Study on the requirements for compliance with the regulation on Land Use, Land Use Change and Forestry (LULUCF) and associated regulations : final report.
Date: 2021-06-21
Institutions: Directorate-General for Climate Action
Subjects: EU Member State, European forestry policy, adaptation to climate change, environmental monitoring, information analysis, land use, reduction of gas emissions, research report, sustainable forest management

Study on the requirements for 
compliance with the regulation on 
Land Use, Land Use Change and 
Forestry (LULUCF) and associated 
regulations

Final report 

Written by - Eric Arets, Jan-Peter Lesschen, Gerard Hazeu (Wageningen Environmental Research) 

    Dana Iliescu 
    John Watterson (Ricardo Energy & Environment) 

May – 2021 

EUROPEAN COMMISSION 

Directorate-General for Climate Action 

Directorate C — Climate Strategy, governance and emissions from non-trading sectors 

Unit C.3 — Land Use and Finance for Innovation 

Contact: Rene COLDITZ  

E-mail:  Rene.COLDITZ@ec.europa.eu 

European Commission 

B-1049 Brussels 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Study on the requirements for 
compliance with the 
regulation on Land Use, Land 
Use Change and Forestry 
(LULUCF) and associated 
regulations 

Final report 

Service Request 2020/01 under framework contract 
CLIMA.A4/FRA/2019/0011 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Abstract 

This study commissioned by the Directorate-General of Climate Action of the European Commission 

assesses the requirements for compliance with the LULUCF Regulation EU 2018/841 and associated 

regulations. Compliance elements from the LULUCF Regulation, Effort Sharing Regulation (EU 2018/842), 

Governance Regulation (EU 2018/1999) and associated delegated act (EU 2020/1044) and implementing 

act (EU 2020/1208) are identified and described. Timing and sequencing of the elements relating to the 

first compliance period is included in a detailed time table. Detailed GANNT charts and analysis of 

timescales are included for the annual reporting of GHG inventories by Member States, the EU inventory 

and for the compliance check by the end of the first compliance period.  

For the identified compliance elements the study interprets and describes what data and information 

needs to be delivered, in what format it should be provided and how it should be submitted by Member 

States. This includes interpretations of requirements relating the required geographically explicit land-

use information and required tier levels. It also includes interpretations and descriptions of what 

information needs to be provided for the various reporting obligations (i.e. approximated GHG inventory, 

annual GHG inventory, reports on policies and measures and projections and reporting on accounted 

emissions and removals for LULUCF). The Common Reporting Format (CRF) tables used for reporting 

GHG inventories to the UNFCCC are an important basis for reporting. However, not all CRF tables contain 

sufficient detail in their default structure to meet compliance requirements. For such cases, the required 

adjustments to the CRF tables are identified and the additional information to be provided in the national 

inventory reports is identified. 

Finally, an overview of datasets and information sources that can be used to review and verify the data 

and information provided by Member States in their compliance reports is provided. The identification of 

potential data sets and information sources for compliance checking focuses on data sources relating to 

land use change, forest biomass and soil carbon (both mineral and organic). Each data set is described 

and benefits and drawbacks for their use as independent sources of verification of LULUCF inventory data 

and compliance reports are assessed. 

Résumé 

Cette étude commandée par la Direction générale de l'action pour le climat de la Commission 

européenne évalue les exigences en matière de conformité avec le règlement UTCATF UE 2018/841 et 

les règlements connexes. Les éléments de conformité du règlement UTCATF, du règlement sur la 

répartition de l'effort (UE 2018/842), du règlement sur la gouvernance (UE 2018/1999), de l'acte 

délégué associé (UE 2020/1044) et de l'acte d'exécution (UE 2020/1208) sont identifiés et décrits. Les 

échéances et l'ordre des éléments relatifs à la première période de conformité sont indiqués dans un 

échéancier détaillé. Des diagrammes de GANTT détaillés et une analyse des échéances sont inclus pour 

la déclaration annuelle des inventaires de GES par les États membres, l'inventaire de l'UE et pour le 

contrôle de conformité avant la fin de la première période de conformité.  

En ce qui concerne les éléments de conformité identifiés, l'étude interprète et décrit quelles données et 

informations doivent être fournies, sous quelle forme elles devraient être fournies et comment elles 

doivent être communiquées par les États membres. Il s'agit notamment d'interpréter les exigences 

relatives aux informations géographiquement explicites requises sur l'utilisation des terres et aux 

niveaux requis. Il comprend également des interprétations et des descriptions de l'information à fournir 

pour les diverses obligations en matière de déclaration (c.-à-d. l’inventaire approximatif des GES, 

l’inventaire annuel des GES, les rapports sur les politiques, mesures et projections ainsi que les rapports 

sur les émissions et absorptions comptabilisées pour le secteur UTCATF). Les tableaux de format de 

rapport commun (FRC) utilisés pour rapporter les inventaires de GES à la CCNUCC constituent une base 

importante pour la déclaration. Toutefois, les tableaux FRC ne contiennent pas tous suffisamment de 

détails dans leur structure par défaut pour satisfaire aux exigences de conformité. Dans de tels cas, les 

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ajustements à apporter aux tableaux FRC sont identifiés et les renseignements supplémentaires à fournir 

dans les rapports nationaux d'inventaire sont indiqués. 

Enfin, l’étude fournit un aperçu des ensembles de données et des sources d'information qui peuvent être 

utilisés pour examiner et évaluer les données et informations fournies par les États Membres dans leurs 

rapports de conformité. L'identification d'ensembles de données et de sources d'information potentiels 

pour le contrôle de la conformité se focalise sur les sources de données relatives au changement 

d'affectation des terres, à la biomasse forestière et au carbone des sols (minéral et organique). Chaque 

ensemble de données est décrit et leur utilisation en tant que sources indépendantes de vérification des 

données d'inventaire du secteur UTCATF et des rapports de conformité est examinée, afin d'en évaluer 

les avantages et les inconvénients. 

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Table of contents 

List of abbreviations 

Executive summary 
ES.1 This study 
ES.2 Compliance provisions and expected content 

ES.2.1 Timeline of implementation of LULUCF compliance elements for the first compliance 

period. 

ES.3 Basis for assessment for compliance with the LULUCF Regulation 

Résumé exécutif 

RE.1 Cette étude 
RE.2 Dispositions de conformité et contenu attendu 

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12 

17 
18 

21 
21 
22 

RE.2.1 Calendrier de mise en œuvre des éléments de conformité du secteur UTCATF pour la 

première période de conformité. 

RE.3 Base d'évaluation de la conformité avec le règlement UTCATF 

1  Introduction 

1.1  Link between reporting and accounting of GHG emissions and removals for LULUCF 

1.1.1  UNFCCC reporting 
1.1.2  Accounting climate mitigation performance 
1.1.3  EU LULUCF Regulation 2018/841 

1.2  This study 

2  Compliance elements (Task 1) 

2.1  Methods 
2.2  Reporting provisions - overview 

2.2.1  Reporting of approximated GHG inventories (Article 26(2) of the GR) 
2.2.2  Reporting of GHG Inventories (Article 26(3) of the GR and Article 18 of the LULUCF 

28 
29 

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35 
35 
37 
38 
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41 
41 
41 
43 

Regulation) 

43 
2.2.3  Reporting on policies and measures for LULUCF (Article 18 and Annex VI of the GR and 
46 
2.2.4  Reporting on projections for LULUCF (Article 18 and Annex VII of the GR and Article 18 
46 

Article 18 of the LULUCF Regulation) 

of the LULUCF Regulation) 

2.2.5  Reporting on preliminary accounted emissions and removals (Article 26(5) of the 

GR) 

2.2.6  Reporting on final accounted emissions and removals (Article 26(5) of the GR and 

Article 14(1) of the LULUCF Regulation) 

46 

47 

2.2.7  Reporting on summary information on concluded transfers under Article 12 and 13 of 

the LULUCF Regulation (Article 26(3), Annex V, point (f) of the GR) 

2.3  Accounting 
2.4  Review and assessment of progress 

2.4.1  Assessment of progress (Articles 29(5) and 35 of the GR) 
2.4.2  Review (Article 38 of the GR and Article 14(2) of the LULUCF Regulation) 
2.4.3  Report on total Union’s total emissions and total removals of greenhouse gases for 

47 
47 
48 
49 
50 

2.5  Compliance check 
2.5.1  Flexibilities 

each of the land accounting categories (Article 14(3) LULUCF Regulation) 

50 
51 
51 
2.6  Summary information related to the accounting of the different land accounting categories  52 
52 
53 

2.6.1  Accounting for Afforested Land (Article 6 LULUCF Regulation) 
2.6.2  Accounting for Deforested land (Article 6 LULUCF Regulation) 

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54 
2.6.3  Accounting for Managed Cropland (Article 7 LULUCF Regulation) 
2.6.4  Accounting for Managed Grassland (Article 7 LULUCF Regulation) 
54 
2.6.5  Accounting for Managed Wetlands (Articles 7 and 2(2) to 2(4) LULUCF Regulation)  55 
56 
2.6.6  Accounting for Managed Forest Land (Articles 8 and 13 LULUCF Regulation) 
57 
2.6.7  Accounting for Harvested Wood Products 
58 
2.6.8  Accounting for natural disturbances 
59 

2.7  Sequencing of compliance elements and activities and analysis of timelines 

2.7.1  Timeline of implementation of LULUCF compliance elements for the first compliance 

period. 

59 

2.7.2  GANTT chart and analysis of timescales related to the reporting of GHG inventories in 

years without accounting or compliance check 

2.7.3  GANTT chart and analysis of timescales related to the LULUCF compliance elements 
and activities from reporting GHG inventories to compliance check in 2027 

3  Expected content (Task 2) 

3.1  Approach 
3.2  General requirements for the methodologies for monitoring and reporting in the LULUCF 

sector 
3.2.1  Greenhouse gases and carbon pools to be included 
3.2.2  Geographically explicit land use information 
3.2.3  Tier levels 
3.2.4  30 year conversion period consistent with IPCC 

3.3  Reporting of approximated GHG inventories (Article 26(2) of the GR) 
3.4  Reporting of GHG Inventories (Article 26(3) of the GR and Article 18 of the LULUCF 

67 

68 

73 
73 

73 
73 
75 
77 
81 
82 

Regulation) 

82 
3.5  Reporting on Policies and measures for LULUCF (Article 18 and Annex VI of the GR and Article 
83 
3.6  Reporting on projections for LULUCF (Article 18 and Annex VII of the GR and Article 18 of the 
84 

18 of the LULUCF Regulation) 

LULUCF Regulation) 

3.7  Reporting on final accounted emissions and removals (Article 26(5) of the GR and Article 

14(1) of the LULUCF Regulation) 
3.7.1  Conversions to wetlands are not reported explicitly in default CRF tables 
3.7.2  Non-disaggregated reporting of CH4 and N2O gases for land conversions 
3.7.3  Information reported on HWP for Afforested land (AFL), Managed Forest land (MFL) 

85 
86 
87 

90 
91 
92 

and deforested land (DL) 

3.7.4  Natural disturbances 
3.7.5  Technical corrections to the forest reference level 
3.7.6  Calculation of the 3.5% cap on accounting emissions and removals in managed forest 

land 

4  Basis for assessment for compliance with the LULUCF Regulation (Task 3) 

4.1  Introduction 

4.1.1  Background 
4.1.2  Objective 

4.2  Identification of relevant data sets and information sources 
4.3  Analysis of data sets 

4.3.1  Land use change data sets 
4.3.2  Forest biomass information 
4.3.3  Mineral soil data sets 
4.3.4  Organic soil data sets 
4.3.5  Natural disturbance data sets 

5  References 

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List of abbreviations 

AFOLU 

Agriculture, Forestry and Other Land Use 

CGLS 

CLC 

CLMS 

Copernicus Global Land Service 

Corine Land Cover 

Copernicus Land Monitoring System 

CRF tables 

Common Reporting Format tables. Set of standardised data tables containing mainly 

quantitative information that are part of the annual inventories of greenhouse gas 

DA 

DFDE 

DOM 

EEA 

EFFIS 

ENFIN 

ESA 

ESR 

ETS 

EU 

FAO 

emissions for Annex I Parties to the UNFCCC 

Delegated act, referring to delegated regulation EU 2020/1044 

Database on Forest Disturbances in Europe 

Dead Organic Matter. Carbon pool, made up of dead wood and litter 

European Environmental Agency 

European Forest Fire Information System 

European National Forest Inventory Network  

European Space Agency 

Efforts Sharing Regulation (EU 2018/842) 

Emission Trading System 

European Union 

Food and Agriculture Organisation of the United Nations  

FAOstat 

The global statistical database of the Food and Agriculture Organisation of the United 

Nations 

FRL 

Forest Reference Level. Reference level used for managed forest lands under the EU 

GHG 

GIS 

GLC 

GR 

HRL 

HWP 

IA 

IACS 

JRC 

LCCS 

LULUCF Regulation. 

Greenhouse Gas 

Geographic Information Systems 

Global Land Cover 

Governance Regulation (Regulation on the Governance of the Energy Union and 

Climate Action (EU 1999/2018)) 

High Resolution Layers 

Harvested Wood Products 

Implementing Act, referring to implementing regulation EU 2020/1208 

Integrated Administration and Control System. System used for the administration and 

control of payments to farmers in EU countries 

Joint Research Centre of the European Commissions 

Land Cover Classification System. Developed by FAO to provide a consistent 

framework for the classification and mapping of land cover 

LPIS 

Land Parcel Identification System. Database of the agriculture parcels used as a basis 

for area related payments to farmers in relation to the Common Agricultural Policy 

LUCAS 

Land Use and Coverage Area frame Survey of Eurostat 

LULUCF 

Land Use, Land-Use Change and Forestry 

MS 

NFI 

NIR 

SOC 

Member State(s) 

National Forest Inventory 

National Inventory Report 

Soil Organic Carbon 

UNFCCC 

United Nations Framework Convention on Climate Change 

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Executive summary 

The EU LULUCF Regulation (EU 2018/841) sets a binding commitment to all EU Member States to 

compensate accounted greenhouse gas (GHG) emissions from land use by an equivalent accounted 

removal of CO2. Together with the EU Emission Trading System (EU-ETS) and the Effort Sharing 

Regulation (EU 2018/842) (ESR), the LULUCF Regulation  forms a body of legislation that translates the 

EU’s nationally determined contribution under article 4 of the Paris Agreement into European law. 

The LULUCF Regulation sets out rules and specific accounting provisions for “land accounting categories”, 

rules on compliance and use of flexibilities. The LULUCF Regulation allows the trade of net accounted 

removals between Member States to cover for net accounted emissions.  

The ESR sets binding annual emissions targets for each Member State ranging between 0 and 40% 

reductions in GHG emission from the sectors covered by this Regulation by 2030. The ESR and LULUCF 

Regulation are linked through a flexibility framework. After meeting specific requirements and up to a 

Member State’s specific maximum, this flexibility allows for the use of surplus of net accounted removals 

from the LULUCF sector to be used for ESR compliance. Conversely, remaining net accounted emissions 

in the LULUCF sector must be compensated by the use of annual emission allocations from the ESR. As a 

result, the flexibility framework creates incentives to decrease greenhouse gas emissions and/or increase 

CO2 removals through action in the land use, land-use change and forestry sector. 

In addition, the Regulation on Governance of the Energy Union and Climate Action (EU 2018/1999) 

(Governance Regulation, GR) puts together all reporting requirements needed for both meeting EU’s 

reporting obligations under the UNFCCC, including the Paris Agreement, and monitoring progress 

towards achievement of the GHG mitigation targets under EU law. 

Together the LULUCF Regulation, the ESR and GR should constitute a consistent set of legislation that 

needs to be read together in order to give a complete picture of the applicable provisions. Further details 

on the information that needs to be reported and for the GHG inventory review is provided in the 

implementing (EU 2020/1208; IA) and delegated act (EU 2020/1044; DA) adopted under the GR.  

ES.1  This study 

The interlinkages between the different legal texts and references back and forth among the different 

regulations and associated delegated and implementing acts make it difficult to understand and schedule 

the delivery of the various compliance elements. Therefore, the first objective of this study was to 

assess consistency and provide improved understanding of all compliance needs, their interlinkages and 

timing (Task 1), to assist the Commission as well as Members States in scheduling their activities aimed 

at fulfilling the compliance needs.  

Interpretation of specific requirements for the information that needs to be provided for each of the 

compliance elements is not always straightforward. Therefore, the second objective was to identify and 

describe the expected content to be provided in relation to compliance elements. This study assessed 

what data or information needs to be delivered, in what format it should be provided, and how it should 

be submitted for each of the identified elements (Task 2). 

Finally a third objective of this study was to provide the Commission with an overview and guidance of 

data sets and information sources, that can be used to carry out the comprehensive review and analyse 

and verify the data and information provided by the Member States in their compliance reports at the 

end of each compliance period (Task 3). 

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ES.2  Compliance provisions and expected content 

Table ES.1 provides an overview of the elements and provisions related to LULUCF compliance. More 

information with a time line and the sequencing of elements and activities is provided in section 2.7. 

Reporting is considered to be one of the main elements for assessing compliance with the LULUCF 

Regulation. Because the accounting categories and compliance report considered under the LULUCF 

Regulation is directly linked to the reporting categories of the national GHG inventories of the Member 

States, these GHG inventories play a central role in the compliance reporting. The review component 

relates to the review of GHG emission inventories and accounted emissions and removals for the 

purposes of assessing compliance with the LULUCF Regulation; the progress component is the progress 

made by Member States and the EU with the implementation of their targets, including their 

commitments under Article 4 of the LULUCF Regulation.  

Table ES.1. Overview of requirements for LULUCF compliance with reference to their legal act, article or 

recital in that act, and date to which they relate. (MS refers to requirements and dates applicable for 

Member States, COM relates to the dates applicable to the Commission). 

Description of requirement 

Legal Act 

Article 

Recital  Date 

Reporting of approximated GHG 
inventories, annually for year x-1  

Reporting on GHG inventories, 
annually for year x-2 

GR 

GR 

26(2) 

26(3) 

LULUCF Regulation 

18 

Reporting on Policies and Measures 
(PAMS), biennially 

GR 

18 and Annex 
VI 

LULUCF Regulation 

18 

Reporting on projections biennially 

GR 

18 and Annex 
VII 

LULUCF Regulation  

18 

31 July (MS), 30 September (COM) 
Annually, starting 2021 

27, 30 
-33 

15 Jan - preliminary data (MS) 
15 March - final data (MS) 
15 April - reporting to UNFCCC (MS, 
COM) 
Annually, starting 2023  

15 March every second year, starting 
2021 (MS) 
15 March in the intervening years any 
substantial changes need to be reported 
(MS) 

15 March every second year, starting 
2021 (MS) 
15 March in the years in between any 
substantial changes need to be reported 
(MS) 

Assessment of progress reported as 
part of the State of the Energy Union 

GR  

29(5) and 35 

31 October, annually starting 2021 
(COM) 

Reporting on accounted emissions 
and removals for the period 2021 to 
2025 and 2025 to 2030 

GR 

26(5) 

LULUCF Regulation 

14(1) 

Review of GHG emission data and 
accounting emissions and removals 
data for the period 2021 to 2025 and 
2026 to 2030 

GR 

GR IA 

38 

30-34 

LULUCF Regulation 

14(2) 

Compliance check 

LULUCF Regulation  

14 

GR 

ESR 
GR 

38(5) 

9(2) 
38(6) 

LULUCF Regulation  14(3) 

Compliance check 

Report on total Union’s total 
emissions and total removals of 
greenhouse gases for each of the 
land accounting categories 

LULUCF compliance study 

15 Jan 2027- preliminary data (MS), 15 
March 2027- final data (MS)  
15 Jan 2032- preliminary data (MS), 15 
March 2032- final data (MS) 

15 April 2027 – latest 7 September 
2027 (83 days after centralised review) 
(COM) 
15 April 2032 – latest 7 September 
2032 (83 days after centralised review) 
(COM) 

No dates specified, given time periods 
indicated from the review this will be 
latest 7 February 2028 (COM), and 7 
February 2033 (COM) 

No dates specified, given time periods 
indicated from the review this will be 
latest 7 February 2028 (COM), and 7 
February 2033 (COM) 

2027 and 2032, without dates specified 
(COM) 

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Key findings related to the compliance provisions and expected content 

  Overall the assessed regulations were found internally consistent with referencing to articles in 

other legal texts and where necessary duplicating provisions in different legal texts.  

o  All relevant elements from articles for LULUCF reporting and accounting of GHG emissions and 

removals, and for reporting on policies and measures and projections on LULUCF Reporting, 

mentioned in Article 18 of the LULUCF Regulation have been included in the GR Articles 18 and 

26(2), (3) and (5).  

o  Article 14(1) of the LULUCF Regulation, requiring Member States to submit compliance reports 

containing the accounted emissions and removals, prepared according to the rules in the LULUCF 

Regulation, is referenced in Article 26(5) of the GR. The GR requires Member States to report 

accounted emissions and removals prepared according to the LULUCF Regulation. The GR 

attaches to the provision an implementing act (EU 2020/1208) which lays down details for the 

compliance reports, and provides tables for reporting and accounting. 

o  Where gaps or possible pit falls exist these are indicated and highlighted in bold in the text 

below 

  Reporting of approximated GHG inventories (Article 26(2) of the GR): Member States need to 

provide a top-level summary of the more detailed sectoral scope of the total greenhouse gas 

inventory for the year x-1 with the same methodologies as used for the GHG inventories. Reporting 

format is provided in Annex VI to the IA of the GR and is the same as Summary Table 2 of the CRF. 

For LULUCF this implies that this only provides emissions and removals at the level of the main land-

use categories (i.e. forest land, cropland, grassland, etc.) (also see section 2.7.2).  

  Reporting of GHG Inventories (Article 26(3) of the GR and Article 18 of the LULUCF Regulation): the 

first year of full reporting under the GR is 2023 for the year 2021 (x-2). The inventory years up to 

2020 are still being covered by reporting under Regulation 525/2013 according to Article 58 of the 

GR. As part of the required collaboration between Member States and the Commission in preparing 

the EU GHG inventory (Annex XXI of the Implementing regulation of the GR), Member States report 

to the Commission their preliminary GHG inventory data for x-2 by 15 January (see sections 2.2.2 

and 2.7.2, for more details).  

The Commission, assisted by the EEA, performs “initial checks” on these preliminary GHG emission 

data (see section 2.7.2 for all details) and circulates the finding of the “initial checks” including a 

notification of possible gap filling to Member States by 28 February. The primary purpose of the 

initial checks is to ensure the quality of the submission of the annual inventories and to assure 

completeness and consistency of the EU GHG inventory. Issues that arise from the initial quality and 

consistency checks need to be addressed by Member States for their final submission of inventory 

data and report to the Commission by 15 March. By 31 March the Commission assisted by the EEA 

prepares estimates for any data missing from a Member State’s inventory and circulates them to the 

Member States involved. Member States are allowed to comment on the proposed estimates until 7 

April. The whole process ends on 15 April with the reporting of the EU and Member States’ GHG 

inventories to the UNFCCC (also see section 2.7.2). 

Because this collaboration and interactions between Members States and the Commission and EEA 

for reporting GHG inventory reports is based on a very tight time schedule that leaves no room for 

deviations, this is considered to be one of the critical paths in the compliance process. This will 

particularly be the case in the years when Member States need to report their accounted emissions 

and removals (i.e. 2027 and 2032).  

Information on expected content for reporting: 

o  Member States shall determine greenhouse gas inventories using the 2006 IPCC Reporting 

Guidelines and are encouraged to use the 2013 wetland supplement to the 2006 IPCC guidelines. 

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UNFCCC Decision18/CMA.1 prescribes the use of the 100-year time horizon GWP values from the 

IPCC Fifth Assessment Report (see section 3.4 for more details). 

o  Annex I of the LULUCF Regulation and Annex V of the GR list the greenhouse gases that need to 

be included in the reporting. For the LULUCF accounting categories this includes the same gases 

and carbon pools that are required for reporting the LULUCF land-use categories in Member 

State’s national inventory reports (NIR) to the UNFCCC (see section 3.2.1 for details). 

o  Annex V, part 3 of the GR provides specific requirements for the LULUCF inventory reporting and 

accounting. One of the listed requirements is that geographically explicit land-use conversion 

data need to be used in line with the 2006 IPCC guidelines. This relates to Approach 3 in Chapter 

3 of Volume 4 of the 2006 IPCC guidelines (IPCC 2006b). This approach enables explicit tracking 

of land-use conversion over time and allows the use of Geographic Information Systems to link 

the information of land use and land-use changes with other spatially explicit data sets (see 

section 3.2.2 for details) 

o  The requirements on Tier levels for GHG inventory reporting and LULUCF accounting, are similar 

to the existing requirements of the IPCC guidelines. Member States are encouraged to use Tier 3 

methodologies and emission factors, which would improve representation of national 

circumstances, improve the link between biomass and soil carbon dynamics and reduces the 

uncertainty of GHG estimates. Moreover, Tier 3 methodologies can reflect the mitigation effects 

of policies and measures implemented by Member States that will not be reflected with Tier 1 

methodologies and possibly only to a lesser extent with Tier 2 methodologies. Tier 3 

methodologies will be required to actually reflect the effects of mitigation efforts 

greenhouse gas emission reporting and accounting. (see section 3.2.3 for more details). 

o  For the accounting category afforested land a 30 years conversion period may be applied if duly 

justified based on IPCC guidelines (LULUCF Regulation Article 6(2)). From the IPCC guidelines it 

is clear that the choice for a 30 year conversion period would only be justified if soil carbon in 

new forests does not reach a stable level within the default 20 years transition period (See 

section 3.2.4 for further interpretation and details). 

  Reporting on policies and measures for LULUCF (Article 18 and Annex VI of the GR and Article 18 of 

the LULUCF Regulation). The information to be included in the reports on policies and measures in 

the area of GHG emissions is provided in Annex VI of the GR. Tables which Member States shall use 

for reporting are included in Annex XXIV to article 37 of the IA of the GR (see section 3.5 for more 

details). 

  Reporting on projections for LULUCF (Article 18 and Annex VII of the GR and Article 18 of the 

LULUCF Regulation). Member States use their own methodologies but they need to report the 

parameters used and the sensitivity analysis performed. Tables which Member States shall use for 

reporting projections are included in Annex XXV to article 38 of the IA of the GR. The level of detail 

to report for the projection is the same as for annual reporting and reporting of accounted emissions 

by the end of the compliance period (see section 3.6 for more details). 

The modelling efforts for the projections should be able to capture the effects of the identified 

policies and measures. For the LULUCF sector this may imply a substantial modelling effort to 

cover interactions and trade-offs between policies and measures affecting requirements for land. It is 

recommended to assess available capacities in Member States to undertake such modelling exercises 

and identify possible needs for capacity development or knowledge exchange at an early stage. 

 

Assessment of progress (Articles 29(5) and 35 of the GR). From 31 October 2021 onwards the 

Commission annually publishes the progress made by Member States and the EU with the 

implementation of their targets, including their commitments under Article 4 LULUCF as part of the 

State of the Energy Union Report. For this the Commission needs to compile the data that is required 

according to the format in Annex XX of the IA to the GR.  

Most of this required information can be extracted from the CRF tables of the GHG inventory 

submitted by the Member States. However, in its default format the CRF table on Wetlands 

(CRF table 4.F), and also on non CO2-emissions (CRF Tables 4(I), 4(II), 4(III), 4(IV) and 4(V)) 

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do not contain the disaggregation into land-use categories that is needed to distinguish 

the land accounting categories. The CRF tables for Harvested Wood Products do not contain 

information to distinguish HWP between afforested land, deforested land and managed 

forest land. As a result, these emissions and removals cannot be subdivided to the various 

accounting categories. In order to transparently report these emissions for the accounting 

categories Member States will need to include the right level of disaggregation in the CRF 

table manually, at the latest before the compliance report in 2027 (see also sections 3.7.1, 3.7.2 

and 3.7.3). In order to facilitate the assessment of progress, which also benefits Member States, 

they should be encouraged to make these changes already in their NIRs submitted in earlier years. 

Information on division of HWP between afforested land and managed forest land should be included 

in the NIR. 

  Reporting on preliminary accounted emissions and removals (Article 26(5) of the GR). Together with 

the preliminary GHG inventory information, Member States will need to report the accounting 

information relevant for their compliance with the LULUCF Regulation, by 15 January 2027 for the 

period 2021-2025 and by 15 January 2032 for the period 2026-2030. Information to be included in 

the report of accounted emissions and removals is provided in Article 24 and Annex XX to the IA of 

the GR. 

  Reporting on final accounted emissions and removals (Article 26(5) of the GR and Article 14(1) of 

the LULUCF Regulation). Together with their final GHG inventory information, Member States will 

need to report the accounting information relevant for their compliance with the LULUCF Regulation 

by 15 March 2027 for the period 2021-2025 and by 15 March 2032 for the period 2026-2030 (see 

sections 2.2.6, and 2.7.3). Information to be included in the report of accounted emissions and 

removals is provided in Article 24 and Annex XX to the IA of the GR (see section 3.7). The report 

should contain the balance of total emissions and removals for each of the accounting categories 

identified in Article 2 of the LULUCF Regulation and using the accounting rules laid down in the 

LULUCF Regulation (see sections 2.3 and 2.6 for more details). The data used to calculate the 

accounting categories is the same data as included in the final GHG inventory data submitted to the 

Commission on 15 March 2027 or 15 March 2032.  

Information on expected content for reporting accounted emissions and removals: 

o  Information to be included in the report of accounted emissions and removals is provided in 

Article 24 and Annex XX to the IA of the GR. Most of the information can be taken directly from 

the CRF tables. However, similar to the issues identified under “assessment of progress” above, 

there are a number of CRF tables that by default do not contain the needed level of 

disaggregation of the “converted to” categories. In order to transparently report these 

emissions for the accounting categories, Member States will need to include the right level 

of disaggregation in the CRF table manually, at the latest before the compliance report in 

2027 (see also sections 3.7.1, 3.7.2 and 3.7.3).  In order to facilitate the assessment of 

progress, which also benefits Member States, they should be encouraged to make these changes 

already in their NIRs submitted in earlier years. 

o  Additionally, the accounting provides for the possibility to exclude emissions from natural 

disturbances from the accounting of managed forest land or afforested land. As this is not 

standard information provided in the NIR, information on applying the natural disturbances 

provision, including the calculation of the background level and the margin, and how all 

subsequent removals on the land affected by natural disturbances are excluded from accounting 

until 2030, need to be reported in the NIR (see section 3.7.4). Methodological rules are 

provided in Annex VI of the LULUCF Regulation. 

o  For accounting managed forest land a technical correction to the Forest Reference Level (FRL) 

will be required, which for the first compliance period needs to be submitted to the Commission 

by 15 January 2027 (GR Article 26(5), LULUCF Regulation Article 8(11)) or earlier (see section 

3.7.5). In the legislation there are no provisions included on how the technical correction 

of the FRL should be submitted. For transparent reporting and accounting at least a 

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description of the data uses and the applied methodologies would be required. The legal texts 

include no specific provisions for reviewing the technical corrections in the context of 

the FRL. It could be part of the comprehensive review, but this will probably call for additional 

resources and a team of technical experts focussing on the technical assessment of the 

submitted technical corrections of the FRLs.  

o  Article 8(2) of the LULUCF Regulation puts a cap on part of the emissions and removals that can 

be included in the accounting of managed forest land. If, after applying the accounting rules for 

managed forest land, net removals exist in the managed forest land accounting category, a 

maximum amount that is equivalent to 3.5% of the emissions of that Member State in its base 

year may be included in its managed forest land accounts. Net removals resulting from the 

carbon pools of dead wood and HWP, except the category of paper, in the land accounting 

category of managed forest land are not subject to this cap. Information on calculating the 

potential cap and the net removals included in the managed forest land account need to be 

provided in the report.  

The basis for calculating the 3.5% cap limit is not clear, but it is assumed that the intention in 

the LULUCF regulation is to apply a cap of 3.5% of the total base year emissions excluding 

LULUCF (see section 3.7.6). Also the specifications on how to assess the amount of net 

removals that are subject to the cap and the resulting net emissions to be included in the 

managed forest land accounts are not very specific. The interpretation made in this study is that 

it involves the following four steps (see section 3.7.6): 

1.  Calculate the sum of the net emissions/removals for all pools in managed forest land.  

2.  Calculate the difference between step 1 and the FRL, i.e. applying the Managed Forest Land 

accounting rules. In order to refer to the result of this step, the resulting net emissions or 

removals to be considered in the accounting are indicated as net emissions(MFL) and net 

removals(MFL). 

3.  If the result under step 2 is greater than or equal to zero, there is no need to apply a cap 

and the total net emissions(MFL) are to be included in the managed forest land account. 

4.  If this result under step 2 is lower than zero (i.e. net removals(MFL)), then a cap needs to be 

considered. 

a.  Calculate the sum of the potentially capped net emissions(MFL) and net removals(MFL). 

This is the sum of the net emissions(MFL) and removals(MFL) of carbon pools living  

biomass (above- and belowground), litter, soil, the HWP category of paper and if 

occurring also net emissions(MFL) from dead wood and the non-paper HWP 

categories. 

b.  Calculate the sum of net removals(MFL) that are not subject to the cap. These are net 

removals(MFL) for the dead wood and non-paper HWP pools, where the subcategories 

wood panels and sawn wood need to be taken together. 

c.  Compare the potentially capped net removals(MFL) of step 4a with the 3.5% cap. If 

net removals(MFL) are higher than the cap, these will be capped and the net 

removals(MFL) of the pools not subject to the cap (step 4b) are added to the capped 

net removals(MFL). If the potentially capped part of the removals(MFL) are smaller than 

the cap limit, than total net removals(MFL) (step 2) are included in the managed 

forest land account. 

It is recommended that both issues should be addressed in a possible future revision of the 

LULUCF Regulation. 

  Comprehensive review of the GHG inventories. A comprehensive review of the GHG inventories, 

including the accounted emissions and removals for the purposes of assessing compliance with the 

LULUCF Regulation (Article 38 of the GR), is done at the end of each compliance period; one for the 

period 2021-2025 in 2027 and one for the period 2026-2030 in 2032. A detailed time schedule is 

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provided in Annex XXII of the IA of the GR covering the period from 15 April to latest 7 September in 

the year the review takes place. 

The review is the task of the Commission assisted by a team of technical experts. Article 31 of the IA 

of the GR sets the rule that a technical correction can be proposed by the team of technical experts. 

The Commission is entitled to adopt an implementing act in order to set the total GHG emissions and 

removals relevant for compliance. With this decision the Commission will give legal standing to the 

findings of the review and make the technical corrections binding on Member States.  

The description in Annex XXII indicates that the material for the comprehensive review should be 

based on the 15 April submissions of the Member States (i.e. to the UNFCCC). Here a potential issue 

arises in cases where Member States have submitted GHG inventory data to the UNFCCC that differ 

from the reported final GHG inventory data submitted to the Commission on 15 March. In such cases 

the data that are being reviewed (15 April data) differ from the data that are used for the 

final accounted emissions and removals and that are provided in the LULUCF compliance report 

(15 March data). While according to Article 26 (4) the 15 April inventory data should be the same as 

the final data reported on 15 March, there may be instances where these deviate (see part on 

reporting of GHG inventories above and section 2.7.3). An update of the compliance report is 

not foreseen in the legal texts. Therefore, it is recommended that in possible future revisions this 

gap should be closed. This could be by requiring Member States that submit deviating GHG 

inventory data to the UNFCCC on 15 April also submit an updated LULUCF compliance report to 

the Commission that reflects the updates to the GHG inventory (section 2.7.3). 

  Report on the European Union’s total emissions and total removals of greenhouse gases for each of 

the land accounting categories (Article 14(3) LULUCF Regulation) in 2027 and 2032. There is no 

specific date for this report. The report should provide the total reported EU emissions and total 

reported removals for the period minus the value obtained by multiplying by five the Union’s average 

annual reported emissions and removals in the period from 2000 to 2009. This methodology applies 

a general formula to all accounting categories, while the accounting rules that Member States need 

to apply differ between the accounting categories. This calculated amount provides for each of the 

land accounting categories insight in how in the EU the total net emissions from the LULUCF sector 

have changed compared to the period 2000 to 2009. Such insight cannot be gained by summing the 

accounted emissions and removals.  

  Compliance check (Article 38(5) of the GR). The compliance of Member States is checked 4 months 

after the adoption of the implementing act setting the GHG emissions and removals relevant for 

compliance based on the outcomes of the comprehensive review. This is the date when Member 

States need to comply with their obligation under article 4 of the LULUCF Regulation. During this 

period of 4 months, Member States are able to use flexibilities for trading net accounted removals as 

provided in articles 11, 12 and 13 of the LULUCF Regulation and article 7 of the ESR 

  Reporting on summary information on concluded transfers under Article 12 and 13 of the LULUCF 

Regulation (Article 26(3), Annex V, point (f) of the GR). Even if the Registry allows transactions 

strictly during a 4 month period after the review, Member States can still enter into contracts with 

each other to sell expected credits. As Member States will know exactly their numbers only at the 

end of the period, it is not clear how much use will be made of a possibility to trade before this 

period. However, Article 26 of the GR requires Member States that summary information on 

concluded transfers should be included every year in the report on the preliminary (15 January) and 

final (15 March) GHG inventory data to the Commission using the reporting format provided in 

Annex XVI to Article 20 of the IA of GR. 

ES.2.1  Timeline of implementation of LULUCF compliance elements for the first compliance period. 

The overall timeline, with the main deadlines for the different elements relating to the first compliance 

period 2021-2025, is provided in Figure 2.1, in section 2.7.1. To keep the timeline legible it is subdivided 

into time intervals of 2 years: 2021-2022, 2023-2024, 2025-2026 and 2027-2028. It includes the 

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reporting and compliance elements as mapped for the LULUCF Regulation. Additionally it includes the 

reporting and accounting elements that still exist from continuing obligations (e.g. Article 7 of regulation 

EU 525/2013, still requiring the reporting of the national inventories for the years 2019 and 2020, 

including the activities defined in LULUCF decision EU 529/2013).  

ES.3  Basis for assessment for compliance with the LULUCF Regulation 

The objective of Task 3 was to provide the Commission with an overview and guidance of data sets and 

information sources that can be used to carry out the comprehensive review and analyse and verify the 

data and information provided by the Member States in their compliance reports. Based on the outcomes 

of Task 1 and 2 the following actions where additional data sets and information sources are relevant 

were identified: i) annual checks of Member States submissions and compilation of EU NIR, ii) annual 

assessment of progress in State of the Energy Union Report and iii) review of compliance reports in 2027 

(and 2032). The identification of potential data sets and information sources for compliance checking was 

focused on land use change data sources, forest biomass related data sources and soil carbon (both 

mineral and organic) data sources, and in addition data sets related to natural disturbances, which is an 

important aspect of the compliance review. 

Table ES.2 provides an overview of the identified data sets. Each data set was described and an 

assessment was made of the benefits and drawbacks of the data set for purposes of independent 

verification of the LULUCF inventory data and compliance reports. The description included the following 

elements: general description, type of data, spatial resolution and coverage, temporal coverage, 

accessibility and website. 

Based on the assessment of the potential data sources recommendations were made on their usefulness 

for verification and compliance checking of LULUCF inventory data (see Chapter 4). For land use changes 

the Corine Land Cover (CLC) still seems to be the most suitable dataset for monitoring LULUCF as it has a 

long history, regular update frequency, EU wall-to-wall coverage and sufficient thematic detail. The main 

disadvantage is the limited spatial detail. Therefore the Copernicus Land Monitoring Service is now working 

on the CLC+ LULUCF instance (pilot phase), which will have a higher resolution (1 ha) and a land cover/land 

use classification that represents the LULUCF land categories. For improving the interpretation of satellite 

imagery, machine learning and more specific deep learning could open ways to extend the use of satellite 

imagery in mapping land cover/use in a consistent way relevant for LULUCF monitoring. This could be used 

to classify historic satellite imagery like Landsat or more recent Sentinel-2, which are very suitable for land 

cover mapping at national and regional scales and are freely available. 

