Commission guidelines for defining, mapping, monitoring and strictly protecting EU primary and old-growth forests.
Date: 2023-11-03
Institutions: Directorate-General for Environment
Subjects: EU strategy, European Union, European forestry policy, biodiversity, environmental indicator, environmental monitoring, evaluation of resources, financing, forest conservation, natural forest, user guide

Commission guidelines 

for defining, mapping,
monitoring and 
strictly protecting 
EU primary and  
old-growth forests

Environment

Manuscript completed in April 2023

This document should not be considered as representative of the European Commission’s 
official position. 

Luxembourg: Publications Office of the European Union, 2023

© European Union, 2023

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Photo on cover: © Matthias Schickhofer – Romania, Vâlcea:  Primary spruce-beech-fir and 
spruce forest in Boia Mica valley, Natura 2000 site Făgăraș Mountains

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TABLE OF CONTENTS

Disclaimer ����������������������������������������������������������������������������������������������������������������������������������������������������������������4

1�  Context ����������������������������������������������������������������������������������������������������������������������������������������������������������������5

2�  Definitions ���������������������������������������������������������������������������������������������������������������������������������������������������������6
2.1.  Approach ........................................................................................................................................................................6

2.2.  Definition of a primary forest9 ............................................................................................................................7

2.3.  Definition of an old-growth forest ..................................................................................................................8

2.4.  Additional notes and clarifications ..................................................................................................................9

3�  Indicators ��������������������������������������������������������������������������������������������������������������������������������������������������������10
3.1.  Approach .....................................................................................................................................................................10

3.2.  Indicators for old-growth forests ..................................................................................................................11

4�  Mapping �����������������������������������������������������������������������������������������������������������������������������������������������������������12

5�  Monitoring16������������������������������������������������������������������������������������������������������������������������������������������������������14

6�  Strict protection ����������������������������������������������������������������������������������������������������������������������������������������15

7�  Financing ���������������������������������������������������������������������������������������������������������������������������������������������������������17

8�  Indicative timetable for implementation�����������������������������������������������������������������������������18

Annexes �������������������������������������������������������������������������������������������������������������������������������������������������������������������20

Annex I. List of existing international definitions for “primary forests”, “old-growth 
forests” and other related terms. .............................................................................................................................20

Annex II. Overview on the ‘Frequency of key indicators in old-growth forest 
definitions’ based on the replies of 21 Member States28 and 6 other organisations29 ...................22

Annex III. List of organisations participating in the meetings of the Working Group 
Forest and Nature .............................................................................................................................................................23

Magnano, IT (2014) © Sabatini

Disclaimer

This document has been prepared through 
active dialogue with Member State experts 
and key stakeholders in order to ensure that 
it is user-friendly and fit for purpose, and 
that it builds on a collaborative approach. 
The list of Member States’ authorities and 
organisations or stakeholders and civil 
society that participated in the process of 
developing the document is included in 
Annex III. The European Commission wishes 
to thank them all. 

Particular thanks go to the representatives 
from Belgium (Research Institute for Nature 
and Forests, Flanders), Italy (Ministry for 
Agriculture, Food Sovereignty and Forests and 
Ministry for Environment and Energy Security) 
and Poland (Directorate General of the State 
Forests), who co-led the process of drafting 
these guidelines. 

This document can complement regulatory 
frameworks on a national, regional or local 
level on forestry or biodiversity conservation. 
The guidelines are voluntary and not 
prescriptive, and do not constitute a binding 
condition in relation, for example, to state 
aid or EU funding. They aim to provide useful 
information and advice to help competent 
authorities to better identify, map and protect 
the remaining primary and old-growth forests 
in the EU. They have been drafted to allow 
for flexibility in the implementation of the 
indicators for identifying old-growth forests, 
which may vary depending on the local 
context. They should be updated as necessary 
in the future in light of the results of their 
implementation, new experience and best 
practice.

The responsibility for this content lies with 
the Commission services. The text might not 
necessarily reflect the views of all the listed 
individual authorities and organisations, 
because it includes compromise drafting 
for elements on which views in the group 
significantly diverged.

4

DISCLAIMER

Kamptal, AT (2017) © Schickhofer

1.   
Context

Primary and old-growth forests are some 
of the EU’s richest ecosystems. They 
store significant carbon stocks, and are of 
paramount importance for biodiversity and 
the provision of multiple ecosystem services. 
They provide a habitat for many of the EU’s 
endangered and endemic species, and are also 
prime examples of our natural heritage. In the 
EU today, these forest areas are rare, often 
small, and fragmented.

