Opinion of the European Committee of the Regions — EU Forest Strategy for 2030
Date: 2022-04-28
Institutions: Commission for Natural Resources, European Committee of the Regions
Subjects: EU strategy, European forestry policy, adaptation to climate change, forest, forest conservation, forestry economics, forestry research, sustainable forest management, wood industry, wooded area








C_2022301EN.01006101.xml










5.8.2022   


EN


Official Journal of the European Union


C 301/61






Opinion of the European Committee of the Regions — EU Forest Strategy for 2030
(2022/C 301/11)












Rapporteur:



Joan CALABUIG RULL (ES/PES), Regional Secretary for the European Union and External Relations of the Government of Valencia









POLICY RECOMMENDATIONS

THE EUROPEAN COMMITTEE OF THE REGIONS (CoR)

General comments









1.


welcomes the fact that the EU Forest Strategy establishes a policy framework to manage and protect European forests with a view to improving their ecosystem services, securing livelihoods, especially in rural areas, and contributing to a forest bioeconomy supported by sustainable forest management as a multifunctional nature-based tool, while combining regulatory and financial measures as part of a plan for 2030;












2.


considers that the EU Forest Strategy for 2030, which replaces the Forest Strategy that was adopted in 2013 (1) and evaluated in 2018 (2), establishes a framework for European cooperation on forests, highlighting the key role of sustainable forest management in ensuring people's well-being and livelihoods, the conservation of biodiversity and the preservation of climate-resilient ecosystems;












3.


welcomes the assessment and correction of some isolated forestry practices in certain regions in order to protect biodiversity, soil and water quality and resilience to disturbances caused by climate change (water stress, hurricanes, snow, pests and forest fires);












4.


recognises the central role of the forest ecosystem in the European Green Deal (3), the European Climate Pact (4), the European Climate Law (5) and the EU Biodiversity Strategy for 2030 (6) and stresses that the various forest-based sectors — including those utilising non-extractive benefits of forests — can and should contribute to a sustainable, climate-neutral and socio-economically competitive circular bioeconomy;












5.


Notes that the forestry sector has been excluded from the first report of the Expert Platform on Environmental Criteria of the European taxonomy due to the fact that forest is a sensitive sector in which finding a balance between different needs and interests of stakeholders is difficult. Notes also that the opinion of the experts is not binding for the European Commission;












6.


calls for the Commission to deal with the climate and biodiversity objectives and the forest bioeconomy objectives in a balanced, environmentally, socially and economically fair way, which is one of the fundamental pillars of the European Green Deal;












7.


stresses that the Member States and local and regional authorities with responsibility for forests have developed and implemented national and/or regional sustainable forest management strategies, policies, programmes and tools and therefore emphasises the importance of cooperation and constructive dialogue between the Member States, the Commission, stakeholders and forest civil society;












8.


highlights that forests deliver multiple benefits to society at large through a full array of ecosystem services, including non-extractive services, so forest-related decisions are important for a wide range of citizens and forest managers;





The need to enhance dialogue with the forest stakeholders, local and regional authorities, Member States and the Commission









9.


believes that setting a framework and common objectives at European level is a very good idea, but calls for any weakening of subsidiarity and of the role of the Member States in this area to be avoided, given the diversity of forests in Europe, and for a more tailored, regional approach to be adopted. The CoR also shares the view that while the Treaties do not list ‘forest policy’ among the EU's explicit competences, the EU has a wide range of competences on related matters, which have been exercised in legal texts addressing forestry issues;












10.


also points out that forest management has a significant impact, especially in sparsely populated areas and in remote areas where the forest economy is fundamental to people's livelihood;












11.


recommends stepping up communication, dialogue and the involvement of the Member States, local and regional authorities and the sector's stakeholders (public and private owners, professional associations, forest-based companies, nature conservation experts, researchers including climate scientists etc.) in drafting documents within the existing participatory bodies, as was done with previous strategies, in order to achieve maximum consensus among all stakeholders interested in benefitting from our forests, in the CoR's view, the initial discussion was limited and could be improved. On the contrary, a final document was presented based on the argument that much of the content was already included in the 2020 Biodiversity Strategy;












12.