For organic soils the Global Peatland database and European peatland map both provide a good possibility 

to check on the areas of organic soils being reported in the LULUCF inventory. For mineral soils the LUCAS 

data is currently the only EU wide source with measured SOC data, which could be used for verification of 

soil  carbon  stock  changes.  However,  the  current  LUCAS  data  set  will  be  difficult  to  use  for  verification 

purposes of soil carbon stock changes at national level, due to high variability and will require a longer 

time frame and/or more sampling locations. 

Table ES.2. List of identified data sets and information sources that potentially can be used for verification 

and compliance checking of LULUCF inventory data 

Category 

Data source 

Description 

Land use changes 

Remote sensing based 
data sets 

A wide range of European and global land cover products are available, 
including the Copernicus Land Monitoring Service, with CLC and high 
resolution layers (HRL) products, but also a range of global satellite derived 
products are potentially of interest 

IACS/LPIS 

Land use data at parcel level 

Eurostat LUCAS 

LUCAS land use/cover survey data 

Forest biomass 

FAOSTAT 

Forestry production statistics 

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Category 

Data source 

Description 

NFI data  

Forest models 

National Forest Inventories; information on forest composition, structure, 
biomass and other carbon pools 

EU level forest models to assess changes in forest structure, biomass and 
other carbon pools. 

Mineral soils 

LUCAS 

Soil organic carbon data and trends for mineral soils 

FAO GSOC 

EJP Soil 

SOC map and SOC sequestration potential 

SOC sequestration potential, possible more data 

Organic soils 

FAOSTAT 

Organic soil emissions 

Global Peatland database  Areas of organic soils 

European peatland map  Areas of organic soils 

Natural disturbances 

JRC EFFIS 

European Forest Fire Information System 

DFDE 

FORWIND 

DEFID2 

Database on Forest Disturbances in Europe 

Spatial map on forest disturbances due wind in Europe 

Database of European Forest Insect & Disease Disturbances 

For biomass burning and natural disturbances due to forest fires, the EFFIS data set can be a very useful 

source for verification of burnt areas, as both spatial as well as tabular data are provided and frequently 

updated. The other data sources (DFDE, FORWIND and DEFID2) could potentially provide information on 

other natural disturbances, but these data sets are still in development or require  updates, and do not 

have all spatially explicit data available. 

These are the data sets that are already available, or in development. The coming years more relevant 

data sets might become available through other initiatives, like the work that is currently being done, e.g. 

in the H2020 Verify project. Petrescu et al. (2020) provide a state-of-the-art scientific overview of bottom-

up anthropogenic emissions data from agriculture, forestry and other land use in the EU. They based their 

analysis  on  sector  totals  derived  from  UNFCCC  and  models.  For  the  biogenic  carbon  fluxes  of  LULUCF 

results from the EFISCEN and CBM models were used. Large differences in the LULUCF carbon stocks and 

fluxes were found when modelled results were compared to UNFCCC reports. They emphasize the need for 

more detailed quantification of the difference between  LULUCF CO2 estimates, as data from inventories 

and models can show large differences caused by inconsistencies in methodology and/or tier application.  

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Résumé exécutif 

Le règlement de l’UE concernant le secteur UTCATF (UE 2018/841) fixe un engagement contraignant 

pour tous les États membres de l'UE à compenser les émissions de gaz à effet de serre comptabilisées 

(GES) provenant de l'utilisation des terres par une élimination équivalente de CO2. Avec le système 

d'échange de quotas d'émission de l'UE (SEQE) et le règlement sur la répartition de l'effort (UE 

2018/842) (RRE), le règlement UTCATF   constitue un corpus législatif qui traduit en droit européen la 

contribution déterminée au niveau national par l'UE en vertu de l'article 4 de l'Accord de Paris. 

Le règlement UTCATF définit des règles et des dispositions comptables spécifiques pour les « catégories 

comptables des terres », des règles de conformité et l'utilisation des flexibilités. Le règlement UTCATF 

permet l’échange des absorptions nettes comptabilisées entre États membres pour couvrir les émissions 

nettes comptabilisées.  

Le RRE fixe des objectifs annuels contraignants en matière d'émissions pour chaque État membre, allant 

de 0 à 40 % de réduction d'ici 2030 des émissions de GES provenant des secteurs couverts par ce 

règlement. Les règlements RRE et UTCATF sont liés par un cadre de flexibilité. Après avoir respecté des 

exigences spécifiques et jusqu'à un plafond spécifique à l'État membre, cette flexibilité permet d'utiliser 

l'excédent d'absorptions nettes comptabilisées du secteur UTCATF pour se conformer au RRE. À l'inverse, 

les émissions nettes comptabilisées restantes dans le secteur UTCATF doivent être compensées par 

l'utilisation des allocations annuelles d'émissions provenant du RRE. Par conséquent, le cadre de 

flexibilité incite à réduire les émissions de gaz à effet de serre et/ou augmenter les absorptions de CO2 

par des mesures dans le secteur de l'utilisation des terres, du changement d'affectation des terres et de 

la foresterie. 

En outre, le règlement sur la gouvernance de l'union de l'énergie et de l'action pour le climat (UE 

2018/1999) (règlement sur la gouvernance, RG) rassemble toutes les exigences en matière de 

déclaration nécessaires pour respecter les obligations de l'UE en matière de déclaration dans le cadre de 

la CCNUCC, y compris l'Accord de Paris, et pour suivre les progrès accomplis dans la réalisation des 

objectifs de réduction des GES en vertu de la législation de l'UE. 

Les règlements UTCATF, RRE et de gouvernance devraient constituer un ensemble cohérent de textes 

législatifs qui doivent être lus conjointement afin de donner une image complète des dispositions 

applicables. De plus amples détails sur les informations qui doivent être déclarées et pour l'examen de 

l'inventaire des GES figurent dans le l’acte d’exécution (UE 2020/1208 ; AE) et le règlement délégué (UE 

2020/1044 ; RD) adoptés dans le cadre du RG.  

RE.1  Cette étude 

Les corrélations entre les différents textes juridiques et les références entre les différents règlements et 

actes délégués et d'exécution associés compliquent la compréhension et la programmation de la 

transmission des divers éléments de conformité. Par conséquent, le premier objectif de la présente 

étude était d'évaluer la cohérence et de mieux comprendre tous les besoins en matière de conformité, 

leurs interdépendances et leur calendrier (Tâche 1), afin d'aider la Commission et les États Membres à 

planifier leurs activités visant à répondre aux besoins en matière de conformité.  

L'interprétation des exigences particulières relatives aux informations à fournir pour chacun des éléments 

de conformité n'est pas toujours simple. Par conséquent, le deuxième objectif était de déterminer et 

de décrire le contenu attendu à fournir en ce qui concerne les éléments de conformité. Cette étude a 

permis d'évaluer les données ou les informations à fournir, sous quelle forme elles devraient être 

fournies et comment elles devraient être présentées pour chacun des éléments identifiés (Tâche 2). 

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Enfin, un troisième objectif de cette étude était de fournir à la Commission une vue d'ensemble et des 

conseils sur les ensembles de données et les sources d'information qui peuvent être utilisés pour 

procéder à l'examen complet, ainsi que pour l'analyse et la vérification des données et informations 

fournies par les États membres dans leur rapports de conformité à la fin de chaque période de conformité 

(Tâche 3). 

RE.2  Dispositions de conformité et contenu attendu 

Le Tableau ES.1 donne un aperçu des éléments et dispositions relatifs à la conformité du secteur 

UTCATF. Plus d'informations avec un calendrier et un séquençage des éléments et des activités sont 

fournies dans la section 2.7. Les déclarations sont considérées comme l'un des principaux éléments 

permettant d'évaluer la conformité avec le Règlement UTCATF. Étant donné que les catégories 

comptables et le rapport de conformité considérés dans le cadre du règlement UTCATF sont directement 

liés aux catégories de déclaration des inventaires nationaux de GES des États membres, ces inventaires 

de GES jouent un rôle central dans la déclaration de conformité. Le volet « examen » concerne l'examen 

des inventaires des émissions de GES et des émissions et absorptions comptabilisées pour évaluer la 

conformité avec le règlement UTCATF ; le volet « progrès » correspond aux progrès réalisés par les États 

membres et l'UE dans la mise en œuvre de leurs objectifs, y compris leur engagements au titre de 

l'article 4 du règlement UTCATF.  

Tableau RE.1. Aperçu des exigences de conformité au règlement UTCATF avec référence à leur acte 

juridique, à l'article ou au préambule de cet acte, et la date à laquelle ils se rapportent. (EM désigne les 

exigences et les dates applicables aux États membres, COM les dates applicables à la Commission). 

Description de l'exigence 

Acte juridique 

Article 

Préamb

Date 

Déclaration des inventaires 
approximatifs de GES, annuellement 
pour l'année x-1  

RG 

Rapports sur les inventaires de GES, 
annuellement pour l'année x-2 

RG 

26(2) 

26(3) 

Règlement UTCATF 

18 

Rapports sur les politiques et 
mesures (PAMS), tous les deux ans 

RG 

18 et annexe 
VI 

Règlement UTCATF 

18 

Rapports sur les projections tous les 
deux ans 

RG 

18 et annexe 
VII 

Règlement UTCATF  

18 

ule 

31 juillet (EM), 30 septembre (COM) 
Annuellement, à partir de 2021 

27, 30 
-33 

15 janv. - données préliminaires (EM) 
15 mars - données finales (EM) 
15 avril - déclaration à la CCNUCC (EM, 
COM) 
Chaque année, à partir de 2023  

15 mars tous les deux ans, à partir de 
2021 (EM) 
15 mars dans les années 
intermédiaires, tout changement 
important doit être signalé (EM) 

15 mars tous les deux ans, à partir de 
2021 (EM) 
15 mars dans les années 
intermédiaires, tout changement 
important doit être signalé (EM) 

Évaluation des progrès signalés dans 
le cadre de l'état de l'union de 
l'énergie 

RG  

29(5) et 35 

31 octobre, annuellement à partir de 
2021 (COM) 

Déclaration des émissions et 
absorptions comptabilisées pour la 
période 2021 à 2025 et 2025 à 2030 

RG 

26(5) 

Règlement UTCATF 

14(1) 

15 janv. 2027 - données préliminaires 
(EM), 15 mars 2027 - données finales 
(EM)  
15 janv. 2032 - données préliminaires 
(EM), 15 mars 2032 - données finales 
(EM) 

LULUCF compliance study 

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Description de l'exigence 

Acte juridique 

Article 

Préamb

Date 

ule 

Examen des données des émissions 
de GES et des données comptables 
des émissions et des absorptions 
pour la période 2021 à 2025 et 2026 
à 2030 

RG 

38 

AE RG  

30-34 

Règlement UTCATF 

14(2) 

Vérification de conformité 

Règlement UTCATF  

14 

RG 

38(5) 

Vérification de conformité 

RRE 
RG 

9(2) 
38(6) 

Rapport sur les émissions totales et 
les absorptions totales de gaz à effet 
de serre de l'Union pour chacune des 
catégories comptables de terres 

Règlement UTCATF  14(3) 

15 avril 2027 — au plus tard le 7 
septembre 2027 (83 jours après la 
révision centralisée) (COM) 
15 avril 2032 — au plus tard le 7 
septembre 2032 (83 jours après la 
révision centralisée) (COM) 

Aucune date spécifiée, mais compte 
tenu des périodes indiquées lors de 
l'examen, ce sera au plus tard le 7 
février 2028 (COM) et le 7 février 2033 
(COM) 

Aucune date spécifiée, mais compte 
tenu des périodes indiquées lors de 
l'examen, ce sera au plus tard le 7 
février 2028 (COM) et le 7 février 2033 
(COM) 

2027 et 2032, sans dates spécifiées 
(COM) 

Principales conclusions relatives aux dispositions de conformité et au contenu attendu 

  Dans l'ensemble, les règlements évalués ont été jugés intrinsèquement cohérents, avec des 

références à des articles d'autres textes juridiques et, si nécessaire, des dispositions reproduites 

dans différents textes juridiques :  

o  Tous les éléments pertinents des articles relatifs à la déclaration et à la comptabilisation des 

émissions et des absorptions de GES dans le secteur UTCATF, ainsi qu'à la déclaration des 

politiques et mesures et aux projections relatives à la déclaration UTCATF, mentionnés à l'article 

18 du règlement UTCATF, ont été inclus dans les articles 18 et 26, paragraphes 2, 3 et 5 du RG.  
o  L'article 14, paragraphe 1, du règlement UTCATF, exigeant des États membres qu'ils soumettent 

des rapports de conformité contenant les émissions et absorptions comptabilisées, établis 

conformément aux dispositions du règlement UTCATF, est mentionné à l'article 26, paragraphe 5 

du RG. Le RG exige des États membres qu'ils déclarent les émissions et les absorptions 

comptabilisées établies conformément au règlement UTCATF. Le RG associe à cette disposition 

un acte d'exécution (UE 2020/1208) qui établit les détails des rapports de conformité et fournit 

des tableaux pour la déclaration et la comptabilisation. 

o  Les lacunes ou les failles éventuelles sont indiquées et mises en évidence en caractères gras 

dans le texte ci-dessous. 

  Déclaration des inventaires approximatifs de GES (article 26, paragraphe 2, du RG) : Les États 

membres doivent fournir un résumé de haut niveau de la portée sectorielle plus détaillée de 

l'inventaire total des gaz à effet de serre pour l'année x-1, en utilisant les mêmes méthodes que 

celles utilisées pour les inventaires de GES. Le format de déclaration figure dans l'annexe VI de l'AE 

du RG. C'est le même que le Tableau récapitulatif 2 du FRC. Pour le secteur UTCATF, cela implique 

que seules sont fournies les émissions et les absorptions au niveau des principales catégories 

d'utilisation des terres (terres forestières, terres cultivées, prairies, etc.).  

  Déclaration des inventaires de GES (article 26, paragraphe 3 du RG et article 18 du règlement 

UTCATF) : la première année de déclaration complète au titre du RG est 2023 pour l'année 2021 (x-

2). Les années d'inventaire jusqu'en 2020 sont toujours couvertes par la déclaration en vertu du 

règlement 525/2013 conformément à l'article 58 du RG. Dans le cadre de la collaboration nécessaire 

entre les États membres et la Commission pour la préparation de l'inventaire des GES de l'UE 

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(annexe XXI de l’acte d'exécution du RG), les États membres transmettent à la Commission leurs 

données préliminaires d'inventaire des GES pour l'année x-2 au plus tard le 15 janvier.  

La Commission, assistée par l'AEE, effectue des « contrôles initiaux » de ces données préliminaires 

sur les émissions de GES et communique aux États membres les conclusions des « contrôles 

initiaux », y compris une notification des lacunes éventuelles à combler, au plus tard le 28 février. 

L'objectif principal des contrôles initiaux est d'assurer la qualité de la soumission des inventaires 

annuels et d'assurer l'exhaustivité et la cohérence de l'inventaire des GES de l'UE. Les questions 

soulevées par les contrôles initiaux de qualité et de cohérence doivent être traitées par les États 

membres pour qu'ils soumettent définitivement les données d'inventaire et leur rapport à la 

Commission au plus tard le 15 mars. Le 31 mars au plus tard, la Commission et l'AEE établissent des 

estimations pour toute donnée manquante dans l'inventaire d'un État membre et les communique 

aux États membres concernés. Les États Membres sont autorisés à formuler des observations sur les 

estimations proposées jusqu'au 7 avril. L'ensemble du processus se termine le 15 avril avec la 

déclaration des inventaires des GES de l'UE et des États membres à la CCNUCC. 

Étant donné que cette collaboration et ces interactions entre les États membres et la Commission et 

l'AEE pour la déclaration des rapports d'inventaire des GES reposent sur un calendrier très serré 

qui ne laisse aucune marge de dérogation, il s'agit là d'une des voies critiques du processus de 

conformité. Cela sera particulièrement le cas au cours des années où les États membres devront 

déclarer leurs émissions et absorptions comptabilisées (c'est-à-dire 2027 et 2032).  

Informations sur le contenu attendu pour la déclaration : 

o  Les États membres doivent déterminer les inventaires des gaz à effet de serre en utilisant les 

lignes directrices de 2006 du GIEC et sont encouragés à utiliser le supplément de 2013 pour les 

zones humides de ces lignes directrices. La décision 18/CMA.1 de la CCNUCC prescrit l'utilisation 

des valeurs du PRG sur 100 ans figurant dans le cinquième rapport d'évaluation du GIEC. 
o  L'annexe I du règlement UTCATF et l'annexe V du RG énumère les gaz à effet de serre qui 

doivent être inclus dans la déclaration. Pour les catégories comptables de l'UTCATF, cela inclut 

les mêmes gaz et réservoirs de carbone que ceux qui sont requis pour la déclaration des 

catégories d'utilisation des terres UTCATF dans les rapports nationaux d'inventaire (RNI) des 

États membres à la CCNUCC. 

o  La troisième partie de l'annexe V du RG énonce des exigences spécifiques pour la déclaration et 

la comptabilisation des inventaires du secteur UTCATF. L'une des exigences énumérées est que 

les données géographiquement explicites sur la conversion de l'utilisation des terres doivent être 

utilisées conformément aux lignes directrices de 2006 du GIEC. Il s'agit de l'approche 3 du 

chapitre 3 du volume 4 des lignes directrices 2006 du GIEC (GIEC 2006b). Cette approche 

permet un suivi explicite de la conversion de l'utilisation des terres au fil du temps et permet 

l'utilisation de systèmes d'information géographique pour relier l'information sur l'utilisation des 

terres et les changements d'affectation des terres à d'autres ensembles de données spatialement 

explicites. 

o  Les exigences relatives aux Niveaux pour la déclaration des inventaires de GES et la 

comptabilisation du secteur UTCATF sont à l'heure actuelle similaires à celles des directives du 

GIEC. Les États membres sont encouragés à utiliser des méthodes et des coefficients d'émission 

de Niveau 3, ce qui améliorerait la représentation des circonstances nationales, le lien entre la 

biomasse et la dynamique du carbone du sol et réduirait l'incertitude des estimations des GES. 

En outre, les méthodologies de Niveau 3 peuvent refléter les effets d'atténuation des politiques 

et des mesures mises en œuvre par les États membres qui ne seront pas pris en compte dans 

les méthodologies de Niveau 1 et, éventuellement, dans une moindre mesure avec les 

méthodologies de Niveau 2. Des méthodes de Niveau 3 seront nécessaires pour tenir 

compte des effets des efforts d'atténuation de la déclaration et de la comptabilisation 

des émissions de gaz à effet de serre. 

o  Pour la catégorie comptable des terres boisées, une période de conversion de 30 ans peut être 

appliquée si elle est dûment justifiée sur la base des lignes directrices du GIEC (article 6, 

paragraphe 2 du règlement UTCATF). Il ressort clairement des lignes directrices du GIEC que le 

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choix d'une période de conversion de 30 ans ne serait justifié que si le carbone des sols dans les 

nouvelles forêts n'atteint pas un niveau stable au cours de la période de transition par défaut de 

20 ans. 

  Rapports sur les politiques et mesures pour l'UTCATF (article 18 et annexe VI du RG et article 18 du 

règlement UTCATF). Les États membres doivent faire un rapport sur les politiques et mesures du 

secteur UTCATF pour le 15 mars tous les deux ans à compter de 2021. Les informations à inclure 

dans les rapports sur les politiques et mesures dans le domaine des émissions de GES figurent dans 

l'annexe VI du RG. Les tableaux que les États membres doivent utiliser pour la déclaration sont 

inclus dans l'annexe XXIV de l'article 37 de l'AE du RG. 

  Rapports sur les projections pour l'UTCATF (article 18 et annexe VII du RG et article 18 du règlement 

UTCATF). Les États membres communiquent leurs projections concernant le secteur UTCATF au plus 

tard le 15 mars, tous les deux ans à partir de 2021. Les États membres utilisent leurs propres 

méthodologies, mais ils doivent rendre compte des paramètres utilisés et de l'analyse de sensibilité 

effectuée. Les tableaux que les États membres utilisent pour communiquer leurs projections figurent 

à l'annexe XXV de l'article 38 de l'AE du RG. Le niveau de détail à déclarer pour la projection est le 

même que pour la déclaration annuelle et la déclaration des émissions et absorptions comptabilisées 

d'ici la fin de la période de conformité. 

Les efforts de modélisation des projections devraient permettre de saisir les effets des politiques et 

mesures identifiées. Pour le secteur UTCATF, cela peut impliquer un effort de modélisation 

substantiel pour couvrir les interactions et les compromis entre les politiques et les mesures ayant 

une incidence sur les exigences concernant les terres. Il est recommandé d'évaluer les capacités 

dont disposent les États Membres pour entreprendre de tels exercices de modélisation et d'identifier 

les besoins éventuels en matière de renforcement des capacités ou d'échange de connaissances à un 

stade précoce. 

 

Évaluation des progrès accomplis (article 29, paragraphe 5, et article 35 du RG). À partir du 31 

octobre 2021, la Commission publie chaque année les progrès réalisés par les États membres et l'UE 

dans la réalisation de leurs objectifs, y compris leurs engagements au titre de l'article 4 de l'UTCATF 

dans le cadre du rapport sur l'état de l'Union de l'énergie. Pour ce faire, la Commission doit compiler 

les données requises conformément au format figurant dans l'annexe XX de l'AE du RG.  

La plupart de ces informations peuvent être extraites des tableaux FRC de l'inventaire des GES 

soumis par les États membres. Toutefois, dans son format par défaut, le tableau FRC sur les 

zones humides (tableau 4.F FRC), ainsi que sur les émissions autres que de CO2 (tableaux 4 

(I), 4 (II), 4 (III), 4 (IV) et 4 (V) du FRC) ne contiennent pas la décomposition en catégories 

d'utilisation des terres qui est nécessaire pour distinguer les catégories comptables de 

terres. Les tableaux FRC pour les produits ligneux récoltés (PLR) ne contiennent pas de 

renseignements permettant de distinguer les PLR des terres boisées, des terres déboisées et 

des terres forestières gérées. Par conséquent, ces émissions et absorptions ne peuvent être 

sous-divisées en différentes catégories comptables. Afin de déclarer de manière transparente ces 

émissions pour les catégories comptables, les États membres devront inclure manuellement le 

bon niveau de décomposition dans le tableau FRC, au plus tard avant la présentation du 

rapport de conformité en 2027. Afin de faciliter l'évaluation des progrès réalisés (qui profite 

également aux États membres), il convient de les encourager à apporter ces modifications dans leurs 

rapports nationaux présentés les années précédentes. Les informations sur la répartition des PLR 

entre les terres boisées et les terres forestières gérées devraient être incluses dans l’inventaire 

national. 

  Déclaration des émissions et absorptions comptabilisées préliminaires (article 26, paragraphe 5 du 

RG). En plus des informations préliminaires sur les inventaires de GES, les États membres devront 

communiquer les informations comptables pertinentes pour leur conformité avec le règlement 

UTCATF, au plus tard le 15 janvier 2027 pour la période 2021-2025 et au plus tard le 15 janvier 

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2032 pour la période 2026-2030. Les informations à inclure dans la déclaration des émissions et 

absorptions comptabilisées sont fournies dans l'article 24 et dans l'annexe XX de l'AE du RG. 

  Déclaration des émissions et absorptions comptabilisées définitives (article 26, paragraphe 5 du RG 

et article 14, paragraphe 1 du règlement UTCATF). Les États membres devront, en même temps que 

leurs informations définitives d'inventaire des GES, communiquer les informations comptables 

pertinentes pour leur conformité avec le règlement UTCATF d'ici le 15 mars 2027 pour la période 

2021-2025 et le 15 mars 2032 pour la période 2026-2030. Les informations à inclure dans la 

déclaration des émissions et absorptions comptabilisées sont fournies dans l'article 24 et dans 

l'annexe XX de l'AE du RG. Le rapport devrait contenir le bilan des émissions et absorptions totales 

pour chacune des catégories de comptabilisation identifiées à l'article 2 du règlement UTCATF et en 

utilisant les règles de comptabilisation établies dans le règlement UTCATF. Les données utilisées pour 

calculer les catégories comptables sont les mêmes que celles qui figurent dans les données 

définitives d'inventaire des GES soumises à la Commission le 15 mars 2027 ou le 15 mars 2032.  

Information sur le contenu attendu pour la déclaration des émissions et absorptions comptabilisées : 

o  Les informations à inclure dans la déclaration des émissions et absorptions comptabilisées sont 

fournies dans l'article 24 et dans l'annexe XX de l'AE du RG. La plupart des informations peuvent 

être tirées directement des tableaux FRC. Toutefois, à l'instar des questions identifiées dans la 

rubrique « évaluation des progrès » ci-dessus, il existe un certain nombre de tableaux FRC qui, 

par défaut, ne contiennent pas le niveau de décomposition nécessaire des catégories 

« converties en ». Afin de déclarer de manière transparente ces émissions pour les 

catégories comptables, les États membres devront inclure manuellement le niveau de 

décomposition approprié dans le tableau FRC, au plus tard avant la présentation du rapport 

de conformité en 2027. Afin de faciliter l'évaluation des progrès réalisés (qui profite également 

aux États membres), il convient de les encourager à apporter ces modifications dans leurs 

rapports nationaux présentés les années précédentes. 

o  En outre, la comptabilisation prévoit la possibilité d'exclure les émissions résultant de 

perturbations naturelles de la comptabilisation des terres forestières gérées ou des terres 

boisées. Comme il ne s'agit pas d'informations standards fournies dans l’inventaire national, les 

informations sur l'application de la disposition relative aux perturbations naturelles, y 

compris le calcul du niveau de fond et de la marge, et comment toutes les absorptions 

ultérieures sur les terres touchées par des perturbations naturelles sont exclues de la 

comptabilisation jusqu'à 2030, doivent être signalées dans l'inventaire national. Les règles 

méthodologiques figurent dans l'annexe VI du règlement UTCATF. 

o  En ce qui concerne la comptabilisation des terres forestières gérées, une correction technique du 

Niveau de référence pour les forêts (NRF) sera nécessaire, qui, pour la première période de 

conformité, doit être soumise à la Commission au plus tard le 15 janvier 2027 (article 26, 

paragraphe 5 des RG, article 8, paragraphe 11 du règlement UTCATF) ou plus tôt. La législation 

ne contient aucune disposition sur la façon dont la correction technique du NRF devrait 

être présentée. Pour assurer la transparence de la déclaration et de la comptabilisation, il 

faudrait au moins décrire les utilisations des données et les méthodes appliquées. Les textes 

juridiques ne contiennent pas de dispositions spécifiques pour l'examen des corrections 

techniques dans le contexte du NRF. Cela pourrait faire partie de l'examen approfondi, mais 

nécessiterait probablement des ressources supplémentaires et une équipe d'experts techniques 

se concentrant sur l'évaluation technique des corrections techniques soumises pour les NRF. 

o  L'article 8, paragraphe 2 du règlement UTCATF fixe un plafond à une partie des émissions et 

absorptions qui peuvent être incluses dans la comptabilisation des terres forestières gérées. Si, 

après application des règles comptables pour les terres forestières gérées, des absorptions 

nettes existent dans la catégorie de comptabilité des terres forestières gérées, un montant 

maximal équivalent à 3,5 % des émissions de cet État membre au cours de son année de 

référence peut être inclus dans ses comptes des terres forestières gérées. Les absorptions nettes 

résultant des réservoirs de carbone de bois mort et de PLR (à l'exception de la catégorie du 

papier) dans la catégorie comptable des terres forestières gérées ne sont pas assujetties à ce 

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plafond. Des informations sur le calcul du plafond potentiel et des absorptions nettes incluses 

dans la comptabilisation des terres forestières gérées doivent être fournies dans le rapport.  

La base de calcul du plafond de 3,5 % n'est pas claire, mais on suppose que l'intention du 

règlement UTCATF est d'appliquer un plafond de 3,5 % des émissions totales de l'année de 

référence, à l'exclusion du secteur UTCATF. De plus, les spécifications sur la façon d'évaluer 

la quantité d'absorptions nettes assujetties au plafond et les émissions nettes qui en résultent à 

inclure dans la comptabilisation des terres forestières gérées ne sont pas très précises. 

L'interprétation faite dans cette étude est qu'elle comporte les quatre étapes suivantes : 

5.  Calculer la somme des émissions/absorptions nettes pour tous les réservoirs des terres 

forestières gérées.  

6.  Calculer la différence entre l'étape 1 et le NRF, c'est-à-dire en appliquant les règles de 

comptabilisation des terres forestières gérées. Pour se référer au résultat de cette étape, les 

émissions ou absorptions nettes qui en résultent à prendre en compte dans la 

comptabilisation sont indiquées comme émissions nettes(MFL) et absorptions nettes(MFL). 

7.  Si le résultat de l'étape 2 est supérieur ou égal à zéro, il n'est pas nécessaire d'appliquer un 

plafond et les émissions nettes totales(MFL) doivent être incluses dans le compte des terres 

forestières gérées. 

8.  Si ce résultat de l'étape 2 est inférieur à zéro (c.-à-d. les absorptions nettes(MFL)), il faut alors 

envisager un plafond. 

a.  Calculer la somme des émissions nettes(MFL) et des absorptions nettes(MFL) 

potentiellement plafonnées. Il s'agit de la somme des émissions nettes(MFL) et des 

absorptions(MFL) des réservoirs de carbone de la biomasse vivante (en surface et 

souterraine), de la litière, du sol, de la catégorie du papier des PLR et, s'il y a lieu, 

des émissions nettes(MFL) provenant du bois mort et des catégories de PLR non-

papier. 

b.  Calculer la somme des absorptions nettes(MFL) qui ne sont pas assujetties au plafond. 

Il s'agit des absorptions nettes(MFL) pour les réservoirs PLR de bois mort et non-

papier, où les sous-catégories de panneaux de bois et de bois scié doivent être 

regroupées. 

c.  Comparer les absorptions nettes potentiellement plafonnées(MFL) de l'étape 4a avec 

le plafond de 3,5 %. Si les absorptions nettes(MFL) sont supérieures au plafond, elles 

seront plafonnées et les absorptions nettes(MFL) des réservoirs non assujettis au 

plafond (étape 4b) sont ajoutées aux absorptions nettes plafonnées(MFL). Si la partie 

potentiellement plafonnée des absorptions (LMF) est inférieure à la limite du plafond, 

les absorptions nettes totales(LMF) (étape 2) sont incluses dans la comptabilisation 

des terres forestières gérées. 

Il est recommandé que ces deux questions soient abordées dans le cadre d'une révision future 

du Règlement UTCATF. 

 

Examen complet des inventaires de GES. Un examen complet des inventaires de GES, y compris les 

émissions et absorptions comptabilisées pour l'évaluation de la conformité avec le règlement UTCATF 

(article 38 du RG), est effectué à la fin de chaque période de conformité, un pour la période 2021-

2025 en 2027 et un pour la période 2026-2030 en 2032. Un calendrier détaillé figure à l'annexe XXII 

de l'AE du RG pour la période allant du 15 avril au plus tard le 7 septembre de l'année où l'examen a 

lieu. 

L'examen est confié à la Commission, assistée d'une équipe d'experts techniques. L'article 31 de l'AE 

du RG établit la règle selon laquelle une correction technique peut être proposée par l'équipe 

d'experts techniques. La Commission est habilitée à adopter un acte d'exécution afin de fixer les 

émissions et absorptions totales de GES pertinentes à la conformité. Par cette décision, la 

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Commission accordera la qualité juridique aux conclusions de l’examen et rendra les corrections 

techniques contraignantes pour les États membres.  

La description figurant à l'annexe XXII indique que le matériel nécessaire à l'examen approfondi 

devrait être basé sur les soumissions présentées le 15 avril par les États membres (c'est-à-dire à la 

CCNUCC). Un problème potentiel se pose dans les cas où les États membres ont soumis à la CCNUCC 

des données d'inventaire de GES qui diffèrent des données d'inventaire définitif de GES 

communiquées à la Commission le 15 mars. Dans de tels cas, les données qui sont examinées 

(données du 15 avril) diffèrent de celles qui sont utilisées pour les émissions et absorptions 

définitives comptabilisées et qui sont fournies dans le rapport de conformité du secteur UTCATF 

(données du 15 mars). Même si, conformément à l'article 26, paragraphe 4, les données d'inventaire 

du 15 avril devraient être les mêmes que les données finales communiquées le 15 mars, il peut y 

avoir des cas dans lesquels elles diffèrent (voir la partie sur la déclaration des inventaires des GES 

ci-dessus). Une mise à jour du rapport de conformité n'est pas prévue dans les textes 

juridiques. Par conséquent, il est recommandé de combler cette lacune lors de révisions futures. 

Cela pourrait se faire en exigeant que les États membres qui soumettent à la CCNUCC des données 

d'inventaire des GES non-concordants le 15 avril soumettent également à la Commission un 

rapport actualisé sur la conformité du secteur UTCATF qui reflète les mises à jour de 

l'inventaire des GES. 

  Rapport sur les émissions totales et absorptions totales des gaz à effet de serre de l'Union 

européenne pour chacune des catégories comptables de terres (article 14, paragraphe 3, règlement 

UTCATF) en 2027 et 2032. Il n'y a pas de date précise pour ce rapport. Le rapport devrait fournir le 

total des émissions déclarées dans l'UE et les absorptions totales déclarées pour la période, moins la 

valeur obtenue en multipliant par cinq les émissions et absorptions annuelles moyennes déclarées 

par l'Union pour la période allant de 2000 à 2009. Cette méthode applique une formule générale à 

toutes les catégories comptables, tandis que les règles de comptabilisation que les États membres 

doivent appliquer diffèrent d'une catégorie comptable à l'autre. Ce montant calculé fournit, pour 

chacune des catégories comptables de terres, un aperçu de l'évolution des émissions nettes totales 

du secteur UTCATF dans l'UE par rapport à la période 2000-2009. On ne peut obtenir un tel aperçu 

en additionnant les émissions et absorptions comptabilisées.  

  Contrôle de conformité (article 38, paragraphe 5 du RG). La conformité des États membres est 

vérifiée quatre mois après l'adoption de l'acte d'exécution fixant les émissions et absorptions de GES 

pertinentes pour évaluer la conformité, sur la base des résultats de l'examen approfondi. Il s'agit de 

la date à laquelle les États membres doivent se conformer à l'obligation qui leur incombe en vertu de 

l'article 4 du règlement UTCATF. Au cours de cette période de quatre mois, les États membres sont 

en mesure d'utiliser les flexibilités pour l'échange des absorptions nettes comptabilisées, 

conformément aux articles 11, 12 et 13 du règlement UTCATF et à l'article 7 du RRE. 

  Déclaration des informations de synthèse sur les transferts conclus au titre des articles 12 et 13 du 

règlement UTCATF (article 26, paragraphe 3, annexe V, point (f), du RG). Même si le Bureau 

d’enregistrement autorise les transactions pendant une période stricte de quatre mois après 

l'examen, les États Membres peuvent encore conclure des contrats entre eux pour vendre les crédits 

attendus. Étant donné que les États membres ne connaîtront exactement leurs chiffres qu'à la fin de 

la période, il n'est pas clair dans quelle mesure il sera fait usage d'une possibilité d’échange avant 

cette période. Les informations récapitulatives sur les transferts conclus devraient être incluses dans 

le rapport sur les données préliminaires (15 janvier) et finales (15 mars) des inventaires de GES 

soumis à la Commission en utilisant le format de déclaration figurant à l'annexe XVI de l'article 20 de 

l'AE des RG. 

RE.2.1  Calendrier de mise en œuvre des éléments de conformité du secteur UTCATF pour la première 

période de conformité. 

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La frise chronologique globale, avec les principales échéances pour les différents éléments relatifs à la 

première période de conformité 2021-2025, est présentée dans le Schéma à la figure 2.1, à la section 

2.7.1. Pour garder la chronologie lisible, elle est subdivisée en intervalles de temps de 2 ans : 2021-

2022, 2023-2024, 2025-2026 (2027-2028) et 35 Elle comprend les éléments de déclaration et de 

conformité tels qu'ils ont été cartographiés pour le règlement UTCATF. En outre, elle inclut les éléments 

de déclaration et de comptabilisation qui subsistent dans le cadre d'obligations permanentes (par 

exemple, l'article 7 du règlement UE 525/2013, qui exige toujours la déclaration des inventaires 

nationaux pour les années 2019 et 2020, y compris les activités définies dans la décision UE 529/2013 

concernant le secteur UTCATF).  

RE.3  Base d'évaluation de la conformité avec le règlement UTCATF 

L'objectif de la Tâche 3 était de fournir à la Commission un aperçu et une orientation sur les ensembles de 

données  et  les  sources  d'information  qui  peuvent  être  utilisés  pour  procéder  à  l'examen  approfondi,  à 

l'analyse et à la vérification des données et informations fournies par les États membres dans leurs rapports 

de conformité. Sur la base des résultats des Tâches 1 et 2, les actions suivantes, pour lesquelles d'autres 

ensembles de données et sources d'information sont pertinents, ont été identifiées : i) contrôles annuels 

des  soumissions  des  États  membres  et  compilation  des  inventaires  nationaux  de  l'UE,  ii)  évaluation 

annuelle des progrès réalisés dans le rapport sur l'état de l'Union de l'énergie et iii) examen des rapports 

de  conformité  en  2027  (et  2032).  L'identification  d'ensembles  de  données  et  de  sources  d'information 

potentiellement  utilisables  pour  évaluer  la  conformité  a  été  axée  sur  les  sources  de  données  sur  le 

changement  d'affectation  des  terres,  les  sources  de  données  relatives  à  la  biomasse  forestière  et  les 

sources de données sur le carbone des sols (minéral et organique), ainsi que sur les ensembles de données 

sur les perturbations naturelles, qui constituent un aspect important de l'examen de conformité. 

Le Tableau RE.2 donne un aperçu des ensembles de données identifiés. Chaque ensemble de données a 

été décrit et on a évalué les avantages et les inconvénients de l'ensemble de données pour faire une 

évaluation indépendante des données d'inventaire du secteur UTCATF et des rapports de conformité. La 

description comprenait les éléments suivants : description générale, type de données, résolution spatiale 

et couverture, couverture temporelle, accessibilité et site internet. 

Tableau RE.2 Liste des ensembles de données identifiés et des sources d'information susceptibles d'être 

utilisés pour la vérification e le contrôle de conformité des données d'inventaire du secteur UTCATF 

Catégorie 

Source de données  Description 

Changements de 
l'utilisation des terres 

Ensembles de données 
basées sur la 
télédétection 

Une large gamme de produits européens et mondiaux de couverture terrestre 
est disponible, dont le service Copernicus de surveillance des terres, des 
produits CORINE Land Cover (CLC) et des images high resolution layers (HRL) 
mais aussi une gamme de produits satellitaires présentant un intérêt 
potentiel. 

IACS/LPIS 

Données sur l'utilisation des terres au niveau des parcelles 

LUCAS d’Eurostat 

Données de l'utilisation des terres et des enquêtes de couverture LUCAS 

Biomasse forestière 

FAOSTAT 

Statistiques de la production forestière 

Données de l'IFN  

Inventaires forestiers nationaux ; information sur la composition, la structure, 
la biomasse des forêts et d'autres réservoirs de carbone 

Modèles forestiers 

Modèles forestiers au niveau de l'UE pour évaluer l'évolution de la structure 
forestière, de la biomasse et d'autres réservoirs de carbone. 

