COMMISSION STAFF WORKING DOCUMENT ASSESSMENT OF THE NATIONAL FORESTRY ACCOUNTING PLANS REGULATION (EU) 2018/841 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL 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 Accompanying the document Communication from the Commission to the European Parliament, the Council, the European Economic and Social Commitee and the Committee of the Regions United in delivering the Energy Union and Climate Action - Setting the foundations for a successful clean energy transition
Date: 2019-06-18
Institutions: Directorate-General for Energy, European Commission
Subjects: EU Member State, EU energy policy, electrical energy, energy efficiency, energy grid, greenhouse gas, innovation, reduction of gas emissions, renewable energy, self-sufficiency in energy

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 18.6.2019  SWD(2019) 213 final  COMMISSION STAFF WORKING DOCUMENT ASSESSMENT OF THE NATIONAL FORESTRY ACCOUNTING PLANS                  REGULATION (EU) 2018/841 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL 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 Accompanying the document Communication from the Commission to the European Parliament, the Council, the European Economic and Social Commitee and the Committee of the Regions United in delivering the Energy Union and Climate Action - Setting the foundations for a successful clean energy transition {COM(2019) 285 final} - {SWD(2019) 212 final}  
 
 
Table of contents 

1. 

2. 

3. 

4. 

5. 

INTRODUCTION ................................................................................................................................ 3 

SUBMISSION OF THE NATIONAL FORESTRY ACCOUNTING PLANS .................................... 4 

PRINCIPLES  AND  REQUIREMENTS  FOR  THE  TECHNICAL  ASSESSMENT  OF  THE 
NATIONAL FORESTRY ACCOUNTING PLANS ............................................................................ 4 

3.1 

3.2 

3.3 

Principles: Article 8(5) .................................................................................................... 5 

Criteria: Annex IV, Section A ......................................................................................... 6 

Elements: Annex IV, Section B ...................................................................................... 8 

TECHNICAL ASSESSMENT ............................................................................................................ 10 

TECHNICAL RECOMMENDATIONS ............................................................................................. 11 

5.1 

5.2 

5.3 

5.4 

5.5 

5.6 

5.7 

5.8 

5.9 

Belgium ......................................................................................................................... 11 

Bulgaria ......................................................................................................................... 12 

Czechia .......................................................................................................................... 13 

Denmark ........................................................................................................................ 14 

Germany ........................................................................................................................ 15 

Estonia ........................................................................................................................... 16 

Ireland............................................................................................................................ 16 

Greece ............................................................................................................................ 17 

Spain .............................................................................................................................. 18 

5.10  France ............................................................................................................................ 19 

5.11  Croatia ........................................................................................................................... 20 

5.12 

Italy................................................................................................................................ 21 

5.13  Cyprus ........................................................................................................................... 22 

5.14  Latvia ............................................................................................................................. 23 

5.15  Lithuania ........................................................................................................................ 24 

5.16  Luxembourg .................................................................................................................. 25 

5.17  Hungary ......................................................................................................................... 26 

5.18  Malta.............................................................................................................................. 26 

5.19  Netherlands .................................................................................................................... 27 

5.20  Austria ........................................................................................................................... 28 

5.21  Poland ............................................................................................................................ 28 

5.22  Portugal ......................................................................................................................... 29 

5.23  Slovenia ......................................................................................................................... 30 

5.24  Slovakia ......................................................................................................................... 32 

5.25  Finland ........................................................................................................................... 32 

5.26  Sweden .......................................................................................................................... 34 

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5.27  United Kingdom ............................................................................................................ 35 

6.  NEXT STEPS ..................................................................................................................................... 35 

2 

 
1.  INTRODUCTION 

The  land  use,  land  use  change  and  forestry  (‘LULUCF’)  sector  has  the  potential  to 
provide  long-term  climate  benefits,  and  thereby  contribute  to  the  achievement  of  the 
Union’s greenhouse gas emissions reduction target and to the long-term climate goals of 
the Paris Agreement. The LULUCF sector also provides bio-materials that can substitute 
fossil-  or  carbon-intensive  materials  and  therefore  plays  an  important  role  in  the 
transition to a low greenhouse-gas-emitting economy. 

Sustainable  management  practices  in  the  LULUCF  sector  can  contribute  to  climate 
change  mitigation  in  several  ways,  in  particular  by  reducing  emissions  and  enhancing 
through  sequestration.  In  addition,  sustainable 
stable  sinks  and  carbon  stocks 
management  practices  can  maintain  the  resilience,  productivity,  regeneration  capacity 
and vitality of the LULUCF sector, thereby promoting economic and social development 
while reducing the carbon and ecological footprint of all sectors. 

Sustainably managed forests normally are sinks, contributing to climate mitigation. In the 
reference  period  from  2000  to  2009,  the  reported  average  removals  by  sinks  from 
managed forest land were 372 million tonnes of CO2 equivalent per year for the Union as 
a whole. While afforested land and managed grassland represent other carbon sinks in the 
LULUCF  sector,  deforested  land  and  managed  cropland  are  net  sources.  The  total 
LULUCF sink in 2005 was 299 million tonnes of CO2. 

Member States should ensure that sinks and reservoirs, including forests, are conserved 
or  enhanced  with  a  view  to  meeting  the  ambitious  greenhouse  gas  emissions  reduction 
targets of the Union by 2030 and strategies to reduce emissions to net zero by 2050, in 
line with the Paris Agreement. 

To  help  achieve  these  goals,  Regulation  2018/8411 (hereafter‚  ‘LULUCF  Regulation’) 
sets out a robust accounting system. This Regulation sets a binding commitment for each 
Member State to ensure that accounted emissions from land use are at least compensated 
by an equivalent removal of CO₂  from the atmosphere through action in the sector. This 
is known as the ‘no debit’ rule. 

Emissions and removals from forest land depend on a number of natural circumstances, 
notably dynamic age-related forest characteristics, and on past and present management 
practices  that  differ  substantially  between  the  Member  States.  The  relevant  accounting 
rules should therefore provide for the use of ‘reference levels’ to exclude the effects of 
natural  and  country-specific  characteristics.  Forest  reference  levels  should  take  account 
of any unbalanced age structure of forests and should not unduly constrain future forest 
management intensity, so that long-term carbon sinks can be maintained or strengthened. 

1 Regulation of the European Parliament and of the Council (EU) 2018/841 on the inclusion of greenhouse 
gas (GHG) 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 
(LULUCF Regulation) 

3 

 
                                                 
The forest reference level is based on the continuation of sustainable forest management 
practice  as  documented  in  the  reference  period  2000-2009,  thus  providing  a  projected, 
forward-looking  benchmark  against  which  reported  emissions  and  removals  from 
managed forest land from the period 2021 – 2025 will be accounted.2 

2.  SUBMISSION OF THE NATIONAL FORESTRY ACCOUNTING PLANS 

Article  8(3)  of  the  LULUCF  Regulation  requires  Member  States  to  submit  to  the 
Commission their national forestry accounting plans (NFAP), including a proposed forest 
reference level for the period from 2021 to 2025, by 31 December 2018.  

As of 15 May 2019, 27 Member States have submitted their national forestry accounting 
plans. Links to the plans published on the respective national webpages can be found on 
the registry of the Land Use, Land Use Change and Forestry Expert Group. 

3.  PRINCIPLES  AND  REQUIREMENTS  FOR  THE  TECHNICAL  ASSESSMENT 

OF THE NATIONAL FORESTRY ACCOUNTING PLANS 

The  Commission,  in  consultation  with  experts  appointed  by  the  Member  States,  civil 
society  and  other  stakeholders  (forming  the  LULUCF  Expert  Group,  see  section  4), 
undertook  a  technical  assessment  of  the  NFAPs  submitted  by  Member  States,  with  a 
view  to  assessing  the  extent  to  which  the  proposed  forest  reference  levels  have  been 
determined in accordance with the following requirements:  

•  The  principles  set  out  in  Article  8(5)  and  other  related  articles  of  the  LULUCF 

Regulation 

•  The criteria set out in Section A of Annex IV of the LULUCF Regulation 

•  The elements listed in Section B of Annex IV of the LULUCF Regulation 

For  Croatia,  its  forest  reference  level  may  also  take  into  account,  in  addition  to  the 
criteria set out in Section A of Annex IV of the LULUCF Regulation, the occupation of 
its  territory,  and  wartime  and  post-war  circumstances  that  had  an  impact  on  forest 
management during the reference period. 

The following sections explain in more detail how these requirements have been applied 
but are without prejudice to the LULUCF Regulation.  

2 With regard to the other land categories under the LULUCF Regulation, different accounting methods are 
applied:  Emissions and removals from managed cropland, managed grassland and managed wetland will 
be  accounted  for  against  average  annual  values  from  the  base  period  2005  to  2009.  Emissions  and 
removals from afforested and deforested land will be accounted as a sum of total emissions and removals 
in the compliance period, with no comparison to a base year or reference. 

4 

 
 
 
                                                 
3.1  Principles: Article 8(5)  

Subparagraph 1  

‘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.’  

This principle establishes the forest reference level (FRL) as a baseline with the view to 
projecting  how  carbon stocks  of  managed forest land would develop in the compliance 
period of 2021-2025, if there were no changes to the forest management practice of the 
reference  period  2000-2009.  Parameters  defining  the  forest  management  practice  (e.g. 
rotation lengths, rates of harvest in ‘thinnings’ and ‘final cuts’, for a given forest species, 
etc.) during the reference period need to be documented in detail and remain constant in 
the  projection.  Assumed  future  impact  of  policies  or  market  development  is  not  to  be 
included in the estimation of the FRL. However, the impact of age-related dynamics on 
forest characteristics of the managed forest land is taken into account when modelling the 
FRL, e.g. characteristics such as the mean age of a stand, its biomass density, age-related 
diameter class distribution or net increment.  

For modelling their FRL, Member States shall use ‘best available data’. This relates to 
the  description  of  the  forest  management  practice  in  the  reference  period  and  the 
definition of the state of the forest (e.g. total area of the managed forest land, age related 
information,  increment,  species  composition  etc.)  Comprehensive  data  from  the  most 
appropriate  National  Forest  Inventories  and  latest  greenhouse  gas  (GHG)  inventories 
shall  be  used.  A  FRL  projected  in  this  way  represents  the  combination  of  forest 
management practice from the reference period with the impact of age-related dynamics 
on forest characteristics and will therefore allow changes in the future forest management 
practices to be accounted properly.  

Subparagraph 2 

‘Forest reference levels  as determined in accordance with the first subparagraph  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’ 

Allowing the age-related characteristics of the managed forest land to develop over time 
in the FRL modelling means that the harvest volumes may also vary between years in the 
compliance period as well as differ from harvest volumes during the reference period ‘in 
order  not  to  unduly  constrain  forest  management  intensity’.  Any  projected  variation  in 
harvested volumes in the compliance period must therefore be justified by the age-related 
dynamics of forest characteristics.  

5 

 
 
The projected FRL shall at the same time be consistent with ‘the aim of maintaining or 
strengthening  long-term  carbon  sinks’.  In  order  to  allow  for  the  assessment  of 
compliance with this principle, qualitative and quantitative information shall be provided 
on the long-term  emissions and removals from the managed forest land  consistent with 
long-term strategy required under 2018/1999. This part of the principle is closely linked 
to the criterion (a) set out in Annex IV, Section A and will be addressed there.  

Subparagraph 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.’ 

The  criterion  related  to  this  subparagraph  is  embedded  in  criterion  (h)  of  Annex  IV, 
Section A and will be addressed there. 

3.2  Criteria: Annex IV, Section A  

‘A  Member  State’s  forest  reference  level  shall  be  determined  in  accordance  with  the 
following criteria:’ 

Criterion (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  criterion  links  the  LULUCF  Regulation  to  the  Paris  Agreement  and  requires  the 
Member States to take into consideration the long-term development of the forest sinks 
in  constructing  their  FRLs.  The  criterion  suggests  that  a  temporary  increase  in  harvest 
volumes  can  be  warranted  if  it  results  in  enhancing  the  potential  removals  by  forest 
increment in the long-term. In order to assess compliance with this criterion, information 
on the implications of the forest management practice used in the modelling of the FRL 
on the evolution of the forest sink beyond the compliance period must be provided. The 
Commission  suggests  providing  qualitative  and  quantitative  information  until  at  least 
2050 consistent with long-term strategy required under Regulation (EU) 2018/1999. 

Criterion (b) 

‘The  reference  level  shall  ensure  that  the  mere  presence  of  carbon  stocks  is  excluded 
from accounting.’ 

