Resilience Over Removals: EUSTAFOR’s Vision for the EU’s Post-2030 Climate Framework

On 4 May 2026, EUSTAFOR submitted its response to the European Commission’s public consultation on national targets and flexibilities in the EU climate policy framework after 2030.

The overarching message: the post-2030 framework should be built around resilient forests over long time horizons, rather than single-year removal figures imposed by the climate system. Drawing on the EEA’s 2025 land carbon sink report, State of Europe’s Forests 2025, and the 2026 EU GHG inventory, EUSTAFOR argues that the carbon sink is shaped by multiple interacting, climate-dominated drivers, and that recent volatility (a 17% jump in net LULUCF removals between 2023 and 2024) shows why outcome-only targets are a poor fit for the sector.

Key recommendations to the Commission:

• ground the impact assessment in a multi-driver diagnosis of sink dynamics, rather than isolating harvesting as the single lever;
• treat forest resilience as the overarching forest-policy objective;
• move from outcome-based sink targets toward action-based metrics that reflect what Member States can actually steer;
• align LULUCF and CRCF incentives with active Sustainable Forest Management, not harvest-level reductions;
• recognise the full bioeconomy contribution of sustainably managed forests, including improved Harvested Wood Products accounting and coherent treatment of wood across climate, energy, and construction policy.

Read the full response: EUSTAFOR Input to the Post-2030 Climate Targets Consultation (PDF)