 

R 

NO 

NO 

NO 

R 

NO 

NO 

NO 

NO 

R 

NO 

NO 

NO 

NO 

NO 

NO 

R 

NO 

R 

R 

NO 

NO 

IE 

R 

NO 

NO 

NO 

NO 

NO 

NO 

NO 

NO 

R 

R 

NO 

NO 

IE 

R 

R 

NO 

NO 

R 

R 

NO 

NO 

R 

R 

R 

NO 

NO 

R 

R 

NO 

NO 

R 

R 

R 

IE,NO 

IE,NO 

IE,NO 

R 

IE 

R 

R 

NO 

R 

NO 

NO 

R 

R 

R 

R 

R 

R 

NO 

R 

NO 

NO 

R 

R 

R 

R 

R 

R 

NO 

R 

NO 

NO 

R 

R 

 
 
 
  
 
 
 
 
 
  
  
 
 
 
 
 
 
  
  
 
 Guidance on developing and reporting Forest Reference Levels in accordance with Regulation (EU) 2018/841 

Portugal 

Romania 

Slovakia 

Slovenia 

Spain 

Sweden 

United Kingdom 

Iceland  

Austria 

Belgium 

Bulgaria 

Croatia 

Cyprus 

Czech Republic 

Denmark 

Estonia 

Finland 

France 

Germany 

Greece 

Hungary 

Ireland 

Italy 

Latvia 

Lithuania 

Luxemburg 

Malta 

Netherlands 

R 

R 

R 

NO 

R 

R 

R 

R 

R 

R 

R 

R 

R 

R 

R 

R 

R 

R 

R 

R 

R 

R 

R 

R 

R 

R 

R 

R 

R 

R 

R 

IE 

NO 

NO,NR 

R 

R 

R 

NO 

NR 

NO,NR 

NO 

NO 

NO 

NO 

IE 

R 

IE 

R 

R 

R 

IE 

R 

R 

R 

R 

R 

R 

R 

R 

R 

R 

R 

R 

R 

R 

NR,R 

NR,R 

NR,R 

R 

R 

R 

R 

R 

R 

R 

R 

R 

R 

R 

IE 

NO 

R 

R 

R 

IE 

R 

R 

R 

IE 

IE,R 

R 

R 

R 

R 

R 

R 

R 

R 

R 

R 

R 

R 

R 

R 

R 

R 

R 

R 

R 

R 

R 

R 

R 

R 

R 

R 

R 

R 

R 

R 

R 

R 

R 

R 

R 

R 

R 

R 

NO 

NO 

R 

R 

R 

NO 

NO 

NO 

NO 

R 

R 

R 

R 

IE 

R 

NO 

NO 

R 

NO 

R 

R 

NO 

NO 

R 

NO 

R 

NO 

R 

NO 

R 

NO 

R 

NO 

R 

R 

R 

NR 

NO 

NR 

R 

R 

NO 

IE 

IE 

NO 

NO 

NO 

NO 

R 

R 

Deforestation 

IO 

R 

R 

R 

R 

R 

R 

IO 

NO 

NO 

IO 

IO 

R 

R 

IO 

IO 

NO 

IO 

NO 

IE 

NO 

NO 

NO 

IE 

NO 

IE 

NO 

NO 

NO 

IE 

IE 

NO 

IE 

NO 

NO 

NO 

IE 

NO 

NO 

NO 

NO 

NO 

R 

NE 

R 

NO 

NO 

NO 

NO 

NO 

NO 

NO 

NO 

R 

R 

R 

NO 

NO 

NO 

NO 

NO 

NO 

NO 

R 

NE 

R 

R 

NE 

R 

NO 

NO 

NO,R  NO,R 

NO 

NO 

R 

NO 

NO 

R 

NO 

NO 

R 

NO 

NO 

NO 

NE 

R 

NO 

NO 

NO 

NE 

R 

R 

NO 

NO 

IE 

R 

NO 

NO 

R 

R 

R 

R 

R 

R 

R 

R 

R 

NO 

NO 

NO 

NE,R 

IE,NE 

IE,NO,R 

NO,R 

NO,R 

R 

R 

NO 

R 

R 

NO 

R 

R 

R 

NO 

R 

R 

R 

R 

R 

R 

NO 

IE 

R 

R 

NO 

R 

R 

R 

NO 

NO 

NO 

NO 

NO 

NO 

IE 

NO 

IE 

R 

NO 

R 

IE 

NO 

IE 

NO 

NO 

NO 

IE 

NO 

R 

NO 

NO 

NO 

NO 

NO 

NO 

NO 

NO 

R 

R 

NO 

NO 

IE 

NO 

NO 

NO 

NO 

NO 

NO 

R 

NO 

R 

NO 

NO 

NO 

NO 

NO 

NO 

NO 

NO 

R 

R 

NO 

NO 

R 

NO 

NO 

NO 

NO 

NO 

NO 

R 

NO 

R 

NO 

NO 

NO 

NO 

NO 

NO 

NO 

NO 

R 

R 

NO 

NO 

R 

NO 

NO 

NO 

NO 

NO 

NO 

R 

110 

 
 