In May 2020, the European Commission 
published the EU Biodiversity Strategy for 
2030.1 This defined the objective of defining, 
mapping, monitoring and strictly 
protecting all the EU’s remaining primary 
and old-growth forests. The Commission 
thus began developing guidelines on these 
elements within the framework and with 
the support of its Working Group on Forests 
and Nature. The initial steps in this process 
included collecting information on the status 
and trends of primary and old-growth forests 
in EU Member States through a dedicated 
questionnaire. Work on primary and old-
growth forests in Europe has accelerated 
since then, and the publication of the New EU 

Forest Strategy for 20302 in July 2021 has 
again confirmed the course previously set by 
the Commission, which was recalled by the 
Council in November 20213.

The Commission had also “prepared, through 
the Joint Research Centre (JRC), a study 
on primary and old-growth forests that 
included an overview of existing definitions, a 
compilation of all available mapping resources 
on primary and old-growth forests in the 
EU, information on the value of primary and 
old-growth forests, and knowledge gaps. This 
study was published in April 20214. Further 
work has since been shared, such as a study 
from June 2021 carried out by the European 
Forest Institute (EFI), which reviewed scientific 
evidence to inform policy implementation5.

All these methodological discussions were 
held with a view to better defining the 
characteristics of primary and old-growth 
forests. The aim was to identify mapping 
criteria that will support actions to place these 
forests under strict protection, as stated in the 
EU Biodiversity and New EU Forest strategies 
for 2030.

1  EU Biodiversity Strategy 

for 2030: bringing nature 
back into our lives, 
COM(2020) 380 final.

2  New EU Forest Strategy 
for 2030, COM(2021) 
572 final.

3  Council Conclusions 

on the New EU Forest 
Strategy for 2030, 
13537/21

4  Barredo , J.I., Brailescu, 
C., Teller, A., Sabatini, 
F.M., Mauri, A. and 
Janouskova, K., Mapping 
and assessment of 
primary and old-
growth forests in 
Europe, Publications 
Office of the European 
Union, Luxembourg, 
2021, https://dx.doi.
org/10.2760/797591.

5  O’Brien, L., Schuck, 
A., Fraccaroli, C., 
Pötzelsberger, E., Winkel, 
G. and Lindner, M., 
Protecting old-growth 
forests in Europe - a 
review of scientific 
evidence to inform 
policy implementation, 
European Forest 
Institute, 2021, https://
doi.org/10.36333/rs1.

CONTEXT

5

2.   
Definitions

2.1.  Approach

Annex I contains an overview of the main 
international definitions for primary and 
old-growth forests. Input was also gathered 
from discussions in the Working Group, 
recent studies on old-growth forest in Europe, 
definitions in the EU Member States and the 
situations in forest areas exhibiting very high 
levels of naturalness. Using these sources, the 
Working Group has developed definitions for 
‘primary forest’ and ‘old-growth forest’ at EU 
level. These definitions take into consideration 
the major distinction between natural forests, 
which have been almost devoid of human 
activity (i.e. primary forests), and forests 
which may have been directly affected by 
human activity in the past (thus including 
some secondary forests), but which have 
nevertheless developed structural, functional 
and compositional features similar to stands 
in the late-seral development phases of 
undisturbed forests (i.e. old-growth forests). 
A primary forest therefore generally consists 
of a mosaic of different forest developmental 
stages, including ‘old-growth’6.

The latest studies, which are not necessarily 
based on the definitions proposed in this 
document, estimate the area of primary and 
old-growth forests to be less than 3% of EU 
forest land7. It is important to note that areas 
of primary and old-growth forests alone will 
not suffice to reach the 10% quota of strict 
protection called for by the EU Biodiversity 
Strategy, and that the aim of the definitions is 
independent from the strict protection target. 
The objective of these guidelines is instead 
to provide reliable and scientifically sound 
definitions, which will make it possible to focus 
the strict protection requirements for certain 
types of forest with a high ecological value.

To align itself with the ongoing global process 
under the Food and Agriculture Organisation 
(FAO), the Commission proposes to use the 
FAO’s latest definition of primary forests to 
report primary forest areas, enable the use of 
comparable definitions and reduce reporting 
burden (see Section 2.2). Regarding old-
growth forests, a new definition is proposed 
that builds on the work by Erik Buchwald8 
(see Section 2.3). Since many ‘old-growth’ 
characteristics are exhibited at the stand level, 
this definition will be applicable to old-growth 
forest stands. 

6  Oliver, C. D., and Larson, 

B. C., Forest stand 
dynamics (updated 
edition), John Wiley & 
Sons Inc., New York, 
1996, p. 149, Fig. 5.2.

7  Barredo , J.I., Brailescu, 
C., Teller, A., Sabatini, 
F.M., Mauri, A. and 
Janouskova, K., Mapping 
and assessment of 
primary and old-
growth forests in 
Europe, Publications 
Office of the European 
Union, Luxembourg, 
2021, https://dx.doi.
org/10.2760/797591.

8  Buchwald, E., A 

hierarchical terminology 
for more or less 
natural forests in 
relation to sustainable 
management and 
biodiversity conservation. 
Proceedings of the 
Third Expert Meeting on 
Harmonizing Forest-
related Definitions, 11-
19 January 2005, FAO, 
Rome, 2005.