recommends that stakeholders specifically affected by the measures set out in the EU Forest Strategy (local and regional authorities, civil society and businesses) should be involved in their implementation, minimising administrative burdens, especially for forest owners and businesses, but also for local and regional authorities;





The need to reach a consensus at EU level









13.


regrets the lack of political consensus in the EU since, in recent weeks/months, criticism of the EU Forest Strategy as it currently stands has increased, as can be seen in statements from EU bodies such as the European Economic and Social Committee (Opinion NAT/831 on the New EU Forest Strategy for 2030 (7)), various national and regional governments and the political parties supporting them, from MEPs from various political groups and from representatives of the forestry sector (associations of public and private forest owners, local and regional authority forest administrations, business associations and national and regional sectoral platforms);












14.


regrets the failure to comply with the Council conclusions reached under the German Council Presidency on closer future cooperation in the EU, proposing a top-down approach, without taking sufficient account of existing structures (e.g. regional/national forest inventories), with specifications and measures that come exclusively from the Commission, which is not responsible for forest policy, and without sufficiently involving the advisory committee responsible;












15.


recognises that the EU Forest Strategy's overall objectives of securing forest management best practices in the Member States and local and regional authorities, but draws the Commission's attention to the need to strike a balance between the environmental, social and economic aspects of forest management including protection as a management option, and stresses the importance of respecting and maintaining the diversity of forests, and planning and sustainable forest management practices and rotation periods in the Member States and local and regional authorities;












16.


points out that, for the forestry sector's key stakeholders (private and public owners, professionals, businesses and a large part of the forest scientific community), the EU Forest Strategy's approach does not fully correspond to the realities on the ground, suggesting that sustainable forest management practices do not appear to be going in the right direction and should therefore be changed significantly;












17.


stresses that data show a decline in biodiversity in some areas and inadequate conservation in Natura 2000 habitats, partly due to the lack of a suitable incentive framework for their managers (prices, remuneration of externalities, regionally adapted and sound regulatory framework); these are key aspects that the EU Forest Strategy should address with allocation of extra resources from EU and Member States' budgets; calls for closer cooperation to promote efforts towards ecosystem restoration, including targets for restoring damaged forest ecosystems;












18.


thinks that multifunctional forestry is an established sustainable forest management tool in the vast majority of regions, especially in those most affected by the impact of climate change, and that owners and professionals who manage forests are generally committed to protecting their biodiversity and their other ecosystem services and to reducing the level of danger and the incidence of forest fires, while striving to make them more resilient, keep them in good condition and support their growth, making them active contributors to local economies and livelihoods in rural areas;












19.


recommends taking a much more systematic approach, incorporating the diversity and complexity of sustainable forest management with indicators beyond the harvest and increment ratio, property rights and the realities faced by owners, professionals, public and private companies and local and regional authorities, as well as the European forestry sector's achievements in sustainable development and believes that forest protection, in some areas, must go hand in hand with support, including economic support, for active sustainable management aimed at maximising the positive externalities of ecosystem services and avoiding the degradation resulting from neglected forest areas, including environmental degradation;












20.


in the context of biodiversity, it should be highlighted that, thanks to certain outermost regions, the EU possesses primary, Amazonian and subtropical forests, which constitute a unique laboratory for scientific research, specialisation and innovation (such as pharmaceutical research and the development of plant extracts). Biodiversity in these regions represents nearly 80 % of European biodiversity and is vital for the ecological balance of the planet. Local and regional authorities are the guardians of this priceless treasure and ought to be given adequate support for its management and preservation;












21.


believes that, although the EU Forest Strategy is closely related to the Biodiversity Strategy and can in fact create coherence in this regard, it should adopt a different, more inclusive and more systematic approach in order to effectively and consistently align its actions with the objectives of the common policies on the green transition and climate change so as to achieve the EU's environmental, social and growth objectives, including green jobs, making coherence between the relevant EU policies affecting sustainable forest management crucial for the EU Forest Strategy, and fostering the sector's potential to contribute and achieve the sustainable development goals set out in the Green Deal;





A more cross-cutting approach needed by the Commission's departments









22.


welcomes the fact that the EU Forest Strategy was the result of a joint effort by DG AGRI, DG ENV and DG CLIMA but recommends involving the various Commission departments working in the forestry sector (DGs GROW, ENER, REGIO) in order to include all social, economic and environmental aspects and implications as part of a systemic and inclusive approach; otherwise, their approach may be incomplete and biased;