Sols minéraux 

LUCAS 

Données sur le carbone organique du sol et tendances pour les sols minéraux 

FAO GSOC 

Carte SOC et potentiel de séquestration SOC 

EJP Soil 

Potentiel de séquestration SOC, possibilité de plus de données 

Sols organiques 

FAOSTAT 

Émissions organiques des sols 

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Catégorie 

Source de données  Description 

Global Peatland 
database 

European peatland 
map 

Zones de sols organiques 

Zones de sols organiques 

Perturbations 
naturelles 

JRC EFFIS 

Système européen d'information sur les feux de forêt 

DFDE 

Base de données sur les perturbations forestières en Europe 

FORWIND 

Carte spatiale des perturbations forestières dues au vent en Europe 

DEFID2 

Base de données des perturbations causées par les insectes et les maladies 
des forêts européennes 

Sur la base de l'évaluation des sources de données potentielles, des recommandations ont été formulées 

quant  à  leur  utilité  pour  évaluer  la  conformité  des  données  d'inventaire  du  secteur  UTCATF.  En  ce  qui 

concerne  les  changements  d'utilisation  des  terres,  le  Corine  Land  Cover  (CLC)  semble  toujours  être 

l'ensemble de données le plus approprié pour le suivi du secteur UTCATF, car il a une longue histoire, une 

fréquence de mise à jour régulière, une couverture européenne et offre des détails thématiques suffisants. 

Le  principal  inconvénient  est  la  précision  spatiale  limitée.  C'est  pourquoi  le  Service  de  surveillance  des 

terres de Copernicus travaille maintenant sur l'instance CLC+ UTCATF (phase pilote), qui proposera une 

résolution plus élevée (1 ha) et une classification de la couverture terrestre et de l'utilisation des terres qui 

représentent  les  catégories  de  terres  du  secteur  UTCATF.  Pour  améliorer  l'interprétation  de  l'imagerie 

satellitaire, l'apprentissage automatique et l'apprentissage approfondi plus spécifique pourraient ouvrir des 

moyens d'étendre l'utilisation de l'imagerie satellitaire pour cartographier la couverture et l'utilisation des 

terres d'une manière cohérente pertinente pour la surveillance du secteur UTCATF. Cela pourrait être utilisé 

pour classer les images satellitaires historiques comme Landsat ou Sentinel-2 plus récentes, qui sont très 

appropriées  pour  la  cartographie  de  la  couverture  terrestre  à  l'échelle  nationale  et  régionale  et  sont 

disponibles gratuitement. 

Pour les sols organiques, la Global Peatland database et l’European peatland map offrent toutes deux une 

bonne possibilité de vérifier les superficies de sols organiques déclarées dans l'inventaire UTCATF. Pour les 

sols  minéraux,  les  données  LUCAS  sont  actuellement  la  seule  source  européenne  de  données  SOC 

mesurées à disposition qui pourrait être utilisée pour vérifier les variations des stocks de carbone dans les 

sols. Toutefois, l'ensemble actuel de données LUCAS sera difficile à utiliser pour vérifier des variations de 

stocks de carbone des sols au niveau national, en raison de la grande variabilité et nécessitera un délai 

plus long et/ou plus d’emplacements d'échantillonnage.  

En ce qui concerne la combustion de biomasse et les perturbations naturelles dues aux incendies de forêt, 

l'ensemble de données EFFIS peut être une source très utile pour la vérification des zones brûlées, car des 

données spatiales et tabulaires sont fournies et fréquemment mises à jour. Les autres sources de données 

(DFDE,  FORWIND  et  DEFID2)  pourraient  potentiellement  fournir  des  informations  sur  d'autres 

perturbations naturelles, mais ces ensembles de données sont encore en cours d'élaboration ou nécessitent 

des mises à jour et ne disposent pas de toutes les données explicites spatialement disponibles. 

Il s'agit des ensembles de données déjà disponibles ou en cours de développement. Au cours des années 

à  venir,  des  ensembles  de  données  plus  pertinents  pourraient  être  mis  à  disposition  grâce  à  d'autres 

initiatives,  comme  le  travail  actuellement  réalisé  dans  le  cadre  du  projet  H2020  Verify.  Petrescu  et  al. 

(2020) qui fournit un aperçu scientifique de pointe des données ascendantes sur les émissions anthropiques 

provenant  de  l'agriculture,  de  la  foresterie  et  d'autres  utilisations  des  sols  dans  l'UE. Ils  ont  fondé  leur 

analyse sur les totaux sectoriels dérivés de la CCNUCC et des modèles. Pour les flux de carbone biogéniques 

du secteur UTCATF, les résultats des modèles EFISCEN et CBM ont été utilisés. Des différences importantes 

dans les stocks et les flux de carbone du secteur UTCATF ont été constatées lorsque les résultats modélisés 

ont été comparés aux rapports de la CCNUCC. Ils soulignent la nécessité d'une quantification plus détaillée 
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de la différence entre les estimations du CO2 du secteur UTCATF, car les données provenant des inventaires 

et des modèles peuvent faire apparaître d'importantes différences causées par des incohérences dans la 

méthodologie et/ou les niveaux d'application.  

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1 

Introduction 

In October 2014 EU leaders agreed that all sectors should contribute to the EU’s 2030 emission reduction 

target, including the land use sector. The Paris Agreement also points out at the important role of the 

land-use sector to achieve the long-term climate mitigation objective to reach no net increase in global 

emissions by 2050. The resulting legislation (Regulation (EU) 2018/841, also Land Use, Land Use Change 

and Forestry or LULUCF Regulation, Table 1.1) sets a binding commitment to all EU Member States to 

compensate accounted greenhouse gas (GHG) emissions from land use by an equivalent accounted 

removal of CO2.  

The LULUCF Regulation together with the EU Emission Trading System (Directive 2003/87/EC, EU-ETS, 

Table 1.1) and the Effort Sharing Regulation (EU 2018/842, ESR, Table 1.1) form a body of legislation 

that translate the EU’s nationally determined contribution under article 4 of the Paris Agreement into 

European law. While the Regulations address EU member states, also Norway and Iceland decided to join 
the EU in its efforts to reduce emissions by 40% in 20301. 

The LULUCF Regulation sets out rules and specific accounting provisions for “land accounting categories”, 

rules on compliance and use of flexibilities. The ESR sets binding annual emissions targets for each 

Member State ranging between 0 and 40% reductions in GHG emission from the sectors covered by this 

Regulation by 2030. The ESR and LULUCF Regulation are linked through a flexibility framework. Within 

its specific rules and to a Member State’s specific maximum, this flexibility allows for the use of surplus 

of net accounted removals from the LULUCF sector to be used for ESR compliance. Conversely, 

remaining net accounted emissions in the LULUCF sector must be compensated by the use of annual 

emission allocations from the ESR. As a result, the flexibility framework creates incentives to decrease 

greenhouse gas emissions and/or increase CO2 removals through action in the land us and forestry 

sector. 

In addition, the Regulation on Governance of the Energy Union and Climate Action (EU 2018/1999, also 

Governance Regulation; GR, Table 1.1) puts together all reporting requirements needed for both meeting 

EU’s reporting obligations under the UNFCCC, including the Paris Agreement, and monitoring progress 

towards achievement of the GHG mitigation targets under EU law. 

One of the main objectives of the Governance Regulation is to ensure that the reporting deadlines under 

the UNFCCC and the Paris Agreement and those provided under the EU legislation are streamlined. Both 

ESR and LULUCF compliance is based on the GHG inventories reported by Member States to the 

Commission. This submission should contain the same data and information as reported to the UNFCCC 

secretariat. The information on policies and measures and projections under the ESR and LULUCF is used 

also for the purposes of the Biennial reports and National Communications required under the Paris 

Agreement and the UNFCCC. Further details on the GHG inventory review and the information reported 

are provided in the implementing (EU 2020/1208, IA) and delegated (EU 2020/1044, DA) acts adopted 

under the Governance Regulation.  

The LULUCF Regulation, the ESR and the Governance Regulation together constitute a consistent set of 

legislation that needs to be read together to give a complete picture of the applicable provisions. The 

interlinkages between the different legal texts and references back and forth among the different 

regulations and associated delegated and implementing acts make it very difficult to understand and 

schedule the delivery of the various compliance elements. Improved understanding of all compliance 

needs, their interlinkages and timing will assist the Commission as well as Members States in scheduling 

its activities aimed at fulfilling their obligations. 

1 https://ec.europa.eu/clima/news/european-union-iceland-and-norway-agree-deepen-their-cooperation-climate-action_en 

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LULUCF 
Regulation  
(EU 841/2018) 

Effort Sharing 
Regulation  
(EU 842/2018, 
ESR) 

Governance 
regulation  
(EU 1999/2018, 
GR) 

Table 1.1. Overview of the relevant legal texts, their full name and link to the published texts and a list 

of the articles, annexes and recitals containing the most relevant elements for LULUCF compliance. For 

each of the articles, annexes and recitals a short description of the covered topic is provided. 

Legal text 

Full name and link 

Articles 

Topic 

EU Emission 
Trading System  
(Directive 
2003/87/EC, EU-
ETS) 

Consolidated text: Directive 2003/87/EC of the 
European Parliament and of the Council of 
13 October 2003 establishing a system for 
greenhouse gas emission allowance trading within 
the Union and amending Council Directive 
96/61/EC. https://eur-
lex.europa.eu/eli/dir/2003/87/2020-01-01 

Contains no elements that are relevant for LULUCF 
compliance 

Regulation (EU) 2018/841 of the European 
Parliament and of the Council of 30 May 2018 on 
the inclusion of greenhouse gas emissions and 
removals from land use, land use change and 
forestry in the 2030 climate and energy framework, 
and amending Regulation (EU) No 525/2013 and 
Decision No 529/2013/EU. 
http://data.europa.eu/eli/reg/2018/841/oj 

The complete regulation text is considered to be 
relevant for LULUCF compliance 

Regulation (EU) 2018/842 of the 
European Parliament and of the 
Council of 30 May 2018 on binding 
annual greenhouse gas emission 
reductions by Member States from 
2021 to 2030 contributing to climate 
action to meet commitments under 
the Paris Agreement and amending 
Regulation (EU) No 525/2013. 
https://eur-
lex.europa.eu/eli/reg/2018/842/oj 

Regulation (EU) 2018/1999 of the 
European Parliament and of the 
Council of 11 December 2018 on the 
Governance of the Energy Union and 
Climate Action, amending Regulations 
(EC) No 663/2009 and (EC) No 
715/2009 of the European Parliament 
and of the Council, Directives 
94/22/EC, 98/70/EC, 2009/31/EC, 
2009/73/EC, 2010/31/EU, 
2012/27/EU and 2013/30/EU of the 
European Parliament and of the 
Council, Council Directives 
2009/119/EC and (EU) 2015/652 and 
repealing Regulation (EU) No 
525/2013 of the European Parliament 
and of the Council. https://eur-
lex.europa.eu/eli/reg/2018/1999/oj 

7 

9 

Annex III 

Recitals 22-
23 

Flexibility between ESR and LULUCF Regulation 

Compliance check 

Flexibility between ESR and LULUCF Regulation. 
Total net removals from afforested land, deforested 
land, managed cropland and managed grassland 
that Member States may take into account for 
compliance pursuant to Article 7 

Flexibility between ESR and LULUCF Regulation 

18 

26 

29 

35 

37 

38 

57 

58 

Reporting on Policies and Measures (PAMS), 
biennially; Reporting on projections biennially 

Reporting of GHG inventories (approximated, 
preliminary and final); reporting on accounted 
emissions and removals 

Assessment of progress reported as part of the State 
of the Energy Union 

Assessment of progress reported as part of the State 
of the Energy Union 

Union and national inventory systems 

Inventory review and compliance checks 

Repeal of regulation (EU) 525/2013 

Transitional provisions 

Annex V 

GHG inventories - part 1 on information to be 
included in the reports; part 2 on GHGs to be 
covered; and part 3 on methodologies for monitoring 
and reporting in the LULUCF sector 

Annex VI 

Reporting on Policies and Measures (PAMS) 

Annex VII 

Reporting on projections  

3 

6 

Greenhouse gas inventory guidelines 

Initial checks 

Annex 

Global Warming Potentials 

Delegated act  
(EU 2020/1044, 
DA) 

Commission Delegated Regulation 
(EU) 2020/1044 of 8 May 2020 
supplementing Regulation (EU) 
2018/1999 of the European 
Parliament and of the Council with 
regard to values for global warming 
potentials and the inventory guidelines 
and with regard to the Union inventory 
system and repealing Commission 
Delegated Regulation (EU) No 
666/2014. https://eur-
lex.europa.eu/eli/reg/2020/1044/oj 

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Legal text 

Full name and link 

Articles 

Topic 

Implementing act  
(EU 2020/1208, 
IA) 

Commission Implementing Regulation 
(EU) 2020/1208 of 7 August 2020 on 
structure, format, submission 
processes and review of information 
reported by Member States pursuant 
to Regulation (EU) 2018/1999 of the 
European Parliament and of the 
Council and repealing Commission 
Implementing Regulation (EU) 
No 749/2014. https://eur-
lex.europa.eu/eli/reg/2020/1208/oj 

20 

24 

25 

30-34 

37 

38 

Reporting on summary information on concluded 
transfers in accordance with Regulation 2018/841 

Reporting on accounted greenhouse gas emissions 
and removals 

Timescales for cooperation and coordination in 
preparing the Union greenhouse gas inventory and 
the UNFCCC review 

Comprehensive review - procedure and schedule for 
carrying out the comprehensive review 

Reporting on national policies and measures 

Reporting on national projections 

Annex VI 

Table for reporting on approximated greenhouse gas 
inventories 

Annex XVI   Reporting on summary information on concluded 

transfers in accordance with Regulation 2018/841 

Annex XX 

Tables for reporting on accounted greenhouse gas 
emissions and removals pursuant to Article 24 

Annex XXI 

Timescales for cooperation and coordination in 
preparing the Union greenhouse gas inventory report 
pursuant to Article 25(1) 

Annex XXII  Procedure and schedule for the comprehensive 

reviews 

Annex XXIV   Tables for reporting on national policies and 
measures pursuant to Article 37 

Annex XXV  Tables for reporting on national projections pursuant 

to Article 38 

1.1 

Link between reporting and accounting of GHG emissions and removals for LULUCF 

1.1.1  UNFCCC reporting 

Countries that are party to the United Nations Framework Convention on Climate Change (UNFCCC) and 

are included in Annex I of the Convention (the industrialized countries, including the EU member states), 

annually report national emissions and removals of greenhouse gases. This is done for five sectors: 

Energy, Industrial Processes and Product Use, Agriculture, LULUCF, and Waste. The results are reported 

annually in tables with a common reporting format (CRF tables) and described and explained in an 
inventory report, the "National Inventory Report"2. 

In this international monitoring, reporting and verification of greenhouse gas emissions and removals, 

the LULUCF inventory sector covers the anthropogenic emissions and removals of greenhouse gases 

resulting from changes in carbon stocks in living biomass (aboveground and belowground), dead organic 

matter (dead wood, litter), organic carbon in soils (mineral and organic soils) and harvested wood 

products. Additionally also CO2 N2O and CH4 emissions related to management and use of land, like 

fertilizer application, and drainage and rewetting are included.   

Land use and its changes 

The purpose of the UNFCCC inventory is to provide as complete a picture as possible of the emissions 

and removals of greenhouse gases, in this case for the LULUCF sector. The system for determining 

emissions combines information about the size of an activity, event or process (activity data) with 

associated emissions or removals of greenhouse gases (emission data). For the LULUCF sector, spatially 

explicit information about land use, land use change, management practices and soil type are the most 

important activity data.  

2 https://unfccc.int/ghg-inventories-annex-i-parties/2020 

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A distinction is made between six land use classes (IPCC 2006b): 

4.A   Forest Land 

4.B   Cropland  

4.C  Grassland 

4.D  Wetlands 

4.E   Settlements 

4.F   Other land (this may for instance include bare soil without significant cover of vegetation, such 

as beach and drifting sands). 

Each of the land-use categories is divided into land use that remains the same land use, for example 

forest land remaining forest land and land that has been converted into that land use, for example land 

that has been converted into forest land (see Table 1.2). Below, all conversions from the other land use 

categories to destination land use are included and distinguished, e.g. cropland converted to forest land, 
grassland converted to forest land, etc3. Each of the main categories can be further stratified into 
subcategories to take into account different types of land use within a main category. For instance under 

agricultural grasslands may be separated from managed nature grasslands. Other stratifications can be 

used as needed. This requires suitable information for the activity data and emission factors. 

Table 1.2. Matrix of land use and land use change categories as used within the LULUCF reporting. 

Reporting is done under the land use category listed at the top of the columns. Please note the deviating 

default structure for the Wetlands category as explained in the footnote to the text above and further 

explained in section 3.7.1. 

Forest land 

Cropland 

Grassland 

Wetlands  

Settlements 

Other land 

Forest land 
to Cropland 

Forest land 
to Grassland 

Forest land 
to Wetlands 

Cropland to 
Grassland 

Cropland to 
Wetlands 

Forest land 
to 
Settlements 
Cropland to 
Settlements 

Forest land 
to Other land 

Cropland to 
Other land 

Converted to: 

From: 
Forest land 

Cropland 

Grassland 

Forest land 
remaining 
Forest land 
Cropland to 
Forest land 

Grassland to 
Forest land 

Cropland 
remaining 
Cropland 
Grassland to 
Cropland 

Wetlands 

Wetlands to 
Forest land 

Wetlands to 
Cropland 

Settlements 

Other land 

Settlements 
to Forest 
land 
Other land to 
Forest land 

Settlements 
to Cropland 

Settlements 
to Grassland 

Other land to 
Cropland 

Other land to 
Grassland 

Other land to 
Wetlands 

Grassland 
remaining 
Grassland 
Wetlands to 
Grassland 

Grassland to 
Wetlands 

Grassland to 
Settlements 

Grassland to 
Other land 

Wetlands 
remaining 
Wetlands 
Settlements 
to Wetlands 

Wetlands to 
Settlements 

Wetlands to 
Other land 

Settlements 
remaining 
Settlements 
Other land to 
Settlements 

Settlements 
to Other land 

Other land 
remaining 
Other land 

Converted land is reported for 20 years under the sub-category 'land converted to'. This 20 years 

transition period of land use change is the default transition time representing the time required for 

stabilization of changes in soil carbon stocks in. Where needed and supported by data, country specific 

transition periods may be applied (IPCC 2006b). After this transitional period, these units of land and 

associated greenhouse gas emissions and removals will be included in the "land remaining land" 

category. For example, when converting from cropland to forest, the associated greenhouse gas 

emissions and removals are first reported 20 years under “cropland converted to forest land” and after 

those 20 years under “forest land remaining forest land”.  

3 A different main structure is used for wetlands. Here in the default structure the “remaining” and “converted to” categories 
are first subdivided into: peat extraction, flooded land and other wetlands. Under the converted to categories, again 
subdivisions in the different land-use categories converted to the three wetland categories can be identified, but by default the 
CRF table asks for the total of all categories. See section 3.7.1 for more details. 
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Carbon stock changes and emissions and removals 

These activity data must then be combined with emission factors to determine the greenhouse gas 

emissions and removals. The basis for the emission factors for the different land use categories are 

empirical or modelled changes in carbon stocks for the following carbon pools: 

 

 

 

living biomass (above ground and below ground) 

dead organic matter (for forest, further divided in litter and dead wood), 

soil organic carbon (mineral and organic soils listed separately). 

For these carbon pools, all changes in carbon stocks are converted to net CO2 equivalent emissions (as 

carbon stocks decrease) and removals (as carbon stocks increase), by multiplying the changes in carbon 

stocks by -44/12. In tables and graphs where emissions are presented, the CO2 removals usually are 

reported as negative emissions. 

Additionally the category “4.G Harvested Wood Products” (HWP) needs to be reported. This contains the 

carbon stocks and its changes in harvested wood and the products made of it. After wood harvesting the 

carbon in the harvested wood is subtracted from the carbon stocks in biomass in Forest land (i.e. a 

carbon stock loss) and added to the carbon stock in the HWP pool. Subsequently, using a first order 

decay function this carbon then is considered to be gradually released again as CO2 emissions. The half-

life used to assess this decay depends on the on the expected life time of the wood products (paper, 

wood based panels or solid wood products), whereas the use as bioenergy results in instantaneous 

oxidation. Under the accounting rules of the LULUCF regulation it is considered as a carbon pool in the 

land accounting categories afforested land and managed forest land (see section 1.1.3 below). 

Non CO2 emissions 
Additionally the LULUCF sector also includes CO2 emissions and removals and N2O and CH4 emissions 
from other sources related the use of land. Likewise there are activity data (areas, amounts of N-inputs 
from fertilizers or amount of biomass burned) and emission factors for:  

 

 

direct N2O emissions from nitrogen (fertilizer) inputs in managed soils under forest land, wetlands 

and settlements (CRF Table 4(I)),  

emissions of CO2, CH4 and N2O and removals of CO2 resulting from drainage and rewetting and 

other management of organic and mineral soils (CRF Table 4(II)), 

  N2O emissions associated with loss of soil organic matter resulting from change of land use or 

management of mineral soils (CRF Table 4(III)), 

 

Indirect emissions of N2O from managed soils resulting from atmospheric nitrogen deposition or 

nitrogen leaching and run-off that is associated with synthetic and organic N fertilizer from land-

uses other than cropland and grassland (CRF Table 4(IV)), 

  CO2, CH4 and N2O emissions resulting from biomass burning (controlled burning or wildfires, CRF 

table 4(V)). 

1.1.2  Accounting climate mitigation performance 

Accounting systems aim at measuring the climate mitigation performance set out by climate mitigation 

policies. Where for the other sectors the reported emissions of a country are compared with the 

emissions in a base year, usually 1990, for accounting its climate mitigation commitments, for the 

LULUCF sector a distinction is made between the annual reporting to the UNFCCC and how the climate 

performance subsequently is accounted in different frameworks. Specific accounting rules determine 

whether and how each part of the emissions and removals of CO2 are accounted against the agreed 
climate commitments under the Kyoto Protocol (currently after the Doha amendment in its 2nd 
commitment period 2013-2020). This accounting system focusses on activities, which encompass a 

reduced scope compared to the land-use based reporting under the UNFCCC. Mandatory activities are 

afforestation/reforestation, deforestation and forest management and eligible activities include cropland 

management, grazing land management, revegetation and wetland drainage and rewetting. The 

Rulebook to the Paris Agreement (starting 2021) foresees specific provisions for voluntary accounting 

regarding natural disturbances, harvested wood products and age-class legacy effects. Several parties to 

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the UNFCCC, including the EU have set out different LULUCF-specific accounting systems for their 

domestic scope (Fyson and Jeffery 2019). 

The LULUCF accounting system under the Kyoto Protocol focusses on activities afforestation, 

deforestation and forest management that are included mandatory and cropland management, grazing 

land management and wetland management which inclusion is voluntary. In this system there is only an 

indirect link to the emissions and removals reported under the UNFCCC categories. The accounting rules 

to be used by EU member states during this latter period are covered by the EU LULUCF Regulation 

(2018/841). Given the scope of this report here the focus will be on the rules under the EU LULUCF 

Regulation.  

1.1.3  EU LULUCF Regulation 2018/841 

The accounting rules of the EU LULUCF Regulation that apply between 2021 and 2030 make direct use of 

the emissions and removals reported under the UNFCCC. To this end, the land use categories and 

transitions between them are directly translated into a set of “land accounting categories” (Article 2 of 

the LULUCF Regulation) (Table 1.3). These are: 

1)  Afforested land, includes cropland, grassland, wetlands, settlements or other land converted to 

forest land. 

2)  Deforested land, includes forest land converted to cropland, grassland, wetlands, settlements 

or other land. 

3)  Managed cropland, includes; 

a.  cropland remaining cropland; 

b.  grassland, wetlands, settlements or other land converted to cropland, or 

c.  cropland converted to wetlands, settlements or other land. 

4)  Managed grassland, includes; 

a.  grassland remaining grassland; 

b.  cropland, wetlands, settlements or other land converted to grassland, or 

c.  grassland converted to wetlands, settlements or other land. 

5)  Managed forest land, includes forest land remaining forest land. 

6)  Managed wetlands, includes;  

a.  wetlands remaining wetlands; 

b.  settlements or other land converted to wetlands, or 

c.  wetlands converted to settlements or other land.  

In the first compliance period 2021-2025 all land accounting categories, except managed wetlands, must 

be included in the accounting. Managed wetlands may be included in that period on a voluntary basis. In 

the second compliance period 2026-2030, all accounting categories, including managed wetlands, must 

be included. However, Article 2(4) of the LULUCF Regulation indicates that the Commission may make a 

proposal to make accounting for managed wetland not mandatory during the second compliance report if  

this is considered necessary based on experience gained with the application of the IPCC Refinement to 

the IPCC Guidelines. From the text it is not clear, however, which IPCC refinement is meant. Recital 13 of 

the LULUCF Regulation mentions that in the context of wetlands, the IPCC refinements to the 2006 IPCC 

guidelines related to wetlands should be taken into account. Most likely this meant to refer to the 2013 

IPCC wetland supplement to the 2006 IPCC guidelines (IPCC 2014b). 

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Table 1.3. Matrix Distribution of the UNFCCC land use categories according to the accounting categories 

in the EU LULUCF Regulation. 

The LULUCF Regulation prescribes following accounting rules for the six land accounting categories:  

 

Afforested land and deforested land: the net emissions or removals from the five years during 

the compliance periods from 2021 to 2025 or from 2026 to 2030 must be taken together to 

assess net accounted emissions or removals for that compliance period (Article 6). 

  Managed cropland, managed grassland and managed wetlands: The net emissions or removals 

during the compliance periods from 2021 to 2025 or from 2026 to 2030 are accounted against 

the net emissions or removals for the same category during a base period from 2005 to 2009. 

The difference determines the amount of net accounted emissions or removals (Article 7). 

  Managed forest land: The net emissions or removals, including harvested wood products from 

managed forest lands, are accounted against a forest reference level (FRL), for each of the 

periods 2021-2025 and 2026-2030 (Article 8). This FRL provides an estimate of greenhouse gas 

emissions and removals taking into account the age-dependent development of existing forest 

under the assumption that forest management practices from the reference period 2000-2009 

had continued.  

1.2 

This study 

This study under the specific Contract № 340201/2020/826663/ETU/CLIMA.C.3 “Study on the 

requirements for compliance with the regulation on Land Use, Land Use Change and Forestry (LULUCF) 

and associated regulations”, implementing Framework Contract no. CLIMA.001/FRA/2019/0011, has 

been carried out by a consortium consisting of Wageningen Environmental Research (WENR) and 

Ricardo.  

The objectives of this study were to: 

 

Identify the compliance needs and mechanisms resulting from the LULUCF Regulation and 

associated regulations and delegated and implementing acts. 

  Describe and detail the critical-path elements in the compliance of regulation 2018/841. 

 

Identify, time and task the activities that are required for the preparation (including capacity 

building and follow-ups) of the compliance reporting and checking. 

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To:From:Forest land (FL)FL-FLFL-CLFL-GLFL-WLFL-SFL-OLCropland (CL)CL-FLCL-CLCL-GLCL-WLCL-SCL-OLGrassland (GL)GL-FLGL-CLGL-GLGL-WLGL-SGL-OLWetland (WL)WL-FLWL-CLWL-GLWL-WLWL-SWL-OLSettlements (S)S-FLS-CLS-GLS-WLS-SS-OLOther land (OL)OL-FLOL-CLOL-GLOL-WLOL-SOL-OLManaged Forest LandAfforested landDeforested landManaged CroplandManaged GrasslandManaged WetlandOthers, not accountedForest land (FL)Cropland (CL)Grassland (GL)Wetland (WL)Settlements (S)Other land (OL) 
 
 
 
 
 
 
 
 
 
 
For this, recitals, articles and annexes of the LULUCF Regulation (EU 2018/841), Effort Sharing 

Regulation (EU 2018/842) and the Regulation on the Governance of the Energy Union and Climate Action 

(EU 2018/1999), including its delegated (EU 1044/2020) and implementing acts were (EU 2020/1208) 

were assessed, analysed and documented. 

To do this the study completed the following tasks, which are reported in the subsequent chapters in this 

report: 

Task 1: Mapping and critical path of compliance requirements, subdivided in three specific subtasks: 

A)  Mapping of compliance elements. 
B)  Analysing and linking of compliance elements, identification of activities to be undertaken. 
C)  Sequencing of compliance elements and activities, and a critical path analysis. 

The results of this task are described in Chapter 2. 

Task 2: Description of the content that is expected for each compliance element and by each activity. 

The results of this task are described in Chapter 3. 

Task 3: Basis for assessment providing description of data sources that can be used for assessing and 

verifying the content delivered compliance elements 

The results of this task are described in Chapter 4. 

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2 

Compliance elements (Task 1) 

2.1 

Methods 

In performing this task, the LULUCF Regulation, the Governance Regulation (GR) and the Effort Sharing 

Regulation (ESR) were thoroughly “mapped” in order to reveal all provisions relevant for the compliance 

with the LULUCF Regulation obligations. This mapping analysis included the recitals, the body of the texts 

and Annexes. Secondary legislation relevant for implementation was also scrutinised and included in the 

study. Such legislation is the Delegated act adopted under Article 26(6) of the GR, the draft 

Implementing Act under the Governance Regulation, the draft Delegated act on Registry Regulation. 

The objectives of this task were to: 

 

 

Identify the compliance needs and mechanisms resulting from the LULUCF regulation and 

associated regulations and delegated and implementing acts. 

Identify the sequence and timing of the compliance elements and activities that are required for 

the compliance reporting and checking. 

  Describe and detail the critical-paths elements in the compliance of the LULUCF Regulation. 

The information was organised in several ways in order to give a clear picture of the steps and processes 

needed for assessing compliance starting with the reporting of the GHG inventory information and ending 

with the compliance calculation by the Registry. A thorough analysis of the annual initial checks of the 

GHG inventory and of the review of inventories at the end of each compliance period was included. 

In this chapter, the results of mapping, analysing and linking the different compliance elements is 

provided in Sections 2.2 to 2.6. The compliance elements have been identified and classified into five 

categories: 

1)  Reporting provisions: elements related to reporting (section 2.2) 

2)  Accounting (section 2.3) 

3)  Review and assessment of progress (section 2.4) 

4)  Compliance with the LULUCF Regulation and the use of flexibilities (section 2.5) 

Section 2.6 provides summary information related to the accounting of the different land accounting 

categories. 

As part of Task 1C on sequencing elements in section 2.72.6, timelines have been identified, providing a 

detailed sequencing of elements and activities from reporting to compliance checks. 

2.2 

Reporting provisions - overview 

This section maps and links the provisions related to reporting. Table 2.1 provides an overview of the 

provisions related to various relevant reporting requirements. More information with a time line and the 

sequencing of elements and activities is provided in section 2.7. 

Article 18, and the relevant recitals 27, 31, 32 and 33 of the LULUCF Regulation, amend Regulation 

525/2013 in order to include reporting and accounting of GHG emissions and removals of the LULUCF 

sector. It also refers to reporting on policies and measures and projections on LULUCF. 

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Table 2.1. Overview of reporting provisions with reference to their legal act, article or recital, date and 

accounting categories to which they relate. (MS refers to date applicable for Member States, COM relates 

to the dates applicable to the Commission) 

Description of reporting 

Legal Act 

Article 

Recital 

Date 

Accounting 
category1 

Governance 
Regulation 

26(2) 

31 July (MS), 30 September 
(COM) Annually, starting 2021 

All 

requirement 

Reporting of approximated 
GHG inventories, annually for 
year x-1  

Reporting on GHG inventories, 
annually for year x-2 

Governance 
Regulation 

26(3), 
Annex V 

LULUCF 
Regulation 

18 

27, 30 -33 

15 Jan - preliminary data (MS) 
15 March - final data (MS) 
15 April - reporting to UNFCCC 
(MS and COM) 
Annually, starting 2023  

All 

Reporting on Policies and 
Measures (PAMS), biennially 

Governance 
Regulation 

18 and 
Annex VI 

15 March every second year, 
starting 2021 (MS) 

All 

LULUCF 
Regulation 

18 

Reporting on projections 
biennially 

Governance 
Regulation 

18 and 
Annex VII 

LULUCF 
Regulation  

18 

Reporting on accounted 
emissions and removals for the 
period 2021 to 2025 and 2025 
to 2030 

Governance  
Regulation 

26(5) 

LULUCF 
Regulation 

Article 14(1) 

Reporting on summary 
information on concluded 
transfers 

Governance 
Regulation 

26(3) and 
Annex V(f) 

LULUCF 
Regulation 

12 and 13 
(reporting 
Article 14) 

15 March in the years in 
between any substantial 
changes need to be reported 
(MS) 

15 March every second year 
(MS) 
(starting 2021 GR, starting 
2023 LULUCF Regulation) 

15 March in the years in 
between any substantial 
changes need to be reported 
(MS) 
15 Jan 2027- preliminary data 
(MS) 
15 March 2027- final data (MS)  
(15 Jan 2032- preliminary data 
15 March 2032- final data for 
the 2nd compliance period) 

All 

All 

15 Jan - preliminary data (MS) 
15 March - final data (MS) 
Annually starting 2023, in 
relation to LULUCF only relevant 
in 2027 and 2032 

All 

1) This column provides the accounting categories as defined in the LULUCF Regulation to which the provision is applicable. 

Regulation 525/2013 was repealed by the Governance Regulation with effect from 2021 . However, by 
way of derogation, Article 7 of regulation 525/2013 dealing with the GHG inventories shall continue to 

apply. This ensures that until 2022 the reporting process as currently applies stays in place and that also 

the reporting obligations under LULUCF decision 529/2013 remain active until 2022 (when the GHG 

emissions until 2020 are reported). 

All the relevant elements from articles relevant for the LULUCF Reporting mentioned in Article 18 have 
been included in the Governance Regulation Articles 18 and 26(2), (3) and (5) and Annex V. 

Article 14(1) of the LULUCF Regulation, requiring Member States to submit compliance reports containing 

the accounted emissions and removals prepared according to the rules in the LULUCF Regulation, is 

referenced in Article 26(5) of the GR. The GR requires Member States to report accounted emissions and 

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removals prepared according to the LULUCF Regulation. Both Regulations require Member States to 

report accounted data two years after the end of each of the compliance periods 2021-2025 and 2026-

2030, i.e. respectively in 2027 and 2032. The two-year delay after the end of the compliance period is 

due to the delay in the availability of GHG inventory data which is reported for the year x-2, where x is 

the year of the report. 

Inclusion of this requirement in the GR also has two key benefits: 

 

The GR attaches to the provision an implementing act which enables the Commission to lay 

down details for the compliance reports. Implementing tables for reporting are included in the IA 

under the GR. 

 

The requirement gathers all the information on compliance with the LULUCF Regulation 

(reporting on GHG emissions and removals, reporting on the use of flexibilities and the 

accounting) in the same report. 

The reporting elements identified in Table 2.1 are further described in more detail in the subsections 

below. 

2.2.1  Reporting of approximated GHG inventories (Article 26(2) of the GR) 

Reporting date: 

According Article 26(2) of the GR, Member States need to report approximated GHG inventories by 31 

July for the year x-1, starting in 2021. 

Reporting methodology: 

The sectoral scope of the approximated inventory represents a top-level summary of the more detailed 

sectoral scope of the total greenhouse gas inventory. This ensures that the emission and removal 

estimates reported in the approximated inventory for the year x-1 are consistent with the final 

greenhouse gas inventory estimates reported for the year x-2 in the subsequent year. The LULUCF sector 

is an integral part of the annual inventory, and Member States have to include estimates of emissions 

and removals from LULUCF in their approximated greenhouse gas inventory. The same methodologies to 

be used for the GHG inventories are to be used for the approximated inventory. 

Reporting format: 

The level of disaggregation is the one provided in Annex VI to the IA of the GR, which is the same as 

Summary Table 2 of the CRF. For LULUCF this implies that this only provides emissions and removals at 

the level of the main UNFCCC land-use categories (i.e. forest land, cropland, grassland, etc.). The total 

national emissions that are reported exclude the approximated LULUCF totals. The first proxy inventory 
relevant for the compliance with the LULUCF Regulation will be reported in 2022 for the year 2021.   
However, due to the high level of aggregation of the reported data, based on these approximated data it 

will not be possible to make the linkages to land accounting categories. As a result it will be difficult to 

use these data for a first indication about Member State’s accounting values and compliance with the 

LULUCF Regulation. 

2.2.2  Reporting of GHG Inventories (Article 26(3) of the GR and Article 18 of the LULUCF Regulation) 

Because of all the interactions and links between Member States and Commission in the process of 

reporting annual GHG inventories a detailed GANTT chart with timing of activities and links between 

these activities is provided in section 2.7.2. 

Reporting date: 
The first year of full reporting under the GR is 2023 for the year 2021 (x-2). The inventory years up to 
2020 are covered by reporting under Regulation 525/2013, according to Article 58 of the GR. 

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 

The LULUCF compliance cycle starts 15 January every year with the reporting by Member States 

of their preliminary GHG inventory data for the year x-2 (GR Article 26(3)). 

  Member States are required to report final GHG inventory data for the year x-2 by 15 March (GR 

Article 26 (3)). 

  Member States and the EU report GHG inventories to the UNFCCC by 15 April (GR Article 26 

(4)). 

Reporting methodology: 

According to the delegated act under Article 26(6) of the GR, point b, Member States “shall” determine 

greenhouse gas inventories using the 2006 IPCC Reporting Guidelines (on the basis of Article 3(a) of the 

delegated act). Additionally according Article 3(b) of the DA to the GR indicates that the GHG inventories 

should be in accordance with the modalities, procedures and guidelines for the transparency framework 

for action and support referred to in Article 13 of the Paris Agreement and set out in the Annex to 

UNFCCC Decision 18/CMA.1. This decision indicates that each party is encouraged to use the 2013 

wetland supplement to the 2006 IPCC guidelines (IPCC 2014b).  The GWPs used are the ones for a 100 

year period from the IPCC AR5. 

According to the Annex V part 3 to the GR Regulation, relating specifically to LULUCF, Member States are 

obliged to use at least Tier 1 methodologies according to 2006 IPCC Guidelines. However, if a carbon 

pool represents more than 25%-30% from a source/sink which is identified as a key category in the 

Member State’s national inventory, Tier 2 methodologies must be used for the estimation of the GHG 

emissions or removals in that pool. Use of Tier 3 methodologies in accordance with the IPCC 2006 

guidelines is encouraged. This annex requires enhanced accuracy of reporting net emissions, in the sense 

that significant emissions and removals from carbon pools in a key category must be estimated with 

higher Tier (2 or 3) methods.  

Member States may ask for a derogation from Annex V, part 3 of the GR as per the following procedure: 

 

The Member State is to make a reasoned request by 31 December 2020 

  Basis for the request: a) the improvement of methodologies to meet the criteria cannot be 

achieved in time to be taken into account for the 2021-2030 period or b) the cost is 

disproportionate compared to the low significance of the emissions and removals from the 

carbon pool concerned 

 

The Commission can ask for further information 

  Decision of the Commission (in reasonable time) including reasons for refusal (if applicable). 

The timeline assumed in this study for granting the derogation provided for in Annex V, part 3 of the GR 

is: 

  Member State Request - by 31 December 2020 (as provided in legislation) 

  Commission assessment - (9 months) by 30 September 2021 

  Commission request for additional information – 30 September 2021 

  Member State answers - (one month) by 31 October 2021 

  Decision of the Commission by 31 December 2021. 

The assumed timeline takes into account that there is sufficient time from 31 December 2020 to 15 

January 2023 (the submission deadline of the 2021 preliminary GHG inventory) when this technical 

provision first applies. It also considers the major deadlines for the reporting of inventories and avoids 

overloading a system which is already busy with the inventory submission in the year 2021. By 31 June, 

Member States are supposed to have finished also a possible resubmission of inventories to the UNFCCC. 

Reporting format: 

Member States use the Common Reporting Format (CRF) tables to report their GHG inventories. In 

practice, all reporting templates are included in an online platform (CRF Reporter). This tool is provided 
and maintained by the UNFCCC Secretariat, but will also be used to submit the data to the Commission.  

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The Common Reporting Tables (CRT) to be used under the Paris Agreement have not yet been agreed 

on. Once there is an agreement at UNFCCC level, they need to be made binding under EU law through 
the implementing act under Article 26(7) of the GR. 