This  criterion  reflects  the  need  of  the  FRL  to  account  for  net  changes  in  forest  carbon 
stocks,  rather  than  accounting  for  total  existing  carbon  stocks  in  forests,  in  order  to 
encourage their enhancing. A properly applied FRL approach by definition ensures that 
‘the mere presence of carbon stocks is excluded from accounting.’ 

6 

 
 
 
Criterion (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 a key objective of the LULUCF Regulation to correctly account for 
emissions  from  biomass  use  elsewhere  in  the  climate  policy  framework  within  the 
LULUCF sector. For example, emissions from the combustion of wood for bioenergy are 
excluded from energy sector accounting. To this end, the FRL needs to be based on the 
continuation of forest management practices applied during the reference period in order 
to allow for the ‘robust and credible’ accounting of the biomass use.  

Criterion (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.’  

The LULUCF Regulation encourages sustainable production of harvested wood products 
(HWP)  from  forest  biomass  in  order  to  limit  emissions  and  enhance  removals  through 
their  substitution  effect.  This  criterion  asks  Member  States  to  include  the  HWP  carbon 
pool in their FRL projection and to provide a comparison to an FRL where instantaneous 
oxidation is assumed, i.e. a counterfactual where the HWP carbon pool is assumed to be 
zero.  

Criterion (e) 

‘A constant ratio between solid and energy use of forest biomass as documented in the 
period from 2000 to 2009 shall be assumed.’  

Compliance with this criterion requires that a ratio between solid use of forest biomass, 
i.e. paper, wood panels and sawn wood as specified in Article 9(1), and its energy use as 
documented in the reference period is established, and is applied as a constant parameter 
in the determination of the FRL. This approach provides a direct accounting incentive for 
favouring solid biomass in the downstream use of wood.  

Criterion (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  is  tied  to  the  notion  of  sustainable  forest  management  practice,  as 
documented in the reference period, upon whose continuation the FRL should be based 
(Article 8(5)). Qualitative information should therefore be provided to document how the 
forest  management  practice  of  the  reference  period  is  consistent  with  ‘the  objective  of 
contributing  to  the  conservation  of  biodiversity  and  the  sustainable  use  of  natural 
resources’.  

7 

 
Criterion (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  links  the  FRL  submitted  within  the  LULUCF  Regulation  to  the  overall 
policies and requirements as set out in Regulation (EU) No 525/2013, now replaced with 
Regulation (EU) 2018/1999. In case the FRL projection differs quantitatively from these 
national  projections  of  greenhouse  gas  emissions,  a  clear  explanation  and  rationale  of 
such differences should be provided. 

Criterion (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.’ 

The FRL is a benchmark for accounting for the managed forest land accounting category, 
which is directly based upon data collated from the national GHG inventories. In order to 
assess  compliance  of  the  FRL  with  this  criterion,  therefore,  it  needs  to  use  data  and 
methods  consistent  with  those  used  in  the  latest  GHG  inventories.  The  regulation  (Art 
5(1))  also  requires  that  the  methods  used  for  FRL  modelling  must  be  transparent, 
complete  (in  terms  of  mandatory  pools  and  greenhouse  gases  included),  accurate, 
consistently applied over time and comparable to IPCC methods.  

To  demonstrate  this  consistency,  the  model  used  to  construct  the  FRL  must  be  able  to 
reproduce historical data  (e.g.  on biomass  gain,  biomass losses  and net  greenhouse  gas 
emission/removals)  as  reported  in  the  GHG  inventories,  in  particular  for  the  reference 
period (2000-2009).  

3.3  Elements: Annex IV, Section B 

‘The national forestry accounting plan submitted pursuant to Article 8 shall contain the following 
elements:’ 

Element (a)  

‘A general description of the determination of the forest reference level and a description 
of how the criteria in this Regulation were taken into account.’ 

The  NFAP  should  contain  a  description  of  how  the  FRL  was  determined.  A  summary 
section explaining how the criteria of the LULUCF Regulation were addressed should be 
included.  

Element (b) 

‘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 

8 

 
 
level  determination,  and  demonstration  of  the  consistency  between  the  carbon  pools 
included in the forest reference level.’  

The NFAP must describe which carbon pools and greenhouse gases are included in the 
FRL calculation. In case a carbon pool was omitted, a justification needs to be provided. 
A description of  the methodological  consistency  of calculating emissions  and removals 
among  different  carbon  pools  is  also  to  be  included  in  the  NFAPs.  Recommendations 
under this element may include consistency of carbon pools and greenhouse gases with 
the national GHG inventory. 

Element (c)  

‘A  description  of  approaches,  methods  and  models,  including  quantitative  information, 
used in the determination of the forest reference level, consistent with the most recently 
submitted  national  inventory  report,  and  a  description  of  documentary  information  on 
sustainable  forest  management  practices  and  intensity  as  well  as  of  adopted  national 
policies.’  

A comprehensive description of the methodology used in the FRL modelling as well as 
documentation  of  input  data  in  the  NFAPs  must  be  provided  in  the  NFAP.  This  will 
permit  the  full  technical  understanding  of  the  derivation  of  the  FRL.  Documentary 
information  of  the  forest  management  practices  of  the  reference  period,  as  well  as 
relevant  national  policies,  is  also  expected  to  be  included  in  the  plan.  Furthermore,  the 
methodology and data used must be consistent with the latest National Inventory Report.  

Element (d) 

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

The FRL is in effect a ‘business as usual’ scenario; which is likely to be compared with a 
‘with  existing  measures’  or  ‘with  additional  measures’  scenario,  thus  providing  a 
comparison  of  sink  and  (among  other  parameters)  harvesting  rates.  This  underpins  the 
planning objective of the exercise to help identify the expected impact of policies (such 
as promotion of HWP) on forest sink and biomass use in the LULUCF sector. 

Element (e)  

‘A  description  of  how  each  of  the  following  elements  were  considered  in  the 
determination of the forest reference level:’ 

(i) the area under forest management 

The total area of managed forest land included under the accounting category (as defined 
in Art 2(1) of the LULUCF Regulation) must be consistent with the latest national GHG 
inventory.  Member  States  may  choose  to  provide  a  dynamic  development  of  managed 
forest  land  area  taking  into  account  afforested  and  deforested  land  moving  between 
accounting categories during the compliance period.  

9 

 
 
 
 
(ii)  emissions  and  removals  from  forests  and  harvested  wood  products  as  shown  in 
greenhouse gas inventories and relevant historical data 

The  FRL  must  include  emissions  and  removals  aggregated  in  accordance  with  carbon 
pools and gases, as specified in Annex I of the LULUCF Regulation, consistent with the 
latest national GHG inventory, applicable through the reference period 2000-2009.  

forest  characteristics, 

(iii) 
forest  characteristics, 
increments, rotation length and other information on forest management activities under 
‘business as usual’  

including  dynamic  age-related 

A  detailed  description  must  be  included  in  the  NFAPs  of  how  age-related  forest 
characteristics (e.g. mean age of stands, diameter class, growing stock volume, etc.) were 
considered  in  the  determination  of  the  FRL.  Forest  management  practices  for  the 
reference  period  have  to  be  documented  comprehensively  by  including,  for  example, 
information  on  thinning  and  harvesting  rates,  rotation  lengths,  etc.,  related  to  the  age-
related forest characteristics.  

(iv) historical and future harvesting rates disaggregated between energy and non-energy 
uses 

Information (for  the reference period and projected for the  compliance period)  must  be 
provided on harvesting rates, disaggregated between energy and non-energy uses. 

4.  TECHNICAL ASSESSMENT  

Following  the  submission  of  the  NFAPs  and  in  accordance  with  Article  8(6)  of  the 
LULUCF  Regulation,  the  Commission,  in  consultation  with  experts  appointed  by  the 
Member  States,  stakeholders  and  the  civil  society,  undertook  a  technical  assessment  of 
the NFAPs.  

To this end, the Commission established the expert group on land use, land use change 
and  forestry  (‘the  LULUCFEG’).  The  LULUCFEG  includes  representatives  from 
Member  States,  technical  specialists,  NGOs  and  research  organizations,  representatives 
of  Norway,  Iceland  and  the  EFTA  Surveillance  Authority,  and  observers  from  various 
interested stakeholder groups. The precise composition of the LULUCFEG can be found 
in the Register of Commission Expert groups3.  

The LULUCFEG was convened in Brussels on the 6 February 2019 and during 1 April to 
12 April 2019. During this latter period, experts and observers were divided in five sub-
groups  to  assess  Member  State  NFAPs  and  develop  synthesis  report  conclusions  in  a 
parallel  process.  Conclusions  were  presented  in  plenary  sessions  to  the  whole  expert 

3 http://ec.europa.eu/transparency/regexpert/index.cfm?do=groupDetail.groupDetail&groupID=3638&news

=1 

10 

 
                                                 
group for comments and adoption. The compilation of synthesis reports and the minutes 
of the expert group are publicly available4.  

5.  TECHNICAL RECOMMENDATIONS  

With a view to facilitating the technical revision of the proposed forest reference levels 
and reflecting the conclusions of the technical assessment, while taking into account the 
expert group’s request to harmonise and ensure fair treatment of each Member State, the 
Commission has formulated  the  following technical  recommendations  on the submitted 
NFAPs.  

Technical recommendations are issued for each Member State, depending on whether the 
forest  reference  level  was  determined  in  accordance  with  the  Article  8(5)  principles, 
criteria  set  out  in  Annex  IV,  Section  A,  and  elements  of  Annex  IV,  Section  B.  Each 
technical  recommendation  links  to  one  of  the  principles  or  requirements  that  are 
explained in section 3.  

5.1  Belgium 

Technical recommendations on Article 8(5) Principles  
No recommendation 
Technical recommendations on Annex IV, Section A Criteria 
a)  Demonstrate how the goal of achieving a balance between anthropogenic emissions 
and removals will be achieved in the second half of the century. Provide qualitative 
and  quantitative  information  until  at  least  2050  consistent  with  the  long-term 
strategy required under Regulation (EU) 2018/1999. 

c)  Provide  credible  and  robust  evidence  for  the  model  to  reproduce  historical  data. 
Assess  if  the  increasing  area  of  Douglas  fir  entering  the  size  classes  with  high 
annual growth is the sole or key driver for the overall trends in growth and harvest. 
Provide  information  on  projected  growth  in  light  of  the  projected  increase  in 
harvest. 

d)  Provide information such as partitioned quantities of tree biomass felled / dead into 
e.g.  dead  organic  matter,  harvested  timber,  felling  residues,  fuel  wood,  industrial 
roundwood,  and  the  into  different  product  classes  including  energy  wood,  or  any 
other class that is appropriate.  

e)  Ensure  the  consistency  and  comparability  of  definitions  such  as  'timber',  'harvest' 
etc. and the grading of felling in the data sources used for the ratio calculated from 
these data. 

g)  Demonstrate  the  consistency  with  the  national  projections  of  anthropogenic 
greenhouse  gas  emissions  reported  under  Regulation  (EU)  No  525/2013.  Provide 
explanations for possible differences between national projections and the proposed 
FRL. 

h)  Estimate  the  FRL  based  on  the  area  under  forest  management  as  indicated  in 
Annex IV, Part B (e) i. Demonstrate the ability of the model used to construct the 
FRL  to  reproduce  historical  data  from  the  national  GHG  inventory.  Demonstrate 

4 http://ec.europa.eu/transparency/regexpert/index.cfm?do=groupDetail.groupMeeting&meetingId=12931 

11 

 
                                                 
the  consistency  between  historical  data  from  the  national  GHG  inventory  and 
modelled data for estimating the FRL for the reference period. 

Technical recommendations on Annex IV, Section B Elements 
a)  Provide  an  estimate  of  the  FRL  with  the  correct  sign.  Provide  information  if  and 

b) 

how natural disturbances have been taken into account. 
Include  the  carbon  pools  and  greenhouse  gases  required  by  Regulation  (EU) 
2018/841 in the FRL and the national GHG inventory. Assure consistency for the 
starting point of projections for all carbon pools, including the HWP pool. 
d)  Provide information on harvesting rates for at least one different policy scenario. 
e) i  Provide the area under forest management consistent with Table 4.A (“Forest land 
remaining  Forest  land”)  from  the  latest  national  GHG  inventory  using  the  year 
preceding the starting point of the projection. 

e) ii  Distribute simulated harvest data into HWP pools. Compare simulated harvests to 

reported historical harvest data. 

e) iii Provide additional information on the characteristics of the virtual forests used by 
model and a verification with actual field data in order to improve the confidence 
on the modelling approach.  

e) iv Provide the historical and future harvesting rates disaggregated between energy and 

non-energy uses. 