23.


recommends clearly defining the role of the Standing Forestry Committee as a key player in the EU Forest Strategy, so that the views of the sector and other key stakeholders are expressed, enabling the active use of forests across the various regions of the EU;












24.


recommends taking into account the morphology of the landscape, as both innovation and investment in infrastructure are necessary to facilitate logistics and enable digitalisation that modernise forest-based value chains as levers to combat resource loss and depopulation, as is an appropriate system of incentives;





The role of the regional and local levels









25.


recommends considering the territorial dimension of forests such as land use, with forests covering an increasing proportion of land (currently 43 %), mainly in depopulated regions (in the hinterland: mountains, cold climates, flood-prone areas, poor soils), by incorporating the land management and depopulation policies of the Member States and local and regional authorities;












26.


considers it necessary to recognise the principle of subsidiarity, but also the shared competence over forest due to the various environmental and landscape conservation legislations that impact forest policy, taking into account the various guidelines relevant to forests including but not limited to forestry practices and the differences in the Member States' forest holdings, due to the biological, social, economic and cultural diversity of forests in the various regions of the EU;












27.


stresses the need for the main aspects of the EU Forest Strategy to set out principles agreed at EU level. However, the national level must be able to decide on the means needed to achieve the objectives, so that they correspond with the policies and regulations of the local and regional authorities responsible for forests; emphasises that sustainable forest management, a competitive and profitable sector in general and a suitable policy consistency are required to protect forests;





Compatibility between the environmental, social and economic functions of forests is necessary to meet the EU's main challenges









28.


believes that the EU Forest Strategy must sufficiently consider the importance of the full array of forest products and services, hence the Bioeconomy Strategy and sustainable forest management should ensure a balance between forest functions, including the provision of various ecosystem services. Only favouring one aspect upsets the balance;












29.


stresses that the forestry sector (management and harvesting, industrial processing of wood and paper) directly employed 2.1 million people in the EU in 2018, generating a gross added value of EUR 109 855 million. Moreover, 1.2 million people worked in wooden furniture manufacturing and paper printing, generating a gross value added of EUR 25 000 million and EUR 31 000 million respectively. In 2018, 397 000 companies operated in forest-based industries, representing 15 % of manufacturing companies. Finally, bioenergy, wood construction and non-timber forest products provided an additional 4 million jobs;












30.


points out that biodiversity conservation, restoration of ecosystems and an increase in carbon sinks are the fundamental aspects of the EU Forest Strategy, but that the resulting lack of coherence with climate objectives and sustainable socio-economic growth is one of the most problematic points;












31.


highlights the social dimension of forests in the EU, as 60 % of the forest area belongs to more than 16 million private owners, the vast majority of whom are small owners spread across all regions, with an average of 13 hectares each;












32.


argues that the principles of sustainable forest management consider sustainability from a global, i.e. an environmental, economic and social perspective. This means that sustainable forest management should be seen as the best way to manage through conservation or to conserve through management, and is therefore the way to resolve the supposed dichotomy between conservation and management, which is more rooted in political discourse than in actual management practice on the ground;












33.


points out that forests owned by local and regional authorities account for approximately 14 % (22 million hectares) of the total forest area. Not only are local and regional authorities forest owners, but they also manage and administer the implementation of forest policy and budgets, enforce laws and provide sustainable forest management support to private owners, which are always subject to forest policies falling within the remit of the Member States and to EU initiatives stemming from various sectoral policies, while always seeking to reconcile the environmental, social and economic functions of forests;












34.


stresses that the discussions that have run alongside the process are establishing a false dichotomy between the environmental and socio-economic functions of forests, leading to biased discussions and diverting the focus from the fundamental objective of the sustainable development: long-term protection of our forests' health, the ability to tackle the climate crisis with resilient ecosystems, sustainable management of resources and responsible and efficient processing of their products, with a view to ensuring the well-being and way of life of millions of Europeans;












35.