Initial Checks: 

The Commission performs initial checks on the GHG emission data, as part of the compilation of the EU 

GHG inventory (see GANTT chart in section 2.7.2). According to Annex XXI of the IA of the GR, the 
Commission assisted by the EEA circulates the finding of “initial checks”  including a notification of 
possible gap filling. This is done by 28 February. Member States can comment on these findings until 15 

March. By 31 March the Commission assisted by the EEA prepares estimates for any data missing from a 

Member State’s inventory and circulates them to the Member States involved. Member States are 

allowed to comment on the proposed estimates until 7 April. The whole process ends on 15 April with the 
reporting of the EU and Member States GHG inventories to the UNFCCC (also see section 2.7.2). 

In practice, this process is led by the EEA and its European Topic Entre on Climate, Mitigation and Energy 

(ETC/CME). According to Article 6 of the DA under the GR, the following checks are performed during this 

time: 

1)  an assessment whether all categories required under the modalities, procedures and guidelines 

for the transparency framework for action and support referred to in Article 13 of the Paris 

Agreement set out in the Annex to Decision 18/CMA.1 and all greenhouse gases referred to in 

Annex V of Regulation (EU) 2018/1999 are reported by the Member State; 

2)  an assessment checking if time series of emissions by sources and removals by sinks are 

consistent; 

3)  an assessment whether implied emission factors across Member States are comparable taking 

into account the IPCC default emission factors for different national circumstances; 

4)  an assessment of the use of ‘Not Estimated’ notation keys where IPCC Tier 1 methodologies 

exist and where the use of the notation key is not justified in accordance with point 32 of the 

Annex to Decision 18/CMA.1; 

5)  an analysis of recalculations performed for the greenhouse gas inventory submission, including 

whether the recalculations are based on methodological changes; 

6)  a comparison of the verified greenhouse gas emissions reported under the European Union's 

emission trading system with the greenhouse gas emissions reported pursuant to Article 26(3) of 

Regulation (EU) 2018/1999; 

7)  a comparison of the results of Eurostat's reference approach with the Member States' reference 

approach; 

8)  a comparison of the results of Eurostat's sectoral approach with the Member States' sectoral 

approach; 

9)  an assessment whether issues from earlier Union initial checks and reviews as well as 

recommendations from UNFCCC reviews have been implemented by the Member State; 

10)  an assessment of the accuracy of Member States’ emissions by sources and removals by sinks 

estimates in relation to Union key categories; 

11)  an assessment of the transparency and completeness of the methodological descriptions 

reported by Member States for the Union key categories; 

12)  an assessment of monitoring and reporting of emissions by sources and removals by sinks in the 

land use, land use change and forestry (LULUCF) sector pursuant to Part 3 of Annex V to 

Regulation (EU) 2018/1999, including the assignment of key categories, Tier methodology 

applied, and a comparison of reported land use and land use change activity data with 

information derived from the Union and Member State programmes and surveys. 

In case Member States do not report GHG inventories in time or where major issues remain unsolved, 

the Commission can start an infringement procedure. This is usually preceded by informal talks with the 

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Member States in order to understand better the issue at hand and the appropriateness of starting an 

infringement against that Member States. 

2.2.3  Reporting on policies and measures for LULUCF (Article 18 and Annex VI of the GR and Article 18 

of the LULUCF Regulation) 

Reporting date: 

Member States report on LULUCF Policies and Measures (PAMs) by 15 March every second year starting 

2021. 

In the years in-between, Member States may submit updates to their PAMs report. 

Reporting methodology: 

The information to be included in the reports on policies and measures in the area of GHG emissions is 

provided in Annex VI of the GR. 

Reporting format: 

Tables which Member States shall use for reporting are included in Annex XXIV to article 37 of the IA of 

GR. 

2.2.4  Reporting on projections for LULUCF (Article 18 and Annex VII of the GR and Article 18 of the 

LULUCF Regulation) 

Reporting date: 

Member States report on LULUCF projections by 15 March every second year starting 2021. 

In the years in-between, Member States may submit updates to their projections report. 

Reporting methodology: 

Member States use their own methodologies but they need to report the parameters used and the 

sensitivity analysis performed. 

Reporting format: 

Tables which Member States shall use for reporting are included in Annex XXV to article 38 of the IA of 

GR for reporting on GHG emissions projections (table 1a and 1b) and reporting on accounted emissions 

(Tables 5a and 5b). 

2.2.5  Reporting on preliminary accounted emissions and removals (Article 26(5) of the GR) 

Reporting date: 

Member States report by 15 January 2027 and by 15 January 2032 preliminary GHG inventory data with 

accounting information relevant for their compliance with the LULUCF Regulation. 

Methodology: 

Application of the accounting rules in LULUCF Regulation; see the section dedicated to discussing this, 

Section 2.3. 

Reporting format: 

Article 24 and Annex XX to the IA of the GR. 

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2.2.6  Reporting on final accounted emissions and removals (Article 26(5) of the GR and Article 14(1) 

of the LULUCF Regulation) 

Member states report by 15 March 2027 and by 15 March 2032 final GHG inventory data with accounting 

information relevant for their compliance with the LULUCF Regulation. 

Methodology: 

Application of the accounting rules as set out in the LULUCF Regulation. 

The wording of this article is explicit in that Member States are not required to report preliminary or final 

accounted data on a yearly basis. The article is also explicit in the requirement to report preliminary AND 

final accounted data at the end of each 5 years period. The Commission is obliged under Article 29(5) GR 

to report on progress towards meeting the targets with the LULUCF Regulation on a yearly basis. It 

follows that the Commission will need to obtain the data needed for this report (see section 2.4.1).  

Member States should be encouraged to already compile the data and fill in the formats provided in 

Annex XX of the IA to the GR. This will allow them to check if all information is actually available and 

leaves time to adjust calculation schemes if needed. This will help facilitate timely and accurate reporting 

when it comes to actual accounting with tight deadlines. 

2.2.7  Reporting on summary information on concluded transfers under Article 12 and 13 of the LULUCF 

Regulation (Article 26(3), Annex V, point (f) of the GR) 

Reporting date: 

15 January (preliminary data) and 15 March (final data) every year 

Reporting methodology: 

The summary information on concluded transfers should be included in the report on the preliminary (15 

January) and final (15 March) GHG inventory data to the Commission.  

Reporting format: 
Annex XVI to Article 20 of the IA of GR.  

2.3 

Accounting 

According to Article 14 of the LULUCF Regulation Member States need to submit a compliance report 

containing the balance of total emissions and removals for each of the accounting categories identified in 

Article 2 of the LULUCF Regulation and using the accounting rules laid down in the regulation. This 

compliance report needs to be submitted to the Commission by 15 March 2027 for the period 2021-2025 

and by 15 March 2032 for the period 2026-2030. 

Article 14(1) of the LULUCF Regulation and Article 26(5) of the GR require Member States to report to 

the Commission its final (15 March) national inventory data prepared for their LULUCF accounting as 

required for the compliance report under Article 14 of the LULUCF Regulation. Article 26(5) of the GR 

requires Member States to also report preliminary accounting information to the Commission by 15 

January. Subsequently Article 24 of the IA to the GR indicates that the accounted GHG emissions and 

removals need to be reported in accordance with the format set out in Annex XX to the GR IA. 

Table 2.2 gives the overview of the accounting provisions applicable to the different accounting 

categories specified in the LULUCF Regulation. 

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Table 2.2. Overview of accounting provisions with reference to their legal act, article or recital, date and 

accounting categories to which they relate 

Description of accounting 

Legal Act 

Article 

Recital  Date  

provision 

General accounting rules 

LULUCF Regulation 

5 

14 

NA 

Accounting 

category 

All 

Accounting for afforested land 
and deforested land 

LULUCF Regulation 

6, Annex I, II 

GR IA 

24, Annex XX 

15 January 
2027/2032-
preliminary data 

Afforested land 

Deforested land 

Accounting for managed 
cropland, managed grassland 
and managed wetland 

LULUCF Regulation 

7, Annex I 

13 

GR IA 

24, Annex XX 

15 January 
2027/2032-
preliminary data 

Managed cropland,  

Managed grassland  

15 March 2027/2032 
final data 

Accounting for managed forest 
land 

LULUCF Regulation 

8, Annex I, II, 
III and IV 

16,17,1
8,22,23 

GR IA 

24, Annex XX 

15 March 2027/2032 
final data 

Managed wetland 

Accounting for 
wetlands in 2027 - 
optional  

15 January 
2027/2032-
preliminary data 

Managed forest 
land 

15 March 2027/2032 
final data 

Accounting for harvested wood 
products under managed forest 
land and afforested land  

LULUCF Regulation 

19 

9, Annex I 
part B, Annex 
V 

15 January 
2027/2032-
preliminary data 

GR IA 

24, Annex XX 

Accounting for natural 
disturbances under managed 
forest land and afforested land 

LULUCF Regulation 

Article 10, 
Annex VI 

20 

GR IA 

Article 24, 
Annex XX 

15 March 2027/2032 
final data 

15 January 
2027/2032-
preliminary data 

15 March 2027/2032 
final data 

Managed forest 
land 

Afforested land 

Managed forest 
land 

Afforested land 

We provide more textual explanation on the accounting provisions in summaries of the relevant 

provisions applying to each of the land accounting categories in section 2.6. 

2.4 

Review and assessment of progress 

Table 2.3 provides an overview of the provisions relating to the review and assessment of progress. The 

review component is the review of GHG emissions inventories and accounted emissions and removals for 

the purposes of assessing compliance with the LULUCF Regulation; the progress component is the 

progress made by Member States and the EU with the implementation of their targets, including their 

commitments under Article 4 of the LULUCF Regulation. 

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Table 2.3. Overview of review and assessment provisions with reference to their legal act, article or 

recital, date and accounting categories to which they relate 

Description of review or 

Legal Act 

Article 

Recital 

Date 

Accounting category 

assessment provision 

Assessment of progress reported 
as part of the State of the Energy 
Union 

Governance 
Regulation  

Review of GHG emissions data 
and accounting emission data for 
the period 2021 to 2025 and 2026 
to 2030 

Governance 
Regulation  

GR IA 

29(5) and 
35 

38 

30-34, 
Annex XXII 

LULUCF Regulation 

14(2) 

LULUCF Regulation 

14(3) 

Report on total Union’s total 
emissions and total removals of 
greenhouse gases for each of the 
land accounting categories 

All 

All 

31 October, 
annually starting 
2021  

15 April – latest 7 
September (83 
days after 
centralised 
review) in 2027 
(for period 2021-
2025) or in 2032 
(for the period 
2026-2030) 

2027 and 2032, 
without dates 
specified 

All 

2.4.1  Assessment of progress (Articles 29(5) and 35 of the GR) 

Commission obligation: 

From 31 October 2021 onwards the Commission annually publishes the progress made by Member 

States and the EU with the implementation of their targets, including their commitments under Article 4 

of the LULUCF Regulation, as part of the State of the Energy Union Report (Article 29(5) of the GR). 

From the GR it is not clear what is the basis for this assessment. Since it is not possible to assess the 

accounting categories from the approximated inventory it is assumed that this is based on the final 

inventory data provided by Member States on 15 March of the same year.  

In order to do this, the Commission will need to compile the data according the format in Annex XX of 

the IA to the GR. Most of this required information can be extracted from the CRF tables of the GHG 

inventory submitted by the Member States. It will not be possible to take into consideration provisions 

regarding natural disturbances. The information required to do so is not included in the current CRF 

tables. This is specific information that Member States need to include in their compliance reports by 15 

January 2027 or 2032 (preliminary data) and 15 March 2027 or 2032 (final data) using the reporting 

format provided in Annex XX to the IA of the GR which asks for additional supporting information for 

natural disturbances to be provided as an annex to their National Inventory Report (NIR) in 2027 or 

2032.  

In the current UNFCCC reporting under harvested wood products (HWP) also wood from deforestation 

events or from other land-uses than forest land may be included. In contrast, under the LULUCF 

Regulation (Article 5(4), Annex I) only HWP in the land accounting categories afforested land and 

managed forest land are to be included in the accounting. Moreover, the CRF tables submitted by 

Member States do not contain information on the allocation of emissions and removals from HWP 

between afforested land and managed forest land. The CRF tables only give the total emissions per HWP 

category. In order to make sure that only emissions and removals from HWP from afforested land and 

managed forest land are included in the accounting, and in order to make the distinction between HWP 

from these two categories, Member States need to provide additional information in the NIR that 

accompanies their compliance report in 2027 or in 2032. The Commission could encourage Member 

States to provide this information already on a regular basis in their NIRs submitted in earlier years.  

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2.4.2  Review (Article 38 of the GR and Article 14(2) of the LULUCF Regulation) 

This Article sets the legal basis for the review of GHG emissions inventories and accounted emissions and 

removals for the purposes of assessing compliance with the LULUCF Regulation (and ESR). 

Date of the review: 

The GR sets two reviews at the end of each compliance period, one for the period 2021-2025 in 2027 

and one for the period 2026-2030 in 2032. A detailed time schedule is provided in Annex XXII of the IA 

of the GR covering the period from 15 April to latest 7 September in the year the review takes place. 

Actors involved: 

The review is the task of the Commission assisted by a team of technical experts. The IA of the GR 

(Article 30 and Annex XXII) lays down additional rules for recruiting of the team of technical experts to 

support the Commission in this task and sets the European Environment Agency as the secretariat of the 

review. As part of its secretarial tasks, the EEA coordinates the communication with the Member States 

including the circulation of the final review reports. 

Technical corrections: 

Article 31 of the IA of the GR sets the rule that a technical correction can be proposed by the team of 

technical experts only if the threshold of significance is met. Article 31 sets the threshold of significance 

for a given source or sink to 0.05 % of a Member State's total national greenhouse gas emissions 

without LULUCF for the year of the inventory under review, or 500 kt CO2 equivalent, whichever is 

smaller. 

With this current text there may be a discussion whether this also applies to technical corrections 

identified for LULUCF. Even if the Article refers to sources and sinks, as long as it refers to the totals 

without LULUCF it could be interpreted to apply only to the ESR without imposing any threshold of 

significance for categories in the LULUCF sector. On the other hand it does not necessarily follow that 

estimating a value based on a percentage on totals without LULUCF excludes it from also being 

applicable to LULUCF. This will need further discussion and clarification. 

Commission decision: 

The Commission is entitled to adopt an implementing act in order to set the total GHG emissions and 

removals relevant for compliance. With this decision the Commission gives legal standing to the findings 

of the review and makes the technical corrections binding on Member States. There will be two decisions 

of the Commission for each compliance period. According to the timeline, such decision will be adopted 

by 7th of October 2027 and by 7th of October 2032. 

2.4.3  Report on total Union’s total emissions and total removals of greenhouse gases for each of the 

land accounting categories (Article 14(3) LULUCF Regulation) 

This is a Commission obligation. 

Reporting date: 2027 and 2032, but without a date specified. 

Content: 

The total EU emissions and removals for each land accounting category. 

Methodology: 

The total reported emissions and total reported removals for the period minus the value obtained by 

multiplying by five the Union’s average annual reported emissions and removals in the period from 2000 

to 2009. It should be noted that this methodology applies a general formula to all accounting categories, 

while the accounting rules that Member States need to apply differ between the accounting categories. It 

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introduces the calculation of emissions and removals in a way that is not considered in other places of 

the LULCUF regulation.  

This article was added to the LULUCF Regulation at the request by a number of Member States. This 

calculated amount provides for each of the land accounting categories insight in how in the EU the total 

net emissions from the LULUCF sector have changed compared to the period 2000 to 2009. Such insight 

cannot be gained by summing the accounted emissions and removals.  

Reporting format 

Reports are usually adopted by the Commission as Staff working documents. In order to avoid 

administrative burden, this value of the total emissions and total removals of greenhouse gases for each 

of the land accounting categories alternatively could be included in: 

1. 

2. 

the IA on the reviewed emissions relevant for compliance adopted under Article 38 of the GR 

the State of the Energy Union Report. 

Choosing one of these two alternatives depends also on the broader significance the Commission gives to 

this paragraph. 

2.5 

Compliance check 

According to Article 38(5) of the GR, the compliance check is done 4 months after the adoption of the 

implementing act setting the GHG emissions and removals relevant for compliance after the 

comprehensive review. This is the date where the compliance of Member States is checked and when 

they need to comply with their obligation under article 4 of the LULUCF Regulation. This period of 4 

months is important for the use of flexibilities but Member States do not need to wait for the adoption of 

the IA by the Commission to trade. This means that the implementation in the Registry Regulation 

should ideally allow a functionality for Member States to make transactions during the compliance period. 

Even if the Registry allows transactions strictly during the 4 month period (which is what the proposed 

DA on Registry Regulation seems to imply), Member States can still enter into contracts with each other 

to sell expected credits. As Member States will know exactly their numbers only at the end of the period, 

it is not clear how much use will be made of a possibility to trade before this period. However, Article 26 

of the GR requires Member States to report annually on such transfers. 

Table 2.4 shows an overview of compliance check provisions. 

Table 2.4. Overview of compliance check provisions (see Sections 2.7.2 and 2.7.3 for the specific timing 

and sequence of the compliance check) 

Description of provision  Legal Act 

Article 

Recital  Date 

Compliance check 

LULUCF Regulation  

14 

Compliance check 

GR 

ESR 
GR 

38(5) 

9(2) 
38(6) 

No dates specified, given time 
periods indicated from the 
review this will be latest 7 
February 2028 (COM), and 7 
February 2033 (COM) 
No dates specified, given time 
periods indicated from the 
review this will be latest 7 
February 2028 (COM), and 7 
February 2033 (COM) 

Accounting 

category 

All 

All 

2.5.1 

Flexibilities 

Table 2.5 shows an overview of flexibility provisions. 

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Table 2.5. Overview of flexibility provisions 

Description of flexibility 

Legal Act 

Article 

Recital 

Date 

Accounting category 

Flexibilities 

LULUCF Regulation  

11 

General flexibilities 

LULUCF Regulation 

12 

21 

21 

NA 

NA 

All 

All 

Managed forest land flexibility 

LULUCF Regulation 

13 and Annex 
VII 

24,25,26,27   

Managed forest land 

Additional use of up to 280 
million tonnes CO2 eq. net 
removals from LULUCF, with a 
maximum amount specified per 
Member State 

ESR 

7, Annex III 

22, 23 

NA 

Afforested land  

Deforested land, 

Managed cropland,  

Managed grassland  

Managed forest land  

Managed wetland where 
made mandatory under 
Regulation (EU) 
2018/841 

2.6 

Summary information related to the accounting of the different land accounting 

categories 

In the next paragraphs we provide a summary of the relevant provisions applying to each of the land 

accounting categories. The text includes information on 1) reporting date on emissions and removals; 2) 

date for the compliance report; 3) reporting format; 4) reporting rules; 5) accounting towards the no-

debit rule; 6) accounting period; 7) accounting rules; and 8) information on the use of flexibilities. 

According to Article 26(3) of the GR, Member States need to report their final greenhouse gas inventories 

by 15 March each year and preliminary data by 15 January each year. This refers to the information to 

be reported under the UNFCCC, using the structure as required by the UNFCCC national inventories. This 

will cover all the land uses and land use conversions and harvested wood products. This does not require 

Member States to also report on the aggregated accounting categories as specified under the LULUCF 

Regulation. Information on the aggregated accounting categories needs to be provided in the compliance 

reports by 15 January (preliminary) and by 15 March (final) in the years 2027 and 2032 (Article 26(5)) 

of the GR. 

2.6.1  Accounting for Afforested Land (Article 6 LULUCF Regulation) 

1)  Reporting date on emissions and removals for underlying land use categories: 15 January 

(preliminary data) and 15 March (final data) for year X-2 (Article 26 GR), every year as part of its 

national inventory reporting. 

2)  Compliance report: 15 January (preliminary data) and 15 March (final data) of 2027 and of 2032.  

3)  Reporting format: Common reporting format (CRF) included in Article 8 of the implementing act 

under Article 26 of the GR. The CRFs  applicable for the Paris Agreement are still being negotiated at 

international level. Once they are agreed upon, the Commission will need to propose their inclusion 

in the EU law by means of an implementing act under the GR. 

4)  Reporting rules: 2006 IPCC Guidelines and 100 GWP. Tier 2 if carbon pool amounts to more than 

25%-30% emissions or removals in a source or sink key category. Tier 3 is encouraged. 

Geographically explicit information. 

5)  Accounting towards the no debit rule: obligatory for all 

6)  Accounting period: 2021 to 2025 and 2026 to 2030 

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7)  Accounting rules: 1) MS must ensure that the data provided is accurate, complete, consistent, 

comparable and transparent (TACCC principles); 2) avoid double counting; 3) As a rule, a MS must 

wait for 20 years before the “category converted to forest land” can be changed to “forest land 

remaining forest land category ”. However, this period can be 30 years if duly justified based on 

IPCC Guidelines. It is a Member State’s decision to make use of this flexibility. The LULUCF 

Regulation does not set any procedure for making use of this derogation. The change in the 

transition period in the first place will need to be explained and approved in GHG reporting to the 

UNFCCC MS will have to duly explain their decision in the Compliance report and their decision will 

be scrutinised at the latest during the first review in 2027. The Commission could also use WG5 in 

order to find out if and which MS intend to use this derogation and based on which reasons in 

advance of 2027. The Commission could informally signal to the MS concerned if the change is likely 

to be accepted by the Commission. 4) When a carbon pool is a source MS must include the changes 

in carbon stocks of the following carbon pools: above ground biomass, below ground biomass, litter, 

dead wood, soil organic carbon, harvested wood. 5) archiving of the data used; 6) MS shall account 

for the total emissions and removals for each of the year of the periods 2021 to 2025 and 2026 to 

2030. 7) Annex II of the LULUCF Regulation fixes the values for area size, tree crown cover and tree 

height parameters of the forest definition.                   

8) Flexibilities: 

a.  banking of removals (possible)                                     

b. 

transfers of removals (possible) 

c.  use for compliance with the ESR (possible) 

2.6.2  Accounting for Deforested land (Article 6 LULUCF Regulation) 

1)  Reporting date on emissions and removals for underlying land use categories: 15 January 

(preliminary data) and 15 March (final data) for year X-2 (Article 26 GR), every year as part of its 

national inventory reporting. 

2)  Compliance report: 15 January (preliminary data) and 15 March (final data) of 2027 and of 2032.  

3)  Reporting format: Common reporting format (CRF) included in Article 8 of the implementing act 

under Article 26 of the GR. The CRFs  applicable for the Paris Agreement are still being negotiated at 

international level. Once they are agreed upon, the Commission will need to propose their inclusion 

in the EU law by means of an implementing act under the GR. 

4)  Reporting rules: 2006 IPCC Guidelines and 100 GWP. Tier 2 if carbon pool amounts to more than 

25%-30% emissions or removals in a source or sink key category. Tier 3 is encouraged. 

Geographically explicit information. 

5)  Accounting towards the no debit rule: obligatory for all 

6)  Accounting period: 2021 to 2025 and 2026 to 2030 

7)  Accounting rules: 1) MS must ensure that the data provided is accurate, complete, consistent, 

comparable and transparent (TACCC principles); 2) avoid double counting; 3) Member States must 

wait for 20 years before the “category forest land converted to x land” can be changed to “x land 

remaining x land”, where “x” may be cropland, grassland, wetlands, settlements or other land. Once 

the units of land are changed into the remaining category the land will move to the accounting 

category relevant for the new land-use; 4) When a carbon pool is a source, MS must include the 

changes in carbon stocks of the following carbon pools: above ground biomass, below ground 

biomass, litter, dead wood, soil organic carbon, harvested wood; 5) archiving of the data used; 6)MS 

shall account for the total emissions and removals for each of the year of the periods 2021 to 2025 

and 206 to 2030. 7) Annex II of the LULUCF Regulation fixes the values for area size, tree crown 

cover and tree height parameters of the forest definition.  

8) Flexibilities: 

a.  banking of removals (possible)                                     

b. 

transfers of removals (possible) 

c.  use for compliance with the ESR (possible) 

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2.6.3  Accounting for Managed Cropland (Article 7 LULUCF Regulation) 

1)  Reporting date on emissions and removals for underlying land use categories: 15 January 

(preliminary data) and 15 March (final data) for year X-2 (Article 26 GR), every year as part of its 

national inventory reporting. 

2)  Compliance report: 15 January (preliminary data) and 15 March (final data) of 2027 and of 2032.  

3)  Reporting format: Common reporting format (CRF) included in Article 8 of the implementing act 

under Article 26 of the GR. The GHG inventory reporting tables applicable for the Paris Agreement 

are still being negotiated at international level. Once they are agreed upon, the Commission will 

need to propose their inclusion in the EU law by means of an implementing act under the GR. 

4)  Reporting rules: 2006 IPCC Guidelines and 100 GWP. Tier 2 if carbon pool amounts to more than 

25%-30% emissions or removals in a source or sink key category. Tier 3 is encouraged. 

Geographically explicit information. 

5)  Accounting towards the no debit rule: obligatory for all 

6)  Accounting period: 2021 to 2025 and 2026 to 2030 

7)  Accounting rules: 1) Member States must ensure that the data provided is accurate, complete, 

consistent, comparable and transparent (TACCC principles); 2) avoid double counting; 3) Member 

States must wait for 20 years before the land category “land converted to cropland” can be changed 

to “cropland remaining cropland” category, or the cropland converted to wetlands, settlements or 

other land can be changed to their respective “remaining” land categories. 4) When that carbon pool 

is a source Member States must include the changes in carbon stocks of the following carbon pools: 

above ground biomass, below ground biomass, litter (as part of dead organic matter, DOM), dead 

wood (as part of DOM), soil organic carbon. 5) archiving of the data used;6)MS shall account for 

emissions and removals in the period 2021 to 2025 (respectively 2026 to 2030) minus 5 times the 

average emissions in the base period years 2005 to 2009                   

8)  Flexibilities: 

a.  banking of removals (possible) 

b. 

transfers of removals (possible) 

c.  use for compliance with the ESR (possible) 

2.6.4  Accounting for Managed Grassland (Article 7 LULUCF Regulation) 

1)  Reporting date on emissions and removals for underlying land use categories: 15 January 

(preliminary data) and 15 March (final data) for year X-2 (Article 26 GR), every year as part of its 

national inventory reporting. 

2)  Compliance report: 15 January (preliminary data) and 15 March (final data) of 2027 and of 2032.  

3)  Reporting format: Common reporting format (CRF) included in Article 8 of the implementing act 

under Article 26 of the GR. The GHG inventory reporting tables applicable for the Paris Agreement 

are still being negotiated at international level. Once they are agreed upon, the Commission will 

need to propose their inclusion in the EU law by means of an implementing act under the GR. 

4)  Reporting rules: 2006 IPCC Guidelines and 100 GWP. Tier 2 if carbon pool amounts to more than 

25%-30% emissions or removals in a source or sink key category. Tier 3 is encouraged. 

Geographically explicit information. 

5)  Accounting towards the no debit rule: obligatory for all 

6)  Accounting period: 2021 to 2025 and 2026 to 2030 

7)  Accounting rules: 1) Member States must ensure that the data provided is accurate, complete, 

consistent, comparable and transparent (TACCC principles); 2) avoid double counting; 3) Member 

States must wait for 20 years before the category “land converted to grassland” can be changed to 

“grassland remaining grassland” category, or the grassland converted to wetlands, settlements or 

other land can be changed to their respective “remaining” land categories. 4) When that carbon pool 

is a source Member States must include the changes in carbon stocks of the following carbon pools: 

above ground biomass, below ground biomass, litter (as part of DOM), dead wood (as part of DOM), 

soil organic carbon. 5) archiving of the data used; 6) MS shall account for emissions and removals in 

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the period 2021 to 2025 (respectively 2026 to 2030) minus 5 times the average emissions in the 

base period years 2005 to 2009                   

8)  Flexibilities: 

a.  banking of removals (possible) 

b. 

transfers of removals (possible) 

c.  use for compliance with the ESR (possible) 

2.6.5  Accounting for Managed Wetlands (Articles 7 and 2(2) to 2(4) LULUCF Regulation) 

1)  Reporting date on emissions and removals for underlying land use categories: 15 January 

(preliminary data) and 15 March (final data) for year X-2 (Article 26 GR), every year as part of its 

national inventory reporting. 

2)  Compliance report: 15 January (preliminary data) and 15 March (final data) of 2027 (only if 

voluntary included by notification to the Commission by 31 Dec 2020). 15 January (preliminary data) 

and 15 March (final data) of 2032 (for all MS). 

3)  Reporting format: Common reporting format (CRF) for emissions included in Article 8 of the 

implementing act under Article 26 of the GR. The GHG inventory reporting tables applicable for the 

Paris Agreement are still being negotiated at international level. Once they are agreed upon, the 

Commission will need to propose their inclusion in the EU law by means of an implementing act 

under the GR. Any details on the information regarding wetlands needed could be included in the 

implementing act under Article 26 of GR. 

4)  Reporting rules: 2006 IPCC Guidelines and the Supplement on Wetlands. Tier 2 if carbon pool 

amounts to more than 25%-30% emissions or removals in a source or sink key category. Tier 3 is 

encouraged. Geographically explicit information. 

5)  Accounting towards the no debit rule: First period voluntary inclusion. Second period obligatory 

for all  

6)  Accounting period: 2021-2025 (voluntary), 2026 to 2030 obligatory 

7)  Accounting rules: 1) Member States must ensure that the data provided is accurate, complete, 

consistent, comparable and transparent (TACCC principles); 2) avoid double counting; 3) Member 

States must wait for 20 years before the category “settlement converted to wetlands” or “other land 

converted to wetlands” can be changed to “wetlands remaining wetlands” category, or wetlands 

converted to settlements or other land can be changed to their respective “remaining” land 

categories. 4) When a carbon pool is a source Member States must include the changes in carbon 

stocks of the following carbon pools: above ground biomass, below ground biomass, litter (as part of 

DOM), dead wood (as part of DOM), soil organic carbon; 5) archiving of the data used; 6) MS shall 

account for emissions and removals in the period 2021 to 2025 (respectively 2026 to 2030) minus 5 

times the average emissions in the base period years 2005 to 2009    

8)  Flexibilities: 

a.  banking of removals (only if included in the first period) 

b. 

transfers of removals (possible) 

c.  use for compliance with the ESR (once the DA under Article 7 ESR is adopted and not for the 

first compliance period) 

Article 2(3) of the LULUCF Regulation requires Member States to notify the Commission by 31 December 

2020 of their intention to include managed wetlands in the scope of their commitment. In context of Art 

2(1) and 2(2) the notification under this Article applies to the compliance period 2021-2025. The 

question if a Member State can redraw its notification during the period (before the compliance 

assessment) has practical importance. While it is clear from the text that a Member State who did not 

notify by 31 December 2020 cannot include wetlands in the scope of its commitment, it is not clear what 

happens if a Member State decides during the period that (for unexpected reasons) the managed 

wetlands category creates accounted emissions instead of the expected accounted removals. In law it 

can be argued both ways. It can be argued that the notification creates a binding obligation for the 

Member State to account for managed wetlands, which would imply that the Member State cannot 

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change its mind after 31 December 2020. However, given the fact that this inclusion is at the discretion 

of the Member State, it could also be argued that the notification date is only for information purposes of 

the Commission and does not create a legal obligation for the Member State to account for managed 

wetlands if the Member State decides at a later date to redraw the notification. For reasons of legal 

certainty and also for avoiding abusing this provision (being used only when it is certain that it would 

bring a benefit for the Member State), the project team inclines towards the first interpretation that does 

not allow Member States to change their mind after the date of 31 December 2020. 

Article 2(4) of the LULUCF Regulation states that the Commission may make a proposal to postpone the 

mandatory accounting for managed wetland for an additional period of five years. Such decision should 

be based on experience gained with application of the IPCC Refinements. This seems to refer to the 2019 

refinements to the 2006 IPCC guidelines, which were not yet finished at the time the LULUCF Regulation 

was adopted. The use of the term "refinements” seems to exclude experience gained with application of 

the 2013 Wetland supplement.  

Article 4(2), however, seems to provide no legal basis for implementation because it does not explicitly 

give the Commission the right to adopt a delegated or implementing act and neither Article 16 -Exercise 

of the delegation does not refer to Article 2(4). The Commission can propose a new Regulation that 

would amend the LULUCF Regulation by postponing mandatory accounting for wetlands. 

Article 7(4) lays down the obligation for Member States to report to the Commission the GHG emissions 

and removals from the land use categories that make up the managed wetlands accounting category, 

even if they chose not to include wetlands in their accounting.  

2.6.6  Accounting for Managed Forest Land (Articles 8 and 13 LULUCF Regulation) 

1)  Reporting date on emissions and removals for underlying land use categories: 15 January 

(preliminary data) and 15 March (final data) for year X-2 (Article 26 GR), every year as part of its 

national inventory reporting. 

2)  Reporting on National Forestry Accounting plan: 31 December 2018 for (2021 to 2025) and 30 

June 2023 (for 2026 to 2030) and where necessary based on a technical assessment by the 

Commission a revised version on 31 December 2019 or 30 June 2024. The national forestry 

accounting plan: i) contain a Member State’s proposed forest reference level determined according 

to  the criteria set in Annex IV Part A of the LULUCF Regulation and ii) include the elements reported 

in Annex IV Part B of the LULUCF Regulation. In addition, for Croatia the impact of the occupation of 

its territory, and wartime and post-war circumstances; 3) the plan must be made public on internet; 

4) the FRL is to be based on the continuation of sustainable forest management practice, as docu-

mented in the period from 2000 to 2009 with regard to dynamic age-related forest characteristics in 

national forests, using the best available data. It shall take into account also the future impact of 

dynamic age-related forest characteristics in order not to unduly constrain forest management 

intensity (Art 8(5) paragraph 1 and 2). 5) consistency of data between the ones used for the FRL 

and the GHG inventory data reported for managed forest land ((Art 8(5) paragraph 3). 

3)  Compliance report: 15 January (preliminary data) and 15 March (final data) of 2027 and of 2032.  

4)  Reporting format: Common reporting format (CRF) for emissions included in Article 8 of the 

implementing act under Article 26 of the GR. The CRFs applicable for the Paris Agreement are still 

being negotiated at international level. Once they are agreed upon, the Commission will need to 

propose their inclusion in the EU law by means of an implementing act under the GR. 

5)  Reporting rules: 2006 IPCC Guidelines and 100 GWP. Tier 2 if carbon pool amounts to more than 

25%-30% emissions or removals in a source or sink key category. Tier 3 is encouraged. 

Geographically explicit information. 

6)  Accounting towards the no debit rule: obligatory for all 

7)  Accounting period: 2021 to 2025 and 2026 to 2030 

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8)  Accounting rules: 1) Member States must ensure that the data provided is accurate, complete, 

consistent, comparable and transparent (TACCC principles); 2) avoid double counting; 3 ) Member 

States must include the changes in carbon stocks of the following carbon pools: above ground 

biomass, below ground, dead wood and  harvested wood in every situation and changes in below 

ground biomass, litter and soil organic carbon only if that pool is a source; 4) archiving of the data 

used; 5) MS shall account for emissions and removals in the period 2021 to 2025 (respectively 2026 

to 2030) minus 5 times the forest reference level  of that Member State for the relevant period. 

When this result is negative, Member States may include an amount of (accounted) removals not 

bigger than 3.5% of that Member State’s base year emissions pursuant to Annex III multiplied by 5. 

Removals from carbon pools of dead wood and harvested wood products (except for paper) can be 

included without any limit; 6) In order to ensure 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, Member States shall, where necessary, submit to the 

Commission technical corrections to its Forest Reference Level by 15 March 2027 or 15 March 2032. 

The legal texts do not provide instructions on the format and information that needs to be provided 

for these technical corrections in the context of the forest reference level.  

9)  Flexibilities: 

a.  banking of removals (possible) 

b. 

transfers of removals (possible) 

c.  use for compliance with the ESR (possible once the DA under Article 7(2)(a) of the ESR is 

adopted), which now is possible with the FRL’s adopted for the first compliance period 

(Delegated act (EU) 2021/268). Article 7(2)(a) of the ESR implies that the inclusion of the 

managed forest land category needs to be done for each period separately. The legal basis does 

not leave any discretion to the Commission as not to include them. 

d.  Managed forest land flexibility (Article 13 LULUCF): can be used to compensate emissions from 

managed forest land category when: 1) the Member State is in debit across all accounting 

categories, 2) to compensate emissions only from managed forest land category, 3) The Member 

State included in its long term strategy measures to ensure conservation or enhancement of 

forest sinks or reservoirs. The measures can be ongoing or planned. 3) total emissions do not 

exceed total removals in the EU (see discussion under Article 14(3) for this condition). This 

calculation will avoid double counting. 4) Only sinks accounted for as emissions against the FRL 

can be compensated and up to the amount in Annex VII in the Regulation for the period 2021 to 

2030, 4) Finland can compensate up to 10 million tonnes of CO2  

The regulation is silent about the split of the compensation between the two compliance periods 

leaving it at Member State’s discretion if to use it all in the first period or in the second or split it 

in any way they like. The only requirement is for Member States to inform the Commission of 

the amount they intend to use of the compensation as part of the Compliance report under 

Article 14(1). 

Article 13(4) provides an additional compensation amount for Finland, on top of the amount 

already provided in Annex VII. However, the two amounts are not cumulative; rather Finland 

can use an additional amount on top of Annex VII up to 10 million tonnes of CO2. It is not clear 

from the text if the condition that only emissions from sinks accounted against the reference 

level can be included in this additional amount since Article 13(4) refers only to the conditions in 

paragraph 2. This can be interpreted either way, with the stricter interpretation being in favour 

of the environmental integrity principle. 

2.6.7  Accounting for Harvested Wood Products 

1)  Reporting date on emissions and removals for Harvested Wood Products (HWP) which are 

included under Managed Forest Land and/or Afforested land: 15 January (preliminary data) 

and 15 March (final data) for year X-2 (Article 26 GR), every year as part of its national inventory 

reporting. 

2)  Compliance report: 15 January (preliminary data) and 15 March (final data) of 2027  

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3)  Reporting format: Common reporting format (CRF) included in Article 8 of the implementing act 

under Article 26 of the GR. The CRFs and the CTFs (common tabular formats) applicable for the Paris 

Agreement are still being negotiated at international level. Once they are agreed upon, the 

Commission will need to propose their inclusion in the EU law by means of an implementing act 

under the GR.  

4)  Reporting rules: 2006 IPCC Guidelines with use of first order decay function and methodological 

guidance and default half-live values as provided in Annex V of the LULUCF Regulation. Member 

States may use country-specific methodologies and half-life values instead of the methodologies and 

default half-life values specified in Annex V, provided that such methodologies and values are 

determined on the basis of transparent and verifiable data and that the methodologies used are at 

least as detailed and accurate as those specified in Annex V. 

5)  Accounting towards the no debit rule: obligatory for all 

6)  Accounting period: 2021-2025 and 2026 to 2030 

7)  Accounting rules: 1) Member States must ensure that the data provided is accurate, complete, 

consistent, comparable and transparent (TACCC principles); 2) avoid double counting; 3) archiving 

of the data used; 4) respective emissions to be included in the accounts for managed forest land and 

afforested land. Where it is not possible to differentiate between emissions and removals from HWP 

from afforested land and those from Managed Forest land they may be included in the managed 

forest land accounts, 5) categories: paper, wood panels, sawn wood, 6) production approach 

retained, Member States account for all harvested wood products produced from wood harvested in 

their MS, ignoring imports and exports of wood and wood products 7) The residence time of CO2 in 

the product pools is estimated using a first order decay function for each product group and default 

half-life values specified in Annex V of the LULUCF Regulation. 8) Energy wood and wood in landfills 

is excluded and considered to cause emissions immediately. 9) Member States may specify the 

wood-based material products provided that the available data is transparent and verifiable 

8)  Flexibilities: the rules applying to the category in which they are included (afforested land or 

Managed Forest land) apply also to harvested wood products. 

2.6.8  Accounting for natural disturbances 

1)  Reporting date on emissions: there is no basis for reporting emissions from natural disturbances 

in the national inventories. It is only requested for the compliance report. 