5.2  Bulgaria  

Technical recommendations on Article 8(5) Principles  
1)  Provide  information  on  the  continuation  of  harvest  levels  by  sustainable  forest 
management  practices  and  according  to  age-dynamics.  Justify  the  reasons  for  the 
increase of the harvest during the projected period. 
Technical recommendations on Annex IV, Section A Criteria 
a)  Demonstrate how the goal of achieving a balance between anthropogenic emissions 
and removals will be achieved in the second half of the century. Provide qualitative 
and  quantitative  information  until  at  least  2050  consistent  with  the  long-term 
strategy required under Regulation (EU) 2018/1999. 

c)  Clarify  how  the  values  of  the  actual  harvest  used  for  FRL  have  been  produced. 

Describe data sources of harvests. 

e)  Provide a ratio between solid and energy use of  forest biomass as documented in 
the period from 2000 to 2009 used for the estimation of the forest reference level 
and demonstrate it remains constant throughout the projection. 

g)  Demonstrate  the  consistency  with  the  national  projections  of  anthropogenic 
greenhouse  gas  emissions  reported  under  Regulation  (EU)  No  525/2013.  Provide 
explanations for possible differences between national projections and the proposed 
Forest Reference Level. 

h)  Estimate  the  FRL  based  on  the  area  under  forest  management  as  indicated  in 
Annex  IV,  Part B  (e) i. Estimate  the FRL  based  on carbon pools  and  greenhouse 
gases  as  indicated  in  Annex  IV,  Part  B  (b).  Demonstrate  the  ability  of  the  model 
used  to  construct  the  FRL  to  reproduce  consistently  historical  data  from  the 
national GHG inventory for the reference period.  
Technical recommendations on Annex IV, Section B Elements 
b) 

Include the carbon pools and greenhouse gases consistent with those applied in the 
latest national GHG inventory. 

c)  Provide  explanations  on  how  harvest  from  illegal  logging  is  considered  in  the 

adopted policies  

12 

 
e) i  Provide the area under forest management consistent with Table 4.A (“Forest land 
remaining  Forest  land”)  from  the  latest  national  GHG  inventory  using  the  year 
preceding the starting point of the projection. 

e) iii Provide information about increments by forest management practice and age-class. 

Clarify how the values for the actual harvest used for the FRL has been produced. 

e) iv Provide  historical  and  future  harvesting  rates  disaggregated  between  energy  and 

non-energy uses. 

5.3  Czechia 

Technical recommendations on Article 8(5) Principles  
No recommendation 
Technical recommendations on Annex IV, Section A Criteria 
a)  Demonstrate how the goal of achieving a balance between anthropogenic emissions 
and removals will be achieved in the second half of the century. Provide qualitative 
and  quantitative  information  until  at  least  2050  consistent  with  the  long-term 
strategy required under Regulation (EU) 2018/1999. 

e)  Provide  complete  and  transparent  information  on  logging  residues.  Provide 
information on dataset used  and  methods applied to assess the  use of the logging 
residues across the entire time series and on the method applied for projecting these 
quantities beyond 2017.  
Provide  information  on  the  provisions  of  the  Czech  Forest  Act  on  sustainable 
management  and  biodiversity  conservation  together  with  a  table  that  shows  the 
evolution from 2000 to 2030 of the total forest growing stock. 

f) 

g)  Demonstrate  the  consistency  with  the  national  projections  of  anthropogenic 
greenhouse  gas  emissions  reported  under  Regulation  (EU)  No  525/2013.  Provide 
explanations for possible differences between national projections and the proposed 
FRL. 

h)  Estimate  the  FRL  based  on  the  area  under  forest  management  as  indicated  in 
Annex IV, Part B (e) i. Demonstrate the ability of the model used to construct the 
FRL  to  reproduce  historical  data  from  the  national  GHG  inventory.  Demonstrate 
the  consistency  between  historical  data  from  the  national  GHG  inventory  and 
modelled data for estimating the FRL for the reference period. Provide information 
on  the  changes  in  the  level  of  agreement  in  the  period  2000-2017  between  the 
projected increment and the actual increment and assess its potential impact on the 
FRL.  

Technical recommendations on Annex IV, Section B Elements 
b)  Noting the inclusion of additional carbon pools in the FRL, include those pools in 
the next submission of the national GHG inventory to ensure consistency between 
the FRL and the national GHG inventory. 

c)  Provide  information  if  the  factors  used  in  the  national  GHG  inventory  have  also 
been applied to the FRL. Assure that modelling starts the year after describing the 
state of the forest. 

d)  Provide detailed information on how harvesting rates are expected to develop under 

different policy scenarios. 

e) i  Provide the area under forest management consistent with Table 4.A (“Forest land 
remaining  Forest  land”)  from  the  latest  national  GHG  inventory  using  the  year 
preceding the starting point of the projection. 

e) ii  Harmonize the information for comparison between table 8 and figure 10.  

13 

 
e) iii Provide  information  on  the  use  of  the  forest  age  to  determine  the  current  annual 
increment  and  on  how  the  annual  area  from  an  age-class  to  the  following  is 
calculated. 

e) iv Provide information on dataset used and methods applied to assess the use of the 
logging  residues  across  the  entire  time  series  and  on  the  method  applied  for 
projecting these quantities. 

5.4  Denmark 

Technical recommendations on Article 8(5) Principles  
1) 

 Clarify which and how the different National Forest Inventory sources (i.e. 2002, 
2012 and 2017) were used to develop the FRL; in particular, the time period, data 
source  and  method  used  to  generate  the  survival  curves  and  carbon  stocks,  and 
HWP  projections  could  be  clarified  more  clearly.  Indicate  if  data  outside  the 
reference period (2000-2009) were used, and if so, provide a justification.   

Technical recommendations on Annex IV, Section A Criteria 
c)  Clarify  the  period,  data  source  and  method  used  to  generate  the  survival  and 
growth models, in particular the number of national forest inventory cycles used to 
generate  the  models.  In  addition,  demonstrate  how  the  energy  use  of  domestic 
harvest  trend  line  endpoint  is  representative  of  the  reference  period  and  how 
consistency is assured in relation to the other elements of the reference period. 
d)  Clarify that the method employed to estimate the HWP pool to ensure that this is 
consistent  with  the  stock  change  approach  applied,  and  that  the  total  amount  of 
harvest is consistent with the assumptions made for the other pools.  

e)  Provide a ratio between solid and energy use of  forest biomass as documented in 
the period from 2000 to 2009 used for the estimation of the forest reference level 
and demonstrate it remains constant throughout the projection.  

g)  Demonstrate  the  consistency  with  the  national  projections  of  anthropogenic 
greenhouse  gas  emissions  reported  under  Regulation  (EU)  No  525/2013.  Provide 
explanations for possible differences between national projections and the proposed 
FRL. 

h)  Estimate  the  FRL  based  on  the  area  under  forest  management  as  indicated  in 
Annex IV, Part B (e) i. Use the conversion period for Land converted to forest land 
(Afforested Land) consistent with the latest national GHG inventory. Demonstrate 
the  ability  of  the  model  used  to  construct  the  FRL  to  reproduce  consistently 
historical data from the national GHG inventory for the reference period.  

Technical recommendations on Annex IV, Section B Elements 
b)  Noting  the  inclusion  of  additional  greenhouse  gases  in  the  FRL,  include  those 
greenhouse gases in the next submission of the national GHG inventory to ensure 
consistency between the FRL and the national GHG inventory. Assure consistency 
for the starting point of projections for all carbon pools, including the HWP pool. 
d)  Provide information on harvesting rates for at least one different policy scenario. 
e) i  Provide the area under forest management consistent with Table 4.A (“Forest land 
remaining  Forest  land”)  from  the  latest  national  GHG  inventory  using  the  year 
preceding  the  starting  point  of  the  projection.  Given  the  use  of  the  dynamic  area 
approach, provide a detailed disaggregated calculation of the managed forest land 
area  at  annual  time  steps  for  the  entire  time  series  since,  at  least,  year  2000. 
Document and check the Forest Land area in the FRL, including how deforestation 
is addressed.  

14 

 
 
e) ii  Explain more clearly the HWP pool computation methodology with respect to the 

fraction of biomass remaining for bioenergy use. 

e) iii Provide  additional  information  on  increments.  Document  the  National  Forest 
Inventory periods employed in the models and correct (see Table 2 of NFAP) the 
use of age class for stratification. 

e) iv In function of Annex IV, Part B (e) ii, revise historical and future harvesting rates 

disaggregated between energy and non-energy uses.  

5.5  Germany 

Technical recommendations on Article 8(5) Principles 
1)  Provide qualitative and quantitative description of forest management practices for 
that  forest  management  practices  as 
the  period  2000-2009.  Demonstrate 
documented in the period 2000-2009 are captured by the stock changes measured 
from 2002 to 2008, in particular those related to natural disturbances. Ensure that 
changes in forest management practices are not internalized in the determination of 
the FRL after 2009.  

Technical recommendations on Annex IV, Section A Criteria  
a)  Demonstrate how the goal of achieving a balance between anthropogenic emissions 
and removals will be achieved in the second half of the century. Provide qualitative 
and  quantitative  information  until  at  least  2050  consistent  with  the  long-term 
strategy required under Regulation (EU) 2018/1999. 

d)  Provide FRL by assuming instantaneous oxidation of HWP.  
e)  Check  and  correct  the  inconsistency  about  the  harvest  volume  between  the  value 
reported at page 10,  Annex  I  of  the NFAP of Germany and the  value reported in 
Table 6 of the NFAP of Germany. 
Improve the information on the consistency between the FRL and the objective of 
contributing  to  the  conservation  of  biodiversity  and  sustainable  use  of  natural 
resources, as set out in the EU forest strategy, national forest policies, and the EU 
Biodiversity Strategy. 

f) 

g)  Demonstrate  the  consistency  with  the  national  projections  of  anthropogenic 
greenhouse  gas  emissions  reported  under  Regulation  (EU)  No  525/2013.  Provide 
explanations for possible differences between national projections and the proposed 
FRL. 

h)  Estimate  the  FRL  based  on  the  area  under  forest  management  as  indicated  in 
Annex IV, Part B (e) i. Demonstrate the ability of the model used to construct the 
FRL  to  reproduce  historical  data  from  the  national  GHG  inventory.  Demonstrate 
the  consistency  between  historical  data  from  the  national  GHG  inventory  and 
modelled data for estimating the FRL for the reference period. 

Technical recommendations on Annex IV, Part B Elements 
a)  Clearly explain how the general criteria set out by the Regulation were taken into 

account in the determination of the FRL. 

c)  Provide  information  on  sustainable  forest  management  practices  and  intensity  as 

used in the determination of the FRL.  

e) i  Provide the area under forest management consistent with Table 4.A (“Forest land 
remaining  Forest  land”)  from  the  latest  national  GHG  inventory  using  the  year 
preceding  the  starting  point  of  the  projection.  Clarify  how  the  afforestation  area 
less than 20-year transition period is excluded from managed forest land.  

e) iii Provide  information  on  increments  and  rotation  lengths  related  to  forest 

management activities.  

15 

 
5.6  Estonia 

Technical recommendations on Article 8(5) Principles 
1)  Noting  the  projected  decrease  in  sink  in  the  compliance  period,  demonstrate  that 
the  approach  used  in  the  determination  of  the  FRL  ensures  the  continuation  of 
forest  management  practices  as  documented  in  the  period  2000-2009,  and  revise 
the  FRL  if  applicable.  Clarify  that  those  practices  applies  to  all  forest  lands 
including those being subject to privatization. Provide detailed information on the 
consistency between the actual felling ages and the legally allowed felling ages.  