6

DEFINITIONS

2.2.  Definition of a primary forest9

5.  Primary forests have a number of key 

characteristics:

 •

 •

 •

they show natural forest dynamics12, 
such as natural tree species 
composition, occurrence of dead wood, 
natural age structure and natural 
regeneration processes;

the area is large enough to maintain 
its natural ecological processes;

there has been no known significant 
human intervention, or the last 
significant human intervention was 
sufficiently long ago to have allowed 
the natural species composition and 
processes to re-establish themselves.

Primary forest: ’Naturally regenerated 
forest of native tree species, where there 
are no clearly visible indications of human 
activities and the ecological processes are not 
significantly disturbed.’10

Explanatory notes11:

1.  This definition includes both pristine and 
managed forests that meet the definition.

2.  This definition includes forests where 

indigenous peoples engage in traditional 
forest stewardship activities that meet the 
definition.

3.  This definition includes forests with visible 
signs of abiotic damage (e.g. storms, snow, 
droughts and fires) and biotic damage (e.g. 
from insects, pests and diseases).

4.  This definition excludes forests where 

hunting, poaching, trapping or gathering 
have caused the loss of significant native 
species or disturbance to ecological 
processes.

9  As further explained in 

Section 3.1, the definition 
and the explanatory 
notes for primary forests 
in this document will 
be aligned with the 
Operational guidance 
for improved primary 
forest reporting for the 
Global Forest Resources 
Assessment developed 
by the FAO, once it has 
been published. 

10  The definition, which 

includes the explanatory 
notes, is the same as in 
the FAO Forest Resource 
Assessment 2020’s 
Terms and Definitions. 

11   Idem

12  These include the 

persistence of processes 
that set up and 
characterise the habitat 
(e.g. periodic floods for 
riparian forests and 
rockfalls for ravine 
forests).

Kamptal, AT (2018) © Schickhofer

DEFINITIONS

7

2.3.  Definition of an old-growth forest

Old-growth forest: ‘A forest stand or area 
consisting of native tree species that have 
developed, predominantly through natural 
processes, structures and dynamics normally 
associated with late-seral developmental 
phases in primary or undisturbed forests 
of the same type. Signs of former human 
activities may be visible, but they are 
gradually disappearing or too limited to 
significantly disturb natural processes.’ 

Explanatory notes: 

1.  This definition includes forest stands 
that originate not only from natural 
regeneration, but also from planted or 
sown native tree species (provided that 
they meet the rest of the definition).

2.  This definition includes forest stands where 
indigenous peoples engage in traditional 
forest stewardship activities that otherwise 
meet the definition.

3.  This definition includes forest stands 
with visible signs of abiotic damages 
(e.g. storms, snow, droughts and fires) 
and biotic damage (e.g. from insects and 
diseases) that meet the definition (see the 
third additional note in Section 2.4).

4.  Forests with visible signs of past human 

activity are not excluded from the 
definition of old-growth forests, unless the 
magnitude of the impact of the activity is 
such as to prevent the forest stand from 
counting as old-growth (see Section 3.2).

5.  Old-growth forest stands do not include 
stands for which there is evidence 
that they are under active productive 
management. This includes low-intensity 
silvicultural regimes and coppicing. 

6.  Some key characteristics of old-growth 

forest stands are:

 •

 •

they contain structural features and 
dynamics such as natural regeneration, 
gap dynamics, large and diverse dead 
wood, structural complexity, and the 
presence of old trees, or trees reaching 
senescent stage and tree-related 
microhabitats.

they have acquired these structural 
features and dynamics through several 
decades of natural development 
without significant human intervention.

8

DEFINITIONS

2.4.  Additional notes and clarifications

 • An old-growth character is a feature of the 
state and structure of a forest. It should 
not be confused with forest ancientness, 
which indicates a temporal continuity 
without a change in land use13. Areas 
showing old-growth characteristics and 
ancientness may often overlap. However, 
an ancient forest (i.e. a continuously 
wooded forest land) which has been 
actively managed over the centuries 
generally lacks old-growth characteristics. 
Conversely, areas which have been 
forested more recently can develop 
structures associated with old-growth 
forests when given enough time.

 • Some EU Member States or forest types 
may not have surviving examples of 
primary forests or old-growth forests. 
Restoration of such forest types to achieve 
old-growth qualities should therefore be 
encouraged as a priority. 

 • An extensive part of primary forests might 
also consist of old-growth forest stands. 
However, primary forests may also contain 
younger stands in the regeneration phase 
(e.g. after natural disturbances).

 • Old-growth forest stands may also 

temporarily lose some of their defining 
features when subject to natural 
disturbances such as pests, windstorms or 
other stand-replacing disturbances. In such 
cases, even if some of the indicators are 
temporarily absent, the strict protection 
objective should remain unchanged (see 
Section 6).

