EUSTAFOR Responds to Open Letter Questioning its Public Positions

On 26 March 2026, EUSTAFOR received an open letter led by Zoltan Kun and co-signed by a number of environmental organisations, challenging several of EUSTAFOR’s public positions and statements on EU forest policy.

On 15 April 2026, EUSTAFOR issued a detailed response addressing the points raised and correcting what it considers to be mischaracterisations of its positions.

Key clarifications include:

• Positions taken out of context – Several of EUSTAFOR’s statements were cited selectively or without full consideration of the available information. EUSTAFOR notes that prior clarification with the organisation was not sought before the letter was published.
• EU Deforestation Regulation – EUSTAFOR did not advocate to “stop” the EUDR. Its call at the time was for additional implementation time to ensure the necessary IT systems and benchmarking frameworks were fit for purpose, a concern that has since proven well-founded. EUSTAFOR members are fully committed to compliance.
• Mapping of primary and old-growth forests – EUSTAFOR’s position was misrepresented. Its concern was strictly technical – the risk of data duplication and the use of localisation instead of measurable units.
• Protected areas targets – EUSTAFOR does not seek to exclude public forests from EU protection targets. Its position calls for a balanced and equitable approach to land protection across all land ownership types and habitat categories – not a disproportionate burden on state forests, which represent only around 30% of EU forests.
• Carbon sink targets and logging – EUSTAFOR’s position on LULUCF reflects the complexity of forest carbon dynamics, where climate-driven disturbances play a central role. The latest data shows wood removals are declining and remain within sustainable limits.
• EU Forest Monitoring Law and satellite data – EUSTAFOR has consistently supported transparent forest monitoring. Its position advocates for combining satellite data with ground-level verification – not against transparency or the use of satellite technology.

EUSTAFOR welcomes engagement from civil society and remains open to constructive dialogue. Read the full response here.