recommends strengthening the content of the EU Forest Strategy with regard to some environmental objectives (water, soil, landscape) while placing greater emphasis on the key contribution made by industrially and sustainably processed and managed forest products to the bioeconomy — which is a basic pillar of the Green Deal. As regards these forest products, technologically innovative processes need to be financed in order to develop various businesses, particularly first-stage processing businesses which are the weak link in the forestry and wood industry and which have the greatest potential for making the best use of local resources;












36.


advises that greater emphasis be placed on sustainable forest management definitions and measures aimed at improving water cycles and soil conservation, especially in Mediterranean and mountain ecosystems and points out that indicators need to be enhanced to improve the sustainable management of forests, which is a prerequisite for the long-term provision of ecosystem services;












37.


recommends re-establishing objectives to give greater visibility to ensuring a sustainable balance and compatibility between the environmental, social and economic functions of forests based on sustainable and multifunctional forest management in the various forest regions (boreal, continental, Mediterranean, mountain and urban forests), without abandoning the protection of biodiversity and other environmental services;












38.


believes that the EU Forest Strategy should more clearly highlight the importance of promoting inclusiveness and equality in the forest sector; also considers that, in line with the new EU Gender Equality Strategy of March 2020, the new EU Forest Strategy should work towards more equal labour market participation among genders so that the forest sector can reach its full potential;












39.


recommends highlighting the role of forests in the most remote areas, in mountain regions and in the most disadvantaged regions, where the percentage of forest area is higher and there is a greater risk of depopulation and where, furthermore, forest value chains are the main sources of employment and economic activity associated with the harnessing and initial transformation of forest resources;












40.


points out that the role of forests in the development of a circular bioeconomy is presented more from the perspective of risk rather than that of opportunity and stresses the important role that bio-based products play in decarbonisation by reducing the consumption of fossil fuels and materials derived from fossil resources, which is one of the main objectives set by the Commission; however, the decarbonisation must take into account the life-cycle assessment of forest-based products and favour the production of long-life products;












41.


recommends the promotion of processing wood products and non-timber forest products locally in order to decrease the impact on the environment;












42.


welcomes the recommendation of the Conference on the Future of Europe citizens' panel that calls for a special focus to be given to the reforestation of exploited or destroyed forests and the afforestation of the areas with degraded soil as well as more responsible solutions to be promoted for a better utilisation of the wood (8);












43.


recommends redefining the EU Forest Strategy's objectives and its synergies with the 2012 Bioeconomy Strategy, which was revised in 2018 (9), incorporating and promoting forest products, both wood (not only construction wood, but also biocomposite materials, biofuels, wood for biorefineries and products with high added value for the chemical, food, and cosmetics and perfume industries) and non-timber forest products (cork, fungi, wild fruits, aromatic and medicinal plants, and resins), taking into account their contribution to climate change mitigation as carbon sinks throughout their life cycles and the effect of substituting these products for other materials that are net emitters of greenhouse gases;












44.


advises redefining objectives and synergies with the 2020 New Circular Economy Action Plan (10), which is a basic pillar of the Green Deal, enhancing the recovery and recycling of forest products in all their waste processing and recovery chains;












45.


recommends establishing a system for transferring best practices that are in use in most companies (optimised, rational and responsible use of resources, certification of chain of custody, ecodesign, energy efficiency, material or energy recovery of waste) to the entire forest-based industrial sector;












46.


highlights that the EU Forest Strategy's objective should recognise the importance of forest not only as carbon sink, but also as carbon stock which could be increased as a major contributor to the EU climate neutrality target by 2050; stresses the substitution impact of forest-based product should take a full life-time impact into account to appreciate the full potential of the forestry sector in climate change mitigation; notes that the net effect of forests as carbon sinks also decreases with forest age;












47.


recommends that clear definitions be established for forests, at least distinguishing between primeval forests that have never been managed (0,7 % of all forests) and forests that were managed in the past but have not been in recent decades, in order to effectively protect old-growth forests, especially in some regions in central and eastern Europe and revitalising the mountains in which management has been abandoned, leading to a risk of forest fires, diseases and pests;












48.


believes that bioenergy should be considered as an opportunity for carrying out sustainable forest management action and as a renewable source, in relation to industrial by-product processing procedures and in recycling, in line with the 2018 Directive on the promotion of the use of energy from renewable sources (11); considers that bioenergy is important for Europe's energy security and independence from fossil fuels;