13  Forest ancientness is not 
covered by the definition 
of old-growth forests. 
It is nevertheless an 
important indicator of 
the ecological value of 
forests, because many 
forest-related species 
depend on a forest’s 
temporal continuity.

Natura 2000, RO (2016) © Schickhofer

DEFINITIONS

9

3.   
Indicators

In addition, Member State methodologies 
should be:

 •

 •

 •

science-based; 

developed transparently and shared 
publicly; 

ensure cross-border harmonisation and 
consistency with the common definition; 

 • make it possible to objectively verify fit 
and appropriate implementation by all 
relevant forest stakeholders.

3.1.  Approach

In addition to the agreed definitions, there 
is also a need for operational criteria for 
primary and old-growth forests to guide their 
delineation, using indicators in the field. 

To ensure consistency in the reporting of 
primary forests, reduce reporting burden, and 
allow for international comparisons beyond 
the EU, the Commission plans to follow the 
methodology which the FAO is currently 
developing for reporting on areas of primary 
forests. It should be noted that while the FAO’s 
methodology targets the reporting of areas, 
this document aims to facilitate mapping the 
location of primary forests to allow for their 
strict protection.

Regarding old-growth forests, the Commission 
has developed in cooperation with the Member 
States a list of indicators that can be adapted 
to the different forest types and naturalness 
levels existing in the EU. Given this variety, 
thresholds for each indicator should not be 
developed at EU level at this stage. 

While Member States will use their own 
methodology to conduct the identification 
of old-growth forests, these methodologies 
should build on the list of indicators in Section 
3.2, and be consistent with the common 
definition. 

10

INDICATORS

Parangalista, BG (2015) © Sabatini

Fonte Novello, IT (2013) © Sabatini

3.2.  Indicators for old-growth 

forests

All the main indicators and at least two 
complementary indicators need to be met.

Main indicators

1.  Native species

Old-growth forests are composed of native 
species. However, the presence of a small 
number of non-native trees should not 
disqualify a forest from being designated as 
old-growth, if they do not significantly disturb 
ecological processes. 

2.  Deadwood

Old-growth forests are characterised by a high 
proportion and diversity of standing and lying 
deadwood. The amount and type of deadwood 
can vary greatly between old-growth forests 
(depending on the forest type, the local 
environmental conditions, and the area’s 
recent disturbance history). 

3.  Old or large trees

Old-growth forests are often characterised 
by a high volume of standing trees relative 
to earlier development stages for the given 
forest type and local growing conditions, and 
by the presence of old or large trees, some of 
which may reach the maximum age known for 
the species under the local site conditions.

Complementary 
indicators

4.  Stand origin

Most old-growth forest stands originate 
from natural regeneration, but some sown 
or planted forests can meet the definition, 
if given enough time to develop the 
characteristics of old growth forests.

5.  Structural complexity

Old-growth forests are generally characterised 
by structural complexity. This can include 
a multi-layer canopy structure, horizontal 
structural diversity, and soil microrelief 
structures such as mounds caused by 
uprooting.

6.  Habitat trees

Old-growth forests are often characterised 
by the high density and high diversity of 
tree-related microhabitats. These are defined 
as a ‘distinct, well-delineated structure 
occurring on living or standing dead trees, 
that constitutes a particular and essential 
substrate or life site for species or species 
communities during at least a part of their life 
cycle to develop, feed, shelter or breed’14.

7.  Indicator species

Old-growth forests often host species of late-
seral developmental phases that are specific 
to a certain forest type. These can include 
species on the red-list of the International 
Union for Conservation of Nature (IUCN).

14  Larrieu L. et al. 2022, 

‘Key factors determining 
the presence of Tree-
related Microhabitats: 
A synthesis of potential 
factors at site, stand 
and tree scales, with 
perspectives for further 
research’, Forest Ecology 
and Management, 515 
(2022) 120235, https://
dx.doi.org/10.1016/j.
foreco.2022.120235.

INDICATORS

11

4.   
Mapping

The mapping of primary and old-growth 
forests should take place once the 
methodology for their identification and 
mapping has been developed at the national 
level. This methodology should be based 
on the definitions, criteria and indicators in 
this document. Remote-sensing data could 
be used in the first stage for pre-screening 
potential areas, in combination with in-situ 
data and modelling techniques. The mapping 
will need to be coordinated at national level 
to ensure consistency and comparability. At a 
minimum, Member States who have already 
identified their primary and/or old-growth 
forests should cross-check with the criteria 
and indicators in this document, and, if 
necessary, refine their mapping. 