2)  Compliance report: 15 January (preliminary data) and 15 March (final data) of 2027  

3)  Reporting format: Table 2 of Annex XX of the IA to the governance regulation. Reporting in this 

table is required by Member States who apply the provision to exclude emissions from natural 

disturbances in accordance with Article 10 of the LULUCF Regulation. Detailed explanation on how 

the subsequent removals to be excluded from accounting are calculated needs to be provided in a 

relevant annex of the NIR. Also information on the calculation of the background level and the 

margin, for which methodological rules are provided in Annex VI of the LULUCF Regulation, need to 

be reported in the NIR (footnote 7 to Table 2 of Annex XX of the IA to the governance regulation). 

From this it is not clear where in the NIR this should be included, but it seems obvious to include an 

annex to the NIR in which all the required information related to natural disturbances is included. 

This should be included at least in the final inventory data that is submitted to the Commission by 15 

March 2027 and 15 March 2032. 

4)  Reporting rules: Annex VI of the LULUCF Regulation. 

5)  Accounting towards the no debit rule: This natural disturbances provision may be used by 

Member States. 

6)  Accounting period: 2021-2025 and 2026 to 2030 

7)  Accounting rules: 1) MS must ensure that the data provided is accurate, complete, consistent, 

comparable and transparent (TACCC principles); 2) avoid double counting; 3) emissions to be 

excluded from the accounts for managed forest land and for the accounts for afforested land, 4) 

methodology: emissions that can be excluded are those that exceed the average emissions caused 

by natural disturbances in the period from 2001 to 2020, excluding statistical outliers (‘background 

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level’) plus a margin. 5) rules for calculating the background level and margin are specified in Annex 

VI of the LULUCF Regulation. 

8)  Flexibilities: the rules applying to the category in which they are included (Afforested land or 

Managed Forest land) apply also to Natural disturbances. 

2.7 

Sequencing of compliance elements and activities and analysis of timelines 

After mapping the compliance elements, this information was included in a “Microsoft Project” project to 

further assess their linkages and sequence. Additional information on the activities that need to be 

undertaken was added to the MS Project. With this it is possible to assess the consistency in relations 

between the compliance elements and to assess the critical paths. Using this tool, a timeline is 

constructed for the deadlines and milestones over time (Section 2.7.1). A more detailed GANTT chart for 

the elements and activities for the annual inventories is provided in section 2.7.2 and a detailed GANTT 

chart of the LULUCF compliance elements and activities from reporting GHG inventories to compliance 

check in 2027 in section 2.7.3. 

2.7.1 

Timeline of implementation of LULUCF compliance elements for the first compliance period. 

The overall timeline, with the main deadlines for the different elements relating to the first compliance 

period 2021-2025, is provided in Figure 2.1. To keep the timeline legible, it is subdivided into time 

intervals of 2 years: 2021-2022, 2023-2024, 2025-2026 and 2027-2028. It includes the reporting and 

compliance elements as mapped in the sections 2.2 to 2.5.1. Additionally it includes the reporting and 

accounting elements that still exist from continuing obligations. For instance Article 7 of the MMR 

(regulation EU 525/2013), which by way of derogation (Article 58 of the GR) was excluded from the 

repeal of the MMR in article 57 of the GR, requires the reporting of the national inventories for the years 

2019 and 2020, including the activities defined in LULUCF decision EU 529/2013. Although the reported 

years 2019 and 2020 are before the first compliance period the actual reporting is done in 2021 (for the 

years including 2019) and in 2022 (for the years including 2020). In 2022 also the final reporting on the 

second commitment period (2013-2020) under the Kyoto Protocol is done (Figure 2.1(a)).  

The first approximated GHG inventory that needs to be provided under Article 26(2) of the governance 

regulation is in 2021. This is the inventory for the year 2020, which is a reporting year that is outside of 

the compliance period.  

Reporting and compliance checking for the first compliance period covers the period 2021-2028. 

Emissions and removals for 2025 included in the inventory and compliance report are submitted in March 

2027, after which the submitted reports are reviewed. Member States then still have some time to make 

use of the flexibilities in the LULUCF Regulation and ESR. Final compliance which also considers the used 

flexibilities is eventually checked in 2028. 

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Figure 2.1(a). Timeline with the deadlines and milestones for the LULUCF reporting and compliance elements of the first compliance period 2021-2025 during the 

period 1 January 2021 to 31 December 2022. More detailed planning of the activities under the annual inventory reporting process is provided in the GANTT chart 

(Figure 2.2) in Section 2.7.2. To provide a complete overview of what needs to be done in this period it also includes reporting requirements from continuing 

obligations, like the reporting of Cropland Management and Grazing land Management as part of the EU LULUCF decision 529/2013. The text’s colours group elements 

that are closely related, with lighter tints and italic font referring to the additional elements of the continuing reporting obligations. Member States’ obligations are 

indicated below the timeline, and Commission obligations are indicated above the timeline.  

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Figure 2.1(b). Timeline with the deadlines and milestones for the LULUCF reporting and compliance elements of the first compliance period 2021-2025 during the 

period 1 January 2023 to 31 December 2024. More detailed planning of the activities under the annual inventory reporting process is provided in the GANTT chart 

(Figure 2.2) in Section 2.7.2. To provide a complete overview of what needs to be done in this period it also includes the deadlines associated with drafting the 

Member State’s National Forestry Accounting Plans (NFAP, in red) and Forest Reference Levels (FRL, in red) for the second compliance period (2026-2030). The text’s 

colours group elements that are closely related. Member States’ obligations are indicated below the timeline, and Commission obligations are indicated above the 

timeline.

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Figure 2.1(c). Timeline with the deadlines and milestones for the LULUCF reporting and compliance elements of the first compliance period 2021-2025 during the 

period 1 January 2025 to 31 December 2026. More detailed planning of the activities under the annual inventory reporting process is provided in the GANTT chart 

(Figure 2.2) in Section 2.7.2. To provide a complete overview of what needs to be done in this period it also includes the deadline associated with adopting the 

Member States’ National Forestry Accounting Plans (NFAP, in red) and Forest Reference Levels (FRL, in red) for the second compliance period (2026-2030). The text’s 

colours group elements that are closely related. Member States’ obligations are indicated below the timeline, and Commission obligations are indicated above the 

timeline.

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Figure 2.1(d). Timeline with the deadlines and milestones for the LULUCF reporting and compliance 

elements of the first compliance period 2021-2025 during the period 1 January 2027 to 31 December 

2028. More detailed planning of the activities under the annual inventory reporting process and 

comprehensive review in 2027 is provided in the GANTT chart (Figure 2.3) in Section 2.7.3  To provide 

a complete overview of what needs to be done in this period it also includes the reporting and 

compliance elements associated with the second compliance period (2026-2030). The text’s colours 

group elements that are closely related, with lighter tints and italic font referring to the additional 

elements associated with the second compliance period. Member States’ obligations are indicated 

below the timeline, and Commission obligations are indicated above the timeline.  

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2.7.2  GANTT chart and analysis of timescales related to the reporting of GHG inventories in years 

without accounting or compliance check 

The GANNT chart in Figure 2.2 provides the timing and sequencing of the annual reporting of GHG 

inventories by Member States and the EU inventory. The start of the preparations by Member States is 

an estimate and will depend on the arrangements in the Member States. The date (1 August) is just after 

the deadline for Member States to report their approximated GHG inventory for the year x-1 to the 

Commission. Around the same time also the UNFCCC reviews of the NIR of that year is carried out, after 

which potential issues identified during that review can be taken into consideration in calculating the new 
GHG inventory4. The other activities included in the GANTT chart and their timescales are taken from 
Annex XXI to Article 25(1) of the IA of the Governance regulation. 

Figure 2.2. Detailed GANTT chart of the LULUCF compliance elements and activities and their links, 

relating to reporting GHG inventories in 2023 (reporting years up to 2021) as an example for years 

without a compliance check. In the years 2024 to 2026 (reporting up to 2024) the same schedule 

applies. MS refers to Member State’s activities (also in green) and COM refers to activities of the 

Commission (in blue). Deadlines and milestones are indicate with diamonds, the activities are included as 

bars. 

The initial checks on the preliminary GHG inventory data and report that Member States submit by 15 

January consist of a question and answer loop between the EEA and Member States as soon as issues 

are identified. Although the timescales identify a date for circulation of the initial checks, this is 

considered the latest date with the final circulation of the findings. 

Because there is no slack time in between the identified elements and activities the whole process is 

identified as a critical path. This is partly because the MS project tool is now used to assess a predefined 

timescale in which all dates are considered to follow each other. Nevertheless experience from both EEA 

and Member States is that this is a very tight time schedule that leaves no room for deviations. 

4 It should be noted, however, that the implementation for some recommendations from the UNFCCC review may take 
longer and as a result may not be available to be included in the next inventory. 

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The primary purpose of the initial checks is to ensure the quality of the submission of the annual 

inventories and to assure completeness and consistency of the EU GHG inventory. Issues that arise from 

the initial quality and consistency checks need to be addressed by Member States for their final 

submission of inventory data and report to the Commission by 15 March. In those cases the preliminary 

submitted inventory data of 15 January will be different from the finally submitted inventory of 15 March.  

Subsequently Member States should submit the same final inventory data as submitted to the 

Commission to the UNFCCC by 15 April of the inventory year. However, in some cases between 15 and 

31 March there may be follow-up questions from the Commission regarding the Member States’ 

responses to the initial questions. Also the Commission may prepare estimates for missing data by 31 

March of the reporting year and will communicate this with the Member State concerned. This may result 

in further changes to be applied to the final GHG inventory data that Member States submitted to the 

Commission. Here there appears to be a gap in the legal texts as Article 26 of the GR requires Member 

States to submit the 15 March data to the UNFCCC. If Member States indeed would submit the 15 March 

data to the UNFCCC instead of the information that includes the missing data and other changes applied 

based on the follow-up questions, this will result in an inconsistency with the EU GHG inventory which 

would include these changes. Nevertheless, the timescales for cooperation and coordination in preparing 

the EU GHG inventory listed in Annex XXI implicitly imply that such changes should be included in the 

submission to the UNFCCC. These also indicate that Member States need to provide the Commission with 

any other resubmissions to the UNFCCC after 15 April. To improve clarity and consistency in the legal 

text this process should be covered more explicitly in the text of Article 26 of the GR.  

Compliance with the LULUCF Regulation is assessed during the comprehensive review that is carried out 

at the end of the compliance period. It would, however, be relevant to already flag and address potential 

issues for accounting and compliance in an earlier stage instead of waiting until the review at the end of 

the compliance period. One way of monitoring progress of Member State’s GHG emissions and removals 

between the two reviews provided in Article 38 GR, is to make use of the initial checks phase. The 

challenge of this approach is the already short time available for these checks, deriving from the tight 

schedule of the compilation of the EU GHG Inventory. Another approach would be to carry out trial 

reviews before 2027 to avoid surprises and errors to show up only in 2027 during the comprehensive 

review. This would still need careful planning and timing with Member States to avoid overloading of the 

inventory teams. Probably the best time window for such trial reviews would be the time between the 

submission of the GHG inventories to the UNFCCC and the submission of the approximated inventory 

(April-July).    

In order to further elaborate the initial checks and verify Member States inventory data ETC/CME is 

currently assessing and developing more complex and automated initial checks for the LULUCF sector. 

With a potentially “heavier” role of the initial checks it would then also be necessary for the Commission 

to allocate sufficient resources for performing these tasks. 

2.7.3  GANTT chart and analysis of timescales related to the LULUCF compliance elements and activities 

from reporting GHG inventories to compliance check in 2027 

Compliance with the LULUCF Regulation for the first compliance period 2021-2025 is checked in 2027 

after the Member States have submitted their GHG inventory and compliance reports that cover the 

period 2021-2025. Figure 2.3 provides the detailed GANTT chart with dependencies between the different 

elements and activities and lists the actors responsible for the activities. In the MS Project tool also other 

visualizations can be used and checked, including PERT charts/Network Diagrams, but these are not very 

convenient for use in the report. The analysis for the annual inventory 2027 would be the same as for 

the annual inventory provided in Section 2.7.2. The process of initial checks, drafting the EU inventory 

report and submitting final greenhouse gas inventory data remain the same.  

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Figure 2.3. Detailed GANTT chart of the LULUCF compliance elements and activities from reporting GHG 

inventories to compliance check in 2027. This closes the first compliance period. 

Reporting accounted emissions and removals 

Additionally to their regular GHG inventory data and report Member States need to report their 

preliminary and final accounted emissions and removals for the first compliance period by 15 January 

2027 and 15 March 2027 respectively. For accounting managed forest land a technical correction to the 

forest reference level may be required, which for the first compliance period needs to be submitted to 

the Commission by 15 March 2027 (Article 8(11) of the LULUCF Regulation). Since according to the 

governance regulation (Article 26(5)) it is also required to report preliminary accounted emissions and 

removals by 15 January 2027, Member States in principle should be able to submit such Technical 

Correction to the Commission by 15 January 2027 or earlier. In the legal texts there is currently no 

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protocol indicating how these Technical Corrections in the context of the FRL need to be delivered, nor is 

there a provision for their review. 

Also information on the emissions from areas subject to natural disturbances that the Member State 

wishes to exclude following the natural disturbances provision in the LULUCF Regulation (Article 10) 

should be included in the reported preliminary accounted emissions and removals by 15 January 2027.  

The compliance report containing the information on final accounted emissions and removals of the first 

compliances period needs to be submitted to the Commission by 15 March 2027.  

Comprehensive review 

The next step in the process of monitoring compliance is the comprehensive review of Member State’s 

GHG inventory data, including the LULUCF sector and the accounting categories and application of the 

accounting rules from the LULUCF Regulation. The schedule for the 2027 and 2032 comprehensive 

reviews is provided in Annex XXII of the IA to the GR. The review starts 15 April with the preparation of 

the review material by the EEA. The task description for this preparation in Annex XXII indicates that the 

material for the comprehensive review should be based on the 15 April submissions (i.e. to the UNFCCC) 

of the Member States. Yet the compliance reports submitted by the Member States are based on the 15 

March inventory data (Article 26(5) of the GR and Article 14(1) of the LULUCF Regulation).  

Potential issue 

Here a potential issue arises in cases where Member States have submitted GHG inventory data to the 

UNFCCC that differ from the reported final GHG inventory data submitted to the Commission on 15 

March. In such cases the data that are being reviewed (15 April data) differ from the data that are used 

for the final accounted emissions and removals and that are provided in the LULUCF compliance report 

(15 March data). While according Article 26 (4) the 15 April inventory data should be the same as the 

final data reported on 15 March, there may be instances where these deviate.  

For instance the description of the timescales for cooperating in the preparation of the EU GHG inventory 

suggest that as a result of follow-ups on the initial checks and Commission estimates for data missing 

from a national inventory, the data in the Member State’s inventory can still change between 15 March 

and 15 April to maintain consistency between de EU and Member States inventories.  

At the same time there are known cases from the past where Member States have submitted data to the 

UNFCCC on 15 April that deviated from the final inventory data that were submitted to the Commission 

on 15 March without notifying the Commission. Also the reporting requirements under the UNFCCC allow 

for resubmissions of inventory data to the UNFCCC, but in such cases the Member States should also 

provide these data to the Commission (see point 16 in Annex XXI of the IA to the GR). 

An update of the compliance report is not foreseen in the legal texts. Therefore is recommended to close 

this gap in possible future revisions of the regulation. This could be by requiring Member States that 

submit deviating GHG inventory data to the UNFCCC on 15 April also submit an updated LULUCF 

compliance report to the Commission that reflects the updates to the GHG inventory.  

Given the tight time schedule of the comprehensive review it will be very difficult to also consider further 

resubmitted LULUCF data in the review, in case a Member State finds an issue with its data after 15 

April. The UNFCCC review of National Inventories is usually carried out in September or October of the 

year the National Inventory Report is submitted and hence starts after the comprehensive review is 

finalised. Potential issues with the inventory raised in this UNFCCC review, therefore cannot be addressed 

anymore in the compliance process. While the UNFCCC review provides a quality check on the GHG 

inventories, the EU inventory is a separate review which is considered to be a more thorough review 

which requires equal and consistent treatment of the Member States’ inventories. Nevertheless, since the 

UNFCCC reviews can be considered as an important quality check that likely will pick up important errors 

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and inconsistencies in inventory reporting, Member States should be encouraged to address 

recommendations from earlier UNFCCC reviews as soon as possible and not to wait to do this until the 

2027 inventory report. 

Analysis of time schedule 

For similar reasons to the annual inventory process (see section 2.7.2), all elements and activities 

relating to the comprehensive review process are identified as critical paths with a tight schedule which 

leaves little room for deviations in the schedule.  

In order to facilitate a smooth progress of the comprehensive review, it would be recommended to 

prepare clear guidance in advance of the review and provide a training of the selected reviewers. This 

could be similar to the UNFCCC review process, or the process used with the LUULCF expert group for 

the technical assessments of the Forest Reference Levels in 2019 and 2020. Additionally it would be 

recommended to carry out trial reviews or latest a trial review in 2026 to test the process and guidance 

and to avoid errors to show up only in 2027 during the comprehensive review. 

It will be important that Member States make sure resources and inventory compilers are available 

during this time to engage in the comprehensive review, respond to review questions and comment to 

the draft review report. Because this is the first time the LULUCF sector will be reviewed in a 

comprehensive way by the Commission it is recommended to pay attention to this, for instance, in the 

context of working groups 1 and 5 of the Climate Change Committee. 

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3 

Expected content (Task 2) 

This chapter is the result of Task 2, describing the content that is expected for the compliance elements 

identified in Task 1 (Chapter 1).  

The objectives of this task are to list and interpret what information is expected to be provided in each 

step of the compliance process. Basic information in this respect was already provided together with the 

mapping of the compliance elements in Chapter1. Where relevant, this chapter will provide more detailed 

interpretations and clear description of the content that actors are expected to provide for each of the 

compliance elements. 

3.1 

Approach 

Interpretation of specific requirements for the information that needs to be provided for each of the 

compliance elements is not always very straightforward. For each of the compliance elements mapped in 

Task 1 and for relevant activities identified in Task 1 we interpreted what data or information needs to be 

delivered, in what format it should be provided and how it should be submitted. 

Member States need to provide a range of information to fulfil the reporting requirements of the LULUCF 

Regulation, the Governance Regulation (GR) and the Effort Sharing Regulation (ESR). Some of this 

information will be directly available to the Member States from the National Inventory Reports (NIRs) 

and the CRF tables that the Member States submit under the UNFCCC. For these cases the reporting 

burden on the Member States is minimised, and we have outlined what information needs to be provided 

and where it can be found in the current CRF tables or the NIRs. Sometimes there are specific 

requirements on data quality and inventory approaches that require methodological improvements. For 

each of the compliance elements we indicate what the specific requirements are that ask for improved 

methodologies, such as the requirement of using geographically explicit land use changes, and at least 

tier 2 reporting for significant carbon pools. Where needed we refer to the relevant IPCC methodological 

guidance documents. (i.e. IPCC 2006a, b) 

The additional information on expected content covers the following elements: 

  General requirements for the methodologies for monitoring and reporting in the LULUCF sector. 

  Reporting of approximated GHG inventories, annually for year x-1 

  Reporting on GHG inventories, annually up to year x-2 

  Reporting on Policies and Measures, biennially 

  Reporting on projections, biennially 

  Reporting on accounted emissions and removals for the period 2021 to 2025 and 2026 to 2030 

3.2 

General requirements for the methodologies for monitoring and reporting in the 

LULUCF sector 

For monitoring and reporting of greenhouse gas emissions and removals in the LULUCF sector a number 

of requirements and minimum standards are provided in the various legal texts. As a result of the direct 

link between the land-use categories that are reported in the National Inventory Reports (NIR) to the 

UNFCCC, and the accounting categories under the LULUCF Regulation these requirements relate to both 

reporting of the national GHG inventories and reporting of the LULUCF accounting categories. 

3.2.1  Greenhouse gases and carbon pools to be included 

The LULUCF Regulation in Annex I (section A) lists the greenhouse gases that need to be included in the 

reporting of the LULUCF accounting categories; 

a)  Carbon dioxide (CO2), 

b)  Methane (CH4), 

c)  Nitrous oxide (N2O). 

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Similarly Annex V of the GR lists the greenhouse gases that need to reported in the Member States’ 

national GHG inventory, which besides these gases also lists a number of other greenhouse gases, but 

those are not relevant to LULUCF. 

These greenhouse gases currently are already part of the national GHG inventories to the UNFCCC.  

Carbon dioxide is the most relevant greenhouse gas occurring in the LULUCF sector resulting from the 

loss or gain of carbon stocks in the land-use systems and harvested wood products (CRF tables 4.A-F 
and 4.Gs1)5. However, the following emissions and removals need to be considered also for reporting 
GHG inventories and hence the LULUCF accounting; 

 

 

direct N2O emissions from nitrogen (fertilizer) inputs in managed soils under forest land, wetlands 

and settlements (CRF Table 4(I)), 

emissions of CO2, CH4 and N2O and removals of CO2 resulting from drainage and rewetting and 

other management of organic and mineral soils (CRF Table 4(II), 

  N2O emissions associated with loss of soil organic matter resulting from change of land use or 

management of mineral soils (CRF Table 4(III)), 

 

Indirect emissions of N2O form managed soils resulting from atmospheric nitrogen deposition or 

nitrogen leaching and run-off that is associated with synthetic and organic N fertilizer from land-

uses other than cropland and grassland (CRF Table 4(IV)), 

  CO2, CH4 and N2O emissions resulting from biomass burning (controlled burning or wildfires, CRF 

table 4(V)) 

Direct and indirect N2O emissions from agricultural soils (e.g. as a result of fertilizer application on 

cropland and grassland and associated atmospheric N-deposition) and other non-CO2 emissions from 

agricultural soils are reported in the agricultural sector (CRF Table 3D) and hence are outside the scope 

of LULUCF reporting and accounting. Instead these emission are part of the emissions covered under the 

ESR.  

Under the CRF category 4.H Other, also other emissions and removals that a Member States considers 

relevant may be provided. Specific items or subdivisions need to be specified in the CRF reporter. For 

these items total net emissions may be provided, but the same items will also be included in CRF Tables 

4(I) on direct emissions from N inputs, 4(II) on emissions from drainage and rewetting of soils and Table 

4(V) on biomass burning to be able to specify these emissions separately. If estimates are reported 

under the category 4.H. “Other”, information regarding activities covered under the category and 

background information on the emissions need to be provided in the NIR. Currently France uses this 

option to report emissions from a reservoir in French Guiana and to provide biogenic NMVOC emissions 

from managed forests. These emissions, however, are not included in one of the accounting categories of 

the LULUCF Regulation. Because CRF Table 4(II) does not cover the land-use category settlements, 

Germany reports N2O emissions from drainage and rewetting and other management of organic and 

mineral soils for settlements under a self-defined subcategory for settlements under category “4H. 

Other”.   

In addition, section B of Annex I of the LULUCF Regulation sets out the carbon pools that need to be 

covered in the LULUCF accounting; 

a)  above ground biomass, 

b)  below ground biomass, 

c) 

litter, 

d)  dead wood, 

e)  soil organic carbon, 

f)  harvested wood products in the land accounting categories of afforested land (i.e. the UNFCCC 

categories of land converted to forest land) and managed forest land (i.e. UNFCCC category 

forest land remaining forest land). 

5 The Common Reporting Format (CRF) tables are standard tables that are used to provide quantitative information as part of 
the National Greenhouse Gas Inventories of Annex 1 parties to UNFCCC. LULUCF is sector 4 in the CRF tables. 
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Carbon pools that are “not a source” of emissions may be excluded, except in the case of the carbon 

pools of above-ground biomass, dead wood and harvested wood products in the accounting category 

managed forest land (article 5(4) of the LULUCF Regulation), and hence the UNFCCC land-use category 

forest land remaining forest land. In section 3.2.3 on tier levels we discuss some issues regarding this 

use of “not a source”. 

The carbon pools that need to be covered in the LULUCF accounting framework as listed above, in 

principle are the same as those required for reporting the LULUCF land-use categories in Member State’s 

national inventory reports to the UNFCCC. However, the pool indicated by “living biomass” in the CRF 

combines above-ground and below-ground living biomass (see e.g. section 4.2.1 in the 2006 IPCC 

guidelines (IPCC 2006b)) reported for the land-use categories in the UNFCCC CRF tables (4.A-4.F).  

Moreover, in the UNFCCC CRF tables the pools dead wood and litter should only be reported separately in 

forest land (CRT table 4.A). In the CRF tables for the other land-use categories (CRF tables 4.B-4.F) 

carbon stock changes for the aggregated pool of dead organic matter (DOM) needs to be reported. 

Although in these non-forest categories DOM will mainly be based on litter, carbon stock changes in dead 

wood should be included under DOM in cases where dead wood is an important pool, . However, in such 

cases from the CRF table the contributions of litter and dead wood cannot be identified separately. 

Because the separation between some of the carbon pools (above ground and below ground living 

biomass under biomass, and dead wood and litter under DOM) cannot be determined from the CRF 

tables directly, this potentially creates a transparency issues for the review and compliance assessment. 

This particularly will be an issue in cases where Member States use the option provided in article 5(4) of 

the LULUCF Regulation to exclude from accounting the changes in carbon stocks for those carbon pools 

that are not a source (except above-ground biomass, dead wood and HWP from managed forest land). 

Therefore the methodologies used to assess the carbon stock changes in the different carbon pools need 

to be carefully described in the National Inventory Reports. These descriptions should provide 

transparent information on whether and how the different carbon pools are covered. To further increase 

transparency and to support the review process Member States could be encouraged to provide the 

changes in carbon stocks for above-ground and below-ground biomass, and were relevant dead wood 

and litter, more explicitly in their National Inventory Reports to the UNFCCC. This requires a limited 

effort by the Members States as these need to be calculated anyway.  

Also the Commission could require Member States to report on the additional values in a separate report 

to be annexed to the NIR. The legal basis in Article 26(7) of GR allows for the Commission to ask for this 

data at disaggregated level.  

3.2.2  Geographically explicit land use information 

Information that needs to be included in GHG inventories is listed Annex V of the GR. In part 3 of this 

Annex specific requirements for the LULUCF inventory reporting and accounting is provided. One of the 

listed requirements is that geographically explicit land-use conversion data need to be used in line with 

the 2006 IPCC guidelines.  

Information on land use and land-use change areas represents important activity data for the calculation 

of emissions and removals from LULUCF. Chapter 3 of Volume 4 of the 2006 IPCC guidelines (IPCC 

2006b) provides the guidelines to be used for consistent representation of lands. The guidelines provide 

three different approaches for representing land in the inventory (IPCC 2006b, see Table 3.1). 

 

Approach 1 identifies the total change in area for each individual land-use category within a country, 

but does not provide information on the nature and area of conversions between land uses. This only 

provides the net changes and does not allow for tracking gross changes. For instance if total area of 

forest land increases, the effects of gross deforestation that is compensated by afforestation 

elsewhere are missed. 

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 

Approach 2 introduces tracking of land-use conversions between categories, but is not spatially 

explicit. This approach therefore does not allow to track conversions over time for individual land 

units. As a result the cumulative effect of subsequent changes on for instance soil carbon cannot be 

assessed.  

 

Approach 3 is characterised by spatially-explicit observations of land-use categories and land-use 

conversions. This approach enables tracking of conversions of individual land units over time.  

Table 3.1. Examples of different data inputs and methods to derive land-use classes for the three 

approaches identified in the IPCC guidelines. Approach 3 is the spatially explicit approach which is 

required by the LULUCF Regulation. (Source: Table 3.6a in Chapter 3 of IPCC 2019)  

Method 

Approach 1 

Approach 2 

Approach 3 

Sample- based 
methods 

  Single sample 
  Temporary sample 

units 

  Samples collected from permanent 

  Permanent and consistent 

units but changes only tracked 
across two consecutive sample 
periods. 

georeferenced ground plots. 

  Continuous and consistent 

samples using remote sensing 
data. 

Survey-based 
methods 

  Single census at one 

  General surveys between two 

  Specific survey designs that 

point in time 

periods. 

  Repeat census but 

  National census data that can refer a 

without reference to 
previous censuses. 

past period. 

identify activities through time 
for each land unit within a 
known region. 

Wall-to- Wall 
methods 

  Single map 
  Inconsistent maps 

developed at different 
times. 

  Inconsistent maps through time 
combined with Approach 2-type 
samples (e.g. using maps as 
stratifications). 

  Maps developed using consistent 

methods changes tracked across two 
consecutive maps only not tracked 
through a time-series of maps. 

  Tracking pixels / land units 
using time-series consistent 
data. 

This means that, to meet the requirements of Annex V Part 3, consistent land-use change time series are 

required that are in line with Approach 3 in IPCC (2006b). Besides that it allows for explicit tracking of 

land-use conversion over time, and important advantage of Approach 3 is also that it enables the use of 

Geographic Information Systems (GIS) to link the information of land use and land-use changes with 

other spatially explicit data sets, for example soil mapping, or management practices. This allows for 

better alignment of land use and land-use conversion with data mapped for classification of carbon 

stocks and emission factors (e.g. on, vegetation type, soil type and/or management). This is particularly 

important for using higher tier emission estimation (see e.g. section 3.2.3). 

The geographically or spatially explicit land-use conversion data may be obtained by various sample 

based, survey based or wall-to-wall mapping methods, or combination of these methods (see Chapter 3 
in IPCC 20196 for guidance). Chapter 3 in IPCC 2019 provides detailed information and guidance on good 
practices and issues that need to be considered while using the spatially explicit approach. One of the 

important elements is that the spatial and temporal resolution of the used method is able to represent 

lands according the definition applied by the country. If the land use changes are tracked in a resolution 

that is not consistent with the spatial definitions used by the country, the IPCC guidance prescribes that 

it is good practice to apply additional methods to provide supplemental information and to demonstrate 

that the method does not systematically over- or underestimate emissions and removals. However, the 

minimum forest area as defined by the Member State and laid down in Annex II of the LULUCF 

Regulation directly links to the forest definition (Article 3.6 of the LULUCF Regulation) used in accounting 

6 Although the use of the 2006 IPCC guidelines is compulsory for inventory preparation, Chapter 3 of volume 4 of the 
2019 refinements to the 2006 IPCC guidelines provide much more detailed background information and guidance on 
land representation and particularly also in relation to spatially explicit approaches, including remote sensing which has 
seen many developments since the 2006 guidelines were drafted. For instance Chapter 3.3.3 of volume 4 of the 2019 
refinements gives detailed good practices for different types of methods (wall-to-wall, sample based or survey based 
methods) for land use and land-use change information. This information was not yet included in the 2006 guidelines. 
Therefore in this particular case the use of the 2019 refinement is recommended to be used.  
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of afforested land, deforested land and managed forest land. Therefore, to meet the compliance 

requirements the spatial resolution of the approaches used for assessing the land uses involving forest 

land should be able to represent this defined minimum forest area more strictly.  

Another important issue that needs to be considered when using Approach 3 is that the applied methods 

and data sources result in consistent time-series. It should be noted that consistent time series do not 

mean that all data need to be from the same source or obtained with the same remote sensing products 

and that in most cases it indeed will be necessary to combine data source. See Chapter 3.3.4 in IPCC 

(2019) on combining multiple data source to obtain further guidance. Also the Global Forest 

Observations Initiative provides methods and guidance for integrating information from different sources 

(GFOI 2020). Annex 3A.2.4 of IPCC (2019) provides good practices for ensuring time series consistency, 

with reference to techniques on time series consistency from Chapter 5 of Volume 1 of the 2019 

refinements of the 2006 IPCC guidelines. For instance overlap techniques from Chapter 5, Volume 1 of 

the guidelines can be used in cases where new higher resolution sensor data become available in more 

recent years. 

Reporting of GHG inventories for the first compliance period (2021-2025) start from 2023 when the year 

2021 is included in the reporting time series (starting in the base year, 1990 for most Member States). 

As a result, consistent and robust land use change time series in line with Approach 3 are required latest 

for the 2023 submission. These will need to cover the whole inventory from 1990 onwards for all land 

use and land-use change categories. In line with the 2006 IPCC guidelines (IPCC 2006b) Member States 

will need to transparently describe in their NIRs the used Approach 3 methodologies, the used data 

sources including information on for instance resolution of the mapping products, and information on 

approaches used to ensure time-series consistency (see Chapter 3.3. on representing land-use areas in 

IPCC (2006b), or better in IPCC (2019) for the details and good practices that need to be provided under 

specific circumstances).  

Typically this information should be provided in the following chapters of the NIR (i.e. in line with the 

current UNFCCC reporting guidelines on annual inventories for Parties included in Annex I to the 

Convention, UNFCCC decision 24/CP.19 of 2013): 

  Chapter 6.2. “Land-use definitions and the classification systems used and their correspondence 

to the land use, land-use change and forestry categories (e.g. land use and land-use change 

matrix)” and  

  Chapter 6.3. Information on approaches used for representing land areas and on land-use 

databases used for the inventory preparation.  

3.2.3 

Tier levels 

Part 3 of Annex V of the GR identifies the minimum requirement for the Tier levels of the methodologies 

from the 2006 IPCC guidelines that should be used for monitoring and reporting of LULUCF emissions 

and removals. 

The IPCC Guidelines (IPCC 2006a, b) differentiate between three levels of methodological complexity, 

indicated as Tier levels. “Tier 1” level uses the gain-loss method and default emission factors and other 

parameters provided by the IPCC, “Tier 2” level usually uses the same methodology as Tier 1, but 

applies country specific emission factors and parameters, while “Tier 3” level represents higher-order 

methods including models and national inventory information. Improving methodologies from Tier 1 to 

Tier 3 generally improves representation of national circumstances, improves the link between biomass 

and soil carbon dynamics and reduces the uncertainty of GHG estimates. 

Annex V, part 3 of the GR defines Tier 1 methodologies in accordance with the 2006 IPCC guidelines as 

the minimum requirement. This means that for all categories and emission sources/sinks emission and 

removal information should be calculated using at least default methods and data if those are available in 

the guidelines. 

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However, Article 5(4) of the LULUCF Regulation indicates that Member States may choose not to include 

in their accounts for each land accounting category changes in carbon stocks of a carbon pool that is not 

a source. Exceptions on this rule to not include changes in carbon stocks if they are not a source exist for 

above ground biomass, dead wood and harvested wood products in managed forest land. 

This, however, raises a number of questions. First, whether the “not a source” in Art 5(4) of the LULUCF 

Regulation relates to reported emissions and removals (UNFCCC) or to accounted emissions and 

removals (after applying the accounting rules for the accounting category). According to the definition of 

“source” in Article 3 (1) subparagraph 2 of the LULUCF Regulation, the word “source” when used in the 

LULUCF Regulation refers to emissions and not to accounted emissions. Also, the accounting rules are 

applied to the whole category (sum of the carbon stock changes of all pools in a land accounting 

category). Hence we conclude that this “not a source” exemption should relate to the direct carbon stock 

changes and not to accounted carbon stock changes. Thus carbon stock changes of carbon pools that do 

not result in a source of emissions may be excluded from the calculations of the accounting categories. 

To ensure time series consistency as referred to in the IPCC guidelines, the determination of whether a 

carbon pool is not a source of emissions should be based on the entire time series. When a carbon pool is 

a source for one or more years, it should be included for the entire time series. Moreover, also to make 

sure that calculations for reference period and accounting period are consistent as required by article 

5(1) of the LULUCF Regulation, excluding carbon pools should be done consistently over the whole time 

series as well as in the Forest Reference Level calculations if any of the permitted carbon pools is 

excluded from reporting managed forest land. 

Article 5(4) of the LULUCF Regulation refers in this respect to the calculation of the emissions and 

removals in the accounting categories. At the same time, according Annex V, part 3 of the GR which 

requires the use of at least tier 1 methods, Member States still will need to report in their national 

inventories the carbon stock changes in these pools that are considered to be “not a source”, while these 

pools subsequently may be excluded for accounting categories. This would result in an inconsistency 

between the UNFCCC reporting and reporting of the accounting categories in the compliance report. 

Applying this provision could result in excluding specific carbon pools from accounting that have a decline 

in removals between base/reference period and compliance period while including pools with increasing 

trends of removals, with the risk that Member States incorporate subjective choices (cherry picking) into 

the accounting.  

Further instructions on what to do in such cases would be required. The difference could be explained in 

an additional Annex to the NIR, or in an adapted format for the compliance report. It will need both 

quantitative information on removals to exclude for accounting and a justification for applying the “not a 

source” exemption. Alternatively, and clearly the simpler approach, will be to not make use of this 

accounting option. This will assure consistency with the reported quantities under the UNFCCC and avoid 

questions on subjectivity in the accounting.  

The GHG inventory also should be in accordance with the modalities, procedures and guidelines for the 

transparency framework for action and support referred to in Article 13 of the Paris Agreement and set 

out in the Annex to UNFCCC Decision 18/CMA.1 (Article 3(b) of the DA to the GR). In paragraph 32 of 

Decision 18/CMA.1 the use of the notation key “NE” (not estimated) is explained for cases where the 

estimates of emissions would be insignificant in terms of their level. Such emissions should be below 

0.05% of the total national total GHG emissions without LULUCF or less than 500 kilotonnes of CO2 eq. If 

a Member State would apply this option to report insignificant emissions for pools or categories for which 

Tier 1 methodologies exist, this would conflict with the requirement in Annex V of the GR to use at least 

tier 1 methodologies. Hence this provision of Decision 18/CMA.1 cannot be applied to the LULUCF sector.  

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Higher tiers for significant pools of key sources  

Part 3 of Annex V of the GR also indicates: “For emissions and removals for a carbon pool that accounts 

for at least 25-30 % of emissions or removals in a source or sink category which is prioritised within a 

Member State’s national inventory system because its estimate has a significant influence on a country’s 

total inventory of greenhouse gases in terms of the absolute level of emissions and removals, the trend 

in emissions and removals, or the uncertainty in emissions and removals in the land-use categories, at 

least Tier 2 methodology in accordance with the 2006 IPCC Guidelines for National Greenhouse Gas 

Inventories” 

This part indicates that higher tier methodologies (“at least Tier 2”) need to be applied for quantifying 

emissions and removals of a significant pool carbon pool of a key category.  

The text mirrors the definition for what is a key category from Chapter 4 of Volume 1 of the 2006 IPCC 

guidelines (IPCC 2006a). The need to use higher Tier methodologies for key categories, however, is 

restricted to those carbon pools that significantly contribute, i.e. at least 25-30%, to the emissions and 

removals in the key category. This concept of significant carbon pools is taken from the 2003 IPCC good 

practice guidance for LULUCF (IPCC 2003). While in Volume 4 (AFOLU) of the 2006 IPCC guidance this 

concept of significant pools is not defined any longer, the 25-30% contribution is retained in the decision 

trees which should be used for the identification of the appropriate tier level to be used in a given land 

remaining in the same land-use category, or for land converted to another land-use category (see figures 

1.2 and 1.3 in Chapter 1 of Volume 4 of the 2006 IPCC guidelines or Figure 3.1 below). Also these 

decision trees identify the use of Tier 2 data and methods as the minimum requirement to be applied for 

significant carbon pools in key categories. This means that in principle Member States currently should 

already meet this requirement in their national GHG inventories.  

For those carbon pools for which Member States still use Tier 1 methods and data, the Member State will 

need to show that it is part of a land use category that is not a key source, or if the category is a key 

source or sink that the specific carbon pool is not significantly contributing to the emissions or removals 

of the category. Results of the key category analyses should be presented in the NIR and CRF (Table 7), 

as currently is already required by the UNFCCC. If a carbon pool’s contribution to a key source is not 

considered to be significant, this should be justified transparently in the NIR chapter on LULUCF. This 

could be presented for instance in the section describing the general methodology and coverage of the 

sector. 

Reporting of the GHG inventories following the rules of the GR will start in 2023 with the inventory report 

covering the period 1990-2021. As a result the minimum Tier level requirements need to be 

implemented for the NIR 2023. Since the Tier requirements indicated in part 3 of Annex V of the GR 

relate to the national GHG inventories this means that also reporting of the wetlands categories needs to 

meet these requirements by 2023, even if the Member State has chosen to not account for managed 

wetlands during the first compliance period.  