  
 
 
 
 
 
  
 
 
 
 
 
 
 
  
  
 
 Guidance on developing and reporting Forest Reference Levels in accordance with Regulation (EU) 2018/841 

Poland 

Portugal 

Romania 

Slovakia 

Slovenia 

Spain 

Sweden 

United Kingdom 

Iceland  

Austria 

Belgium 

Bulgaria 

Croatia 

Cyprus 

Czech Republic 

Denmark 

Estonia 

Finland 

France 

Germany 

Greece 

Hungary 

Ireland 

Italy 

Latvia 

Lithuania 

Luxemburg 

Malta 

R 

R 

R 

R 

R 

R 

R 

R 

R 

R 

R 

R 

R 

R 

R 

R 

IE 

NO 

R 

R 

R 

R 

R 

R 

R 

NR,R 

IE,NR  NR,R 

NR,R 

NR,R 

R 

R 

R 

R 

R 

R 

R 

R 

R 

R 

R 

R 

R 

R 

R 

R 

R 

R 

R 

R 

R 

IE 

R 

R 

R 

IE 

NO 

NO 

NO 

R 

R 

IE 

R 

R 

R 

R 

R 

R 

R 

R 

R 

R 

R 

R 

R 

R 

IE 

NO 

R 

NO 

IE 

R 

R 

IE 

R 

R 

NR 

NR 

R 

R 

R 

R 

R 

R 

NO 

R 

NO 

R 

R 

R 

IE 

R 

R 

NR 

NR 

R 

R 

R 

R 

R 

NO 

NO 

NO 

NO 

R 

R 

R 

R 

R 

R 

NO 

R 

R 

R 

R 

R 

R 

NR 

NR 

NA 

NR 

NO 

NO 

R 

NO 

R 

NO 

NR 

NO,NR 

NO 

NO 

R 

IE 

R 

NO 

NO 

NO 

NO 

R 

R 

R 

R 

IE 

R 

NO 

R 

R 

NR 

R 

R 

NO 

NO 

R 

R 

R 

NR 

IO 

NR 

IO 

IO 

NO 

NO 

IE 

IE 

NO 

NO 

NO 

NO 

NO 

NO 

Forest Management 

R 

R 

R 

R 

R 

R 

R 

R 

R 

R 

R 

R 

R 

R 

R 

IO 

NO 

NO 

NO 

NO 

NO 

NO 

IE 

NO 

R 

NO 

NO 

NO 

IE 

IE 

NO 

NO 

NO 

NO 

NO 

NO 

NO 

NO 

NO 

NO 

NO 

R 

NO 

NO 

NO 

NO 

NO 

NO 

R 

NO 

NO 

R 

R 

NO 

NO 

NO 

NO 

NO 

NO 

NO 

NO 

NO 

NO 

R 

R 

NA 

NA 

R 

R 

NO 

NO 

NO,R  NO,R 

NO 

NO 

R 

NO 

NO 

R 

NO 

NO 

R 

R 

NO 

NO 

R 

R 

NO 

NO 

NO 

R 

R 

NO 

R 

NO 

IE 

R 

NO 

NO 

NO 

NO 

NO 

R 

R 

NO 

NO 

R 

R 

NO 

NO 

R 

R 

NO 

NO 

NE,R 

IE,NE 

NO,R 

IE,NO,R 

IE,NO,R 

R 

R 

NE 

NO 

R 

NO 

NO 

NO 

NO 

NO 

R 

R 

R 

NO 

NO 

NO 

NO 

R 

NO 

NO 

NO 

R 

R 

NO 

NO 

NO 

NO 

NO 

NO 

IE 

NO 

R 

R 

NO 

NO 

IE 

NO 

R 

NO 

NO 

NO 

NO 

R 

NO 

IE 

NO 

R 

R 

R 

NO 

IE 

R 

R 

NO 

R 

NO 

R 

NO 

R 

R 

R 

NO 

R 

R 

R 

NO 

R 

NO 

R 

NO 

R 

R 

R 

NO 

R 

R 

R 

IE,NO 

NO,R 

NO,R 

R 

IE 

R 

R 

R 

R 

NO 

NO 

R 

R 

R 

R 

R 

R 

R 

R 

R 

R 

R 

R 

NO 

NO 

NO 

NO 

111 

 
 
  
 
 
 
 
 
  
 
 
 
 
 
 
 
  
  
 
 Guidance on developing and reporting Forest Reference Levels in accordance with Regulation (EU) 2018/841 