One of the issues identified by the Working 
Group is that existing data and the mapping/
assessment of primary and old-growth forests 
are not always kept in one repository at 
national level. There is often a gap between 
the data available to the public and the 
data available for private forests. Member 
States that have not organised this data in 
a coordinated manner should therefore start 
to look into developing a mapping process. 
This approach should make it possible to 
properly consolidate and integrate all data 
available (from forest owners, universities, 
communities, authorities, etc.). Private 
certification schemes could also contribute 
by compiling national GIS maps of High 
Conservation Value areas, their attributes and 
monitoring results. These findings should then 
be made available to the relevant authority.

Kalkhochalpen, AT (2012),  
© Schickhofer

12 MAPPING

It is of the utmost importance that GIS 
mapping of primary and old-growth forests is 
developed at national level by the competent 
authorities, and made available to the public 
in a transparent manner. This would be 
especially relevant for procedures used to 
authorise specific activities and projects. It 
would also apply to:

 •

procedures for environmental impact 
assessment or strategic environmental 
assessment, state aid or private payments 
for ecosystem services;

 •

compensatory payments under Rural 
Development Programmes;

 • Common Agricultural Policy (CAP) Strategic 

Plans;

 •

forest monitoring and inventory. 

Such data may also be relevant for those 
working in research, tourism, education or 
other areas. It should be made available in 
the most appropriate format, and also to the 
general public in an easily accessible format. 
The GIS data compiled by the JRC in its April 
2021 study15 could support the work of 
Member States. Available data in repositories 
may be further used at national level when 
deemed necessary.

The GIS data on primary and old-growth 
forests areas should, once legally protected, 
be reported to the European Environment 
Agency’s Common Database on Designated 
Areas. This is a dataset of nationally 
designated protected areas.

15  Barredo , J.I., Brailescu, 
C., Teller, A., Sabatini, 
F.M., Mauri, A. and 
Janouskova, K., Mapping 
and assessment of 
primary and old-
growth forests in 
Europe, Publications 
Office of the European 
Union, Luxembourg, 
2021, https://dx.doi.
org/10.2760/797591

Fagaras, RO (2018), © Schickhofer

MAPPING

13

5.   
Monitoring16

Structural and regular monitoring of primary 
and old-growth forests is relevant to 
measuring and assessing the impact of:

The following elements should be considered 
when developing monitoring programmes:

 •

governance;

 • management measures;

 • human, and natural (biotic and abiotic) 
disturbances, including the impact of 
climate change. 

Monitoring is also crucial for guiding the 
conservation of these forest areas, and 
for informing about the implementation 
of current and future strategies, policies 
and legislation. Moreover, participatory 
approaches for monitoring programmes can 
increase local employment opportunities and 
ecological knowledge, and help develop skills 
in forest protection.

1.  focus on the most important forest 

attributes of primary and old-growth 
forests, including those outlined in Sections 
2 and 3 of this document;

2.  coordinate or integrate with National Forest 

Inventories (NFIs), the reporting requirements 
of the Habitats Directive and other 
environment monitoring and assessment 
programmes, such as the Forest Information 
System for Europe (FISE).

3.  the possible use of remote-sensing 

tools for certain indicators about habitat 
conditions and conservation status. 
For example, habitat loss, defoliation, 
forest disturbances, forest damage, 
fragmentation and canopy composition. 

4.  elements relevant to the climate 

adaptation agenda, with a view to 
observing how primary and old-growth 
forests react to new climatic conditions 
compared to other forests.

16  This section 

includes general 
recommendations 
pending the 
development of the 
legislative initiative 
on forest monitoring 
and strategic plans 
announced by the 
European Commission 
for Q2 2023.

14 MONITORING

6.   
Strict protection

Identified areas of primary and old-growth 
forests should be placed under strict 
protection, as stated in the EU Biodiversity 
and Forest Strategies for 2030. Primary and 
old-growth forests that met the definitions of 
this document after 20 May 2020 (when the 
EU Biodiversity Strategy17 was published), but 
have since lost their defining characteristics 
due to human activity, should also be strictly 
protected so they can redevelop. In line with 
the precautionary principle, Member States 
should without delay strictly protect those 
forest areas for which there is a strong 
probability, on the basis of the currently 
available information, that they meet 
definitions and criteria set out  
in this document. 

Guidance on management principles for 
strictly protected areas have been developed 
at EU level. The Commission’s Expert Group 
on the Birds and Habitats Directives (NADEG) 
has produced a technical note on guidance 
for strict protection18, which underlines 
that many strictly protected areas will be 
non-intervention areas. In these cases, only 
limited and well-controlled activities that 
do not interfere with natural processes or 
enhance them will be allowed. Subject to 
a case-by-case assessment, permissible 
activities may include:

 •

 •

 •

 •

scientific research; 

natural disaster prevention (e.g. wildfires); 

control of invasive alien species; non-
intrusive activities and installations; 

non-intrusive and strictly controlled 
recreational activities, when such activities 
are compatible with the conservation 
objectives of the areas. In practice, this 
means that productive forest management 
regimes are to be excluded from primary 
and old-growth forests. 