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Figure 3.1. Decision tree for identification of appropriate tier level for land remaining in the same land-

use category, using Forest Land Remaining Forest Land as an example. Source: Figure 1.2 in Chapter 1 

of Volume 4 of the 2006 IPCC guidelines (IPCC 2006b). 

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Tier 3 level encouraged 

Nevertheless Member States are encouraged to apply Tier 3 methodologies in accordance to the 2006 

IPCC guidelines. Such Tier 3 methodologies and emission factors will improve the representation of 

national circumstances, improve the link between biomass and soil carbon dynamics and reduces the 

uncertainty of GHG estimates. Moreover Tier 3 methodologies are better able to reflect the mitigation 

effects of policies and measures implemented by Member States.  

Where (spatially explicit) monitoring tools and sampling programs are not able to provide annual data, 

these should be supplemented by other tools and information (models, remote sensing) to provide 

accurate information for the years in between the available monitoring information to provide accurate 

annual data for those years. This will improve the evidence base for reaching of the targets and 

accounted emissions and removals. This is improved evidence base is also considered to be important 

because the flexibilities that allow to transfer accounted removals with the ESR and other Member 

States. 

It should be noted that there is no need to progress to Tier 2 before improving methodologies to Tier 3. 

In many cases it is probably even more cost-effective to move from Tier 1 to Tier 3 directly than first 

producing a Tier 2 methodology before moving to Tier 3. 

3.2.4  30 year conversion period consistent with IPCC 

The standard conversion period during which units of land that are converted to another land use type 

are reported under the UNFCCC “land converted to” category (e.g. cropland converted to grassland) is 20 

years (IPCC 2006b). This is also the conversion period that must be used for the land accounting 

categories under the LULUCF Regulation (Article 5(3)), with the exception of the land accounting 

category afforested land (i.e. UNFCCC’s “land converted to forest land”) where a 30 year conversion 

period may be applied if duly justified based on IPCC guidelines (LULUCF Regulation Article 6(2)). In 

such case, a unit of cropland, grassland, wetland, settlement or other land that is converted to forest 

land is reported under “land converted to forest land” and accounted under afforested land for 30 years 

after conversion and after these 30 years will be reported under “forest land remaining forest land” and 

accounted under managed forest land.  

Since afforested land is accounted gross-net (Article 6(1) of the LULUCF Regulation), i.e. all emissions 

and removals in a given year are counted and managed forest land is accounted against a forest 

reference level, moving from the 20 year to a 30 year conversion period will have an effect on the total 

accounting outcome. The same amount of removals will create more credits under afforested land than 

under managed forest land, where the removals are accounted against the removals according the forest 

reference level. Some interpretations of this rule have suggested that this could be a way to increase 

credits from forest land, particularly for Member States that had high afforestation rates 20-30 years ago 

(see e.g. Böttcher et al. 2019).  

Article 6(2) of the LULUCF Regulation, however, also requires that the choice of a 30 year conversion 

period should be duly justified based on the IPCC guidelines. Land converted to forest land is covered in 

Chapter 4.3 of Volume 4 of the 2006 IPCC guidelines (IPCC 2006b). Regarding the issue of the duration 

of the conversion the IPCC guidelines provide the following direction: “Land Converted to Forest Land is 

covered in this section of the national greenhouse gas inventory until the time the soil carbon in new 

forests reach a stable level. A default period of 20 years is suggested. Forest ecosystems may require a 

certain time to return to the level of biomass, stable soil and litter pools of undisturbed state. With this in 

mind and as a practical matter, the default 20-year time interval is suggested. Countries also have an 

option to extend the length of transition period. After 20 years or other time interval chosen, the 

converted lands become forest, i.e., the land areas are transferred from the Land Converted to Forest 

Land category to Forest Land Remaining Forest Land, where areas still becoming established can be 

treated as a separate stratum if necessary.” 

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From this it is clear that the choice for a 30 year conversion period would only be justified based on the 

IPCC guidelines if this choice is supported by data or information indicating that soil carbon in new 

forests does not reach a stable level within the default 20 years transition period. This also implies that 

this provision to use the 30 year conversion period can only be used if at the same time carbon stock 

changes in soils of land converted to forest land is reported using higher tier levels (as the default Tier 1 

assumes 20 years). 

In their NIR Member States will need to provide supporting information that justifies the use of the 30 

years transition period using data and information of dynamics in soil carbon after afforestation 

conversions. This should include an analysis of data showing that after afforestation at least for some of 

its stratified forest-soil combinations the carbon stocks in soil are not stable yet 20 years after the 

conversion. 

3.3 

Reporting of approximated GHG inventories (Article 26(2) of the GR) 

The reporting format for approximated GHG inventories is provided in Annex VI of the IA to the GR. It 

asks for reporting total net emissions per gas (CO2, CH4 and N2O) aggregated at the level of the main 

land-use categories; forest land, cropland, grassland, wetlands, settlements, other land, harvested wood 

products and other. This is a similar aggregation level as in Summary table 2 of the CRF reporter.  

The legal texts do not provide detailed requirements for the approximated GHG inventories. Recital 7 of 

the IA indicates that the approximated inventory information should represent a top-level summary of 

the sectoral scope of the full GHG inventory which should ensure that the emission and removal 

estimates reported in the approximated inventory for the year x-1 are consistent with the greenhouse 

gas inventory estimates reported in the year x-2. As a result the methodologies to calculate the 

approximated GHG inventory should be the same as for the total annual GHG inventories. Hence the 

same rules and requirements as for the GHG inventory apply, including the greenhouse gases and carbon 

pools covered (section 3.2.1), the use of geographically explicit land use conversion data (section 3.2.2), 

and the use of Tier levels (section 3.2.3). 

Where updated monitoring data are available for the year x-1, these should be included in the 

calculations of the approximated inventory, otherwise interpolations or estimates on the basis of recent 

information may be used.  

3.4 

Reporting of GHG Inventories (Article 26(3) of the GR and Article 18 of the LULUCF 

Regulation) 

The GHG inventories shall be determined using the 2006 IPCC guidelines (DA to the GR, Article 3(a)) and 

the modalities, procedures and guidelines for the transparency framework for action and support referred 

to in Article 13 of the Paris Agreement and set out in the Annex to UNFCCC Decision 18/CMA.1 (DA to 

the GR, Article 3(b)). This means that on the basis of this UNFCCC decision Member States are 

encouraged to use the 2013 wetland supplement to the 2006 IPCC guidelines (IPCC 2014b). 

Additionally the UNFCCC Decision18/CMA.1 prescribes the use of the 100-year time horizon GWP values 

from the IPCC Fifth Assessment Report. These global warming potentials to be used, also listed in the 

Annex to the DA, are 28 for CH4 and 265 for N2O. These differ from the GWP values that are used for the 

inventories up to the 2022 inventory reports (reported year 2020), which are still based on the 100-year 

time horizon GWP values from the IPCC Fourth Assessment Report. 

Annex V of the GR lists the information that needs to be provided for the GHG inventories. The elements 

that are relevant for LULUCF are the following: 

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  Point a): Anthropogenic emissions of GHG listed in Annex V, part 2 of the GR. These include CO2, CH4 

and N2O, i.e. the gases that are relevant to LULUCF inventory reporting and are also listed in Annex I, 

part A in the LULUCF Regulation. See section 3.2.1 for the content expected from this provision. 

  Point c): anthropogenic emissions and removals of CO2 resulting from LULUCF, using the 

methodologies in Part 3 of Annex V to the GR. The requirements and expected content based on this 

point are provided in section 3.2.2 (geographically explicit land use conversion data) and 3.2.3 (Tier 

levels for methodologies) 

  Point d): changes in the reported emissions in the time series between 1990 and the year x-3 

compared to the previous submission, with explanation of the reason for the change. 

This is also part of the UNFCCC requirements to be presented in the national inventory reports. The 

recalculations of the time series until the year x-3 need to be provided in the CRF Table 8s2. 

Additionally the reasons for the recalculations need to be provided and are described in the NIR in the 

section on changes in the current year and recalculations for the years previously reported in the 

LULUCF chapter. The changes leading to recalculations may relate to methodological changes, new or 

improved data, e.g. trend projections or modelled data that are replaced by newly available 

monitoring data, or error corrections. 

Member States use the Common Reporting Format (CRF)  tables to report on their GHG inventories. In 

practice, all reporting templates are included in an online platform (CRF Reporter). This tool is provided 

and maintained by the UNFCCC Secretariat. 

3.5 

Reporting on Policies and measures for LULUCF (Article 18 and Annex VI of the GR and 

Article 18 of the LULUCF Regulation) 

Member States need to report by 15 March 2021 and every two years after information on policies and 

measures and on projections. Policies and measures in this context refer to national and EU policies and 

measures (or groups of measures) that limit or reduce a Member State’s emissions by sources or 

enhance removals by sinks. This is a general activity covering all emission sectors, including LULUCF. For 

LULUCF this replaces the previous Article 10 reports from LULUCF decision 529/2013. In the reporting of 

ex ante and ex post assessments of the effect of (groups of) policies and measures on the mitigation of 

climate change, a distinction has to be made between the emissions covered by the ETS, ESR and 

LULUCF Regulation. 

Next to general information on the national system for reporting on policies and measures the reports 

more specifically need to include the following information, which should be organised on a sectoral basis 

and by greenhouse gas. The information should be provided in the format provided in Annex XXIV to the 

IA of the GR, 

(i) 

the objective of the policy or measure and a short description of the policy or measure. For 

LULUCF the objectives to choose from include: afforestation and reforestation; conservation of 

carbon in existing forests; enhancing production in existing forests; increasing the harvested 

wood products pool; enhanced forest management; prevention of deforestation; strengthening 

protection against natural disturbances; substitution of GHG intensive feedstocks and materials 

with harvested wood products; prevention of drainage or rewetting of wetlands; restoration of 

degraded lands; other LULUCF (Table 1 of Annex XXIV to the IA of the GR), 

(ii) 

(iii) 

(iv) 

the type of policy instrument;  

the status of implementation of the policy or measure or group of measures;  

indicators used to monitor and evaluate progress over time; 

(v)  where available, quantitative estimates of the effects on emissions by sources and removals by 

sinks of GHGs broken down into:  

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 

the results of ex ante assessments of the effects of individual or groups of policies and 

measures on the mitigation of climate change. Estimates shall be provided for a sequence of 

 

 

four future years ending with 0 or 5 immediately following the reporting year.  

the results of ex post assessments of the effects of individual or groups of policies and 

measures on the mitigation of climate change where available 

the results of the ex ante and ex post assessments need to be presented, per pillar (ETS, 

ESR or LULUCF) in Table 2 of Annex XXIV to the IA of the GR, where for LULUCF the effect 

on limiting emissions by sources and enhancing removals by sinks should be indicated in 

terms of net accounted emissions and removals.  

(vi) 

available estimates of the projected costs and benefits of policies and measures, as well as 

estimates of the realised costs and benefits of policies and measures (in Table 3 of Annex XXIV 

to the IA of the GR);  

(vii)  all existing references to the assessments of the costs and effects of national policies and 

measures, to information in the implementation of Union policies and measures that limit or 

reduce GHG emissions by sources or enhance removals by sinks and to the underpinning 

technical reports (in Table 1 of Annex XXIV to the IA of the GR);  

(viii)  an assessment of the contribution of the policy or measure to the achievement of the long-term 

strategy referred to in Article 15 of the GR; 

For LULUCF also information on additional national policies and measures that are planned with the aim 

to enhance the result of accounted emissions and removals beyond the no debit commitment in the 

LULUCF Regulation need to be describe in textual format. 

Information on the link between the different reported policies and measures and how they contribute to 

the different projection scenarios needs to be described in textual format. 

3.6 

Reporting on projections for LULUCF (Article 18 and Annex VII of the GR and Article 18 

of the LULUCF Regulation) 

With the report on policies and measures information on projections needs to be provided, too. 

Projections should cover: 

a)  projections without measures where available, projections with measures, and, where available, 

projections with additional measures;  

b)  total GHG projections and separate estimates for the projected GHG emissions for the emission 

sources covered by the ETS, ESR and the projected emissions by sources and removals by sinks 

under the LULUCF Regulation; 

c) 

the impact of policies and measures identified as part of Article 18(1), see above in section 3.5. 

Where such policies and measures are not included, this shall be clearly stated and explained;  

d)  results of the sensitivity analysis performed for the projections and information on the models and 

parameters used;  

e)  all relevant references to the assessment and the technical reports that underpin the projections 

referred to in Article 18(4) of the GR. 

The results of the LULUCF projections need to be provided for each gas for the reference year, and years 

t-5, t, t+5, t+10 and t+15, both for the reported GHG emissions and removals for each of the land-use 

change categories (Table 1a or 1b included in Annex XXV of the IA of the GR, where Table 1b only needs 

to be filled if Table 5a is not filled in full) and the accounted GHG emissions and removals for each of the 

land-use change categories as part of a land accounting category (Table 5a in Annex XXV of the IA of the 

GR).  

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Additional supplementary information on variables used for the projections (either input or output) needs 

to be provided in Table 3 (in Annex XXV of the IA of the GR) for the reference year, t-5, t, t+5, t+10 and 

t+15. For LULUCF this includes the following information, and units: 

Managed forest land 

 

 

 

 

 

Forest harvest removals for energy use (1000 m3) 
Forest harvest removals for non-energy use (1000 m3) 
Forest increment (1000 m3) 
Forest disturbances included in modelling (Yes / No) 

Area of forest land remaining forest land (1000 ha) 

Afforested land 

 

 

 

 

Forest harvest removals for energy use (1000 m3) 
Forest harvest removals for non-energy use (1000 m3) 
Forest increment (1000 m3) 
Area for each of the land use conversions that is part of afforested land (1000 ha) 

For managed cropland, managed grassland and managed wetlands 

 

Area for the land use conversions that are is part of the accounting category (1000 ha) 

Harvested wood products 

  Gains of Harvested wood products (kt C), may include HWP from managed forest land and 

afforested land 

 

Losses of Harvested wood products (kt C) , may include HWP from managed forest land and 

afforested land 

  Half-life of Harvested wood products (years), for each of the HWP types in separate rows. 

Modelling 

The modelling efforts for the projections should be able to capture the effects of the identified policies 

and measures. For the LULUCF sector this may imply a substantial modelling effort to cover interactions 

and trade-offs between policies and measures affecting requirements for land. Modelling approaches that 

may need to be applied include land-use modelling, modelling of effects of land use conversions and 

management activities on soil carbon, and projections of forest resources. It is recommended to assess 

available capacities in Member States to undertake such modelling exercises and identify possible needs 

for capacity development or knowledge exchange at an early stage. 

3.7 

Reporting on final accounted emissions and removals (Article 26(5) of the GR and 

Article 14(1) of the LULUCF Regulation) 

Member states report by 15 March 2027 and by 15 March 2032 final GHG inventory data with accounting 

information relevant for their compliance with the LULUCF Regulation.  

The format to report on the accounted emissions and removals is provided in Annex XX to the IA of the 

GR. As a result of the direct link between the land use conversion categories in the national greenhouse 

gas inventories most of these data directly follow from the data submitted in the CRF tables that are 

included with the inventory. Nevertheless, there are a number of inconsistencies between the default 

structure of the CRF tables and the data required to fill the Table 1a of Annex XX. These will be 

addressed in sections 3.7.1 and 3.7.2 below. Also the accounting formats require separate reporting on 

harvested wood products from managed forest land and afforested land. In the current inventory 

reporting this distinction is not made. This issue is addressed in section 3.7.3. 

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Additionally the accounting requires information on emissions from natural disturbances to be excluded 

from the accounting of managed forest land or afforested land. These requirements are discussed in 

section 3.7.4 below. 

3.7.1  Conversions to wetlands are not reported explicitly in default CRF tables 

In the Common Reporting Format (CRF) that is used to report data on the wetland land-use category, in 

contrast to the other land use categories, the category 4.D.2 Land converted to Wetlands is not 

subdivided into the other land use categories converted to wetlands (e.g. forest land converted to 

wetlands, cropland converted to wetlands, etc). These subdivisions, however, are relevant for the 

accounting categories deforestation (forest converted to wetlands), managed cropland which includes 

cropland converted to wetlands, managed grassland which includes grassland converted to wetlands and 

finally also for managed wetlands, which includes:  
  Wetlands remaining wetlands 
 
  Other land converted to wetlands. 

Settlement converted to wetlands,  

Instead of being subdivided into conversions of other land use categories to Wetlands, the information 

requested to be reported in the Wetland CRF table 4.D is subdivided in: 4.D.2.1 Land converted to peat 

extraction, 4.D.2.2 Land converted to flooded land and 4.D.2.3 Land converted to other Wetlands (see 

Table 3.2 for an illustration).  

Table 3.2. A fragment from CRF Table 4.D from the EU 2020 submission below illustrates this issue. This 

is the default structure of the CRF table. 

Nevertheless, as they are required to report geographically-explicit land-use conversions (approach 3) 

under Article 26 of the GR and its Annex 3, Member States should have the required information 

available. In order to comply with the LULUCF Regulation Member States will need to transparently 

report on the required land use conversions to wetlands. They would have two options to do this. They 

could include the disaggregated information for all land conversions either in the CRF or in an additional 

separate report. 

The first option would require Member States to include the additional information in the CRF reporter. 

The CRF reporter allows the inclusion of additional disaggregated land use conversions (see for example 

Table 3.3 for Germany, but also many other Member States in their 2020 submission already provided 

this subdivision for relevant land converted to wetlands categories). To this end, Member States would 

need to manually create the relevant conversion categories in the CRF reporter and adjust the way they 

fill the CRF tables. 

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D. Total wetlands1. Wetlands remaining wetlands1.1  Peat extraction remaining peat extraction1.2 Flooded land remaining flooded land1.3 Other wetlands remaining other wetlands (7) 2. Land converted to wetlands(8)2.1 Land converted to peat extraction2.2 Land converted to flooded land2.3 Land converted to other wetlandsLand-use category 
 
 
 
  
 
 
 
 
 
Table 3.3. A fragment from CRF Table 4.D from the 2020 submission of Germany illustrating the option 

to manually include subdivisions for the different land use conversions in land converted to wetlands. 

Land converted to peat extraction has the notation key IE, indicating that the land conversions have 

been included elsewhere. 

In the case Member States do not want to make these changes to the CRF reporter, an additional table 

with the required information could be added in an annex to the NIR that goes only to the EU. Also the 

table in Annex XX of the Implementing Act of the GR on Reporting on accounted emissions and removals 

pursuant to Article 24 explicitly asks for this information to be provided. 

From a legal perspective, according to Article 26(7) the Commission can propose in its implementing acts 

to determine the structure, technical details, format and processes for the Member States' submission of 

GHG inventories. In this process the Commission is to “take into account” the UNFCCC and Paris 

Agreement requirements. This means that the Commission is not bound to implement the international 

requirements without any change or adjustment. According to this legal basis for implementation, the 

Commission can include a table in the GR Implementing act requiring the information needed.  

By doing so, the Commission would not infringe its mandate for an implementing act as it is not adding 

substantial obligations to the adopted legislation. Thus, the information to be reported in the tables is 

already required by the primary legislation: the LULUCF Regulation is explicit on the definition of the 

accounting categories and Article 26, Annex 3 of the GR requires Member States to report data using 

geographically-explicit land-use conversions. 

3.7.2  Non-disaggregated reporting of CH4 and N2O gases for land conversions  

In the CRF tables of the LULUCF sector (Sector 4) with roman numbers do not always include the 

subdivision in land-use categories as needed to separate the land accounting categories as required by 

the LULUCF Regulation. For instance the aggregated data reported as “land converted to wetlands” or 

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D. Total wetlands1. Wetlands remaining wetlands1.1  Peat extraction remaining peat extraction1.2 Flooded land remaining flooded land1.3 Other wetlands remaining other wetlands (7) 2. Land converted to wetlands(8)2.1 Land converted to peat extraction2.2 Land converted to flooded land4.D.2.2.1  Forest land converted to flooded land4.D.2.2.2  Cropland converted to flooded land4.D.2.2.3  Grassland converted to flooded land4.D.2.2.4  Settlements converted to flooded land4.D.2.2.5  Other land converted to flooded land2.3 Land converted to other wetlands4.D.2.3.1  Forest land converted to other wetlands4.D.2.3.2  Cropland converted to other wetlands4.D.2.3.3  Grassland converted to other wetlands4.D.2.3.4  Settlements converted to other wetlands4.D.2.3.5  Other land converted to other wetlandsLand-use category 
 
 
 
 
 
 
 
 
 
land converted to Settlements may enter in different land accounting categories that have different 

accounting rules. 

In the standard version of CRF Table4(I) (see example in Table 3.4 below), all land converted categories 

are reported in one aggregated category. This potentially creates a problem because different accounting 

rules apply for the underlying land use conversions (e.g. for forest land converted to wetlands the 

deforestation accounting rules apply, while for cropland converted to wetlands the managed cropland 

rules apply, etc). However, at this moment, this may not be an issue since all Member States (see Table 

3.4) report IE and NO for the land converted to categories that would be divided over more different 

accounting categories (land converted to wetlands and land converted to settlements). Member States 

likely have a general statistic on fertilizer use and include this to category 3D.a.1 (inorganic) and 3D.a.1 

(organic) in the agriculture sector. 

Table 3.4. A fragment from CRF Table 4.(I) from the EU 2020 submission7 below illustrates this issue.  

Similar issues apply to CRF Table 4(II), Table 4(III), Table 4(V), where in the default set-up of the CRF 

reporter there are no or not all required subdivisions included for the different land use conversions that 

may be covered by different accounting rules. In the case of CRF Table 4(II) on emissions and removals 

from drainage and rewetting and other management of organic and mineral soils the default outline is 

even aggregated at the main land-use type without subdivision between “remaining” and “converted to”  

Here again, like in the previous issues described in section 3.7.1, some Member States manually 

specified specific ‘child nodes’ for the various land use conversions. So, from a technical perspective, 

Member States could report on the disaggregated data in the CRF Reporter itself (see for example Table 

7 https://unfccc.int/documents/227990 
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TABLE 4(I)   SECTORAL BACKGROUND DATA FOR LAND USE, LAND-USE CHANGE AND FORESTRYInventory 2018Submission 2020 v2EUROPEAN UNIONGREENHOUSE GAS SOURCE AND SINK CATEGORIESACTIVITY  DATA   AND  OTHER  RELATED  INFORMATIONIMPLIED EMISSION FACTORSEMISSIONS(4)ValueN2O–N emissions per unit of N-inputN2Okg N/yrkg N2O–N/kg N(3)(kt)Total for all land use categories12424324.440.010.20A. Forest land(5)11303329.440.010.181. Forest land remaining forest land10833159.000.010.171.   Inorganic N fertilizers(6)10833159.000.010.172.  Organic N fertilizers(7)IE,NA,NE,NOIE,NA,NE,NOIE,NA,NE,NO2. Land converted to forest land470170.440.010.011.   Inorganic N fertilizers(6)470170.440.010.012.  Organic N fertilizers(7)IE,NA,NOIE,NA,NOIE,NA,NOD. Wetlands(5)NO,IENO,IE,NANO,IE,NA1. Wetlands remaining wetlandsNO,IENO,IE,NANO,IE,NA1.   Inorganic N fertilizers(6)IE,NOIE,NA,NOIE,NA,NO2.  Organic N fertilizers(7)IE,NOIE,NA,NOIE,NA,NO2. Land converted to wetlandsNO,IENO,IE,NANO,IE,NA1.   Inorganic N fertilizers(6)IE,NOIE,NA,NOIE,NA,NO2.  Organic N fertilizers(7)IE,NOIE,NA,NOIE,NA,NOE. Settlements(5)1120995.000.010.021. Settlements remaining settlements1120995.000.010.021.   Inorganic N fertilizers(6)IE,NA,NOIE,NA,NOIE,NA,NO2.  Organic N fertilizers(7)1120995.000.010.022. Land converted to settlementsNO,IE,NANO,IE,NANO,IE,NA1.   Inorganic N fertilizers(6)IE,NA,NOIE,NA,NOIE,NA,NO2.  Organic N fertilizers(7)IE,NA,NOIE,NA,NOIE,NA,NOH. Other (please specify)(5) (8)NA,NONA,NE,NONA,NE,NODirect nitrous oxide (N2O) emissions from nitrogen (N) inputs(1) to managed soilsLand-use category(2) 
 
 
 
 
 
 
 
 
                                                 
3.5 and Table 3.6). Alternatively they could include this in a separate table to be included in the NIR or 

as a separate table to be reported only to the Commission.  

Table 3.5. A fragment from CRF Table 4.(III)) from the EU 2020 submission (this would be the default 

structure from the CRF reporter).  

CRF Table 4(IV) on indirect N2O emissions from managed soils does only require totals to be provided 

without any subdivisions at all. These emissions for cropland and grassland are included in the 

agriculture sector and reported in table 3.D(b) and also if the sources of nitrogen cannot be separated 

other than between cropland and grasslands they should be included in the agriculture sector and 

reported in table 3.D(b) (most Member States indeed report IE in this CRF table). In this case we could 

not assess if additional child nodes can be defined for the emission sources included. The Member States 

that at the moment (i.e. based on the NIR 2020) report emissions in this table only report total 

emissions, in most cases only relating to emissions related to forest land. If child notes indeed cannot be 

created Member States should report these emissions subdivided per land-use change subcategory in a 

separate table in their NIR or as a separate table to be reported only to the Commission. 

From a legal perspective, according to Article 26(7) the Commission can propose in its implementing acts 

to determine the structure, technical details, format and processes for the Member States' submission of 

GHG inventories. In this process the Commission is to “take into account” the UNFCCC and Paris 

Agreement requirements. This means that the Commission is not bound to implement the international 

requirements without any change or adjustment. According to this legal basis for implementation, the 

Commission can include a table in the GR Implementing act requiring the information at the level of 

disaggregation needed. 

By doing so, the Commission would not infringe its mandate for an implementing act as it is not adding 

substantial obligations to the adopted legislation. Thus, the information to be reported in the tables is 

already required by the primary legislation: the LULUCF Regulation is explicit on the definition of the 

accounting categories and Article 26, Annex V of the GR requires Member States to report data using 

geographically-explicit land-use conversions. Furthermore, Article 2 of the LULUCF Regulation makes 

clear that it applies to all the gases covered by the GR and not to their aggregated CO2 equivalent. 

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GREENHOUSE GAS SOURCE AND SINK CATEGORIESTotal all land-use categories ........D. Wetlands1. Wetlands remaining wetlands2. Lands converted to wetlands(5)E. Settlements 1. Settlements remaining settlements2. Lands converted to settlements(5)Land-use category(2) 
 
 
 
 
 
 
 
 
 
 
Table 3.6. A fragment from CRF Table 4.(III)) from the 2020 submission of Germany.  

3.7.3 

Information reported on HWP for Afforested land (AFL), Managed Forest land (MFL) and 

deforested land (DL) 

Wood can go to the HWP pool from afforested land (which should be accounted according the AFL 

accounting rules) or Managed Forest land (which should be accounted according the MFL accounting 

rules (FRL)). Even though the conversion times of 20 and 30 years are relatively short for expecting 

large amounts of wood to be harvested from afforested land, in some short rotation systems harvests 

may occur before the forest areas is considered under managed forest land. Also thinning harvests may 

occur within this time frame, but where these are used as fuel wood the carbon still will not enter the 

HWP pool.  

In the current KP reporting this distinction between HWP from Afforestation, Deforestation and Forest 

Management is explicitly asked for (CRF Table 4(KP-I)C), but this is not the case for the convention 

reporting (CRF Table 4.Gs1). Therefore it will not be possible to distinguish in the CRF table the HWP 

gains and losses between AFL, DL and MFL. Even though Member States may be able to differentiate, 

they are not able to provide this information in the CRF. This will require Member States to additionally 

report on the different accounting classes.  

Annex V of the LULUCF Regulation under methodological issues indicates: If it is not possible to 

differentiate between harvested wood products in the land accounting categories of afforested land and 

managed forest land, a Member State may choose to account for harvested wood products assuming 

that all emissions and removals occurred on managed forest land. However, this is an exception and not 

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GREENHOUSE GAS SOURCE AND SINK CATEGORIESTotal all land-use categories ........D. Wetlands1. Wetlands remaining wetlands2. Lands converted to wetlands(5)4.D.2.1  Forest land converted to wetlands4.D.2.2  Cropland converted to wetlands4.D.2.3  Grassland converted to wetlands4.D.2.4  Settlements converted to wetlands4.D.2.5  Other land converted to wetlandsE. Settlements 1. Settlements remaining settlements2. Lands converted to settlements(5)4.E.2.1  Forest land converted to settlements4.E.2.2  Cropland converted to settlements4.E.2.3  Grassland converted to settlements4.E.2.4  Wetlands converted to settlements4.E.2.5  Other land converted to settlementsLand-use category(2) 
 
 
 
 
 
 
 
 
a rule, as indicated by the introduction of the sentence by “if”. Should the legislator consider that 

differentiating between HWP in the different accounting categories is not possible, it would have made it 

simply a rule without introducing it by “if”. 

Table 1a of Annex XX of the IA to the GR requests the allocation of HWP emissions and removals to 

afforested land and managed forest to be included as part of the Compliance Report to be reported at the 

end of each compliance period.  

3.7.4  Natural disturbances 

Member states may exclude in the accounting of afforested land and managed forest land the emissions 

from natural disturbances that exceed an average background level in the period 2001-2020. In the GHG 

inventory reporting under the UNFCCC there are currently no provisions for reporting natural 

disturbances. In the CRF current convention tables there is no place to report on natural disturbances. 

This information is currently included in the KP tables, which will become obsolete. 

Member States that wish to use the provision to exclude emissions from natural disturbances in 

accordance with Article 10 of the LULUCF Regulation therefore will need to provide in their compliance 

reports the information that is required to fill Table 2 of Annex XX of the IA to the governance regulation. 

This information will need to be provided in the compliance report. This information will also be subject 

to the review at the end of each compliance period in order to ensure that the methodology is followed. 

The information on the calculation of the background level and the margin, for which methodological 

rules are provided in Annex VI of the LULUCF Regulation, need to be reported in the NIR (footnote 7 to 

Table 2 of Annex XX of the IA to the governance regulation). Also detailed explanations on how the 

subsequent removals to be excluded from accounting are calculated needs to be provided in the NIR. The 

location where the information can be found in the NIR needs to be provided in a document box that is 

part of table 2 of Annex XX of the IA. From this it is not clear where in the NIR this should be included, 

but the most straightforward approach would be to include an annex to the NIR in which all the required 

information related to natural disturbances is included. This information should be included at least in the 

final inventory data that is submitted to the Commission by 15 March 2027 and/or 15 March 2032. 

For the background level, the following information shall be provided (Annex VI of the LULUCF 

Regulation: 

 

 

 

 

historical levels of emissions caused by natural disturbances; 

the type(s) of natural disturbance included in the estimation; 

total annual emissions estimations for those natural disturbance types for the period from 2001 

to 2020, listed by land accounting categories; 

a demonstration of the time series consistency in all relevant parameters, including minimum 

area, emission estimation methodologies, coverages of carbon pools and gases 

The background level and its margin then need to be calculated using the iterative approach provided in 

Annex VI (point 2). This approach is similar to the approach for defining the background level under the 

LULUCF reporting under the Kyoto Protocol. The requirement that the margin should be equal to a 95% 

probability level is the same as the requirement under the Kyoto Protocol provision that the margin 

should equal twice the standard deviation of the time series defining the background level. 

In general the methodology and guidance on documenting and calculating the background level and 

margin as provided in section 2.3.9 of the 2013 IPCC KP supplementary methods (IPCC 2014a) can still 

be used (but note differences in definitions of lands). The guidance on the background level in section 

2.3.9.6 of the IPCC guidelines also provides guidelines for alternative methods, but Annex VI of the 

LULUCF Regulation specifically describes the iterative approach for excluding statistical outliers, which 

would be the default method in the 2013 IPCC KP supplement. The MS Excel tables that the Commission 

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provided through Working Group 5 to support Member States to calculate the background level and 

margin for natural disturbance for their KP reporting could also be used under the LULUCF Regulation. 

When using the provision for excluding natural disturbances the following emissions on the areas of the 

natural disturbances should not be excluded (Annex VI of the LULUCF Regulation, point 3):  

 

 

 

emissions from harvesting and salvage logging activities that took place on land following the 

occurrence of natural disturbances,  

emissions from prescribed burning that took place on land in any year during the compliance 

periods, and  

emissions on lands that were subject to deforestation following the occurrence of the natural 

disturbance. 

Information on how these emissions have been calculated and removed from the excluded emissions 

needs to be provided in the NIR. 

If a country decides to exclude emissions from natural disturbances, the following further information has 

to be reported to the Commission (Annex VI of the LULUCF Regulation):  

 

 

 

identification of all land areas affected by natural disturbances in that particular year, including 

their geographical location, the period and types of natural disturbances 

evidence that no deforestation has occurred during the rest of the period from 2021 to 2025 or 

from 2026 to 2030 on lands that were affected by natural disturbances 

a description of verifiable methods and criteria to be used to identify deforestation on those 

lands in the subsequent years of the period from 2021 to 2025 or from 2026 to 2030 

Again the 2013 IPCC KP supplement provides guidelines on how this information and evidence can be 

provided transparently. Evidence needs to be provided in the NIR as well. 

3.7.5 

Technical corrections to the forest reference level 

Technical corrections are needed to ensure consistency between the data and methods used for 

determining the adopted forest reference levels and the data and methods used for reporting managed 

forest land at the point of compliance. 

Such technical corrections would be needed if changes in the data and methods for reporting managed 

forest land have occurred. Also the “Guidance on developing and reporting Forest Reference Levels in 

accordance with Regulation (EU) 2018/841” (Forsell et al. 2018) specifies cases where a technical 

correction would be required. An important reason for a technical correction is to consider the area 

development and changes to strata that actually took place during the compliance period. Either of the 

approaches on dealing with changes in the managed forest land area provided in the guidance document 

will require such technical correction.  

Since the technical correction will need to consider the actual land use changes to and from managed 

forest land. This can only be done once the changes over the first compliance period 2021-2025 are 

known by early 2026. Possible spatially explicit data then still needs to be processed and land use 

conversions need to be assessed. Next, based on the actual changes in the area of managed forest land 

an estimate of the difference to the adopted FRL needs to be calculated and documented. This process 

will probably take some time. However, for accounting managed forest land a technical correction for the 

first compliance period needs to be submitted to the Commission latest by 15 January 2027. This means 

that Member States should start with assessing the technical correction and process the land-use 

conversion data as soon as possible. 

Currently in the legislation there are no provisions included on how the technical correction of the FRL 

should be submitted and whether this should be covered by an updated National Forest Accounting Plan. 

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For transparent reporting and accounting at least a description of the data uses and the applied 

methodologies would be required. The legal texts do not include specific provisions for reviewing the 

technical corrections in the context of the FRL. It could be part of the comprehensive review, but this will 

probably call for additional resources and a team of technical experts focussing on the technical 

assessment of the submitted technical corrections of the FRL. Alternatively this could also be organised 

as dedicated sessions of Working Group 5 of the Climate Change Committee. In that case timing will be 

important as many experts probably also are involved in the inventory preparation of the Member States 

may be busy delivering and updating the inventories until 15 March. 

3.7.6  Calculation of the 3.5% cap on accounting emissions and removals in managed forest land 

Article 8(2) of the LULUCF Regulation puts a cap on part of the emissions and removals that can be 

included in the accounting of managed forest land. Where, after applying the accounting rules for 

managed forest land, net removals exist in the managed forest land accounting category, a maximum 

amount that is equivalent to 3.5% of the emissions of that Member State in its base year may be 

included in its managed forest land accounts. Net removals resulting from the carbon pools of dead wood 

and HWP, except the category of paper, in the land accounting category of managed forest land are not 

subject to this cap.  

The legal text of Article 8(2), however, raises a number of questions that make it difficult to apply in an 

unambiguous way. The first issue relates to the calculation of the 3.5% cap itself. The text indicates 

3.5% of the emissions of the Member State in its base year or period, where emissions is understood as 

total GHG emissions. Yet, the statements lacks clarity if and what emissions from the LULUCF sector 

should be included. This could refer to total gross emissions (including the emissions but excluding 

removals from LULUCF), total net emissions (including emissions and removals from LULUCF), or to total 

GHG emissions without LULUCF. All three interpretations would result in different levels of the cap (see 

Table 3.7). For example, in the case of Sweden emissions and removals in the LULUCF sector have a 

large effect on the total GHG emissions of the country, and consequently the choice of which emissions 

to include in the calculation of the cap has a large effect on the outcomes. In contrast, in The 

Netherlands, an example for a country with a small contribution of emissions and removals from LULUCF 

to the total emissions, the different choices only have limited effect on the calculated 3.5% cap.   

If the total net emissions including emissions and removals from LULUCF were to be used, Member 

States with a large net sink in LULUCF and comparatively small emissions in other sectors, like Sweden 

in the example, will have a relatively small cap to be applied to accounting of managed forest land. At 

the same time, it can be expected that the managed forest land category plays an important role in the 

total LULUCF accounting in these Member States. Also using total gross emissions including LULUCF, but 

excluding removals from LULUCF may be challenging, because for the LULUCF inventory reports for 

many pools only carbon stock changes are included as net values. As a result it is not possible to assess 

the correct gross emissions from the CRF tables; the calculations in Table 3.7 are only an approximation 

of the actual gross LULUCF emissions. 

Moreover, under the second commitment period of the Kyoto Protocol (KP), a cap was applied to 

removals of forest management. This KP cap was set at 3.5 % of the total base year emissions excluding 
LULUCF8. Probably the intention in the LULUCF regulation was also to imply a cap of 3.5% of the total 
base year emissions excluding LULUCF. Therefore it is recommended to use the interpretation of total 

emissions excluding the LULUCF sector. In a possible revision of the LULUCF Regulation the emissions 

that should be used as a basis for the 3.5% cap should be specified more clearly. 

8 Paragraph 13 of the Annex to UNFCCC Decision 2/CPM.7 

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Table 3.7. Calculation of the 3.5% cap value using different definitions of emissions illustrated with data 

from Sweden and The Netherlands as an example. The data used are for the base years and taken from 

the CRF tables 4 and 10s1 of the 2020 GHG inventories of both countries. Data from Sweden are used as 

an example for a country where LULUCF emissions and removals have a strong effect on the total 

emissions, while the data from The Netherlands illustrate a situation where LULUCF emissions and 

removals have a small effect on total emissions. Also note that in The Netherlands LULUCF is a net 

source of emissions. The calculated 3.5% cap is 3.5% of the base year emissions, multiplied by five, as 

required by the LULUCF Regulation. 

Emissions included in calculation of cap 

Sweden 

The Netherlands 

Emissions  

3.5% cap 

Emissions  

3.5% cap 

(kt CO2 eq.) 

Total (net) emissions (incl. LULUCF) 

36,697 

6,422 

227,233 

39,766 

Total (gross) emissions (excl. LULUCF removals)1,2) 

80,118 

14,021 

229,157 

40,103 

Total emissions (excl. LULUCF) 

71,185 

12,457 

220,741 

38,630 

Information items: 

  LULUCF emissions2) 

  LULUCF removals2) 

  Net LULUCF emissions and removals 

8,933 

-43,421 

-34,488 

8,416 

-1,925 

6,492 

1) Gross emissions from all UNFCCC reporting sectors, including emissions from LULUCF, but excluding LULUCF removals. 
2) To calculate LULUCF emissions and LULCUF removals the data from CRF Table 4 were used, which provides the net emissions 

or removals for lands “remaining” and lands “converted to” for each of the six main land use categories and total net 
emissions or removals for HWP. If different aggregation levels would have been used, the gross emissions and removals 
presented would have been different, with lower aggregation levels providing larger emissions and removals, and higher 
aggregation levels providing smaller emissions and removals. Net emissions or removals would remain the same. 