Technical recommendations on Annex IV, Section A Criteria  
a)  Demonstrate how the goal of achieving a balance between anthropogenic emissions 
and removals will be achieved in the second half of the century. Provide qualitative 
and  quantitative  information  until  at  least  2050  consistent  with  the  long-term 
strategy required under Regulation (EU) 2018/1999. 

e)  Provide a ratio between solid and energy use of  forest biomass as documented in 
the period from 2000 to 2009 used for the estimation of the forest reference level 
and demonstrate it remains constant throughout the projection. 
Provide  information  on  how  the  projected  increase  in  harvest  rates  is  consistent 
with the objective of contributing to the conservation of biodiversity, in particular 
of old-growth forest stands.   

f) 

g)  Demonstrate  the  consistency  with  the  national  projections  of  anthropogenic 
greenhouse  gas  emissions  reported  under  Regulation  (EU)  No  525/2013.  Provide 
explanations for possible differences between national projections and the proposed 
FRL. 

h)  Estimate  the  FRL  based  on  the  area  under  forest  management  as  indicated  in 
Annex  IV,  Part B  (e) i. Estimate  the FRL  based  on carbon pools  and  greenhouse 
gases  as  indicated  in  Annex  IV,  Part  B  (b).  Demonstrate  the  ability  of  the  model 
used  to  construct  the  FRL  to  reproduce  historical  data  from  the  national  GHG 
inventory.  Demonstrate  the  consistency  between  historical  data  from  the  national 
GHG inventory and modelled data for estimating the FRL for the reference period.  

Technical recommendations on Annex IV, Part B Elements 
b) 

Include  the  greenhouse  gases  consistent  with  those  applied  in  the  latest  national 
GHG inventory. 

e) i  Provide the area under forest management consistent with Table 4.A (“Forest land 
remaining  Forest  land”)  from  the  latest  national  GHG  inventory  using  the  year 
preceding the starting point of the projection. 

e) iii Provide  additional 

increments,  dynamic  age-related  forest 
characteristics, actual management activities, harvesting rates and rotation lengths.  
e) iv Provide  historical  and  future  harvesting  rates  disaggregated  between  energy  and 

information  on 

non-energy uses.  

5.7 

Ireland 

Technical recommendations on Article 8(5) Principles 
No recommendation 
Technical recommendations on Annex IV, Section A Criteria  
a)  Demonstrate how the goal of achieving a balance between anthropogenic emissions 
and removals will be achieved in the second half of the century. Provide qualitative 
and  quantitative  information  until  at  least  2050  consistent  with  the  long-term 
strategy required under Regulation (EU) 2018/1999. 

16 

 
c)  Provide  more  information  on  the  correlation  between  the  reduced  harvest  levels 
(i.e.<70% of net growth) and the negative biomass stock changes (Table 19 at page 
51  and  Table  C1  at  page  66,  NFAP  of  Ireland)  in  the  period  2020-2025.  Provide 
more information complementing the statement about the robust accounting system 
(Table  1,  page  4,  NFAP  of  Ireland).  Provide  detailed  information  of  the 
implemented  accounting  system,  in  particular  in  relation  to  biomass  and 
instantaneous oxidation assumption, in a dedicated section.  
Provide information on the consistency between forest management practices and 
the  objectives  set  by  the  European  Biodiversity  and  Forest  Strategies.  Provide 
further information on how the biodiversity  issues  associated with the conversion 
of grasslands and wetlands into forest land are taken into account.  

f) 

g)  Demonstrate  the  consistency  with  the  national  projections  of  anthropogenic 
greenhouse  gas  emissions  reported  under  Regulation  (EU)  No  525/2013.  Provide 
explanations for possible differences between national projections and the proposed 
FRL.  

h)  Estimate  the  FRL  based  on  the  area  under  forest  management  as  indicated  in 
Annex IV, Part B (e) i. Use the conversion period for Land converted to forest land 
(Afforested Land) consistent with the latest national GHG inventory.  

Technical recommendations on Annex IV, Part B Elements 
b)  Noting the inclusion of additional carbon pools in the FRL, include those pools in 
the next submission of the national GHG inventory to ensure consistency between 
the FRL and the national GHG inventory. 

c)  Provide a justification for a different starting year of projection than 2010. Provide 

information on the forest model.  

d)  Provide information on harvesting rates for at least one different policy scenario. 
e) i  Provide the area under forest management consistent with Table 4.A (“Forest land 
remaining  Forest  land”)  from  the  latest  national  GHG  inventory  using  the  year 
preceding  the  starting  point  of  the  projection.  Given  the  use  of  the  dynamic  area 
approach, provide a detailed disaggregated calculation of the managed forest land 
area at annual time steps for the entire time series since, at least, year 2000. 

e) iii Provide additional information on increments.  

5.8  Greece 

Technical recommendations on Article 8(5) Principles  
1)  Demonstrate  that  the  approach  used  in  the  determination  of  the  FRL  ensures  the 
continuation  of  forest  management  practices  as  documented  in  the  period  2000-
2009, and revise the FRL if applicable.  

2)  Demonstrate  how  dynamic  age-related  forest  characteristics  have  been  taken  into 

account and revise the FRL, if applicable.  

Technical recommendations on Annex IV, Section A Criteria 
a)  Demonstrate how the goal of achieving a balance between anthropogenic emissions 
and removals will be achieved in the second half of the century. Provide qualitative 
and  quantitative  information  until  at  least  2050  consistent  with  the  long-term 
strategy required under Regulation (EU) 2018/1999. 

c)  Provide a justification for the harvest fraction used as biomass for energy.  
d)  Revise the HWP estimates, taking into account also paper and paperboard data for 
2000-2009, ensuring consistency with the national GHG inventory estimates 

17 

 
 
e)  Provide  a  ratio  between  solid  (HWP)  and  energy  use  of  forest  biomass  as 
documented in the period from 2000 to 2009 used for the estimation of the forest 
reference level and demonstrate it remains constant throughout the projection. 
g)  Demonstrate  the  consistency  with  the  national  projections  of  anthropogenic 
greenhouse  gas  emissions  reported  under  Regulation  (EU)  No  525/2013.  Provide 
explanations for possible differences between national projections and the proposed 
FRL. 

h)  Estimate  the  FRL  based  on  the  area  under  forest  management  as  indicated  in 
Annex IV, Part B (e) i. Demonstrate the ability of the model used to construct the 
FRL  to  reproduce  historical  data  from  the  national  GHG  inventory.  Demonstrate 
the  consistency  between  historical  data  from  the  national  GHG  inventory  and 
modelled data for estimating the FRL for the reference period.  

c) 

Technical recommendations on Annex IV, Section B Elements 
b) 

Include the carbon pools required by Regulation (EU) 2018/841 in the FRL and the 
national GHG inventory. 
Justify why best available Forest Management Plans data, as used in national GHG 
inventory,  have  not  been  used  in  the  area  assessment  for  FRL.  Demonstrate  the 
validity of the applied modelling framework for the estimation of the increment. 
e) i  Provide the area under forest management consistent with Table 4.A (“Forest land 
remaining  Forest  land”)  from  the  latest  national  GHG  inventory  using  the  year 
preceding the starting point of the projection. Explain and justify why the class of 
“other  wooded  Land”  and  “unmanaged  forest”  is  included  in  the  managed  forest 
land area estimate for the FRL. 

e) iii Provide  information  on forest characteristics, such as  increments,  rotation lengths 

and dynamic area characteristics. 

e) iv Provide  historical  and  future  harvesting  rates  disaggregated  between  energy  and 

non-energy uses. 

5.9  Spain 

Technical recommendations on Article 8(5) Principles  
No recommendation 
Technical recommendations on Annex IV, Section A Criteria 
a)  Demonstrate how the goal of achieving a balance between anthropogenic emissions 
and removals will be achieved in the second half of the century. Provide qualitative 
and  quantitative  information  until  at  least  2050  consistent  with  the  long-term 
strategy required under Regulation (EU) 2018/1999. 

c)  Provide  credible  and  robust  evidence  for  the  use  of  the  model  for  the  FRL  and 
revise the FRL, if applicable,  including a complete and transparent description  of 
the model, a demonstration of its performance over the period 2010-2017, and an 
explanation on the discrepancies between projected harvest and historical data. 
e)  Provide  a  ratio  between  solid  (HWP)  and  energy  use  of  forest  biomass  as 
documented in the period from 2000 to 2009 used for the estimation of the forest 
reference level and demonstrate it remains constant throughout the projection. 
g)  Demonstrate  the  consistency  with  the  national  projections  of  anthropogenic 
greenhouse  gas  emissions  reported  under  Regulation  (EU)  No  525/2013.  Provide 
explanations for possible differences between national projections and the proposed 
FRL. 

h)  Estimate  the  FRL  based  on  the  area  under  forest  management  as  indicated  in 
Annex IV, Part B (e) i. Demonstrate the ability of the model used to construct the 
FRL  to  reproduce  historical  data  from  the  national  GHG  inventory.  Demonstrate 

18 

 
the  consistency  between  historical  data  from  the  national  GHG  inventory  and 
modelled data for estimating the FRL for the reference period.  

Technical recommendations on Annex IV, Section B Elements 
a)  Correct  header  information  in  Tables  14  and  15  of  the  NFAP  (2025  instead  of 
2015).  Provide  information  if  and  how  natural  disturbances  have  been  taken  into 
account. 
Include the carbon pools required by Regulation (EU) 2018/841 in the FRL and the 
national GHG inventory. 

b) 

c)  Provide  a  complete  and  transparent  description  of  the  FRL  model  including  a 
validation  during  the  reference  period.  Demonstrate  how  the  modelled  forest 
management approach is consistent with the forest management approach observed 
during  the  reference  period.  Provide  a  full  and  transparent  description  of  the 
calibration  process  and  the  results.  Provide  more  information  on  the  National 
Forest Inventory such as the number of sample plots in each maturity class. Explain 
the  unexpected  behaviour  of  harvest  early  in  the  historic  period.  Review  the 
accuracy  of  the  input  data  to  the  projection  model,  in  particular  for  the  total 
biomass in a Eucalyptus plantation at maturity in the northern region. Describe the 
evolution of growth and harvest across the projected period. Provide evidence that 
the increase in harvest projected over the commitment period is not influenced by 
the projected very high harvest in the beginning of the projection period. Clarify if 
the model takes natural disturbances into account. 

e) i  Provide the area under forest management consistent with Table 4.A (“Forest land 
remaining  Forest  land”)  from  the  latest  national  GHG  inventory  using  the  year 
preceding the starting point of the projection. 

e) ii  Provide detailed data on the evolution of HWP for the historical and the projection 
period  and  on  the  evolution  with  time  of  the  harvest  rate.  Specify  the  half-life 
values used for the HWP categories.   

e) iii Provide more information on the modelled increment and harvest. 
e) iv Provide  historical  and  future  harvesting  rates  disaggregated  between  energy  and 

non-energy uses. 

5.10  France 

Technical recommendations on Article 8(5) Principles  
1)  Demonstrate  that  the  approach  used  in  the  determination  of  the  FRL  ensures  the 
continuation  of  forest  management  practices  as  documented  in  the  period  2000-
2009,  and  revise  the  FRL  if  applicable.  Demonstrate  how  dynamic  age-related 
forest  characteristics  have  been  taken  into  account  and  revise  the  FRL,  if 
applicable. Specifically, clarify why there is a discrepancy in biomass gain between 
model  output  and  greenhouse  gas  inventory  for  the  period  2010-2016.  Describe 
how the model used input data and model calibration, thereby minimizing this gap.  

Technical recommendations on Annex IV, Section A Criteria 
a)  Demonstrate how the goal of achieving a balance between anthropogenic emissions 
and removals will be achieved in the second half of the century. Provide qualitative 
and  quantitative  information  until  at  least  2050  consistent  with  the  long-term 
strategy required under Regulation (EU) 2018/1999. 

c)  Provide  data  from  the  reference  period  to  the  dataset  used  for  the  ex-post 
adjustment, since this has an impact on the accuracy of the FRL. As France did not 
use  the  entire  reference  period  consistently,  additional  available  data  from  the 
reference period to the dataset used for the ex-post adjustment should be used. 

19 

 
e)  Provide more detailed documentation of data source(s) used for the ratio between 

solid and energy use of forest biomass. 

g)  Demonstrate  the  consistency  with  the  national  projections  of  anthropogenic 
greenhouse  gas  emissions  reported  under  Regulation  (EU)  No  525/2013.  Provide 
explanations for possible differences between national projections and the proposed 
FRL. 

h)  Estimate  the  FRL  based  on  the  area  under  forest  management  as  indicated  in 
Annex IV, Part B (e) i. Demonstrate the ability of the model used to construct the 
FRL  to  reproduce  historical  data  from  the  national  GHG  inventory.  Demonstrate 
the  consistency  between  historical  data  from  the  national  GHG  inventory  and 
modelled data for estimating the FRL for the reference period. 

