The Confederation of European Forest Owners (CEPF) recognises the opportunity to contribute to the review and simplification of the climate delegated act of the EU taxonomy, and acknowledging the current lack of uptake among forest owners, CEPF would like to emphasise the benefits and practicality of building on existing tools and processes already in use.
The taxonomy’s forestry criteria have seen very limited uptake among forest owners, in many countries seemingly completely lacking. This is primarily because there is no clear benefit for forest owners themselves, nor do other actors in the value chain require or benefit from its implementation. Furthermore, the taxonomy does not align well with existing reporting frameworks, such as those used in forest certification schemes. As a result, forest owners often see the taxonomy merely as an additional unnecessary administrative layer, which does not support them in contributing to climate change mitigation and adaptation although they wish to be a part of the solution.
Similarly, we observe that few banks have adopted the forestry criteria for taxonomy compliance, and forest owners report that banks rarely inquire about taxonomy alignment when assessing loan applications. This further reduces the incentive for forest owners to engage with the taxonomy.
The climate benefit analysis remains unclear and arbitrary. Forest owners lack information on the measuring of the climate benefit and its practical implications on forest management. The 13-hectare threshold for inclusion does not aid the matter, as while it excludes the majority of forest owners, and particularly the smallest ones for whom the administrative burden would be the most unreasonable with no foreseeable benefits, the line is not drawn at a limit where the benefits would be clearly worth the additional effort. The costs of monitoring, reporting, and verification (MRV) are unlikely to be covered by any potential income from demonstrating sustainable practices, making participation unappealing and financially infeasible for many. Accuracy in monitoring can be achieved only by combining remote sensing with field inventories, which also tends to create higher costs. For cost-efficiency and simplicity, existing sustainable forest management certification systems could be recognised as reliable sources within the taxonomy framework. Sourcing level should always be a priority for a climate benefit analysis, as on a plot level the benefit is much harder to demonstrate.
Forest owners already invest significant time and resources in planning and implementing their forest management, including sustainability planning, record keeping and when relevant also audits. The taxonomy should seek to integrate with, rather than duplicate, these efforts. CEPF recommends a more streamlined approach, building on existing certification schemes, national and regional legislation, and publicly available reliable forest data, to reduce bureaucracy while maintaining environmental integrity. The availability of sustainability-related data varies by country, but most EU member states have a national forest inventory that could serve as a reliable source for taxonomy purposes.
The criteria for addressing societal aspects in afforestation and forest management plans are often unclear and difficult to implement. Clarifying expectations and documentation requirements would help reduce uncertainty and administrative effort. This goes for the DNSH criteria as well, as the current lack of well-defined criteria for compliance creates confusion.
CEPF stands ready to engage further in the development and refinement of the taxonomy to ensure it is practical and effective to respond to the reality of European forests and forest owners.