49.


recommends revising the proposed amendments to the sustainability criteria for bioenergy or forest treatment, as some of the proposed measures may increase the burden on local and regional authorities as forest owners and as the institutions responsible for sustainable forest management in many Member States, as restrictions related to the strict legal protection of 10 % of forests will generate significant compensation without a clear financial commitment from the Commission; considers that the sustainability criteria for bioenergy set out in the 2018 Renewable Energy Directive should apply;












50.


believes that the socio-economic role of the forestry sector is important for the development of rural areas and local economies in many regions, and regrets that the EU Forest Strategy does not include as one of its primary objectives the clear and unequivocal development of the use of timber resources and non-timber forest products, as well as their industrial processing by EU companies (the vast majority of which are SMEs located in rural regions), based on sustainable forest management and as part of the green bioeconomy;












51.


considers that the EU Forestry Strategy should promote and strengthen education on sustainable forest management at all levels, especially in schools and civil society organisations, but also in media campaigns, as a way of overcoming European citizens' lack of knowledge about sustainable forest management and its threefold environmental, economic and social dimension;












52.


thinks that the EU Forest Strategy should include an international dimension aimed at curbing global deforestation and biodiversity loss, capitalising on the experience, knowledge sharing and best practices with regard to sustainable forest management as practised in the Member States and the vast majority of local and regional authorities; welcomes against this background the Commission proposal for a regulation on the making available on the Union market as well as export from the Union of certain commodities and products associated with deforestation and forest degradation and repealing Regulation (EU) No 995/2010 (12), which intends to curb the import of commodities linked to deforestation and forest degradation globally. Also stresses that the proposal has been accompanied by a Subsidiarity Grid (13), which provides a substantial analysis addressing subsidiarity concerns;





The need to reach a consensus at scientific and technical level









53.


recommends that the EU Forest Strategy showcase forestry best practices with good outcomes in European forests in recent decades (continuous growth of the forest area, growth of carbon sinks, increase in the number of protected areas and ecosystems, increase in harvesting, development of responsible businesses and industries, better training in sustainable forest management and better training for forest operators) and that it explicitly recognise this work, which puts the EU at the forefront of global forestry best practices and serves as an example for other countries;












54.


calls for the sustainable forest management definitions, and especially the FOREST EUROPE process, derived from the international commitments made by the EU and its Member States to be used;












55.


recommends carrying out further studies on planning possible implementation in order to avoid overlap with existing systems, and clarifying the synergies, added value and cost-benefit ratio that could be offered by the proposed close-to-nature forest management certification and an independent EU certificate, as well as the strategic forest plans, in relation to the existing forest certification systems (Programme for the Endorsement of Forest Certification (PEFC) and Forest Stewardship Council (FSC)), which are recognised and implemented internationally, and to the sustainable forest management strategies, plans and programmes already available in the Member States and local and regional authorities; there is also a lack of clarity regarding whether the new scheme should be mandatory or voluntary and regarding the legal basis on which such actions would be carried out;












56.


calls on clearly referring to the full array of non-extractive benefits of forest;












57.


calls for a review and analysis of the assessments made by forest scientific experts including forest ecologists across Europe, which warn that the proposed policies may not take sufficient account of the potential increase in risks related to major disturbances (fires, hurricanes, heavy snowfall and pests), with particular attention being paid to forests, which are especially vulnerable to the climate emergency;












58.


proposes that a broader consensus be reached on the assumptions underpinning both the EU Forest Strategy and the Biodiversity Strategy, based on a rigorous scientific and technical approach involving a representative panel of scientific experts who are meticulous and have proven experience covering all aspects of the entire forest value chain and the different types of forest in Europe;












59.


considers that, under certain conditions supported by scientific analyses, protected habitats in some Natura 2000 sites that are threatened or compromised by climate change-related disturbances, can be supported in becoming more resilient ecosystems;












60.


acknowledges and welcomes the proposal for reliable data collection, stressing the importance of publishing a new legislative proposal on EU forest observation, reporting and data collection;





The strategy needs important clarifications before its implementation









61.


thinks that the EU Forest Strategy does not set a coherent and comprehensive objective for the EU forestry sector for 2030 but rather covers a number of actions and initiatives, many of which are still vague and only some of which have an indicative timetable;