Technical recommendations on Annex IV, Section B Elements 
b)  Ensure  consistent  modelling  of  carbon  pools,  in  particular  across  the  time  series 

and between Metropolitan France and Overseas Territories. 

c)  Provide  complete  data  on  historical  and  projected  harvest  levels.  Provide  more 
detailed  description  of  sustainable  forest  management  practices  used  in  the 
determination of the FRL.  

e) i  Provide the area under forest management consistent with Table 4.A (“Forest land 
remaining  Forest  land”)  from  the  latest  national  GHG  inventory  using  the  year 
preceding  the  starting  point  of  the  projection.  Given  the  use  of  the  dynamic  area 
approach, provide a detailed disaggregated calculation of the managed forest land 
area at annual time steps for the entire time series since, at least, year 2000. Provide 
more  complete  information  regarding  managed  and  unmanaged  forest  area  to 
guarantee  that  the  same  information  is  used  for  the  FRL  and  the  national  GHG 
inventory. 

e) iii Provide  data  on  increments,  dynamic  age-characteristics  and  rotation  length. 
Provide a more detailed description on the share of even and uneven-aged forests 
and the related information for the strata.  

e) iv Provide historical and future harvesting rates disaggregated between energy and 

non-energy uses. 

5.11  Croatia 

Technical recommendations on Article 8(5) Principles  
No recommendation 
Technical recommendations on Annex IV, Section A Criteria 
a)  Demonstrate how the goal of achieving a balance between anthropogenic emissions 
and removals will be achieved in the second half of the century. Provide qualitative 
and  quantitative  information  until  at  least  2050  consistent  with  the  long-term 
strategy required under Regulation (EU) 2018/1999. 

g)  Demonstrate  the  consistency  with  the  national  projections  of  anthropogenic 
greenhouse  gas  emissions  reported  under  Regulation  (EU)  No  525/2013.  Provide 
explanations for possible differences between national projections and the proposed 
FRL. 

h)  Estimate  the  FRL  based  on  the  area  under  forest  management  as  indicated  in 
Annex IV, Section B (e) i. Estimate the FRL based on carbon pools and greenhouse 
gases as indicated in Annex IV, Section B (b). Demonstrate the ability of the model 
used  to  construct  the  FRL  to  reproduce  historical  data  from  the  national  GHG 
inventory. Compare historical data from the national GHG inventory and modelled 
data for estimating the FRL for the reference period by using, for information only, 
the same harvest intensities applied in line with Article 8(4).  

20 

 
Technical recommendations on Annex IV, Section B Elements 
b) 

Include  the  greenhouse  gases  consistent  with  those  applied  in  the  latest  national 
GHG inventory. Include the carbon pools required by Regulation (EU) 2018/841 in 
the FRL and the national GHG inventory. 

e) i  Provide the area under forest management consistent with Table 4.A (“Forest land 
remaining  Forest  land”)  from  the  latest  national  GHG  inventory  using  the  year 
preceding the starting point of the projection. 

e) ii  Provide a calculation of GHG emissions and removals during the reference period 
using harvest intensities as elaborated for the FRL estimation for a fictive no-war 
scenario and include this assessment in the NFAP. 

e) iii Provide  complete  information  on  age-class  distribution  including  an  aggregation 

for country level. Describe the "normal area" concept and its use. 

e) iv Provide  detailed  information  on  the  historical  and  future  harvesting  rate 

disaggregated between energy and non-energy uses. 

5.12  Italy 

Technical recommendations on Article 8(5) Principles  
1)  Demonstrate  how  dynamic  age-related  forest  characteristics  have  been  taken  into 
account  and  revise  the  FRL,  if  applicable.  Specifically,  demonstrate  the  linkage 
between biomass density and age-class distribution. Provide additional information 
on  forest  management  practices,  including  rotation  length  and  thinning  intensity 
and demonstrate how these have been taken into account.  

Technical recommendations on Annex IV, Section A Criteria 
a)  Demonstrate how the goal of achieving a balance between anthropogenic emissions 
and removals will be achieved in the second half of the century. Provide qualitative 
and  quantitative  information  until  at  least  2050  consistent  with  the  long-term 
strategy required under Regulation (EU) 2018/1999. 
Provide  additional  information  on  existing  biodiversity  goals  and  strategies, 
including on protected areas and endangered endemic species.  

f) 

g)  Demonstrate  the  consistency  with  the  national  projections  of  anthropogenic 
greenhouse  gas  emissions  reported  under  Regulation  (EU)  No  525/2013.  Provide 
explanations for possible differences between national projections and the proposed 
FRL. 

h)  Estimate  the  FRL  based  on  the  area  under  forest  management  as  indicated  in 
Annex IV, Section B (e) i. Estimate the FRL based on carbon pools and greenhouse 
gases as indicated in Annex IV, Section B (b).  

Technical recommendations on Annex IV, Section B Elements 
b) 

Include the carbon pools and greenhouse gases consistent with those applied in the 
latest national GHG inventory. 

e) i  Provide the area under forest management consistent with Table 4.A (“Forest land 
remaining  Forest  land”)  from  the  latest  national  GHG  inventory  using  the  year 
preceding the starting point of the projection. 

e) ii  Include a description of imports and exports in the HWP pool and apply changes to 
the  FRL,  if  applicable.  Assure  consistency  for  carbon  stock  change  in  living 
biomass derived from table 6 and final FRL estimates. Correct editorial mistakes in 
table  7,  36  and  37  of  the  NFAP.  Provide  national  totals  and  units  in  tables  of 
NFAP. 

e) iii Provide  information  on  age-class  structure  and  additional  information  on  rotation 

length. 

21 

 
5.13  Cyprus 

Technical recommendations on Article 8(5) Principles 
1)  Demonstrate  that  the  approach  used  in  the  determination  of  the  FRL  ensures  the 
continuation  of  forest  management  practices  as  documented  in  the  period  2000-
2009,  and  revise  the  FRL  if  applicable.  Demonstrate  how  dynamic  age-related 
forest  characteristics  have  been  taken  into  account  and  revise  the  FRL,  if 
applicable. Provide information justifying the use of a constant harvest rate for the 
reference period in the determination of the FRL.  
Technical recommendations on Annex IV, Section A Criteria  
a)  Demonstrate how the goal of achieving a balance between anthropogenic emissions 
and removals will be achieved in the second half of the century. Provide qualitative 
and  quantitative  information  until  at  least  2050  consistent  with  the  long-term 
strategy required under Regulation (EU) 2018/1999. 

c)  Provide  transparent  information  ensuring  that  emissions  and  removals  resulting 
from  biomass  use  are  properly  accounted  for,  including  those  related  to  natural 
disturbances.  

d)  Provide differentiation of the HWP pool at the level of products’ group. Provide a 
comparison  of  the  FRL  between  assuming  instantaneous  oxidation  and  applying 
the first-order decay function and half-life values.  

e)  Provide a ratio between solid and energy use of  forest biomass as documented in 
the period from 2000 to 2009 used for the estimation of the forest reference level 
and demonstrate it remains constant throughout the projection.  
Provide further explanation on how non-exploitable forests were considered in the 
determination of the FRL.  

f) 

g)  Demonstrate  the  consistency  with  the  national  projections  of  anthropogenic 
greenhouse  gas  emissions  reported  under  Regulation  (EU)  No  525/2013.  Provide 
explanations for possible differences between national projections and the proposed 
FRL.  

h)  Estimate  the  FRL  based  on  the  area  under  forest  management  as  indicated  in 
Annex  IV,  Part B  (e) i. Estimate  the FRL  based  on carbon pools  and  greenhouse 
gases  as  indicated  in  Annex  IV,  Part  B  (b).  Demonstrate  the  ability  of  the  model 
used  to  construct  the  FRL  to  reproduce  historical  data  from  the  national  GHG 
inventory.  Demonstrate  the  consistency  between  historical  data  from  the  national 
GHG inventory and modelled data for estimating the FRL for the reference period. 

Technical recommendations on Annex IV, Part B Elements 
a)  Provide a description of how the criteria of the Regulation were taken into account. 

b) 

Provide information if and how natural disturbances have been taken into account. 
Include the carbon pools and greenhouse gases consistent with those applied in the 
latest  national  GHG  inventory.  Include  the  carbon  pools  required  by  Regulation 
(EU) 2018/841 in the FRL and the national GHG inventory. 

c)  Assure that modelling starts the year after describing the state of the forest. Provide 
a quantitative description of sustainable forest management practices and intensity. 
Check  and  further  explain  the  information  provided  for  carbon  stock  changes  for 
coniferous species, including harvest (pages 18-19 in the NFAP of Cyprus).  
d)  Provide information on how harvest rates are expected to develop under different 

policy scenarios. 

e) i  Provide the area under forest management consistent with Table 4.A (“Forest land 
remaining  Forest  land”)  from  the  latest  national  GHG  inventory  using  the  year 
preceding the starting point of the projection. 

22 

 
e) iii Provide  information  on  increments,  rotation  lengths  and  dynamic  age-related 

characteristics.  

e) iv Provide  historical  and  future  harvesting  rates  disaggregated  between  energy  and 

non-energy uses. 

5.14  Latvia 

Technical recommendations on Article 8(5) Principles  
1)  Demonstrate  how  dynamic  age-related  forest  characteristics  have  been  taken  into 
account  and  revise  the  FRL,  if  applicable.  Demonstrate  that  the  FRL  is  based  on 
the  continuation  of  sustainable  forest  management  practices  from  the  reference 
period specifically for harvest rates. Specifically, exclude policy assumptions from 
the  FRL  calculation.  Explain  the  change  and  indicate  drivers  for  living  biomass 
converting  from  a  sink  in  the  reference  period  to  a  source  during  the  compliance 
period. Indicate if data outside the reference period (2000-2009) were used, and if 
so, provide a justification.  

Technical recommendations on Annex IV, Section A Criteria 
a)  Demonstrate how the goal of achieving a balance between anthropogenic emissions 
and removals will be achieved in the second half of the century. Provide qualitative 
and  quantitative  information  until  at  least  2050  consistent  with  the  long-term 
strategy required under Regulation (EU) 2018/1999. 

c)  Provide a detailed description of forest management practices as documented in the 
reference  period  (2000-2009).  Exclude  policy  assumptions  from  the  FRL 
calculation and revise the FRL accordingly.  

e)  Provide  a  ratio  between  solid  (HWP)  and  energy  use  of  forest  biomass  as 
documented in the period from 2000 to 2009 used for the estimation of the forest 
reference level and demonstrate it remains constant throughout the projection. 
g)  Demonstrate  the  consistency  with  the  national  projections  of  anthropogenic 
greenhouse  gas  emissions  reported  under  Regulation  (EU)  No  525/2013.  Provide 
explanations for possible differences between national projections and the proposed 
FRL. 

h)  Estimate  the  FRL  based  on  the  area  under  forest  management  as  indicated  in 
Annex IV, Section B (e) i. Use the conversion period for Land converted to forest 
land  (Afforested  Land)  consistent  with  the  latest  national  GHG  inventory. 
Demonstrate  the  ability  of  the  model  used  to  construct  the  FRL  to  reproduce 
historical  data  from  the  national  GHG  inventory.  Demonstrate  the  consistency 
between  historical  data  from  the  national  GHG  inventory  and  modelled  data  for 
estimating the FRL for the reference period.  

Technical recommendations on Annex IV, Section B Elements 
a)  Ensure  consistency  of  values  throughout  the  NFAP  specifically  between  table  1 

and the text, e.g. on page 6. 

b)  Noting the inclusion of additional carbon pools in the FRL, include those pools in 
the next submission of the national GHG inventory to ensure consistency between 
the FRL and the national GHG inventory. 

c)  Provide  additional  data  on  harvest  assumptions,  specifically  on  harvest  intensity 
and  harvest  frequency.  Demonstrate  the  exclusive  use  of  data  from  the  reference 
period for modelling the FRL. 

e) i  Provide the area under forest management consistent with Table 4.A (“Forest land 
remaining  Forest  land”)  from  the  latest  national  GHG  inventory  using  the  year 
preceding  the  starting  point  of  the  projection.  Given  the  use  of  the  dynamic  area 
approach, provide a detailed disaggregated calculation of the managed forest land 

23 

 
area  at  annual  time  steps  for  the  entire  time  series  since,  at  least,  year  2000. 
Specifically,  provide  information  on  change  in  area  for  each  age  class  using 
sufficiently disaggregated age-classes, e.g. 10-20 years.  

e) iii Provide detailed information on increments, age structure and harvesting rates for 
estimating the FRL. Exclude policy assumptions on harvests in the reference period 
to  balance  age-structure.  Avoid  contradictions  in  the  NFAP  such  as  between 
Figures  4  and  5  regarding  reference  period  and  harvesting  rates  or  table  7  and 
Figure 4 regarding the share of harvest. 

e) iv Provide  information  about  the  future  harvesting  rates  disaggregated  between 
energy  and  non-energy  uses.  Provide  additional  information  on  the  assumptions 
used to allocate round wood to each HWP category. 