17  The Strategy presented 
the goal of strictly 
protecting all the EU’s 
remaining primary and 
old-growth forests.

18  Commission Staff 

Working Document - 
Criteria and guidance 
for protected areas 
designations, 
SWD(2022) 23 final.

STRICT PROTECTION

15

Management activities authorised in areas of 
primary and old-growth forests should only 
include those that are essential for supporting 
or enhancing natural processes and those that 
are necessary for restoring and/or conserving 
the habitats and species for whose protection 
the area has been designated. For example, 
population control of wild ungulates in 
areas where natural predation is insufficient 
would be considered compatible with strict 
protection. The small-scale subsistence use 
of resources by indigenous people are also 
considered compatible, provided they do not 
interfere with the conservation objectives of 
the area. Data for activities which are or are 
not compatible with strict protection should 
become available once these forests have 
been integrated into strictly protected areas. 
The corresponding management plans or 
equivalent management tools should also 
have been developed. 

Strict protection of primary and old-growth 
forests should be accompanied by legal 
protection of the area. It should also be 
complemented by suitable management 
approaches in the surrounding buffer zones 
with the double objective of ensuring that: 

1.  human activities and developments in the 
areas surrounding primary and old-growth 
forests do not affect the natural processes 
of these forests; 

2.  natural processes within primary and 

old-growth forests do not have a negative 
spill-over effect on the management 
objectives of the surrounding areas. 

The size of the buffer zone will depend on 
the size and characteristics of the forest 
areas subject to protection. Buffer zones 
for primary and old-growth forests might 
also be protected under other protection 
regimes (e.g. Natura 2000 sites), if existing 
management plans sufficiently ensure 
conservation. Permitted activities should also 
not compromise the conservation objectives 
for the main strictly protected area.

16

STRICT PROTECTION

Fagaras, RO (2018), © Schickhofer

7.   
Financing

It is clear that implementing a new definition, 
nation-wide mapping, monitoring programme 
and site-specific management plans will require 
resources at all levels. The development of a 
national platform/national dialogue space on 
primary and old-growth forests may also be 
envisaged. Consideration should therefore be 
given to a number of points on how to foster 
compensatory measures.

The Commission encourages Member States to 
use the opportunities for EU co-financing under 
the various programmes available, particularly 
the Rural Development Programme19 and the 
CAP Strategic Plans20, Cohesion Policy21, the 
Recovery and Resilience Facility22, the Technical 
Support Instrument23, the EU programme 
for the environment and climate action24, 
and Horizon Europe25. Member States are 
also encouraged to make use of nationally 
funded instruments under State aid26, such as 
payments for ecosystem services27.

19  https://ec.europa.eu/info/
food-farming-fisheries/
key-policies/common-
agricultural-policy/rural-
development_en 

20  https://agriculture.

ec.europa.eu/cap-my-
country/cap-strategic-
plans_en

21  https://ec.europa.eu/

regional_policy/policy/
what/investment-
policy_en 

22  https://ec.europa.eu/info/
business-economy-euro/
recovery-coronavirus/
recovery-and-resilience-
facility_en 

23  Regulation (EU) 

2021/240 of the 
European Parliament 
and of the Council of 
10 February 2021 
establishing a Technical 
Support Instrument

24  https://ec.europa.eu/

easme/en/life 

25  https://research-
and-innovation.
ec.europa.eu/funding/
funding-opportunities/
funding-programmes-
and-open-calls/
horizon-europe/cluster-
6-food-bioeconomy-
natural-resources-
agriculture-and-
environment_en 

26  Guidelines for State aid 
in the agricultural and 
forestry sectors and 
in rural areas (https://
europa.eu/!J8pp7n)

27  The Commission will 
publish a guidance 
on payments for 
ecosystem services in 
Q2 2023 that may be 
useful in the context 
of financing strict 
protection. Additionally, 
future carbon removal 
certificates under the 
proposed Regulation 
establishing a Union 
certification framework 
for carbon removals 
can also fund additional 
carbon removal 
stemming from the 
protection of old-growth 
forests. 

Kamptal, AT (2016), © Schickhofer

FINANCING

17

8.   
Indicative 
timetable for 
implementation

Step

Member States to submit their pledges to the Commission on 
protected areas (under NADEG), including on strict protection.
In line with the precautionary principle, Member States should without 
delay strictly protect those forest areas for which there is a strong 
probability, on the basis of the currently available information, that 
they meet definitions and criteria set out in this document. 

Latest date

Beginning 2023

Develop an identification and mapping methodology. 

End 2023 

Finalise the mapping of public primary and old-growth forests.

Mid 2025

Finalise the mapping of private primary and old-growth forests.

End 2025

Strictly protect identified and mapped primary and old-growth 
forests.