62.


believes that, with regard to implementation of the EU Forest Strategy, the first step must be to clarify concepts and actions and draw up an action plan that provides clarity in terms of objectives, scope, time frame and responsibilities; this action plan must recognise the positions of the Member States, local and regional authorities and the sector's players on the EU Forest Strategy and their thoughts on the proposed way forward; it should also include the views of the CoR, the European Parliament and stakeholders from across the forestry sector;












63.


recommends clarifying how the new sustainable forest management indicators, thresholds and ranges will relate to the FOREST EUROPE sustainable forest management criteria and indicators, given that the EU and its Member States are signatories to FOREST EUROPE; believes that there is also a need for information on the legal basis that would justify this action and on what ‘starting on a voluntary basis’ would involve with regard to possible future steps, and for clarification regarding the link between sustainable forest management and the concept of ‘close to nature’;












64.


recommends that the scope and feasibility of the development of payment for ecosystem services be discussed in depth with the Member States and the sector's stakeholders, and subsequent reality checks be carried out to assess whether the financial mechanisms provided for in the EU Forest Strategy (CAP, carbon farming and carbon certification) would enable the set objectives to be achieved;












65.


welcomes the introduction of EU-wide and coordinated forest monitoring but believes that there is a need for an assessment of the added value and cost-benefit ratio of the new EU forest observation, reporting and data collection proposal, and of existing and missing data and information, with remote data, including information from satellites and other media, being recognised as a cost-effective way to improve the knowledge base in cooperation with existing and ongoing national forest inventories; in this regard, subsidiarity, costs and administrative burdens are key aspects that should be addressed. Forest monitoring across the EU could generate added value provided that it is supported by the Member States and local and regional authorities and is based on data on the ground collected by national and regional forest inventories and on the experience of Forest Focus. Moreover, the nature (voluntary or mandatory), format and exact purpose of the national strategic plans need to be clearly defined and cost-effective incentives must be created for forest owners to contribute to data collection;





Sustainable forest management requires more European funding









66.


recommends committing clear and realistic financial resources since, although a significant increase in EU funding for sustainable forest management and biodiversity conservation can be interpreted from the EU Forest Strategy, the need to depend on funds that already have other objectives and allocations (e.g. CAP) and the lack of contribution from other EU funds in a general context marked by Brexit, the post-COVID-19 economic crisis and an inflation rise, it is questionable whether the current EU underfunding of forest and biodiversity will be reversed in the short or medium term;












67.


advises the Commission to help local and regional authorities to ensure that the available EU funds (EAFRD, ERDF, NextGenerationEU) can be used more for sustainable forest management by simplifying the administrative processes;












68.


recommends committing more financial resources for training, R&D and knowledge sharing at European and international level in order to facilitate cooperation, and exchange and implement best practices in sustainable forest management and forest-based value chains across Europe and around the world;












69.


takes the view that the new EU Forest Strategy should promote initiatives to create platforms for interregional cooperation and funding relating to forests and the decarbonised economy.





Brussels, 28 April 2022.


The President of the European Committee of the Regions

Apostolos TZITZIKOSTAS




(1)  COM(2013) 659 final.

(2)  COM(2018) 811 final.

(3)  European Green Deal https://ec.europa.eu/info/strategy/priorities-2019-2024/european-green-deal_en

(4)  COM(2020) 788 final.

(5)  Regulation (EU) 2021/1119 of the European Parliament and of the Council of 30 June 2021 establishing the framework for achieving climate neutrality and amending Regulations (EC) No 401/2009 and (EU) 2018/1999 (‘European Climate Law’) (OJ L 243, 9.7.2021, p. 1).

(6)  COM(2020) 380 final.

(7)  OJ C 152, 6.4.2022, p. 169.

(8)  Recommendation of the Conference on the Future of Europe citizens' panel on climate change and the environment.

(9)  COM(2018) 673 final and SWD(2018) 431 final.

(10)  COM(2020) 98 final.

(11)  Directive (EU) 2018/2001 of the European Parliament and of the Council of 11 December 2018 on the promotion of the use of energy from renewable sources (OJ L 328, 21.12.2018, p. 82).

(12)  COM(2021) 706 final.

(13)  SWD(2021) 325 final.