5.15  Lithuania  

Technical recommendations on Article 8(5) Principles  
No recommendation 
Technical recommendations on Annex IV, Section A Criteria 
a)  Demonstrate how the goal of achieving a balance between anthropogenic emissions 
and removals will be achieved in the second half of the century. Provide qualitative 
and  quantitative  information  until  at  least  2050  consistent  with  the  long-term 
strategy required under Regulation (EU) 2018/1999. 

c)  Clarify the discrepancies between national GHG inventory data and the projections 
used  to  set  the  FRL  or  revise  the  application  of  the  model.  Demonstrate  that  the 
model's outcomes can capture actual emissions and removals as reported in GHGI 
in both level and trend. 

e)  Provide a ratio between solid and energy use of  forest biomass as documented in 
the period from 2000 to 2009 used for the estimation of the forest reference level 
and demonstrate it remains constant throughout the projection. 

g)  Demonstrate  the  consistency  with  the  national  projections  of  anthropogenic 
greenhouse  gas  emissions  reported  under  Regulation  (EU)  No  525/2013.  Provide 
explanations for possible differences between national projections and the proposed 
FRL. 

h)  Estimate  the  FRL  based  on  the  area  under  forest  management  as  indicated  in 
Annex  IV,  Part B  (e) i. Estimate  the FRL  based  on carbon pools  and  greenhouse 
gases  as  indicated  in  Annex  IV,  Part  B  (b).  Demonstrate  the  ability  of  the  model 
used  to  construct  the  FRL  to  reproduce  historical  data  from  the  national  GHG 
inventory.  Demonstrate  the  consistency  between  historical  data  from  the  national 
GHG inventory and modelled data for estimating the FRL for the reference period.  

Technical recommendations on Annex IV, Section B Elements 
b) 

Include  the  greenhouse  gases  consistent  with  those  applied  in  the  latest  national 
GHG inventory. 

c)  Address the inconsistencies in input data used in setting FRL and the national GHG 
inventory  and  provide  an  explanation  for  the  differences  observed  in  data  of  the 
NFAP and those reported in the NIR of 2018. 

e) i  Provide the area under forest management consistent with Table 4.A (“Forest land 
remaining  Forest  land”)  from  the  latest  national  GHG  inventory  using  the  year 
preceding the starting point of the projection. 

e) iii Provide  more  accurate  information  on  the  total  increment  associated  with  the 
projected  FRL  (both  for  reference  and  compliance  period)  and  transparently 
explain how this increment is incorporated in the applied modelling approach.  
Provide information on the projected harvests in the compliance period. 

24 

 
e) iv Provide  historical  and  future  harvesting  rates  disaggregated  between  energy  and 

non-energy uses. 

5.16  Luxembourg 

Technical recommendations on Article 8(5) Principles  
No recommendation 
Technical recommendations on Annex IV, Section A Criteria 
a)  Demonstrate how the goal of achieving a balance between anthropogenic emissions 
and removals will be achieved in the second half of the century. Provide qualitative 
and  quantitative  information  until  at  least  2050  consistent  with  the  long-term 
strategy required under Regulation (EU) 2018/1999. 
Include  the  carbon  pool  of  HWP  in  the  FRL,  and  thereby  provide  a  comparison 
between  assuming  instantaneous  oxidation  and  applying  the  first-order  decay 
function and half-life values in the NFAP.   

d) 

e)  Provide a ratio between solid and energy use of  forest biomass as documented in 
the period from 2000 to 2009 used for the estimation of the forest reference level 
and demonstrate it remains constant throughout the projection. 

g)  Demonstrate  the  consistency  with  the  national  projections  of  anthropogenic 
greenhouse  gas  emissions  reported  under  Regulation  (EU)  No  525/2013.  Provide 
explanations for possible differences between national projections and the proposed 
FRL. 

h)  Estimate  the  FRL  based  on  the  area  under  forest  management  as  indicated  in 
Annex  IV,  Part B  (e) i. Estimate  the FRL  based  on carbon pools  and  greenhouse 
gases as indicated in Annex IV, Part B (b). Check (and possibly correct) the sign of 
the FRL value, noting that in accordance with Regulation (EU) 2018/841 Art 5(1), 
removals  (or  sink,  in  CO2  equivalent)  are  denoted  with  a  negative  sign. 
Demonstrate  the  ability  of  the  model  used  to  construct  the  FRL  to  reproduce 
consistently  historical  data  from  the  national  GHG  inventory  for  the  reference 
period. 

Technical recommendations on Annex IV, Section B Elements 
b) 

Include  the  greenhouse  gases  required  by  Regulation  (EU)  2018/841  in  the  FRL 
and the national GHG inventory. Noting the inclusion of additional carbon pools in 
the FRL, include those pools in the next submission of the national GHG inventory 
to ensure  consistency  between the  FRL and the  national GHG inventory.  Provide 
an  estimation  of  HWP  pool,  instead  of  the  current  assumption  of  zero.  Provide 
further justification on the meaning and implications of "Considered with LUC" for 
litter and SOC on Table 2.1.  

c)  Provide  information  on  the  biomass  module  used  for  the  estimation  of  FRL, 
including  clear  descriptions  of  forest  management  practices,  and  demonstrate 
consistency with national GHG inventory. 

e) i  Provide the area under forest management consistent with Table 4.A (“Forest land 
remaining  Forest  land”)  from  the  latest  national  GHG  inventory  using  the  year 
preceding the starting point of the projection. 

e) iv Provide  historical  and  future  harvesting  rates  disaggregated  between  energy  and 

non-energy uses. 

25 

 
5.17  Hungary 

Technical recommendations on Article 8(5) Principles 
1)  Demonstrate  how  dynamic  age-related  forest  characteristics  have  been  taken  into 
account. Provide information on modelling of growing stock during the reference 
period. 

Technical recommendations on Annex IV, Section A Criteria  
a)  Demonstrate how the goal of achieving a balance between anthropogenic emissions 
and removals will be achieved in the second half of the century. Provide qualitative 
and  quantitative  information  until  at  least  2050  consistent  with  the  long-term 
strategy required under Regulation (EU) 2018/1999.  

c)  Provide data and information on all HWP uses.  
d)  Provide the FRL by assuming instantaneous oxidation of HWP.  
e)  Provide a ratio between solid and energy use of  forest biomass as documented in 
the period from 2000 to 2009 used for the estimation of the forest reference level 
and demonstrate it remains constant throughout the projection. 

g)  Demonstrate  the  consistency  with  the  national  projections  of  anthropogenic 
greenhouse  gas  emissions  reported  under  Regulation  (EU)  No  525/2013.  Provide 
explanations for possible differences between national projections and the proposed 
FRL. 

h)  Estimate  the  FRL  based  on  the  area  under  forest  management  as  indicated  in 
Annex  IV,  Part B  (e) i. Estimate  the FRL  based  on carbon pools  and  greenhouse 
gases as indicated in Annex IV, Part B (b). Ensure that the model used to construct 
the FRL is able to reproduce historical data from the national GHG inventory.  

Technical recommendations on Annex IV, Part B Elements 
b) 

Include the  carbon pools consistent with those applied in the latest national GHG 
inventory.  Noting  the  inclusion  of  additional  carbon  pools  in  the  FRL,  include 
those  pools  in  the  next  submission  of  the  national  GHG  inventory  to  ensure 
consistency between the FRL and the national GHG inventory.  

e) i  Provide the area under forest management consistent with Table 4.A (“Forest land 
remaining  Forest  land”)  from  the  latest  national  GHG  inventory  using  the  year 
preceding  the  starting  point  of  the  projection.  Given  the  use  of  the  dynamic  area 
approach, provide a detailed disaggregated calculation of the managed forest land 
area at annual time steps for the entire time series since, at least, year 2000. Check 
and correct reference in Table 3 (page 21 in the NFAP of Hungary) to Table 6.5.1 
in the NIR (2018 submission).  

e) iii Provide additional information on dynamic age-related forest characteristics in the 
projection period. Provide clarification on the repetition of pattern in annual 
increment by species in the reference period as reported in Table 8 (page 37 of the 
NFAP of Hungary). Clarify how forest management practices are distributed by 
yield class, and with regards to L-FL. 

e) iv  Provide historical and future harvesting rates disaggregated between energy and 

non-energy uses.  

5.18  Malta 

Note:  Recommendations  on  Malta’s  NFAP  can  only  partly  assess  the  FRL  because 
Malta’s  current  GHG  inventory  does  not  report  emissions  of  removals  for  any 
carbon  pool.  In  addition,  Malta’s  small  forest  land  does  not  undergo  harvest. 
Therefore sub-paragraph 2 of Article 8(5), criteria (b) – (e) and (g) of Annex IV, 

26 

 
Section  A  and  elements  (b), (d), (e) ii and  (e) iv of  Annex  IV, Section B do not 
apply. 

Technical recommendations on Article 8(5) Principles  
No recommendation 
Technical recommendations on Annex IV, Section A Criteria 
a)  Demonstrate how the goal of achieving a balance between anthropogenic emissions 
and removals will be achieved in the second half of the century. Provide qualitative 
and  quantitative  information  until  at  least  2050  consistent  with  the  long-term 
strategy required under Regulation (EU) 2018/1999. 

h)  Estimate  the  FRL  based  on  the  area  under  forest  management  as  indicated  in 

Annex IV, Section B (e) i. 

Technical recommendations on Annex IV, Section B Elements 
e) i  Provide the area under forest management consistent with Table 4.A (“Forest land 
remaining  Forest  land”)  from  the  latest  national  GHG  inventory  using  the  year 
preceding  the  starting  point  of  the  projection.  Assure  consistency  between  forest 
areas reported in Tables 2 and 15 of the NFAP. 

5.19  Netherlands 

Technical recommendations on Article 8(5) Principles  
No recommendation 
Technical recommendations on Annex IV, Section A Criteria 
a)  Demonstrate how the goal of achieving a balance between anthropogenic emissions 
and removals will be achieved in the second half of the century. Provide qualitative 
and  quantitative  information  until  at  least  2050  consistent  with  the  long-term 
strategy required under Regulation (EU) 2018/1999. 

e)  Demonstrate how harvest statistics, information from the forest inventory, the ratio 
between  energy  and  solid  biomass  use  and  HWP  projection  were  considered  in 
elaborating the NFAP. 

g)  Demonstrate  the  consistency  with  the  national  projections  of  anthropogenic 
greenhouse  gas  emissions  reported  under  Regulation  (EU)  No  525/2013.  Provide 
explanations for possible differences between national projections and the proposed 
FRL. 

h)  Estimate  the  FRL  based  on  the  area  under  forest  management  as  indicated  in 

Annex IV, Section B (e) i.  

Technical recommendations on Annex IV, Section B Elements 
c)  Provide a justification for allocating 100% of “unknown management objective” to 

category “multifunctional”  

e) i  Provide the area under forest management consistent with Table 4.A (“Forest land 
remaining  Forest  land”)  from  the  latest  national  GHG  inventory  using  the  year 
preceding the starting point of the projection. 

e) iii Provide  additional  information  on  age-class  structure  and  rotation  length.  Correct 

editorial changes such as in Table 3.2. 

e) iv Provide  explicit  information  on  allocation  of  future  harvest  to  specific  HWP 

categories. Provide information on import and export of HWP. 

27 

 
  
5.20  Austria 

Technical recommendations on Article 8(5) Principles  
No recommendation 
Technical recommendations on Annex IV, Section A Criteria 
a)  Demonstrate how the goal of achieving a balance between anthropogenic emissions 
and removals will be achieved in the second half of the century. Provide qualitative 
and  quantitative  information  until  at  least  2050  consistent  with  the  long-term 
strategy required under Regulation (EU) 2018/1999. 

g)  Demonstrate  the  consistency  with  the  national  projections  of  anthropogenic 
greenhouse  gas  emissions  reported  under  Regulation  (EU)  No  525/2013.  Provide 
explanations for possible differences between national projections and the proposed 
FRL. 

h)  Estimate  the  FRL  based  on  the  area  under  forest  management  as  indicated  in 
Annex IV, Part B (e) i. Demonstrate the ability of the model used to construct the 
FRL  to  reproduce  historical  data  from  the  national  GHG  inventory.  Demonstrate 
the  consistency  between  historical  data  from  the  national  GHG  inventory  and 
modelled data for estimating the FRL for the reference period. Noting the limited 
information given in the NFAP concerning the interlinked models used to develop 
the FRL (CALDIS-VB V0.1, YASSO and  HWP models), it is recommended that 
Austria uses consistent models and provides additional information to demonstrate 
how such models are able to reproduce historical national GHG inventory data for 
the reference period 2000-2009. 