Netherlands 

Poland 

Portugal 

Romania 

Slovakia 

Slovenia 

Spain 

Sweden 

United Kingdom 

Iceland  

Denmark 

Germany 

Ireland 

Italy 

Portugal 

Spain 

United Kingdom 

Denmark 

Germany 

Ireland 

Italy 

Portugal 

United Kingdom 

Romania 

Iceland  

R 

R 

R 

R 

R 

R 

R 

R 

R 

R 

R 

R 

R 

R 

R 

R 

R 

R 

R 

R 

R 

R 

R 

R 

R 

R 

R 

R 

R 

R 

R 

IE 

R 

IE 

R 

R 

R 

IE 

R 

R 

IE 

IE 

R 

R 

IE 

R 

R 

IE 

R 

IE 

NO 

R 

R 

R 

R 

R 

IE 

NO 

NO 

R 

R 

R 

NO 

R 

NO 

NR 

NO,NR  NO,NR  NO,NR  NO,NR 

NR 

NR 

R 

R 

R 

NO 

IE 

NO 

NO 

R 

NR,R 

NR 

NO 

IE 

NO 

NO 

R 

NR 

R 

IE 

R 

NR 

R 

IE 

NR 

NO 

IE,NO 

NO 

NO 

NO 

NR 

NR 

NO 

IE,NO 

NO 

NO 

NO 

NR 

R 

NO 

NR 

NR 

R 

R 

R 

R 

R 

R 

R 

R 

R 

R 

R 

R 

R 

R 

R 

R 

R 

R 

NO 

NO 

R 

R 

R 

R 

R 

NO 

R 

NO 

NO 

R 

R 

R 

NO 

R 

NO 

R 

NO 

NO 

R 

R 

R 

R 

R 

R 

R 

R 

R 

R 

NO 

NO 

IE 

IE 

NO 

NO 

NO 

R 

NO 

NO 

Cropland Management 

Grassland Management 

NE 

NO 

NO 

NO 

NO 

NO 

NO 

R 

R 

R 

NE 

R 

NO 

NO 

NO 

NO 

NO 

R 

NE 

R 

R 

NO,R 

NO 

NO 

NO 

NO 

NE 

R 

NO,R 

NO 

NO 

NO 

NE 

Revegetation Management 

R 

R 

NO 

NO 

NO 

NO 

R 

NO 

R 

R 

NO 

NO 

NE 

R 

R 

NE 

IE 

R 

IE 

NO 

R 

NE,R 

R 

IE 

R 

IE 

NO 

R 

R 

R 

IE 

NO 

NO 

IE 

R 

NO 

NO 

NE 

R 

NO 

NE 

R 

IE 

R 

R 

R 

R 

R 

R 

IE,R 

R 

R 

R 

R 

R 

R 

R 

R 

R 

R 

R 

R 

R 

R 

R 

R 

R 

R 

R 

R 

NO 

NO 

NO 

NO 

NO 

NO 

R 

R 

NO 

NO 

R 

R 

R 

NO 

NO 

R 

R 

R 

NO,R 

IE,NO,R 

IE,NO,R 

NE 

R 

R 

NO 

NO 

NO 

R 

R 

NE 

R 

NE 

NO 

NO 

NO 

NO 

R 

R 

R 

R 

R 

R 

R 

R 

R 

R 

R 

R 

112 

 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
 Guidance on developing and reporting Forest Reference Levels in accordance with Regulation (EU) 2018/841 

United Kingdom 

NR 

NR 

NR 

NR 

NR 

NE 

NE 

NE 

NE 

NE 

NE 

NE 

Wetlands Drainage and Rewetting 

113 

 
 
  
  
  
Table  21.  Values  of  FMRL  and  of  its  technical  correction  reported  by  the  Member  States,  with 
information on the method applied to construct the FMRL. 

Value 
inscribed in 
the 
Appendix to 
the annex to 
decision 
2/CMP.7  
(kt CO2 
eq/yr) 

 FMRL based on projections under a "Business-as-
usual" scenario 

Technical 
correction  

Model-based 
projections using 
country-specific 
methodology 

Model-based 
projections 
using JRC 
approach 

Projections 
based on 
historical data 
assumed as 
proxy for a 
“business-as-
usual”  

-6516 

-2499 

-7950 

-6289 

-157 

-4686 

409 

-2741 

-20466 

-67410 

-22418 

-1830 

-1000 

-142 

-22166 

-16302 

-4552 

-418 

-49 

-1425 

-27133 

-6830 

-15793 

-1084 

-3171 

-23100 

-41336 

-8268 

-315323 

-154 

5823 

NA 

23 

905 

NA 

NA 

-83 

NE 

-14545 

21795 

NE 

257 

-40 

-571 

-1680 

11703 

-922 

182 

49 

NE 

NA 

3286 

-3665 

-1214 

NE 

NO 

9156 

-14515 

15943 

77 

-315476.5 

16020 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

Member State 

Austria 

Belgium 

Bulgaria 

Croatia 

Cyprus 

Czech Republic 

Denmark 

Estonia 

Finland 

France 

Germany 

Greece 

Hungary 

Ireland 

Italy 

Latvia 

Lithuania 

Luxemburg 

Malta 

Netherlands 

Poland 

Portugal 

Romania 

Slovakia 

Slovenia 

Spain 

Sweden 

UK 

EU 

Iceland 

EU+Iceland  

 
 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
 
 
 
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• via EU Bookshop (http://bookshop.europa.eu).

Priced subscriptions: 

• via one of the sales agents of the Publications Office of the European Union

(http://publications.europa.eu/others/agents/index_en.htm).

M
L
-
0
4
-
1
8
-
6
7
7
-
E
N
-
N