More Work on the EU Taxonomy is Needed – Nine Recommendations for Further Steps from EUSTAFOR

Considering the great potential of sustainably managed and multi-functional forests as significant contributors to the EU Green Deal objectives, EUSTAFOR supports the inclusion of forestry activities into the scope of the EU Taxonomy. This, however, must be done in full respect of the subsidiarity principle in order to avoid inconsistencies and contradictions with the already existing forest laws of Member States.

The EU Taxonomy should use the existing definition and principles of sustainable forest management (SFM) that are already applied nationally and internationally, namely those developed under the Forest Europe process.

The EU Taxonomy should also avoid imposing new and superfluous administrative burdens on a sector which has already been well-regulated by a comprehensive system of sustainability requirements. 

EUSTAFOR wishes to draw the Commission’s attention to the following aspects in further work on the Delegated Regulation and associated annexes:

  1. “No one size fits all” should be the guiding principle of the EU Taxonomy with regards to forests and forestry
  2. The EU Taxonomy should address the entirety of a forest’s life and production cycles
  3. Only well-defined and well-understood concepts should be used
  4. “Additionality” and “improved” forest management cannot be accepted without a prior state-of-the-art assessment
  5. Proposed technical screening criteria are unnecessarily complex and burdensome
  6. The EU Taxonomy cannot promote considerations of social issues over those of business planning and governance
  7. Climate benefit analyses should be based on a wide scope of forest products
  8. The conservation of biodiversity and nature is encompassed within SFM.
  9. There is a misconception concerning the use of whole tree stems for bioenergy

EUSTAFOR is of the opinion that a well-designed EU Taxonomy, based on the principles of proportionality and subsidiarity, can be an important policy tool for reaching the EU Green Deal’s objectives for a climate neutral and future-fit Europe. European state forests are ready to further contribute to a transparent and inclusive process set by the Commission and the Member States with an aim to reach final agreement on this important file.

Published 19/12/2020, Brussels

Mr. Piotr Borkowski

Executive Director

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