End 2029 

18

INDICATIVE TIMETABLE FOR IMPLEMENTATION

Kamptal, AT (2016), © Schickhofer

INDICATIVE TIMETABLE FOR IMPLEMENTATION

19

Annexes

Annex I. List of existing international 
definitions for “primary forests”, “old-
growth forests” and other related terms.

Organisation 
(reference)

FAO - Forest 
Resource 
Assessment (FAO, 
2018)

Forest Europe 
(2015)

Term and definition

Primary forests: ‘Naturally regenerated forest of native tree species, 
where there are no clearly visible indications of human activities and 
the ecological processes are not significantly disturbed. Some key 
characteristics of primary forests are 1) They show natural forest 
dynamics, such as natural tree species composition, occurrence of 
dead wood, natural age structure and natural regeneration processes; 
2) The area is large enough to maintain its natural ecological 
processes; and 3) There has been no known significant human 
intervention, or the last significant human intervention was long 
enough ago to have allowed the natural species composition and 
processes to have become re-established.’

Forest undisturbed by man: ‘Forest (or other wooded land) which 
shows natural forest dynamics, such as natural tree composition, 
occurrence of deadwood, natural age structure and natural 
regeneration processes, the area of which is large enough to maintain 
its natural characteristics and where there has been no known 
significant human intervention, or where the last significant human 
intervention was long enough ago to have allowed the natural species 
composition and processes to have become re-established.’

Carpathian 
Convention (2014)

Virgin forests: ‘natural forests which have not been influenced 
directly by human activities in their development and natural forest 
means forests composed of tree species indigenous to the area with 
most of the principal characteristics and key elements of native 
ecosystems, such as complexity, structure and diversity.’

20

ANNEXES

 
Organisation 
(reference)

UNESCO Ancient 
and Primeval 
Beech Forests of 
the Carpathians 
and Other 
Regions of Europe 
(Kirchmeir and 
Kovarovics, 2020)

Term and definition

Primeval or virgin forests: ‘Natural forests which have not been 
influenced directly by human activities in their development. ‘Natural 
forest’ means forests composed of tree species indigenous to the 
area, with most of the principal characteristics and key elements of 
native ecosystems, such as complexity, structure and diversity.’

Ancient (beech) forests: (considered synonymous with ‘old-
growth (beech) forest’) are ‘forest stands which have been directly 
influenced by human activities in the past, but the last significant 
impact is dated back several decades (or even centuries). Throughout 
the period of missing impact (mainly absence of logging), natural 
processes have taken place and structures similar to untouched virgin 
forests have developed. For beech forests, this includes trees that are 
significantly older than the usual period of logging rotation (100–120 
years) and deadwood amounts of over 20 m³ are already in place.’

European 
Commission (EC, 
2015) 

Primary forests: Same as in the FAO’s Forest Resource Assessment 
(see above).

Old-growth forest: ‘Old growth forest stands are stands in primary 
or secondary forests that have developed the structures and species 
normally associated with old primary forest of that type.’

Convention on 
Biological Diversity 
(CBD)

‘Primary forest’ is a forest that has never been logged and has 
developed following natural disturbances and under natural processes, 
regardless of its age. It is referred to ‘direct human disturbance’ as the 
intentional clearing of forest by any means (including fire) to manage 
or alter them for human use. Also included as primary, are forests that 
are used inconsequentially by indigenous and local communities living 
traditional lifestyles relevant for the conservation and sustainable use 
of biological diversity. In much of Europe, primary forest has a different 
connotation and refers to an area of forest land which has probably 
been continuously wooded at least throughout historical times (e.g., the 
last thousand years). It has not been completely cleared or converted 
to another land use for any period of time. However, traditional 
human disturbances such as patch felling for shifting cultivation, 
coppicing, burning and also, more recently, selective/partial logging 
may have occurred, as well as natural disturbances. The present cover 
is normally relatively close to the natural composition and has arisen 
(predominantly) through natural regeneration, but planted stands can 
also be found. However, the suggested definition above would include 
other forests, such as secondary forests.’

‘Old growth forest’ stands are stands in primary or secondary 
forests that have developed the structures and species normally 
associated with old primary forest of that type have sufficiently 
accumulated to act as a forest ecosystem distinct from any younger 
age class. A Secondary forest is a forest that has been logged 
and has recovered naturally or artificially. Not all secondary forests 
provide the same value to sustaining biological diversity, or goods 
and services, as did primary forest in the same location. In Europe, 
secondary forest is forest land where there has been a period of 
complete clearance by humans with or without a period of conversion 
to another land use. Forest cover has regenerated naturally or 
artificially through planting.’