Another issue relates to the calculation of the emissions that should actually be capped. Article 8(2) of 

the LULUCF Regulation indicates that net removals resulting from the carbon pools of dead wood and 

harvested wood products (except the HWP category of paper) in the land accounting category of 

managed forest land shall not be subject to the cap. Calculation of the capped amount can be done in 

different ways. In our view the calculation of the amount of removals to include in the accounts for 
Managed Forest Land involves the following steps9: 

1.  Calculate the sum of the net emissions/removals for all pools in managed forest land.  

2.  Calculate the difference between step 1 and the FRL, i.e. applying the Managed Forest Land 

accounting rules. In order to refer to the result of this step, the resulting net emissions or 

removals to be considered in the accounting are indicated as net emissions(MFL) and net 

removals(MFL). 

3.  If the result under step 2 is greater than or equal to zero, there is no need to apply a cap and 

the total net emissions(MFL) are to be included in the managed forest land account. 

4.  If this result under step 2 is lower than zero (i.e. net removals(MFL)), then a cap needs to be 

considered. 

a.  Calculate the sum of the potentially capped net emissions(MFL) and net removals(MFL). This 

is the sum of the net emissions(MFL) and removals(MFL) of carbon pools living  biomass 

(above- and belowground), litter, soil, the HWP category of paper and if occurring also 

net emissions(MFL) from dead wood and the non-paper HWP categories. 

b.  Calculate the sum of net removals(MFL) that are not subject to the cap. These are net 

removals(MFL) for the dead wood and non-paper HWP pools, where the subcategories 

wood panels and sawn wood need to be taken together. 

c.  Compare the potentially capped net removals(MFL) of step 4a with the 3.5% cap. If net 

removals(MFL) are higher than the cap, these will be capped and the net removals(MFL) of 

9 It should be noted here that the text of Article 8(2) of the LUUCF regulation requires to compare the net removals (which 
expressed as net removals are a positive value) with the calculated cap, which is based on emissions and hence also is a 
positive value. For the calculation of the net emissions or removals that are to be included in the managed forest land account 
it is easier to include removals expressed as negative emissions to prevent calculation errors (see the examples in Table 3.8). 
In that case then also the resulting negative emissions (being removals) need to be compared to the negative value of the cap. 
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the pools not subject to the cap (step 4b) are added to the capped net removals(MFL). If 

the potentially capped part of the removals(MFL) are smaller than the cap limit, than total 

net removals(MFL) (step 2) are included in the managed forest land account. 

Table 3.8 illustrates the calculation of accounted emissions and removals and the application of the 3.5% 

cap in the managed forest land account for ten different examples. 

Table 3.8. Illustration of the calculation of accounted emissions and removals and the application of the 

3.5% cap in the managed forest land account for ten different examples. Net emissions and removals for 

each of the carbon pools are the result of application of the accounting rules under managed forest land, 

i.e. difference with the emissions/removals under the forest reference levels (indicated as net 

removals(MFL) or net emissions(MFL)). All values are taken as examples representing different situations. 

Shaded cells refer to pools and emissions(MFL) and or removals(MFL) that potentially are capped (depending 

on the outcome and the cap level). The eventual emissions(MFL) and removals(MFL) that are to be included 

in the managed forest land account is calculated for three different cap levels (-20, -25 or -30) as 

examples. Removals(MFL) are expressed with negative sign. 

Net emissions(MFL) or net 

A1 

A2 

B 

removals(MFL) 

Above ground biomass 

Below ground biomass 

Litter 

Soil organic carbon 

HWP (paper) 

HWP (wood panels) 

HWP (sawnwood) 

Deadwood 

Total sum of net 
emissions(MFL)/removals(MFL) 

Sum of potentially capped net 
emissions(MFL)/removals(MFL) 

Sum of net removals(MFL) not 
subject to cap 

-17 

-10 

2 

-3 

-1 

-3 

7 

-17 

-10 

2 

-3 

-1 

0 

4 

-17 

-10 

2 

-3 

-1 

-3 

-5 

-25 

-25 

-37 

-22 

-25 

-29 

-3 

0 

-8 

C 

1 

0.5 

1 

1 

-2 

-2 

0 

4 

-4 

Emissions or removals in managed forest land account 

if fictive cap is (based on 
3.5% of total country 
emissions): 

-20 

-25 

-30 

-23 

-25 

-25 

-20 

-25 

-25 

-28 

-33 

-37 

0 

0 

0 

D 

E1 

E2 

-1 

-0.5 

-1 

-1 

2 

2 

0 

0 

- 

0 

0 

0 

-17 

-10 

2 

-3 

-1 

-1 

-5 

-17 

-10 

2 

-3 

-1 

-3 

2 

-5 

-35 

-35 

-29 

-27 

-6 

-8 

-26 

-31 

-35 

-28 

-33 

-35 

0.5 

-0.5 

In examples A1 and A2 in Table 3.8 total net removals(MFL) are -25. This is a negative result, so 

potentially a cap needs to be applied to the relevant pools. Because deadwood in example A1 and A2 is a 

net emission(MFL) source, this net emission(MFL) needs to be included in the calculation of the potentially 

capped emissions(MFL)/removals(MFL). In the case of example A1, these net emissions(MFL) or removals(MFL) 

that need to be included sum up to -22 (sum of the shaded cells in example A1 in Table 3.8). This means 

that in the example of a cap of -20, these are capped at -20, while for accounting the additional 

uncapped -3 from wood panels and sawnwood are added. This results in a value of -23 to be included in 

the managed forest land account. In the examples of a cap of -25 or -30, these are not capped which 

means that the total of -22 is included in the accounting plus -3 from the sources/sinks not subject to 

the cap (makes -25). In the case of example A2, net emissions(MFL)/removals(MFL) that need to be 

considered under the potentially capped net emissions(MFL) and removals(MFL) sum up to a value of -25 

(sum of the shaded cells in example A2 in Table 3.8). This means that in the example of a cap of -20, 

these are capped at -20 and, in contrast to example A1, no uncapped removals(MFL) from wood panels 

and sawnwood are added. This results in a value of -20 to be included in the managed forest land 

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account. In example A2 for caps of -25 and -30 the a net emissions(MFL)/removals(MFL) that need to be 

included sum up to a value of -25. 

In example B in Table 3.8 the net removals(MFL) of all pools sum up to -37. The pools that are not subject 

to the cap all result in net removals(MFL) (summing up to -8), so these should be excluded from the 

emissions(MFL)/removals(MFL) to be capped. The potentially capped emissions(MFL)/removals(MFL) (in the 

other pools) sum up to a value of -29. In the cases the cap is -20 or -25 these net removals(MFL) are 

capped at -20 or -25 to which the -8 are added from the pools that are not subject to the cap. In the 

case of a cap of -35, the potentially capped removals(MFL) (-29) are not capped and hence the total net 

removals(MFL) of -37 are included in the managed forest land account.  

In examples C and D in Table 3.8, the total net emissions(MFL) and removals(MFL) sum up to 0. As a result 

there is no reason to apply a cap and all net emissions(MFL) and removals(MFL) from all pools are to be 

included in the managed forest land account. 

Examples E1 and E2 in Table 3.8 illustrate the effect of either taking the net emissions(MFL) and 

removals(MFL) in wood panels and sawnwood together (E1), or taking them separately (E2). In the case of 

taking them together (E1) the sum of sawnwood and wood panels results in net removals(MFL) with a 

value of -1, which then needs to be added to the capped removals(MFL). However, in the case of taking 

them separately (E2), the net emissions(MFL) in sawnwood would be included in the sum of potentially 

capped emissions(MFL) and removals(MFL), which then sum up to a value of -27. Both alternatives thus will 

result in different amounts of removals(MFL) to be included in the managed forest land account. Since the 

text of Article 8.2 of the LULUCF regulation is phrased in a way that it excludes paper from the total 

HWP, the example in E1 is considered to follow the legal text more closely and here was considered the 

correct interpretation. It should be noted, that this only has an effect if one HWP category shows net 

emissions(MFL) and the other one net removals(MFL). Nevertheless it is recommended to be more specific 

about this issues in a potential future revision of the legal text of the LULUCF Regulation. 

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4 

Basis for assessment for compliance with the LULUCF Regulation (Task 3) 

4.1 

Introduction 

4.1.1  Background 

According to Article 14 of the LULUCF Regulation (EU 2018/841), Member States have to submit to the 

Commission by 15 March 2027 for the period from 2021 to 2025, and by 15 March 2032 for the period 

from 2026 to 2030, a compliance report containing the balance of total emissions and total removals for 

the relevant period on each of the land accounting categories specified in Article 2. The Commission has 

to carry out a comprehensive review of these compliance reports in 2027 and 2032. The Governance 

regulation (EU 2018/1999) Article 38 also requires a comprehensive review of the Member State’s 

national greenhouse gas inventory by the Commission. This review shall include the following aspects: 

 

Verification  of  the  transparency,  accuracy,  consistency,  comparability  and  completeness  of 

information submitted; 

  Checking  whether  inventory  data  are  prepared  in  a  consistent  manner  with  UNFCCC  guidance 

documentation or EU rules; 

  Checking whether LULUCF accounting is carried out according to UNFCCC guidance documentation 

or EU rules 

  Where appropriate, calculating the resulting technical corrections10 to the emissions and removals 

reported in the GHG inventory, in consultation with the Member States. 

For these reviews independent data sets and information sources would be valuable to allow a good 

review of these compliance reports. In addition the Commission has to do quality assurance and control 

of the national inventory reports of the member states. The LULUCF inventory will be part of this 

process. These initial checks, which will be performed by EEA and JRC, will also benefit from the 

availability of independent data sets to assist this control process. 

The flexibilities between the LULUCF sector and the Effort Sharing sectors, as introduced in the regulation 

(EU) 2018/842, make the accuracy of LULUCF emissions and removals much more important than in the 

past, as credits in LULUCF can be used to compensate for emissions in other sectors. This requires a 

stronger role of the annual checks and the compliance review for LULUCF and justifies increased 

spending on improved MRV. Member States will benefit from this information, as some of the new 

information sources could be useful for improvements of their national LULUCF inventories as well. 

4.1.2  Objective 

The aim of this task is to provide the Commission with an overview and guidance of data sets and 

information sources that can be used to carry out the comprehensive review and analyse and test the 

data and information provided by the Member States in their compliance reports.  

Section 4.2 will describe the approach and identification of the relevant data sets and information 

sources. Section 4.3 will describe the identified data sets and will assess their usability for the 

compliance review.  

4.2 

Identification of relevant data sets and information sources 

Based on the work done in Task 1 and 2 we identified the following actions where additional data sets and 

information sources are relevant. 

 

 

Annual checks of Member States’ submissions and compilation of EU NIR 

-  Reported emissions and removals 

Annual assessment of progress in State of the Energy Union Report 

10 Following Art 2(15) of the GR “technical correction” means adjustments to the national greenhouse gas inventory 
estimates when the submitted inventory data are incomplete or are prepared in a way that is not consistent with 
relevant international or Union rules or guidelines and that are intended to replace originally submitted estimates. 

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-  Check  on  the  progress  for  compliance  with  the  no-debit  rule  for  LULUCF,  which 

requires estimates of accounted emissions and removals 

  Review of compliance reports in 2027 (and 2032) 

- 

- 

Accounted emissions 

Technical corrections of forest reference levels 

-  Natural disturbances. 

This list of actions makes clear that the entire reporting of emissions and removals in the LULUCF sector 

should be part of the compliance checks and will require independent data sets for verification. As it will 

be impossible to independently check all separate emissions categories and carbon pool changes, the focus 

of the compliance process should be on the main sources of net GHG emissions and removals per land-use 

category, as shown in Figure 4.1. 

Figure 4.1. Overview of reported emissions and removals (negative) for the EU LULUCF sector for 2018 

(data derived from CRF tables submitted to the UNFCCC) for the GHG inventory 2020. 

The main net emission sources and land transitions in LULUCF are: 

  Organic soil emissions (mainly grassland and cropland) 

  Deforestation (biomass and soil carbon) 

  Conversion of grassland to cropland (mineral soils) 

  Conversion to Settlements (mineral soils and biomass) 

The main removals are: 

 

 

Forest management (biomass and soil carbon) 

Afforestation (mainly biomass) 

  Conversion of cropland to grassland (mineral soils). 

The focus for data sets and information sources for compliance checking is therefore on land use change 

data sources, forest biomass related data sources and soil carbon (both mineral and organic) data 

sources. Besides the main emissions and removals also natural disturbances, including forest fires, can 

have a potential effect on the accounted emissions, and verifying these emissions is an important aspect 

of the compliance review. Kuhnert et al. 2019 

For the identification of relevant data sets and information sources we made use of literature reviews, 

e.g. Hirschmugl et al. (2017) and Petrescu et al. (2020), information from ongoing (EU) projects, and 

expert knowledge, involving experts at Wageningen University and Research in the area of Remote 
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Sensing, Forestry and Soils. For the information from ongoing (EU) projects, specifically the H2020 Verify 
project11 proved to be relevant (e.g. Kuhnert et al. 2019). This H2020 project aims to develop a system 
to estimate greenhouse gas emissions to support verification of countries emission reporting. This 

system will link the inventory based (bottom up) approaches as used for UNFCCC reporting to 

independent land and atmospheric emission observations (top down approaches). Verification following a 

top down approach, i.e. monitoring atmospheric exchange between all land use, is still challenging for 

LULUCF reporting, as top down approaches are not yet able to distinguish between managed and 

unmanaged land, whereas the inventories report on emissions and removals from managed lands, only. 

Still the project also provides alternative bottom-up approaches, that are useful to this project, but not 

all results are available yet, as the project is still ongoing. Table 4.1 provides an overview of the list of 

data sets and information sources that can be potentially used for verification and compliance checking 

of LULUCF inventory data. These data sets are further described and assessed in Chapter 4.3. This study 

focuses on data sets which either have full EU coverage or at least substantial regional coverage; 

Member States may be in possession of national or regional data with much higher level of 

disaggregation and spatial detail. 

Table 4.1. List of identified data sets and information sources that can be potentially used for verification 

and compliance checking of LULUCF inventory data 

Category 

Data source 

Description 

Land use changes 

Remote sensing based 
data sets 

A wide range of European and global land cover products are available, 
including the Copernicus Land Monitoring Service, with Corine Land Cover 
(CLC) and high resolution layers (HRL) products, but also a range of global 
satellite derived products are potentially of interest 

IACS/LPIS 

Land use data at parcel level 

Eurostat LUCAS 

LUCAS land use/cover survey data 

Forest biomass 

FAOSTAT 

Forestry production statistics 

NFI data  

Forest models 

National Forest Inventories; information on forest composition, structure, 
biomass and other carbon pools 

EU level forest models to assess changes in forest structure, biomass and 
other carbon pools. 

Mineral soils 

Eurostat LUCAS 

Soil organic carbon data and trends for mineral soils 

FAO GSOC 

EJP Soil 

SOC map and SOC sequestration potential 

SOC sequestration potential, possible more data 

Organic soils 

FAOSTAT 

Organic soil emissions 

Global Peatland 
database 

European peatland 
map 

Areas of organic soils 

Areas of organic soils 

Natural disturbances 

JRC EFFIS 

European Forest Fire Information System 

DFDE 

FORWIND 

DEFID2 

Database on Forest Disturbances in Europe 

Spatial map on forest disturbances due wind in Europe 

Database of European Forest Insect & Disease Disturbances 

4.3 

Analysis of data sets 

This section provides a description for each of the identified data sets and makes an assessment of the 

benefits and drawbacks of the data set for purposes of independent verification of the LULUCF inventory 

data and compliance reports. The description includes the following elements: 

• 

• 

• 

• 

Type of data 

Spatial resolution and coverage (e.g. coverage of all member states) 

Temporal coverage (update frequency and availability of historic data)  

Accessibility of the data set  

11 https://verify.lsce.ipsl.fr/; https://cordis.europa.eu/project/id/776810  

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• 

• 

Link to data source  

Description of the information source/data set. 

4.3.1 

Land use change data sets 

For land use change a range of different data sets have been identified. The main data sources are 

remote sensing based products on land cover; these data sources are not all described in detail in this 

report, but are summarised in Tables 4.3-4.5. Other data sets are the LUCAS land use/cover survey and 

the IACS/LPIS data set, see Table 4.2 for an overview. 

Table 4.2. Summary table of available data sources for land use change  

Remote sensing based data 

LUCAS land use/cover survey 

IACS/LPIS  

sets 

Type of data 

Remote sensing based maps 
on land cover/use 

Land use and land cover survey 
data 

Land use data at parcel level for 
CAP payments 

Spatial 
coverage 

Temporal 
coverage 

See Table 4.3 

European countries 

Parcel level, for all EU countries 

See Table 4.3 

2006, 2009, 2012, 2015, 2018 

Annually since about 2005 

Accessibility 

See Table 4.4 

Public, can be downloaded from 
Eurostat with additional information 

Link to source 

See Table 4.4 

https://ec.europa.eu/eurostat/web/
lucas  

Not all data is public, country 
dependent, accessible by Member 
States’ authorities, partly 
accessible by EC 

No EU website for data access 

4.3.1.1  Remote sensing based data sets 

Description 

A wide range of European and global remote sensing based data sets on land cover is available, which 

can be used to derive land use and land use change data. Table 4.3 gives an overview of the technical 

characteristics of these remote sensing based data sources and Table 4.4 provides further information on 

the accessibility of these data sources. Finally, Table 4.5 gives an overview of the assessment of these 

data sources in terms of LULUCF class coverage, spatial detail, time series availability, accessibility and 

an overall scoring.  

The High Resolution layers (HRL)12 mentioned in the tables include the following products: 

  HRL Imperviousness =  Imperviousness Density (IMD) + Imperviousness Built-Up (IBU) + 

Imperviousness Change (IMC) + Imperviousness Density Classified Change (IMCC)  

  HRL Forests = Tree Cover Density (TCD) + Dominant Leaf Type (DLT) + Forest Type (FTY) + 

Tree Cover Change Mask (TCCM) + Dominant Leaf Type Change (DLTC) 

  HRL Grassland = Grassland (GRA) + Grassland Vegetation Probability Index (GRAVPI) + 

Ploughing indicator (PLOUGH) + Grassland Change (GRAC) 

  HRL Water and wetness = Water and Wetness (WAW) + Water & Wetness Probability Index 

(WWPI) 

  HRL Small Woody Features (SWF) 

  HRL Crop Types 

12 https://land.copernicus.eu/pan-european/high-resolution-layers 
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Table 4.3. Overview of technical characteristics of identified remote sensing based data sources on land cover 

Name data source 

Extent 

Spatial 
resolution 

Reference 
years 

Update 
frequency 

Thematic content 

Platform/Satellite 

CLC+ 

Corine Land Cover (CLC)+ 
Backbone 

EEA39, wall-to-wall 

10m, 0.5ha 

2018  

CLC+ Core 

EEA39, wall-to-wall 

100m 

*(1) 

*(1) 

12 raster, 18 vector classes 

Sentinel-1/2 

EAGLE LCC, LUA and LCH 

CLC+ LULUCF or Legacy 
instance 

EEA39, wall-to-wall 

CLC 

Corine Land Cover 

EEA39, wall-to-wall 

25ha + 5ha 
for changes 

HRL 

High Resolution Layers (HRL) 
Imperviousness   

EEA39, wall-to-wall 

10, 20 and/or 
100m 

1990, 2000, 
2006, 2012, 
2018 

2006, 2009, 
2012, 2015, 
2018 

6 years 

44 classes 

3 years 

0-100%, built-up or not, and changes 

HRL Forest 

EEA39, wall-to-wall 

HRL Grassland 

EEA39, wall-to-wall 

HRL Water and Wetness 

EEA39, wall-to-wall 

HRL Small Woody Features 

EEA39, wall-to-wall 

HRL Crop Types 

EEA39, wall-to-wall 

10, 20 and/or 
100m 

2012, 2015, 
2018 

10, 20 and/or 
100m 

2012, 2015, 
2018 

3 years 

0-100%, broadleaved or coniferous, and changes 

3 years 

grass or non-grass, probability index 0-100%, numbers of years since 
ploughed, and changes 

10, 20 and/or 
100m 

10, 20 and/or 
100m 

2015, 2018 

3 years 

permanent water, temporary water, permanent wetness and temporary 
wetness, probability index 0-100% 

2015, 2018 

3 years 

linear and patchy woody features, additional woody features 

*(1) 

+/-24 classes (EcoClass 
nomenclature) 

Sentinel-1/2 

High Res. Vegetation Phenology and 
Productivity (HR VPP) 

EEA39, wall-to-wall 

10m and 
100m 

2017 - 2019 

*(1) 

basic vegetation indices (NDVI, LAI, FAPAR, PPI), Seasonal Trajectories (PPI) 
and VPP 

World Cover 

World, wall-to-wall 

10m 

World Cereal 

CGLS-LC (Copernicus Global Land 
Service – Land Cover) 

World, cereals / maize / 
cropland 

10m 

World, wall-to-wall  

100m 

2020 (prototype 
2019)  

2015, 2016, 
2017, 2018, 
2019 

*(1) 

*(1) 

yearly 

10 classes + 4 level 2 classes 
(LCCS based) + CGLS harmonized) 

Sentinel-1/2 

23 classes (LCCS) and fractions for 
10 classes 

PROBA-V 

S2GLC (Sentinel-2 Global Land Cover)  Europe, wall-to-wall 

10m 

2017 

*(2) 

13 classes 

Sentinel-2 

OneSoil 

Europe + USA, cropland 

field level 

2016-2020 

yearly 

diverse crop classes 

Sentinel data 

CCI Land Cover time-series v2.0.7 
(1992 - 2015) 

World, wall-to-wall 

300m 

1992-2015 

*(2) 

22 classes (LCCS) 

AVHRR, MERIS, PROBA-V, Sentinel-3 

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Name data source 

Extent 

Spatial 
resolution 

Reference 
years 

Update 
frequency 

Thematic content 

Platform/Satellite 

Globcover 

World, wall-to-wall 

300m 

2005-06, 2009 

*(2) 

22 classes (LCCS) 

MERIS 

European Monthly vegetation 
Phenology 

Europe, wall-to-wall 

10m 

2016-2018 

European Cropland Dynamics 

Europe, wall-to-wall 

10m 

2016-2018 

Global Cropland Dynamics 

World, wall-to-wall 

10m 

2016-2018 

GlobeLand30 

World, wall-to-wall 

30m 

2000, 2010 

Global Land cover-2000 (GLC2000) 

World, wall-to-wall 

1km 

2000 

*(2) 

*(2) 

*(2) 

*(2) 

*(2) 

MCD12Q1v006 

World, wall-to-wall 

500m 

2001-2018 

yearly 

Global Land Survey (GLS) 

World, wall-to-wall 

30m 

Global Forest Change (GFC) 

World, forest 

30m 

1975, 1990, 
2000, 2005, 
2010 

2000-2012-2015-
2017-2019 

Global Land Cover-Share (GLC-Share)  World, wall-to-wall 

1km, 30 arc 
seconds 

2013? 

*(2) 

*(2) 

*(2) 

10 classes 

Landsat, Chinese HJ-1 

22 classes (LCCS) 

Vegetation on Spot4 

different legends: IGBP, UMD, LAI, 
BGC, PFT, LCCS 

MODIS from Aqua/Terra 

Landsat 

Landsat 

11 classes 

Various/Integration of national data 
with classification of MERIS/MODIS etc. 

(1) The update frequency of datasets is not yet known as first versions of datasets are just in production phase. 

(2) Datasets seems to be only produced once (as project outcome) or only for limited period/limited number of updates. No indications in metadata that it will be regularly updated in the future 

Table 4.4 Accessibility of identified remote sensing based data sources on land cover 

Name data source 

Availability 

Access 
conditions 

Owner/ 
producer 

Framework  References 

CLC+ 

CLC+ Backbone 

In production 

CLC+ Core 

ITT 

CLC+ LULUCF or Legacy instance 

CLC 

Corine Land Cover 

HRL 

High Resolution Layers (HRL) 
Imperviousness   

Available 

Available 

HRL Forest 

Available 2012, 2015 

HRL Grassland 

Available 

EEA 

EEA 

EEA 

EEA 

EEA 

EEA 

EEA 

CLMS 

tender document on EEA website 

CLMS 

tender document on EEA website 

CLMS 

CLMS 

https://land.copernicus.eu/pan-european/corine-land-cover 

CLMS 

https://land.copernicus.eu/pan-european/high-resolution-layers  

CLMS 

https://land.copernicus.eu/pan-european/high-resolution-layers  

CLMS 

https://land.copernicus.eu/pan-european/high-resolution-layers  

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Name data source 

Availability 

Access 
conditions 

Owner/ 
producer 

Framework  References 

HRL Water and Wetness 

Available 

HRL Small Woody Features 

Available 2015 

HRL Crop Types 

ITT is being prepared 

High Res. Vegetation Phenology and 
Productivity (HR VPP) 

In production 

EEA 

EEA 

EEA 

EEA 

CLMS 

https://land.copernicus.eu/pan-european/high-resolution-layers  

CLMS 

https://land.copernicus.eu/pan-european/high-resolution-layers  

CLMS 

https://land.copernicus.eu/news/hrl-crop-types-consultation-final  

CLMS 

tender document on EEA website 

World Cover 

World Cereal 

In production - 10% prototype 

ESA 

In production 

ESA 

https://remotesensing.vito.be/esa-tender-granted-%E2%80%98world-
cover%E2%80%99  

CGLS-LC (Copernicus Global Land Service – 
Land Cover) 

Available 

JRC/VITO 

CGLS 

https://lcviewer.vito.be/2015 

S2GLC (Sentinel-2 Global Land Cover) 

Available 

OneSoil 

Available 

free 

? 

ESA 

OneSoil 

CCI Land Cover time-series v2.0.7 (1992 - 
2015) 

Available 

free 

ESA 

Globcover 

Available 

ESA 

http://s2glc.cbk.waw.pl/  

https://b2b.onesoil.ai/?utm_source=onesoilmap&utm_medium=how_it_works_page
&utm_content=en  

https://www.esa-landcover-cci.org/?q=node/164  
https://www.esa-landcover-cci.org/?q=node/158  
http://maps.elie.ucl.ac.be/CCI/viewer/download.php  

http://due.esrin.esa.int/page_globcover.php  
http://due.esrin.esa.int/page_project68.php  

European Monthly vegetation Phenology 

Available 

not free 

Geoville 

https://landmonitoring.earth/portal/  

European Cropland Dynamics 

Available 

not free 

Geoville 

https://landmonitoring.earth/portal/  

Global Cropland Dynamics 

Available 

not free 

Geoville 

https://landmonitoring.earth/portal/  

GlobeLand30 

GLC2000 

MCD12Q1v006 

Available 

Available 

Available 

China 

JRC 

USGS 

Global Land Survey (GLS) 

University of Maryland 

globland30.org  
https://www.earthobservations.org/uploads/425_151106_geo_plenary_globeland30.
pdf  

https://lpdaac.usgs.gov/products/mcd12q1v006/  
https://modis.gsfc.nasa.gov/data/dataprod/mod12.php  

https://www.usgs.gov/land-resources/nli/landsat/global-land-survey-gls?qt-
science_support_page_related_con=0#qt-science_support_page_related_con 
https://lcluc.umd.edu/content/data-lcluc-research  

Global Forest Change (GFC) 

University of Maryland 

http://earthenginepartners.appspot.com/science-2013-global-forest  

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Name data source 

Availability 

Access 
conditions 

Owner/ 
producer 

Framework  References 

Global Land Cover-Share (GLC-Share) 

Available 

FAO 

http://www.fao.org/geonetwork/srv/en/main.home?uuid=ba4526fd-cdbf-4028-
a1bd-5a559c4bff38  

Table 4.5. Assessment of usefulness for LULUCF purposes of identified remote sensing based data sources on land cover. Datasets relevant for compliance period 

(bold) and reference period (in italics+underlined) 

Name data source 

LULUCF class coverage  

CLC+ 

CLC+ Backbone 

Settlement, Forest, Herbaceous and Cropland 

CLC+ LULUCF or Legacy instance 

all 

CLC 

Corine Land Cover(3) 

all 

HRL(4)  High Resolution Layers (HRL) 

Settlements 

Imperviousness   

HRL Forest 

Forest Land, trees under agricultural use and in 
urban context 

HRL Grassland 

Grasslands 

HRL Water and Wetness 

Wetland 

HRL Small Woody Features 

Forest land 

HRL Crop Types 

Cropland 

High Res.Veg. Phenology and Productivity 
(HR VPP) 

World Cover 

- 

all 

CGLS-LC (Copernicus Global Land Service – 
Land Cover) 

Cropland, Forest Land, Herbaceous 

S2GLC (Sentinel-2 Global Land Cover) 

all 

OneSoil 

Cropland 

CCI Land Cover time-series v2.0.7 (1992 - 
2015) 

Cropland, Forest Land, Herbaceous 

Globcover 

Cropland, Forest Land, Herbaceous 

European Monthly vegetation Phenology 

- 

Spatial 
detail 

Time series  Relevant 
period(1) 

Available 

Potential 

Overall(2) 

++ 

++ 

+ 

+ 

+ 

+ 

++ 

+/++ 

+/- 

+/- 

+/- 

- 

- 

+ 

- 

+ 

+ 

+ 

- 

+ 

+ 

- 

++ 

++ 

+/- 

++ 

++ 

++ 

++ 

++ 

++ 

++ 

++ 

++ 

++ 

++ 

+/- 

+/- 

++ 

- 

- 

++ 

+ 

+ 

+ 

+ 

+ 

- 

- 

- 

+ 

- 

+ 

+/++ 

+ 

+ 

+ 

+ 

++ 

++ 

+ 

+ 

+ 

+ 

+ 

- 

- 

+ 

- 

+ 

+ 

+ 

- 

- 

-- 

+ 

+ 

+ 

+ 

+ 

+ 

- 

- 

- 

+ 

+ 

+/- 

+ 

+ 

+/- 

+ 

+/- 

+/- 

+/- 

- 

- 

+ 

- 

- 

+/- 

+/- 

- 

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Name data source 

LULUCF class coverage  

Spatial 
detail 

Time series  Relevant 
period(1) 

Available 

Potential 

Overall(2) 

European Cropland Dynamics 

Global Cropland Dynamics 

GlobeLand30 

GLC2000 

MCD12Q1v006 

Cropland 

Cropland 

all 

Cropland, Forest Land, Herbaceous 

Cropland, Forest Land, Herbaceous 

Global Land Survey (GLS) 

Global Forest Change (GFC) 

Forest 

Global Land Cover-Share (GLC-Share) 

+/- 

+/- 

+/- 

+ 

+ 

? 

? 

++ 

++ 

++ 

- 

- 

++ 

++ 

- 

+ 

+ 

+/- 

- 

+ 

+ 

+ 

- 

- 

- 

- 

- 

+ 

+ 

+/- 

- 

+/- 

+/- 

+ 

+ 

+ 

+ 

+ 

+ 

- 

- 

- 

- 

+/- 

+/- 

- 

- 

(1)   Relevant period with + = only for one period relevant, ++ = for both periods relevant, i.e. reference period 2005-2009 and compliance periods 2021-2025, 2026-2030. Only CLC, CCI and GLS have 

data available from before 2000. 

(2)   The overall column is presenting an overall assessment of existing datasets based on combing all characteristics (thematic and spatial detail, time series, relevant period and availability). The 

judgement is ranging from ++, +, +/-, - to --. A positive judgement is only possible if datasets cover a relevant period, sufficient thematic LULUCF content and spatial detail. The notation key is 
meant as a key to compare datasets with each other in a relative way based on expert judgement. For datasets in development no overall judgement but their potential is presented. 

(3)   Near future: Traditional CLC will be replaced by CLC+ Legacy, which will be derived out of CLC+ Core with same specifications 

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Assessment 

The data sources based on satellite imagery that are potentially suitable showed that most of the 
datasets lack a long history and/or regular update frequency (Table 4.5) covering both the compliance 
and the reference periods. Also, a lot of datasets do not cover all IPCC LC categories as they are limited 

to a specific domain (e.g. arable land). Some datasets could be potentially suitable but they were the 

results of short projects (not continued or no long-term perspective). Potentially different data sources 

could be used to create long-term time series, however harmonisation of the different data sources to 
make them comparable and useful for monitoring could be challenging. 

At the moment the Corine Land Cover (CLC) looks like one of the most suitable dataset for monitoring 

LULUCF as it has a long history covering the reference period and far beyond, having a regular update 

frequency, a EU wall-to-wall coverage and sufficient thematic detail. Involvement of Member States and 

EEA’s effort to come to a harmonised EU product, resulted in a high quality, detailed LC/LU map of 

Europe at 1:100,000 scale for 1990, 2000, 2006, 2012 and 2018. To a high degree, the translation of 

CLC classes into IPCC land use categories is possible (Bertaglia et al. 2016); further work may focus on 

fine-tuning and streamlining. However, the most limiting factor is the spatial detail of CLC which is 

limited to 25 ha whereas LULUCF, e.g. the definition for forests, requests a spatial detail of 0.5-1ha (and 

in some cases even finer). For the future with higher demands on data quality (thematic, spatial detail 

and update frequency) CLC will become less suitable.  

For these reasons, the suite of CLC+ products is being developed and will become part of the new 

European baseline for LC/LU monitoring for the decade to come. The CLC+ Core database, one of the 

components of CLC+, allows deriving tailored products – so called instances – to support key EU policy 

needs or for specific needs expressed by stakeholders in Member States (see website 

https://land.copernicus.eu/pan-european/clc-plus). Important first use-cases for CLC+ Core instances 

are for monitoring, reporting and validation to support the implementation of the LULUCF Regulation. 

The components of the CLC+ suite are CLC+ Backbone, CLC+ Core and CLC+ Instances. The CLC+ 

Backbone component produces a detailed wall to wall geometric vector reference layer with basic 

thematic content (18 classes) and a 12-class 10m spatial resolution raster product. The products will be 

fully compliant with the EAGLE data model and nomenclature and can be used as input data for the CLC+ 

Core database. The CLC+ Backbone products complement current CLMS products.  

The CLC+ Core component will deliver a consistent multi-use grid-based Land Cover/Land Use (LC/LU) 

hybrid data repository. By implementing a flexible data handling approach, CLC+ Core will incorporate 

existing and future European CLMS products and various national LC/LU products using a standardized 

integration approach in line with the EAGLE data model.  

The main use-case for CLC+ Core is to derive tailor-made LC/LU products (so called "Instances"), on a 

100m grid level, based on an on-demand combination of available (EAGLE harmonized) LC/LU 

information. This allows combining previously non-harmonized datasets in new ways, in particular LC 

information coming from CLMS products with specific land use (LU) information from the countries. The 

CLC+ LULUCF instance will be one of the instances in the near future. The CLC+ LULUCF instance will 

be a CLC-like product at circa 1ha resolution with land cover/land use classes representing the LULUCF 
land categories. This work is currently under development by the EEA.  

Also World Cover or CGLS (Copernicus Global Land Service) have potential to be useful for LULUCF 

monitoring although they are relatively new initiatives and do not provide information for the reference 

period or earlier. The thematic detail seems to be sufficient to cover the IPCC Categories (Forest Land, 

Cropland, Grassland, Wetlands, Settlements and Others), but a more detailed assessment should confirm 

their usefulness. 

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Besides the above-mentioned products derived from satellite imagery, satellite imagery itself can be a 

valuable data source for monitoring land cover/use and land use change. Landsat-like satellite imagery,  

i.e. satellite imagery with the same characteristics regarding spatial resolution (5-30m resolution) and 

spectral characteristics (multispectral with at least visible and NIR wavebands), is suitable for land cover 

mapping at national and regional scales. Landsat acquires imagery at regular time intervals (every 16 

days) since 1972. The historic set can be enriched with Sentinel-2 for more recently periods. The 

Sentinel-2 constellation has a revisiting time of 5 days, making it extremely useful for real time 

monitoring of land cover changes in the future and more specific for LULUCF reporting concerning the 

compliance periods. The readiness of such data may be particularly useful for proxy inventory data under 

the GR. For this readiness, the alignment of newer datasets with historical datasets is needed. The 

Landsat archive, containing satellite imagery already from 1972 onwards, is extremely important for 

LULUCF reporting for the reference period, i.e. backwards monitoring of land cover changes. For example 

Landsat imagery have been used for mapping (and/or backdating) Corine Land Cover to the seventies 

(e.g. Feranec et al. 2000, 2007). In these studies visual interpretation was used but other possibilities 

regarding the interpretation of historical satellite imagery could be the implementation of deep learning 

techniques. Other satellite imagery can have one or more of the following limitations with importance for 

LULUCF monitoring: 

- 

- 

Limited acquisition period 

Lack of continuous archive covering Europe  

-  Commercial or less accessible data 

-  Missing specific spectral bands and/or spatial detail.  

4.3.1.2  LUCAS land use and cover survey 

Description 

LUCAS (Land Use/Cover Area frame statistical Survey) is a harmonised survey across all Member States 

to gather information on land cover and land use. Since 2012, all EU countries have been covered and 

over 270,000 points have been analysed on different land cover types. For a sub-set of these points also 

soil samples have been collected; the LUCAS soil survey is described in Section 4.3.3.1. Estimates of the 

area occupied by different land use or land cover types are computed on the basis of observations. By 

repeating the survey every few years, estimates regarding land use change can be identified. The land 

use/cover classifications within LUCAS are comparable with other statistical standards, such as the EU’s 

farm structure survey (FSS) and the European Nature Information System (EUNIS) for classifying 

forestry types and areas. Only recently the LUCAS data sets of the different surveys have been combined 

and harmonised (d’Andrimont et al. 2020). So far the LUCAS land use/cover data have been mainly used 

to obtain the distribution of the land use/cover types over Europe and as training data sets for satellite 

based land use/cover maps; to our best knowledge the LUCAS data have not been used directly for the 

analysis of land use changes. 

Assessment 

Although the LUCAS land use/cover data set comprises a very rich data set, covering many points in all 

EU countries, and is repeated frequently, there are also several drawbacks that limit the usefulness for 

LULUCF inventories and as verification for those inventories. First of all, the land use/cover classifications 

is not aligned with the classifications used for LULUCF reporting. Especially for forest land there might be 

quite substantial differences, because the definition of forest land in LULUCF also encompasses rather 

small tree stands. Second, not every point is visited during each survey, with about 35,000 points 

revisited during each of the five LUCAS surveys (Table 4.6), which is only 21% of the original points of 

the first survey in 2006. However, this number is increasing with about 54% of the points being revisited 

at least 4 times since the survey in 2009 (d’Andrimont et al. 2020). This is partly due to the fact that the 

number of points has been expanded over time, but also from the original points of the 2006 survey less 

than a quarter has been visited every survey. For statistical purposes this set-up might not be a problem, 

but it limits tracking land use changes over time. The LUCAS survey is therefore not in line with IPPC 

approach 3, i.e. spatially-explicit observations of land-use categories and land-use conversions, which is 

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normally based on tracking patterns at specific point locations and/or using gridded map products, such 

as derived from remote sensing imagery. Also there have been some inconsistencies that could be due to 

subjectivity in interpretation of the legend and the complexity of the field survey with many surveyors 

and complex documentation. These drawbacks make this data set less suitable for direct monitoring land 

use changes for LULUCF inventories. However, it is still a good source for accuracy assessment of 

products derived from satellite data against ground observations. In addition, other land characteristics, 

some land management information and soil organic carbon is collected (see section 0). 

Table 4.6. Number of points included in each LUCAS survey and the times a LUCAS point has been 

revisited (d’Andrimont et al. 2020) 

Survey 

Total number of points 

Number of points 

  Times revisited 

Number of points 

2006 

2009 

2012 

2015 

2018 

168,401 

234,623 

270,272 

340,143 

337,854 

in situ 

155,238   

175,029   

243,603   

242,823   

215,120   

1 

2 

3 

4 

5 

332,605 

101,052 

91,112 

91,807 

35,204 

4.3.1.3  Integrated Administration and Control System (IACS) 

Description 

The Integrated Administration and Control System (IACS) ensures that payments of the EU Common 

Agricultural Policy are made correctly. IACS comprises the Land Parcel Identification System (LPIS), 

which is the spatial register within the IACS. LPIS identifies and quantifies agriculture land for the 

purpose of targeting CAP payments. LPIS contains geo-referenced polygons of land parcels and 

information on the type of land cover, as a minimum in terms of broad categories such as arable land, 

grassland, permanent crops, and broad families of crops, with their area (eligible hectares), but for some 

countries this can be detailed up to hundreds of crop types. The IACS/LPIS is operated by paying 
agencies within each Member State. In the 28 Member States, there were 44 national or regional LPISs13 
in operation in 2016, containing over 135 million reference parcels (ECA 2016). The data is gathered 

each year through beneficiaries’ application forms that are filled out by each farmer receiving CAP 

payments. IACS/LPIS provides land cover/land use information at the level of each individual land unit. 