Technical recommendations on Annex IV, Section B Elements 
b)  Assure  consistency  for  the  starting  point  of  projections  for  all  carbon  pools, 

including the HWP pool. 

d)  Provide a table on harvest intensity, for the reference period and as applied for the 

projection, disaggregated by forest type, growth regions or equivalent. 

e) i  Provide the area under forest management consistent with Table 4.A (“Forest land 
remaining  Forest  land”)  from  the  latest  national  GHG  inventory  using  the  year 
preceding the starting point of the projection. 
e) iii Provide additional information on rotation length. 
e) iv Provide  historical  and  future  harvesting  rates  disaggregated  between  energy  and 

non-energy uses. 

5.21  Poland 

Technical recommendations on Article 8(5) Principles  
1)  Demonstrate  that  the  approach  used  in  the  determination  of  the  FRL  ensures  the 
continuation  of  forest  management  practices  as  documented  in  the  period  2000-
2009, and revise the FRL if applicable.  

2)  Document the (quantitative) description of sustainable forest management practices 
for the period 2000-2009, detailing those parameters used as model input data, so 
as to demonstrate how dynamic  age-related forest characteristics have been  taken 
into account.  

Technical recommendations on Annex IV, Section A Criteria 
a)  Demonstrate how the goal of achieving a balance between anthropogenic emissions 
and removals will be achieved in the second half of the century. Provide qualitative 
and  quantitative  information  until  at  least  2050  consistent  with  the  long-term 
strategy required under Regulation (EU) 2018/1999. 

28 

 
e)  Clarify  that  the  (constant)  ratio  between  solid  and  energy  use  for  forest  biomass 
assumed in the modelling of the FRL is the value presented in row 1 (2000-2009) 
of that Table 12. 

g)  Demonstrate  the  consistency  with  the  national  projections  of  anthropogenic 
greenhouse  gas  emissions  reported  under  Regulation  (EU)  No  525/2013.  Provide 
explanations for possible differences between national projections and the proposed 
FRL. 

h)  Estimate  the  FRL  based  on  the  area  under  forest  management  as  indicated  in 
Annex IV, Part B (e) i. Demonstrate the consistency between the amount of harvest 
used as input to calculate the FRL and relevant historical data on harvest, including 
the reference period 2000-2009. 

Technical recommendations on Annex IV, Section B Elements 
b)  Noting the inclusion of additional carbon pools in the FRL, include those pools in 
the next submission of the national GHG inventory to ensure consistency between 
the FRL and the national GHG inventory. 

c)  Provide information on the age structure module, demonstrating age class transition 
from 2000 to 2020 and 2025 (e.g. in the structure of Table 15 in the NFAP). 
e) i  Provide the area under forest management consistent with Table 4.A (“Forest land 
remaining  Forest  land”)  from  the  latest  national  GHG  inventory  using  the  year 
preceding the starting point of the projection.  

e) ii  Clarify  that  HWP  is  estimated  based  on  managed  forest  land  only,  assuming  that 
the  FRL  is  based  on  managed  forest  land  only  (thereby  not  including  afforested 
land).  Clarify  any  inconsistency  between  the  estimates  of  HWP  in  the  reference 
period  as  reported  in  the  National  Inventory  Report  2018,  under  the  Convention 
and KP, and those used for the FRL in the NFAP. 

e) iii Provide information on increments, dynamic age characteristics and rotation length. 
Provide  information  about  growth  curves  used  in  NFAP  based  on  WISL  (i.e.  for 
each strata actually considered in the model) and a reference for the bark fraction 
value applied for Poland and clarification what the “bark fraction” includes. 

e) iv Provide  historical  and  future  harvesting  rates  disaggregated  between  energy  and 

non-energy uses.  

5.22  Portugal 

Technical recommendations on Article 8(5) Principles  
1)  Demonstrate  that  the  approach  used  in  the  determination  of  the  FRL  ensures  the 
continuation  of  forest  management  practices  as  documented  in  the  period  2000-
2009,  and  revise  the  FRL  if  applicable.  Demonstrate  how  dynamic  age-related 
forest  characteristics  have  been  taken  into  account  and  revise  the  FRL,  if 
applicable.  
If  no  dynamic  age  characteristics  were  used,  provide  evidence  that  such 
information  has  no  impact  on  the  FRL  and  long  term  carbon  sinks  will  be 
maintained or enhanced. 

2) 

Technical recommendations on Annex IV, Section A Criteria 
a)  Given the absence of age-related characteristics in the FRL modelling, demonstrate 
how  the  goal  of  achieving  a  balance  between  anthropogenic  emissions  and 
removals will be achieved in the second half of the century. Provide qualitative and 
quantitative  information  until  at  least  2050  consistent  with  the  long-term  strategy 
required under Regulation (EU) 2018/1999.  

c)  Provide  data  on  harvest  for  solid  biofuel  production,  and  clarify  how  wood 
removals  are  derived  from  the  industrial  roundwood  statistics  and  thus  how  all 

29 

 
harvests are included (i.e. wood removals, solid wood and wood for bioenergy) in 
the estimate of carbon stock change in the FRL.  

e)  Provide a ratio between solid and energy use of  forest biomass as documented in 
the period from 2000 to 2009 used for the estimation of the forest reference level 
and  demonstrate  it  remains  constant  throughout  the  projection.  Evaluate  whether 
the HWP pool needs to be recalculated (and subsequently, the FRL). 

f)  Confirm  the  information  provided  showing  that  the  reference  level  is  consistent 
with  the  objective  of  contributing  to  the  conservation  of  biodiversity  and  the 
sustainable use of natural resources. 

g)  Demonstrate  the  consistency  with  the  national  projections  of  anthropogenic 
greenhouse  gas  emissions  reported  under  Regulation  (EU)  No  525/2013.  Provide 
explanations for possible differences between national projections and the proposed 
FRL. 

h)  Estimate  the  FRL  based  on  the  area  under  forest  management  as  indicated  in 
Annex IV, Part B (e) i. Demonstrate the ability of the model used to construct the 
FRL  to  reproduce  historical  data  from  the  national  GHG  inventory.  Provide 
(numerical) information for the period 2010-2016 demonstrating that the modelling 
approach  used  to  construct  the  FRL  is  comparable  and  consistent  (i.e.,  showing 
justified differences) with the national GHG inventory. 

Technical recommendations on Annex IV, Section B Elements 
c)  Explain  how  the  requirement  to  consider  age-class  dynamic  is  considered  in  the 
applied  approaches,  methods  and  models,  and  provide  explicit  information  on 
forest management practices including references to data sources and background 
information, used for expert judgements cited in the NFAP. 

d)  Provide information on harvesting rates for at least one different policy scenario. 
e) i  Provide the area under forest management consistent with Table 4.A (“Forest land 
remaining  Forest  land”)  from  the  latest  national  GHG  inventory  using  the  year 
preceding  the  starting  point  of  the  projection.  Given  the  use  of  the  dynamic  area 
approach, provide a detailed disaggregated calculation of the managed forest land 
area at annual time steps for the entire time series since, at least, year 2000. 

e) ii  Clarify the estimation of HWP, the computation of GHG emissions and removals 
using  the  production  approach  and  how  double  counting  of  harvest  is  avoided 
considering that different sources are used for estimating industrial harvest, salvage 
logging and information related to burned area and forest conversion. 

e) iii Provide additional information on dynamic age-characteristics and rotation length.  
e) iv Provide  historical  and  future  harvesting  rates  disaggregated  between  energy  and 

non-energy uses. 

5.23  Slovenia 

Technical recommendations on Article 8(5) Principles 
1)  Demonstrate  that  the  approach  used  in  the  determination  of  the  FRL  ensures  the 
continuation  of  forest  management  practices  as  documented  in  the  period  2000-
2009,  including  private  forests,  and  revise  the  FRL  if  applicable.  Provide  further 
information  on  whether  the  correction  factor  used  to  simulate  harvest  intensity  is 
based  on  the  continuation  of  forest  management  practices  as  documented  in  the 
reference  period,  and  how 
the 
determination of the FRL. Indicate if data outside the reference period (2000-2009) 
were used, and if so, provide a justification.  

this  correction  factor 

incorporated 

in 

is 

2)  Clarify whether the correction factor is introduced to reflect the need not to unduly 
constrain forest management intensity. Ensure that the increase in harvest volumes 

30 

 
projected in the FRL is  in line with Art 8(5), reflecting the  evolution  of dynamic 
age-related forest characteristics, and revise the FRL if applicable. 

Technical recommendations on Annex IV, Section A Criteria  
a)  Demonstrate how the goal of achieving a balance between anthropogenic emissions 
and removals will be achieved in the second half of the century. Provide qualitative 
and  quantitative  information  until  at  least  2050  consistent  with  the  long-term 
strategy required under Regulation (EU) 2018/1999. 

c)  Ensure  a  robust  and  credible  accounting  system  based  on  forest  management 
practices  documented  in  the  reference  period  for  all  managed  forest  land  and 
without the use of a correction factor.  

d)  Provide  a  specific  value  for  the  HWP  pool.  Provide  a  comparison  of  the  FRL 
between  assuming  instantaneous  oxidation  and  applying  the  first-order  decay 
function and half-life values.  

e)  Provide a ratio between solid and energy use of  forest biomass as documented in 
the period from 2000 to 2009 used for the estimation of the forest reference level 
and demonstrate it remains constant throughout the projection. 

g)  Demonstrate  the  consistency  with  the  national  projections  of  anthropogenic 
greenhouse  gas  emissions  reported  under  Regulation  (EU)  No  525/2013.  Provide 
explanations for possible differences between national projections and the proposed 
FRL. 

h)  Estimate  the  FRL  based  on  the  area  under  forest  management  as  indicated  in 
Annex  IV,  Part B  (e) i. Estimate  the FRL  based  on carbon pools  and  greenhouse 
gases  as  indicated  in  Annex  IV,  Part  B  (b).  Demonstrate  the  ability  of  the  model 
used  to  construct  the  FRL  to  reproduce  historical  data  from  the  national  GHG 
inventory.  Demonstrate  the  consistency  between  historical  data  from  the  national 
GHG inventory and modelled data for estimating the FRL for the reference period. 
In particular, provide explanation of the trends and data about harvest levels (Table 
8 in the NFAP of Slovenia) and emissions and removals (Figure 7 in the NFAP of 
Slovenia),  and  reduce  discrepancies  between  FRL  projections  and  national  GHG 
inventory estimates (Figure 7 in in the NFAP of Slovenia).  

Technical recommendations on Annex IV, Part B Elements 
a)  Provide a description of how the criteria of the Regulation were taken into account 
Include  the  greenhouse  gases  consistent  with  those  applied  in  the  latest  national 
b) 
GHG inventory. 

d)  Provide information on harvesting rates for at least one different policy scenario.  
e) i  Provide the area under forest management consistent with Table 4.A (“Forest land 
remaining  Forest  land”)  from  the  latest  national  GHG  inventory  using  the  year 
preceding the starting point of the projection.  

e) ii  Provide further information on historical and future HWP outflows.  
e) iii Provide  information  on  increments,  rotation  lengths  and  dynamic  age-related 
characteristics. Provide further information on the use of forest management strata 
in the FRL, forest management practices, diameter class distribution, and harvest in 
privately  owned  forests.  Check  for  consistency  between  Table  5  figures  in  the 
NFAP of Slovenia and the treatment of protected forests.  

e) iv Provide  historical  and  future  harvesting  rates  disaggregated  between  energy  and 

non-energy uses. 

31 

 
5.24  Slovakia 

Technical recommendations on Article 8(5) Principles  
1)  Provide  more  detailed  information  on  harvest  rates  in  the  compliance  period. 
Describe more thoroughly forest management practices in a disaggregated way and 
in qualitative terms, describing different forest stands and forest functions.  