ANNEXES

21

Annex II. Overview on the ‘Frequency 
of key indicators in old-growth forest 
definitions’ based on the replies of 
21 Member States28 and 6 other 
organisations29

Frequency of key indicators in OGF definitions

Historical context, human activities

Age class/structure 

Tree species composition 

Deadwood volume/type

Indicator species

Natural disturbance regime 

Regeneration processes 

Stand origin (natural or artificial) 

Size/area 

Forest habitat types

Absence of alien species 

Microhabitats, undergrowth 

Soil-related indicators

Cultural values 

Other

Growing stock 

EU Member States

Other organisations

28  Belgium, Bulgaria, 
Czechia, Denmark, 
Estonia, Ireland, Spain, 
France, Croatia, Italy, 
Latvia, Lithuania, the 
Netherlands, Austria, 
Poland, Portugal, 
Romania, Slovenia, 
Slovakia, Finland and 
Sweden.

29  CEPI, COPA-CEPF, 

EUSTAFOR, WWF, FSC 
(observer) and EOS 
(observer).

22

ANNEXES

Fagaras, RO (2018), © Schickhofer

Annex III. List of organisations 
participating in the meetings of the 
Working Group Forest and Nature

Member State Experts

Austria

Federal Ministry for Agriculture, Forestry, Regions and Water 
Management

Federal Ministry for Climate Action, Environment, Energy, Mobility, 
Innovation and Technology

Belgium

Service Public de Wallonie (SPW)

Forêt.Nature

Research Institute for Nature and Forest (INBO)

Sonian Forest Foundation

Bulgaria

Executive Forest Agency 

Ministry for Agriculture

Ministry for Environment and Water

Croatia

Ministry for Agriculture

Ministry for Economy and Sustainable Development

Cyprus

Ministry for Agriculture, Rural Development and Environment – 
Department of Forests

Czechia

Ministry for Agriculture

Ministry for Economy and Sustainable Development

Denmark

Ministry for Environment

Estonia

Finland

Danish Environmental Protection Agency - Landscape and Forest

Ministry for Environment, Forest & Nature Conservation Departments 

Ministry for Agriculture and Forestry

Finnish Environment Institute

Ministry for Environment

Natural Resources Institute of Finland

ANNEXES

23

Member State Experts

France

Ministry for Agriculture

Ministry for Environment

Ministry for European Affairs

Germany

Federal Ministry for Environment, Nature Conservation, Nuclear Safety 
and Consumer Protection

Federal Ministry for Food and Agriculture

Federal Agency for Nature Conservation

Greece

Hungary

Ireland

Ministry for Environment and Energy, Directorate General for Forests 
and Forest Environment

Ministry for Agriculture - Department for Forest Management

The National Parks and Wildlife Service - Department of Housing, 
Local Government and Heritage

The Forest Service - Department of Agriculture, Food and the Marine

Italy

Institute for Environment Protection and Research

Ministry for Agriculture, Food Sovereignty and Forests

Ministry for Environment and Energy Security

UNIFI - Università degli Studi di Firenze

Latvia

Ministry for Agriculture 

Ministry for Environmental Protection and Regional Development 

Lithuania

Ministry for Environment

Luxembourg

Ministry for Environment, Climate and Sustainable Development

Malta

Ministry for Agriculture, Fisheries and Animal Rights

Ministry for Environment, Energy and Enterprise

Ambjent Malta

Parks Malta

Netherlands

Ministry for Agriculture, Nature and Food Quality

Poland

Ministry for Climate and Environment 

Directorate General for the State Forests

24

ANNEXES

Member State Experts

Portugal

Institute for Conservation of Nature and Forests 

Ministry for Environment and Climate Action

Romania

Ministry for Environment, Waters and Forests – General Directorate of 
Forests and Strategies in Forestry 

Slovakia

National Forest Centre

Ministry for Environment 

Slovenia

Ministry for Natural Resources and Spatial Planning

Spain

Ministry for Ecological Transition and Demographic Challenge - 
Directorate General of Biodiversity, Forests and Desertification

Sweden

Swedish Forest Agency

Swedish Environmental Protection Agency

Fagaras, RO (2018), © Schickhofer

ANNEXES

25

Forest Stakeholders, Civil Society Organisations and others

CEPF - Confederation of European Forest Owners

CEPI - Confederation of European Paper Industries

COPA/ COGECA - Farmers and Forest-Cooperatives Organisations

EFNA - European Forestry Nursery Association

ELO - European Landowners’ Organization

EOS - European Organisation of the Sawmill Industry

EUSTAFOR - European State Forest Association

FSC - Forest Stewardship Council International

PEFC - Programme for the Endorsement of Forest Certification

USSE - Unión de Selvicultores del Sur de Europa

BirdLife Europe and Central Asia

EEB - European Environmental Bureau

EuroNatur

Fern

Protect the Forest

Wild Europe Foundation

WWF European Policy Office

EFI - European Forest Institute 

EURAF - European Agroforestry Federation

FACE - European Federation for Hunting and Conservation

Pro Silva

Saami Council

26

ANNEXES

GETTING IN TOUCH WITH THE EU

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ANNEXES

27