Yearly at least 5% of the parcels is checked. In the past these were checked on the spot, but since 2018 

also a legal and technical framework is in place to exploit the advantages of Copernicus satellite data in 

the context of CAP controls (see Vajsová et al. 2020), which now gradually is being used by Member 

States. 

Assessment 

Data from IACS can be used to track land use changes at least for changes in agricultural land. Benefits 

are that this data is already collected by Member States, audited by an independent Accredited 

Certification Body, annually updated and available since 2005. However, the data is not fully harmonised 

across the EU as Member States are using different approaches (Figure 4.2). Some Member States cover 

the entire country in LPIS, whereas others only include the land that is eligible for CAP payments. A 

complete overview of data content, time series and coverage is not available for all Member States. As 

the focus may be limited to agricultural land, land use changes such as deforestation and urbanisation 

are not always captured. Although trends in land use changes can be derived, it will require 

computational effort and resources for harmonisation, because of the millions of parcels and different 

approaches used by Member States, to derive a single data set for verification purposes of the LULUCF 

GHG inventory, which covers all EU Member States. Instead, an alternative would be the use and 

alignment of the IACS/LPIS data by the Member States in their national GHG inventories.  

13 The scope of the ECA report includes the UK as an EU Member State at the time. 

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On the other hand, IACS can be an important source for checking activities under managed cropland and 

managed grassland. JRC showed that the use of IACS/LPIS for LULUCF purposes, especially managed 

cropland and managed grassland is possible, with technical issues that could be resolved, but it would be 

necessary to address legal and other implementation constraints, regarding data access and data sharing 

(Bertaglia et al. 2016). Important information that can already be obtained from IACS/LPIS is detailed 

crop data, and information on the use of cover crops, which is especially relevant for monitoring effect of 

mitigation action on managed cropland. Information on the use of tillage and grassland management 

practices could be obtained with remote sensing in the near future. Data sharing is still challenging as 
recently concluded in a presentation by DG AGRI14. However, with the requirements of more continuous 
area based monitoring for the new CAP instead of on the spot controls, further improvements of the 

IACS-LPIS system will be made. For example, the “New IACS Vision In Action” (NIVA) EU-project 

promotes a collaborative approach towards development and validation of new technologies and 

introduces new digital tools and solutions to modernise the IACS systems. 

Figure 4.2. LPIS by type across the EU (based on information from 2014-2015, source: ECA (2016)) 

4.3.1.4  Recommendations 

The Landsat archive and datasets like CLC, CCI, GlobCover and MCD12Q1v006 are most relevant for the 

reference period and/or monitoring land cover/use changes back in time. For the moment Corine Land 

Cover (CLC) seems to be the most suitable dataset for monitoring LULUCF as it has a long history, 

regular update frequency, EU wall-to-wall coverage and sufficient thematic detail. The main disadvantage 

is the limited spatial detail.  

For the future compliance periods satellite imagery form Sentinel-1 and 2 are currently the most valuable 

remote sensing information source. Data sources like CGLS datasets, integration of HRLs and the 

upcoming CLC+ LULUCF instance (pilot phase) are most promising. The CLC+ LULUCF instance will be 

derived from data stored in the CLC+ Core by integrating different HRLs and other spatially explicit 

information including national land use data and additional data sources, into one wall-to-wall EU 

coverage. The CLC+ LULUCF instance will have a resolution of circa 1 ha and a land cover/land use 

classification that represents the LULUCF land categories. 

14 https://www.niva4cap.eu/uploads/downloads/K.%20IACS%20Data%20Sharing.pdf 
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The benefit of the IACS-LPIS data set is that it contains a very high number of observations of 

agricultural land use and is consistent over time and is audited. Also, IACS-LPIS is suitable for tracking 

changes in managed cropland and managed grassland categories, especially for land management 

practices, which is widely lacking in GHG inventories. However, for Member States that only include the 

agricultural parcels limited to payments under the CAP in the database IACS-LPIS cannot be used for 

tracking all relevant land use changes, such as conversions from and to forest land or conversions to 

settlement. Notably conversions from and to forest land are most important in terms GHG emissions and 

removals from land. This issue may be overcome by integrating IACS-LPIS data with best available data 

on forest parcels and settlements structure which in most Member States is readily available and 

updated.  

However, the data is currently not harmonised among Member States and integrated in a single EU wide 

data set. Creating such an integrated and harmonised data set will take a significant effort. Also some 

legal and privacy issues have to be resolved.  

We recommend using IACS-LPIS as baseline data for monitoring and activity data at the level of each 

Member State. Using this already audited data set for estimating of GHG emissions and removals could 

automatically ensure LULUCF compliance. The use of IACS-LPIS for compliance checking across the EU 

will then not be necessary. 

No available data set has a land use/cover classification that directly matches with the land category 

definitions as used for LULUCF reporting. Especially the forest land definition, with a minimum area, tree 

height and crown cover is quite strict, and difficult to derive completely based on remote Sensing data. 

Matching land use classes can also be difficult for grassland, which is a land category that comprises 

many land cover classes that do not fit into the other IPCC land categories, such as shrubland. 

Although a single harmonized database is available for LULUCF (d’Andrimont et al. 2020), no analysis of 

land use changes has been made yet. The main drawback is that only a part of the points has been revisited 

during each survey, which makes this data set less suitable for tracking of land use changes compared to 

remote sensing based approaches and other seamless data sets. 

New developments 

In 2019 a workshop on the use of Copernicus Land Monitoring Service (CLMS) to support LULUCF 

Regulation was organised by the EEA. The presentations and the discussions highlighted that there are 

both practical and technical considerations to be addressed when developing future CLMS products such 

as a LULUCF CLC+ Instance including:  

 

 

 

 

the need for annual updates and consistent time series of classified land uses going back 20-30 

years back in time; 

differences in how countries define, specify and stratify land use and forestry categories; 

the need for data on soil characteristics and land management practices besides information on 

hectares of change between the various LULUCF categories; 

the use of other datasets that can be used complementary or auxiliary data (national forest 

inventories, LPIS, national statistics, cadastre information). 

For improving the interpretation of satellite imagery, machine learning and more specific deep learning 

could open ways to extend the use of satellite imagery in mapping land cover/use in a consistent way 

relevant for LULUCF monitoring. An interesting development in this sense is the development of an 

OpenStreetMap (OSM)-Land Use map by the Heidelberg University where gaps are filled in the OSM data 

by using data derived from Sentinel-2 10m RGB imagery on basis of Deep Learning Methods (Schultz et 

al. 2017). The project started with filling information for Germany in 2017.  

Other new developments to keep an eye on for future monitoring on LIDAR (FI, SE, NL with e.g. mapping 

of trees with LIDAR: http://boomregister.nl), Sentinel-1 and more detailed hyperspectral data (e.g. 

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20cm, every 30min). However, the application of these techniques is not yet rolled out at European 

scale. 

4.3.2 

Forest biomass information 

For assessing forest biomass different types of datasets are available (Table 4.7). These include data sets 

based on National Forest Inventories (NFIs), forest models and biomass maps based on remote sensing.  

Table 4.7. Summary table of available data sources for forest biomass 

FAOSTAT forest 

National Forest 

CBM 

EFISCEN 

EFISCEN space 

Type of data 

land database 

Inventories 

Forest area, annual 
net CO2 emission 
and removal, 
implied emission 
factors. 

Varies, Information 
on structure and 
composition of 
forest, tree 
allometry, harvests 

Forest model, 
change in biomass 
in carbon pools 

Forest model, 
change in biomass 
in carbon pools 

Forest model, 
change in biomass 
in carbon pools 

Approach 

Inventory 

Inventory 

Model 

Model 

Model 

Spatial 
coverage 

Temporal 
coverage 

Country level 

Country level 

Country level 

Spatially explicit, 
direct linked to NFI 
or other inventory 
plots 

1990-2020 

Scenario specific 

Tier level 

Tier 1 

Tier 2/3 

Tier 21 

Tier 31 

Tier 3 

Through European 
Forest Institute or 
Wageningen 
Research 

Through 
Wageningen 
Research 

http://efiscen.efi.int   

Accessibility 

Public, website 

Through JRC 

Link to source 

http://www.fao.org/
faostat/en/#data/G
F  

https://www.nrcan.
gc.ca/climate-
change/impacts-
adaptations/climate
-change-impacts-
forests/carbon-
accounting/carbon-
budget-
model/13107  

https://ec.europa.e
u/jrc/en/scientific-
tool/eu-archive-
index-database-
customised-carbon-
budget-model-cbm-
cfs3 

1according Petrescu et al. (2020) 

4.3.2.1  FAOSTAT Forestland data 

Description 
The FAO forest land database15 (FAO 2020) provides annual data for the period 1990 to 2020 on forest 
area, net CO2 emissions and removals and the implied emission factor for CO2. The emissions are based 

on calculated carbon stock gains or losses for aboveground and belowground biomass in forests and 

forest conversions. The information is based on area and carbon stock data compiled by countries in the 
FAO Global Forest Resources Assessment16. Emissions and removals are calculated using IPPC 2006 
guidelines Tier 1 methodologies. The database has a global coverage and allows for calculating areas and 

emissions and removals for individual countries, groups of countries and regions. 

Assessment 

15 http://www.fao.org/faostat/en/#data/GF 
16 http://www.fao.org/forestry/fra/en/ 
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The FAO forest land database provides a consistent and annually updated overview of emissions and 

removals associated with changes in carbon stocks in forest biomass. This database appears to be 

particularly useful to assess the CO2 emissions and removals for countries and regions where no other 

estimates exist. For several reasons this database is less suitable for verifying the GHG inventory data of 

Member States. These reasons include: 

 

The forest definitions with minimum values for area size, tree crown cover and tree height as used 

by countries to report to the FAO are not necessarily the same as those used for the NIR submitted 

to the UNFCCC (Convention reporting) or definitions included in Annex II of the LULUCF Regulation 

for each Member State. 

 

 

The  calculation  of  the  biomass  carbon  stocks  as  reported  in  the  FRA  country  reports  do  not 

necessarily follow the 2006 IPCC guidelines. 

The methodologies to assess the carbon stock changes in FAOSTAT follow Tier 1 methodologies 

and are based on net area changes in forest land, whereas most Member States already report 
emissions and removals from forest land at higher tiers (see e.g. Table 6.6 in the EU NIR 202017). 

4.3.2.2  NFI data 

Description 

National Forest Inventories (NFI) provide another source of relevant information. Depending on the 

sampling scheme the information can be used for calculating Tier 2/3 emission factors as well as activity 

data. Whether NFI data are publicly available depends on the country. The European National Forest 

Inventory Network (ENFIN) is a network of national forest inventory organisations collaborating to 

harmonise forest information and to support forest related policies. Access to the NFI data could go 

through collaboration with ENFIN, which already has a framework contract with the European 

Commission to provide forest data and services to support the forest work at the Joint Research Centre 

(JRC). 

Assessment 

Usually the information does not provide an entirely independent source for verification, because most 

countries will use the NFI data already for compiling their GHG inventories. Data could be used however 

in cases where there are doubts that the Member State has applied correct methodologies.  

NFI data could be used in modelling approaches, using for instance European scale forest models to 

assess changes in forest biomass or carbon stocks for countries or regions for which no data are 

(publicly) available.  

4.3.2.3  Forest models 

Description 

Petrescu et al. (2020) assessed two different EU wide forest models, 1) the Carbon Budget Model (CBM) 

and 2) the EFISCEN model in their scientific overview of bottom-up anthropogenic emissions data from 

agriculture, forestry and other land use (AFOLU) in the European Union (EU28).  

CBM 

The Carbon Budget Model (CBM) was developed by the Canadian Forest Service to simulate the historical 

and future stand- and landscape-level carbon dynamics under different scenarios of harvest and natural 

disturbances. Since 2009, the CBM has been tested and validated by the Joint Research Centre (JRC) and 
adapted to European forests (Pilli et al. 2016). It is applied to 26 European countries18, both at the 
country and at the NUTS2 level.  

Based on the model framework, each stand is described by area, age, and land use classes, as well as up 

to 10 classifiers based on administrative and ecological information and on silvicultural parameters (such 

17 https://unfccc.int/documents/228021 

18 25 EU Member States (excluding Malta and Cyprus) plus the United Kingdom. 

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as forest composition and management strategy). A set of yield tables define the merchantable volume 

production for each species while species-specific allometric equations convert merchantable volume 

production into aboveground biomass at the stand level. At the end of each year, the model provides 

data on the net primary production (NPP), carbon stocks and fluxes, as annual carbon transfers between 

pools and to the forest product sector. 

The model can support policy anticipation, formulation and evaluation under the LULUCF sector, and can 

be used as verification tool by estimating current and future forest carbon dynamics.  

EFISCEN 

The European Forest Information SCENario Model (EFISCEN) is a large-scale forest model that projects 

forest resource development on a regional to European scale. The model uses NFI data as a main source 

of input to describe the current structure and composition of European forest resources. The model runs 

for 5-year-interval emission projections and projects the development of forest resources, based on 

scenarios for policy, management strategies and climate change impacts. With the help of biomass 

expansion factors, stem wood volume is converted into whole-tree biomass and subsequently to whole-

tree carbon stocks. Information on litter fall rates, felling residues and natural mortality is used as input 

into the soil model Yasso (Liski et al. 2005), which is dynamically linked to EFISCEN and delivers 

information on forest soil carbon stocks. A detailed model description is given by Verkerk et al. (2016). 

The model and its source code are freely available, distributed under the GNU General Public License 

conditions (gpl-3.0). 

EFISCEN space 

While the EFISCEN model was designed to work on aggregated national forest inventory (NFI) data for 

essentially even-aged forests, EFISCEN Space is designed for all types of forests, can handle a wide 

range of management systems and works with detailed NFI data. A more complete description of the 

model can be found in Arets and Schelhaas (2019). In a NFI each plot is considered to be representative 

of a specific forest area, typically in the range of 100–2,000 ha, depending on the density of inventory 

plots. Similarly, in EFISCEN Space, the future development of the forest is modelled through the 

development of the same set of inventory plots which can be initialised using forest inventory data from 

local inventories or NFIs. Most forest models include forest management or harvesting as derived from 

handbooks or management guidelines. In contrast, the EFISCEN space model is applies observed 

frequencies and probabilities for harvesting. This is an important improvement, because the observed 

patterns of harvesting usually differ considerably from the handbook management (Schelhaas et al. 

2018) 

Assessment 

Petrescu  et  al.  (2020)  compared  model  results  of  CBM  and  EFISCEN  with  the  reported  data.  Models 

consistently  estimated  lower  net  removals  than  reported  by  Member  States.  These  discrepancies  were 

explained  by  differences  in  methodologies  and  model  assumptions.  Although  the  magnitude  of  the 

removals  consistently  was  lower  in  the  model  results,  the  observed  trends  in  removals  over  time  were 

similar. 

The similarities between the CBM and EFISCEN models are that they use National Forest Inventory (NFI) 

data as the main source of input to describe the current structure and composition of European forests. 

However, the CBM and EFISCEN models make different assumptions about allometry, wood density or 

carbon content of trees (Petrescu et al. 2020). Importantly, the EFISCEN space model is spatially 

explicit, and as a result is able to provide spatially-explicit output at plot level and more aggregated 

outputs, similar to the other models. 

4.3.2.4  Recommendations  

Differences between FAO forest land data, GHG inventory calculations by Member States and model 

outcomes result from differences in the used forest definitions and assumptions about allometry, wood 

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density or carbon content when translating the basic information from NFI’s or model projections into 

carbon stocks. Definitions of forest land may differ in terms of minimum area, anticipated tree height and 

canopy cover. As a result when using alternative sources for verification, these differences will need to 

be taken into consideration. Model projection could be used to verify reported trends in removals over 

time but should be used more carefully when used for verifying the magnitude of the removals in forest 

land. 

Because the forest models largely depend on NFI data from the Member States that are often also used 

as input in the GHG inventory, the results are not fully independent. However the models apply tested 

harmonised modelling approaches. Comparisons of model outcomes with Member State’s inventories 

allow for identification of possible issues and inconsistencies in Member States time series regarding 

forest carbon pools.  

4.3.3  Mineral soil data sets 

For carbon stock changes in mineral soils three relevant data sets have been identified. The main data 

set is the LUCAS soil survey, from which SOC data but also trends in carbon stock changes can be 

derived. Two other initiatives, one from FAO the Global Soil organic carbon map and carbon 

sequestration potential and the other from the EJP soil programme, can provide data on soil carbon stock 

changes, see Table 4.8 for an overview. 

Table 4.8. Summary table of available data sources for mineral soils 

LUCAS soil survey  

FAO GSOC 

EJP Soil 

Type of data 

SOC data and trend 

Spatial 
coverage 

Temporal 
coverage 

For 2009 23 EU MS, in 2012 
Bulgaria and Romania were 
added, for 2015 and 2018 all 
EU MS 

20091), 2015, 2018 

SOC map and SOC sequestration 
potential 

SOC sequestration potential, possible 
more data 

Global, 1 km2 resolution 

All EU member states 

SOC map 2016, SOC sequestration 
potential 2021? 

2023? 

Approach 

Direct sampling 

Soil maps and modelling 

Modelling 

Tier level 

Tier 3 

Tier 2-3 

Tier 3 

Accessibility 

Public through website 

Public, website 

Will become public 

Link to source 

https://esdac.jrc.ec.europa.eu
/projects/lucas  

http://www.fao.org/soils-
portal/data-hub/soil-maps-and-
databases/global-soil-organic-
carbon-map-gsocmap/en/  

No data yet 

1) In addition Bulgaria and Romania were sampled in 2012 

LUCAS soil survey 

Description 

In 2009, the European Commission extended the periodic LUCAS survey to sample and analyse the main 

properties of topsoil in 23 Member States of the EU. This topsoil survey aims to build a consistent spatial 

database of the soil cover across the EU based on standard sampling and analytical procedures, with the 

analysis of all soil samples being carried out in a single laboratory. Approximately 20,000 points were 

selected out of the main LUCAS land use / cover grid for the collection of soil samples. A standardised 

sampling procedure was used to sample the topsoil (0-20 cm). Soil samples were analysed by an 
accredited laboratory for a range of chemical and physical soil properties. SOC content (g C kg−1) was 
measured by dry combustion (ISO 10694:1995). More details about the survey and the data can be 

found in Tóth et al. (2013) and Panagos et al. (2013). In 2012 also samples from Romania and Bulgaria 

were added. In 2015 the soil survey was repeated on 90% of the locations and 10% of the locations 

were substituted by new locations (Jones et al. 2020). In 2018, the LUCAS Soil survey included the 

following additional analyses for the first time: a) Bulk density (i.e. weight of dry soil in a given soil 

volume). b) Soil biodiversity c) Visual assessment of soil erosion and d) Measurement of the thickness of 

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the organic horizon in organic-rich soil. Future resampling campaigns are foreseen of which the 2022 

campaign is currently being planned. 

Assessment 

The LUCAS soil survey is currently the only data source with measured changes in soil carbon throughout 

Europe. The benefit of LUCAS data is that it is recently observed data and there is a clear link to land use 

and to lesser extent land management. Data from the 2009 and 2015 surveys are now available and 

these two surveys have been compared by the JRC (Fernández-Ugalde et al. 2020). The LUCAS soil 

survey can be considered as a geographically explicit approach (approach 2/3) as most of the sites are 

revisited over time. In the 2015 survey, 80.6% of the sampling locations of the 2009 and 2012 surveys 

were revisited, and 80% of the samples were taken within 10 m of the original location. The comparison 

showed limited changes between 2009 and 2015, which confirmed that soil properties change very 

slowly over time. Still at EU level a statistically significant increase in SOC content of 3.7% was observed 

in grassland and a statistically significant decrease in SOC content of 2.5% was observed in cropland. In 

other land cover categories, the number of repeated points was insufficient to assess statistical 

significance (Fernández-Ugalde et al. 2020). 

Overall the soil properties showed large standard deviations within surveys and between surveys due to 

uncertainties arising from the sampling. The comparison shows that almost 97 % of the samples taken in 

2015 were taken at a distance <100 m from their baseline locations in 2009/2012 as indicated in the 

sampling protocol. However, even within 100 m the distance can still be quite large for soil carbon, as 

the spatial variability within a field can still be high. Due to this uncertainty in the sampling, the number 

of observations is currently not sufficient to assess changes at national level, especially for smaller 

countries the LUCAS soil survey does not comprise sufficient locations for a reliable trend in SOC stock 

changes. So far, only the top 20 cm have been sampled, whereas most countries report on the top 30 

cm conform IPCC guidelines. The 30 cm sampling depth is now also considered for the future LUCAS 

survey, which would align with LULUCF reporting, but may complicate to keep consistency with the 

previous surveys. 

4.3.3.1  FAO GSOCmap and GSOCseq 

In 2018 FAO published the Global Soil Organic Carbon map (GSOCmap)19, which is the first global soil 
organic carbon map that was produced through a consultative and participatory process involving 

member countries. This map has a resolution of 1 km and represents SOC stocks of the topsoil (0-30 

cm). Further information is provided in FAO and ITPS (2018). Following this work, FAO is now working on 

an initiative to create a global Soil Organic Carbon Sequestration Potential (GSOCseq) map. This map at 

a 1 km resolution for agricultural lands, will be based on a ‘bottom–up’, country-driven approach. SOC 

stocks 0 – 30 cm of mineral soils will be projected over a 20–year period after adoption of Sustainable 

Soil Management (SSM) practices oriented to increase carbon inputs to cropland and grassland soils. The 

RothC model will be used as a standard spatialized SOC model for each country. The final product will be 

relevant to identify which regions, environments and agricultural systems present the greater potential 

for increasing SOC stocks, and to establish priorities for the implementation of global and national public 

and private policies. 

4.3.3.2  EJP Soil CarboSeq 

Under the European Joint Programme Cofund on Agricultural Soil Management (EJP Soil) a project is 

expected to start in 2021 to quantify the Soil organic carbon sequestration potential of agricultural soils 

in Europe (CarboSeq). The aim is to estimate the feasible SOC-sequestration potential taking into 

account technical and socio-economic constraints following a country driven modelling approach, also 

based on the RothC model. Besides this project, other relevant projects might start under the EJP Soil 

programme that might deliver useful information for the 2027 compliance review. 

19 http://www.fao.org/soils-portal/data-hub/soil-maps-and-databases/global-soil-organic-carbon-map-gsocmap/en/  
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4.3.3.3  Recommendations 

For  mineral  soils  the  LUCAS  data  is  currently  the  only  EU  wide  source  with  measured  SOC  data,  which 

could be used for verification of soil carbon stock changes. Though, results of the first comparison between 

the 2009 and 2015 surveys show that due to the high variability in SOC within and between the surveys, 

it is difficult to obtain statistically significant trends over this six-year period, at EU level only significant 

changes were found for two grassland and cropland. Therefore the current data set will be difficult to use 

for verification purposes of soil carbon stock changes at national level and will require a longer time frame 

and/or more sampling locations. Nevertheless, Member States could densify the sample network with other 

sample sites and hence enhance LUCAS data for mineral soils to draw conclusions at national scale. This 

may  be  the  more  cost-efficient  solution,  in  particular  for  member  states  with  no  established  sample 

network, yet. For future sampling campaigns it is important to revisit as many original location and take 

the soil samples as close as possible to the original sampling location. 

The FAO GSOCmap provides a baseline map for soil organic carbon stocks, but does not provide any 

information on carbon stock changes, as it a static map and no updates are foreseen, yet. The GSOCseq 

and CarboSeq initiatives will provide insight in the potential for SOC sequestration, but this is not directly 

of use for the verification of reported emissions and removals from agricultural soils. On the other hand, 

both initiatives create a modelling framework based on RothC, in which for the EJP soil initiative bottom-

up information from the countries will be used. Potentially the same framework could be used to monitor 

annual changes in land use and land management, which would then be a relevant source for the 

compliance review. 

Currently there is much attention on soils in the policy arena: 

 

 

 

new EU Soil Strategy: Healthy soil for a healthy life,  

research programmes: EJP soil - Towards climate-smart sustainable management of agricultural 

soils, Mission area on Soil Health and Food, 
initiatives around soil carbon credits, e.g. roundtable on Carbon Farming20 and soil health. 

Monitoring will be an important aspect for these programmes and initiatives. Therefore new data and 

methods will become available in the coming years that might also serve as verification tools for LULUCF 

purposes. Given that soil carbon stock changes are taking place slowly and measurements have a 

relatively high uncertainty, models are likely to be required for simulating trends in soil organic carbon 

stocks. At EU level a modelling framework for soil carbon will be required, which can build on the work by 

JRC with the Century model (Lugato et al. 2014), or the use of the RothC model as proposed in the EJP 

soil project CarboSeq and FAO GSOCseq initiative. 

4.3.4  Organic soil data sets 

For organic soils there are three main sources that can be used: i) FAOSTAT, which provides both activity 

data and calculated emission data, ii) the Global Peatland database and iii) the European peatland map. 

The main characteristics are described in Table 4.9. 

Table 4.9. Summary table of available data sources for organic soils 

FAOSTAT  

Global Peatland database 

European peatland map 

Type of data 

CO2 emissions and areas of 
organic soils 

Areas of organic soils 

Areas of organic soils 

Spatial 
coverage 

Spatial 
coverage 

Global, all EU countries 

Global, all EU countries 

European countries 

Annual, 1990-2019 

No specific year, continuous 
refinement 

Differs, based on most recent 
available national data 

Approach 

Calculation 

Literature and data collection 

National soil maps 

Tier level 

Tier 1 

Tier 2 (only activity data) 

Tier 2 (only activity data) 

20 https://ec.europa.eu/clima/events/2nd-carbon-farming-roundtable  

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FAOSTAT  

Global Peatland database 

European peatland map 

Accessibility 

Public through website 

To be requested 

Public, can be downloaded as Geotiff 
file 

https://www.greifswaldmoor.de/glo
bal-peatland-database-en.html  

https://doi.org/10.19189/MaP.2016.O
MB.264  

Link to source 

http://www.fao.org/faostat/en
/#data/GG 
http://www.fao.org/faostat/en
/#data/GC  

4.3.4.1  FAOSTAT data  

Description 

FAO is reporting CO2 emissions from organic soils for the land use categories cropland and grassland. 

These emissions are those associated with carbon losses from drained Histosols under cropland and 

grassland. The FAOSTAT emissions database is computed following Tier 1 IPCC 2006 Guidelines for 

National GHG Inventories applied to geospatial data. GHG emissions are provided by country with global 

coverage, relative to the period 1990-2019 (with annual updates). Implied emission factor for C, net 

stock change Gg C and activity data (area) are also provided.  

The area of organic soils is derived from the Harmonized World Soil Database (HWSD) (FAO et al. 2012) 

with percentages of the pixel area covered with Histosols (both as dominant and secondary soil type). 

For land cover the annual land cover maps of the Climate Change Initiative of the European Space 

Agency (version 2.0, CCI UCL Geomatics, 2017) and updated version 2.1 under the European Copernicus 

program (2019) have been used. Further information on this data set can be found in Tubiello et al. 

(2016). 

Assessment 

The FAOSTAT data set is a consistent and frequently updated data source with CO2 emissions from 

cropland and grassland. However, there are some drawbacks to this data set. First of all, the data set is 

based on the emission factors of the IPCC 2006 guidelines, whereas the updated emission factors from 

the IPCC 2013 wetland supplement are not used. The 2013 emission factors for grassland are much 

higher and more in line with current emission factors used by EU countries, which means that FAOSTAT 

data underestimate the organic soils emissions in the EU. Furthermore the HWSD soil map that is used is 

static, and relative coarse for the EU. This means that the trend in emissions from organic soils mainly 

reflects changes in land use. 

4.3.4.2  Global Peatland Database 

Description 

The Global Peatland Database (GPD) is a project of the International Mire Conservation Group (IMCG) 

located and maintained at the Greifswald Mire Centre. It provides an overview on the extent and 

drainage status of peatlands/organic soils with global coverage for 268 countries and regions of the 

world. The data is available in a spatially explicit GIS format: in a vector based on a scale 1:25,000 and 

a GIS raster of 0.01 x 0.01 degree grid. The GIS-GPD is a continuously updated and refined 

peatland/organic soil database and can be filled with additional information such as peat depth, carbon 

content, vegetation or peatland type.  

Assessment 

As the database is not directly accessible, access needs to be requested, and it was not possible to judge 

the completeness and quality of the data source. Potentially this data source can be useful, as it is being 

frequently updated and the drainage status is provided. Barthelmes (2018) already performed a 

comparison of this data set with reported areas of organic soils, which shows for several countries an 

underestimation of the areas reported in the NIRs (Figure 4.3). Differences can be due to the wrong 

application of the ‘managed land proxy’, application of land use data, e.g. excluding fallows and areas 

with ceased land use but still with active drainage, and the inability to capture organic soil occurrence 

directly via remote sensing. Currently the accessibility of the map for institutions like the European 

Commission is unclear. 

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Figure 4.3 Comparison of area (activity) data of the land use categories forest land, cropland and 

grassland in the 2017 NIR and in the Global Peatland Database 2018 (Source: Barthelmes 2018). 

4.3.4.3  European peatland map 

Description 

The European peatland map is a composite map of national datasets for the whole of Europe that is 

described in the paper by Tanneberger et al. (2017). Experts from all countries collaborated to this map 

by providing the most recent available information on the areas of peatland. A minimum peat thickness 

criterion was not strictly applied, to allow for country-specific definitions. The map was constructed by 

merging national datasets in GIS while maintaining the mapping scales of the original input data. 

Following this ‘bottom-up’ approach the overall area of peatland in Europe is estimated at 593,727 km².  

Assessment 

The map provides a more representative and updated picture of the distribution of organic soils 

compared to other European or global soil maps, like the European Soil Database (ESDB) and 

Harmonised World Soil Database (HWSD), as most recent available national soil maps have been used. 

As no single definition for peatland was used, the map allows for national definitions, which could align 

with the definitions used for the LULUCF inventory, but this has to be checked. For use in the review, the 

map still has to be combined with a land use map to calculate the areas of organic soils for each land use 

category. 

4.3.4.4  Recommendations 

For organic soils the Global Peatland database and European peatland map both provide a good 

possibility to check on the areas of organic soils being reported in the LULUCF inventory. However, an 

overlay with a spatially explicit land use map is required to link these data sets with the respective land 

categories. The FAOSTAT data set on organic soils does not add much, although emissions are calculated 

for cropland and grassland, but the use of the outdated emission factors from the IPCC 2006 guidelines 

might cause large deviations. 

4.3.5  Natural disturbance data sets 

Natural disturbances are inherently difficult to monitor through remote sensing. Currently it is possible to 

map and monitor forest disturbances using satellite imagery (see e.g. Senf and Seidl 2020), but it is 

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more difficult to distinguish between human induced disturbances (e.g. wood harvesting and 

deforestation) and natural disturbances (e.g. wind damage, damage through pests). 

Still for natural disturbances several relevant data sets have been identified (Table 4.10). The European 

Forest  Fire  Information  System  (EFFIS)  data  can  be  used  for  verification  of  reported  biomass  burning 

numbers  and  this  data  source  can  also  be  used  in case  of  natural  disturbances  due  to  forest fires.  The 

Database  on  Forest  Disturbances  in  Europe  (DFDE)  (Schelhaas  et  al.  2020)  contains  historic  data  for 

various types of natural disturbances like wind damage, forest fire, and pests and diseases. It does not 

contain  spatially  explicit  data  but  could  be  used  to  check  the  scale  of  historic  damage  accounts.  The 

FORWIND  dataset  contains  spatially  explicit  information  on  wind  damage  (Forzieri  et  al.  2020b).  The 

DEFID2 is a recently started data collection by JRC of forest damage from pest and pathogens. 

Table 4.10. Summary table of available data sources for natural disturbances 

EFFIS  

DFDE 

Type of data 

Burnt areas by wild 
fires  

Various disturbance 
types 

FORWIND 

Wind damage 

DEFID2 

Forest damage from pests 
and pathogens 

Approach 

Remote sensing 

Data collection 

Data collection 

Data collection 

Spatial 
coverage 

Temporal 
coverage 

Accessibility 

all EU countries, 
spatially explicit 

Daily resolution, 
2003-now 

Public through 
website 

All EU countries, non-
spatially explicit 

12 EU countries, spatially 
explicit, harmonised vector 

All EU countries 

1076-2019 

2000-2018 

1981-now 

Public through website  Results from a publication 

Link to source 

https://effis.jrc.ec.eur
opa.eu/  

https://dfde.efi.int/db/
dfde_app.php 

Will become public through 
JRC  

No data link yet. 

with data publicly accessible 
from a data repository.  

https://figshare.com/articles
/A_spatially-
explicit_database_of_wind_
disturbances_in_European_f
orests_over_the_period_20
00-2018/9555008 

4.3.5.1  EFFIS 

Description 

The European Forest Fire Information System (EFFIS) supports the services in charge of the protection of 

forests against fires in the EU countries and provides updated and reliable information on vegetation fires 

in Europe. EFFIS is part of the Copernicus programme and maintained by the JRC. EFFIS consists of a 

modular web-based GIS that provides near real-time and historical information on forest fires and forest 

fires regimes in the European, Middle Eastern and North African regions. The monitoring consists of 

vegetation fire forecasting and assessment of post-fire damages. In addition to the web-GIS services, 

also annual reports on forest fires in Europe are produced. Burnt areas are automatically derived from 

daily satellite information (MODIS and VIIRS), with a resolution of 250-375 m, The EFFIS Rapid Damage 

Assessment provides the daily update of the perimeters of burnt areas in Europe for fires of about 30 ha 

or larger. Fires are mapped using a semi-automatic procedure. Fires are first mapped on the basis of an 

unsupervised procedure that uses a combination of band thresholds and ancillary information from the 

CORINE Land Cover, the active-fire detection product, and the news application. Fires that are mapped 

by the unsupervised procedure are visually verified and corrected through visual interpretation of the 

MODIS images. No distinction can be made between wildland fires, environmental burnings or prescribed 

fires. Although only a fraction of the total number of fires is mapped, the area burned by fires of this size 

represents about 75% to 80% of the total area burned in EU. Based on modelling of historical fire data 

from the EFFIS European fire database, equations have been set up for to predict the total area burned 

with good accuracy. 

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Figure 4.4. Screenshot of EFFIS mapping of burnt areas, this example is for a region in Portugal for all 

fires in the year 2020. 

Assessment 

The benefit of using EFFIS for the compliance review and initial checks are clear as this is a truly 

independent data source based on remote sensing and it provides a detailed and up to date overview of 

the vegetation fires that have occurred. Both tabular and spatial data are available, this last aspect is 

relevant for natural disturbance, because if Member States want to make use of the provision of natural 

disturbances, they have to indicate these areas spatially explicit. On the other hand the resolution of 

EFFIS is still limited (250 m), therefore smaller fires (<30 ha) are not detected, and the areas of 

detected forest fires might be relatively coarse. Some EU Member States already use the EFFIS data 

directly for their LULUCF inventory. Still an overlay with land cover maps have to be made to distinguish 

between the different land use categories. 

4.3.5.2  DFDE 

Description 

The Database on Forest Disturbances in Europe (DFDE) aims at providing historic information about 

disturbances in the forests of Europe. The first version of the DFDE was launched at the EFI website in 

2002, containing data until the year 2000. A synthesis of this information is published in Schelhaas et al. 

(2003). Recently the database was redesigned and updated to also cover information on forest 

disturbances up to 2019 (see Schelhaas et al. 2020). The majority of disturbances is caused by natural 

agents, but also human induced impacts like air pollution are taken into account. The information in the 

database is collected through literature review, including information from scientific papers as well as 

from "grey" literature. Each reference to a disturbance event is put in a single record, containing at least 

information on the year of occurrence, the location (as description, such as name of region), disturbance 

type, a quantification of the impact (volume, area, number, percentage or qualitative) and the data 

source. Additional information may include the exact date, tree species affected, detailed causes like 

insect species and other relevant comments. 

Assessment 

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Spatial information on natural disturbances is scarce and only recently remote sensing is providing more 

reliable spatial information on natural disturbances. Locations in the database only provide descriptive 

information of the location, like country, region, or city where the disturbance took place, but no spatial 

GIS data is available. The fact that the data in the database is not spatially explicit will limit its 

application in the verification of the use of the natural disturbances provision. It can be used, however, 

as an indication of the scale of natural disturbances occurring in a region.  

4.3.5.3  FORWIND 

Description 

FORWIND (Forzieri et al. 2020b) is comprised of more than 80,000 spatially delineated areas in Europe 

that were disturbed by wind in the period 2000–2018 and describes them in a harmonized and consistent 

geographical vector format. The database includes all major windstorms that occurred over the 

observational period and represents approximately 30% of the reported damaging wind events in 

Europe. The data were collected through literature review for published storm damages. Forzieri et al. 

(2020b) subsequently retrieved the spatial delineation of the observed wind damage from the 

corresponding authors or contact persons responsible for the original data acquisition. Subsequently data 

were transformed to meet the WGS84 coordinate system and the degree of damage was harmonised. 

Assessment 

The data are based on previous monitoring in a number of EU countries. As a result the data may not 

always represent independent data. The data are also not based on a systematic monitoring of wind 

disturbances. Only if the disturbances were monitored in other studies the data were included in this 

database. This makes the data less suitable for verification of geographically explicit reported natural 

disturbances by Member States. However, the data have also been used to test approaches to 

automatically map wind disturbances that occurred following windstorm using different types of 

classification trees in combination with Sentinel-2 imagery and the FORWIND database. The results 

appeared to be promising. Future developments in this respect may be interesting to follow. Potentially 

this provides new possibilities for improved verification through remote sensing. 

4.3.5.4  DEFID2 

In 2020, JRC launched a collaborative initiative to create a spatio-temporal database of forest damages 

from pests and pathogens in European forests since 1981. They have invited researchers, forest services, 

and forest owners from across Europe engaged in mapping such forest disturbances to contribute their 

observations to this new database, which will be harmonized and stored by the JRC. DEFID2 will be an 

open-access database that can improve the capacity to observe, understand, and predict biotic forest 

disturbances and quantify their impact on forest ecosystems (Forzieri et al. (2020a). The database will 

include descriptive information on the location, complementary information mostly related to occurrences 

characterized by multiple agents or multiple hosts, climate-driven triggering factors and silvicultural 

practices and qualitative assessment of the damage (e.g. percentage of tree mortality).  

4.3.5.5  Recommendations 

For biomass burning and natural disturbances due to forest fires, the EFFIS data set can be a very useful 

source for verification of burnt areas, as both spatial as well as tabular data are provided, which are 

frequently updated. In this regard, an annual spatial and tabular data set could be generated, facilitating 

the work of Member States and Commission services also beyond LULUCF reporting and compliance 

checking. The other data sources (DFDE, FORWIND and DEFID2) could potentially provide information on 

other natural disturbances, but these data sets are still in development (DEFID2) or require updates 

(DFDE, FORWIND), or do not have spatially explicit data available (DFDE). 

There are also other studies using Earth observation information on disturbances in forests across 

Europe. For instance Senf and Seidl (2020) provide spatially explicit mapping of forest disturbances 

across Europe with geographically delineated information on extent and intensity of disturbances. The 

study includes a time series covering the period 2000-2018, but does not make a differentiation between 

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natural (wind, wildfire, pests, etc.) and human induced (deforestation, harvesting) disturbances. The 

authors indicate, however, that work is in progress to also make this differentiation in the future. A 

publication on fire disturbance may be soon forthcoming.  

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5 

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