Technical recommendations on Annex IV, Section A Criteria 
a)  Demonstrate how the goal of achieving a balance between anthropogenic emissions 
and removals will be achieved in the second half of the century. Provide qualitative 
and  quantitative  information  until  at  least  2050  consistent  with  the  long-term 
strategy required under Regulation (EU) 2018/1999. 

f)  Explain how biodiversity goals and in particular conservation of older forest stands 
are taken into account in constructing forest reference levels and past management 
practices.  Describe  how  harvest  levels  are  consistent  with  EU  Nature  & 
Biodiversity policies goals, in particular in National Parks, Nature Reserves, Nature 
2000 sites, Sites of Community Interest, Special Protection Areas. 

g)  Demonstrate  the  consistency  with  the  national  projections  of  anthropogenic 
greenhouse  gas  emissions  reported  under  Regulation  (EU)  No  525/2013.  Provide 
explanations for possible differences between national projections and the proposed 
FRL. 

h)  Estimate  the  FRL  based  on  the  area  under  forest  management  as  indicated  in 

Annex IV, Part B (e) i.  

d) 

Technical recommendations on Annex IV, Section B Elements 
b) 

Include the carbon pools required by Regulation (EU) 2018/841 in the FRL and the 
national GHG inventory. 
Include information on harvesting rates for at least one different policy scenario in 
the revised NFAP. Translate relevant information of studies in Slovak into English. 
e) i  Provide the area under forest management consistent with Table 4.A (“Forest land 
remaining  Forest  land”)  from  the  latest  national  GHG  inventory  using  the  year 
preceding the starting point of the projection. 

5.25  Finland 

Technical recommendations on Article 8(5) Principles  
1)  Demonstrate  that  the  approach  used  in  the  determination  of  the  FRL  ensures  the 
continuation  of  forest  management  practices  as  documented  in  the  period  2000-
2009,  and  revise  the  FRL  if  applicable.  Demonstrate  how  dynamic  age-related 
forest  characteristics  have  been  taken  into  account  and  revise  the  FRL,  if 
applicable.  

2)  Provide 

information  on  forest  dynamics  for/by  development  classes  and 
demonstrate  that  the  increase  in  harvest  volumes  projected  in  the  FRL  is  in  line 
with Art 8(5), reflecting the evolution of dynamic age-related forest characteristics, 
and revise the FRL, if applicable.  

Technical recommendations on Annex IV, Section A Criteria 
a)  Demonstrate how the goal of achieving a balance between anthropogenic emissions 
and removals will be achieved in the second half of the century. Provide qualitative 
and  quantitative  information  until  at  least  2050  consistent  with  the  long-term 
strategy required under Regulation (EU) 2018/1999. 

c)  Provide additional information to clarify how future harvests (as presented in Table 
12) are related to the existing scenarios presented in Section 2.3.2 of the NFAP. 

32 

 
 
e)  Provide  a  ratio  between  solid  (HWP)  and  energy  use  of  forest  biomass  as 
documented in the period from 2000 to 2009 used for the estimation of the forest 
reference  level  and  demonstrate  it  remains  constant  throughout  the  projection. 
Present the ratio together with information in Table 12 of the NFAP. 
Provide  information  on  how  the  projected  increase  in  harvest  rates  is  consistent 
with the objective of contributing to the conservation of biodiversity. Clarify if the 
projected  increase  of  harvest  rates  affects  northern  Finland  more  than  southern 
Finland (see Table 9 of the NFAP). 

f) 

g)  Demonstrate  the  consistency  with  the  national  projections  of  anthropogenic 
greenhouse  gas  emissions  reported  under  Regulation  (EU)  No  525/2013.  Provide 
explanations for possible differences between national projections and the proposed 
FRL. 

h)  Estimate  the  FRL  based  on  the  area  under  forest  management  as  indicated  in 
Annex IV, Part B (e) i. Demonstrate the consistency between historical data from 
the  national  GHG  inventory  and  modelled  data  for  estimating  the  FRL  for  the 
reference  period,  through  the  provision  of  backcasting  information  from  the 
modelling  framework.  Demonstrate  that  the  interest  rate  used  by  the  model  can 
reproduce the harvest documented in the reference period.  

Technical recommendations on Annex IV, Section B Elements 
c)  Clarify  the  NIR  submission  (year)  from  which  data  was  used  for  the  FRL 
calculation  and  the  (partial,  2011  to  2016)  comparison  between  the  FRL  and  the 
national GHG inventory. Provide evidence that the actual management practices of 
the  reference  period  are  equivalent  to  those  described  in  the  Best  Practices  for 
Sustainable  Forest  Management  guidelines  (e.g.  Tapio  2006).  Clarify  whether 
earlier versions of the guidelines (e.g. Tapio 2001) and the forest decree 224/1997 
are  relevant  to  describe  practices  in  the  period  2000-2009.  Clarify  which  forest 
management practices are used in the model.  

e) i  Provide the area under forest management consistent with Table 4.A (“Forest land 
remaining  Forest  land”)  from  the  latest  national  GHG  inventory  using  the  year 
preceding  the  starting  point  of  the  projection.  Provide  a  definition  of  forest  and 
information on the total area under forest management to resolve inconsistencies in 
total areas in Table 3 and Table 5 of the NFAP.  

e) iii Provide  information  concerning:  (Stand,  category)  development  classes  for  time 
periods comparable to Table 5 (e.g. NFI9 and NFI11); Information on the standing 
volume per development class in the compliance period in order to relate the area 
to the standing volume; Documentation on the way the estimate of the interest rate 
was  derived,  including  more  specific  references  and  demonstrating  that  it  is 
representative  for  the  entire  forest  area  and  the  reference  period;  Additional 
information  on  the  impact  of  the  interest  rate  in  the  model  outcomes  for  harvest 
volume  by  period;  A  clarification  on  the  impact  of  assuming  ‘non-declining’ 
industrial  roundwood  removals,  in  relation  to  Article  8(5)  Paragraph  1  of  the 
Regulation. 

e) iv Provide  historical  and  future  harvesting  rates  disaggregated  between  energy  and 
non-energy  uses.  Provide  information  on  harvest  volume  development  through 
periods  up  to  2060  to  improve  the  understanding  of  the  long-term  development, 
consistent with Table 14 of the NFAP.  

33 

 
5.26  Sweden 

Technical recommendations on Article 8(5) Principles  
1)  Provide transparent documentation of forest management practices in the reference 
period. Ensure that the approach used in the determination of the FRL reflects the 
continuation  of  sustainable  forest  management  practices  as  documented  in  the 
reference  period,  excluding  policy  assumptions  on  harvest  rates  from  the  FRL 
calculation.  Provide  transparent  information  on  harvest-to-growth  ratio  from  the 
reference period. In light of 100% harvest rate of net biomass increment applied in 
the  FRL  on  productive  forest  land  managed  for  wood  supply  regardless  of  age-
class distribution, explain how this is applied to modelling of the FRL and revise 
the FRL accordingly. 

2)  Ensure  that  harvest  volumes  projected  in  the  FRL  are  in  line  with  Art  8(5), 
reflecting the evolution of dynamic age-related forest characteristics, and revise the 
FRL accordingly. 

Technical recommendations on Annex IV, Section A Criteria 
c) 

Justify how the proposed FRL ensures a robust and credible accounting system in 
light of documented forest management practices during the reference period.  
d)  Provide  an  explanation  on  the  decreasing  trend  of  HWP  sink  and  include  the 

projected shares of different HWP categories while harvests are increasing. 

e)  Provide a ratio between solid and energy use of  forest biomass as documented in 
the period from 2000 to 2009 used for the estimation of the forest reference level 
and demonstrate it remains constant throughout the projection. 
Provide more information on the projected development of total forest area of old 
forest stands (>80 years). Provide additional information on the impact of projected 
increased harvest on biodiversity. 

f) 

g)  Demonstrate  the  consistency  with  the  national  projections  of  anthropogenic 
greenhouse  gas  emissions  reported  under  Regulation  (EU)  No  525/2013.  Provide 
explanations for possible differences between national projections and the proposed 
FRL. 

h)  Estimate  the  FRL  based  on  the  area  under  forest  management  as  indicated  in 
Annex IV, Part B (e) i. Use the conversion period for Land converted to forest land 
(Afforested Land) consistent with the latest national GHG inventory. Demonstrate 
the ability of the model used to construct the FRL to reproduce historical data from 
the national  GHG  inventory. Demonstrate the  consistency between  historical data 
from the national GHG inventory and modelled data for estimating the FRL for the 
reference  period.  Specifically,  information  is  required  on  1)  the  validation  of 
simulated increments for all stands and present values of increment instead of total 
volume,  2)  the demonstration  of  the modelling framework to reproduce historical 
harvest  data,  3)  the  bias  between  measurements  and  model  estimates  for  mineral 
soils.  

Technical recommendations on Annex IV, Section B Elements 
c)  Document  sustainable  forest  management  practices  in  the  reference  period, 
including information on harvesting intensities per strata, using consistent sources, 
definition  and  units,  and  apply  those  to  the  forest  development  during  the 
simulation, and subsequently the calculation of the FRL. 

e) i  Provide the area under forest management consistent with Table 4.A (“Forest land 
remaining  Forest  land”)  from  the  latest  national  GHG  inventory  using  the  year 
preceding  the  starting  point  of  the  projection,  and  the  future  development  of  the 
managed forest land area, including afforested and deforested land. 

34 

 
e) iii Provide  information  on  increments,  age-related  dynamics  and  rotation  length. 
Provide  the  projected  increment  per  strata  for  historic  data  and  the  compliance 
period. 

5.27  United Kingdom 

Technical recommendations on Article 8(5) Principles  
No recommendation 
Technical recommendations on Annex IV, Section A Criteria 
a)  Demonstrate how the goal of achieving a balance between anthropogenic emissions 
and removals will be achieved in the second half of the century. Provide qualitative 
and  quantitative  information  until  at  least  2050  consistent  with  the  long-term 
strategy required under Regulation (EU) 2018/1999. 

e)  Provide  a  ratio  between  solid  (HWP)  and  energy  use  of  forest  biomass  as 
documented in the period from 2000 to 2009 used for the estimation of the forest 
reference level and demonstrate it remains constant throughout the projection. 
g)  Demonstrate  the  consistency  with  the  national  projections  of  anthropogenic 
greenhouse  gas  emissions  reported  under  Regulation  (EU)  No  525/2013.  Provide 
explanations for possible differences between national projections and the proposed 
FRL. 

h)  Estimate  the  FRL  based  on  the  area  under  forest  management  as  indicated  in 
Annex IV, Part B (e) i. Use the conversion period for Land converted to forest land 
(Afforested  Land)  consistent  with  the  latest  national  GHG  inventory.  Explain  the 
difference  of  approximately  2  Mt  CO2  between  the  national  GHG  inventory  and 
FRL  for  the  reference  period  (Figure  4.1  in  the  NFAP).  Demonstrate  possible 
impacts  of  the  different  age-class  structures  used  in  the  FRL  and  national  GHG 
inventory in the reference period and on the trends during the years 2010-2016.  

Technical recommendations on Annex IV, Section B Elements 
b)  Provide missing information on non-CO2 emissions from drained organic soils for 

the FRL, which are reported in GHG inventory.  

c)  Provide  more  detailed  information  on  the  calculation  of  the  background  level  for 

natural disturbances, consistent with Regulation (EU) 2018/841.  

e) i  Provide the area under forest management consistent with Table 4.A (“Forest land 
remaining  Forest  land”)  from  the  latest  national  GHG  inventory  using  the  year 
preceding  the  starting  point  of  the  projection.  Given  the  use  of  the  dynamic  area 
approach, provide a detailed disaggregated calculation of the managed forest land 
area at annual time steps for the entire time series since, at least, year 2000. 

e) iii Provide additional information on increments. 
e) iv Provide  additional  information  on  disaggregation  of  energy  and  non-energy  uses 

for historical and future harvesting rates.  

6.  NEXT STEPS  

Based on the technical assessments and the technical recommendations, Member States 
shall communicate their  revised  proposed  forest reference levels to the Commission by 
31 December 2019 for the period from 2021 to 2025. The Commission shall publish the 
proposed forest reference levels communicated to it by Member States. 

Based  on  the  proposed  forest  reference  levels  submitted  by  Member  States,  on  the 
technical assessment and recommendations, and on the revised proposed forest reference 

35 

 
level submitted, the Commission shall adopt by 31 October 2020 a delegated act with a 
view to laying down the forest reference levels to be applied by the Member States for 
the period from 2021 to 2025.  

If a Member State does not submit its (revised) forest reference level to the Commission 
by 31 December 2019, the Commission shall adopt a delegated act with a view to laying 
down the forest reference level to be applied by  that Member State for the period from 
2021 to 2025, based on any technical assessment carried out. 

36