Where Member States choose to deploy it, the most important EU instrument to support European forest owners and sustainable forest management is the European Agricultural Fund for Rural Development (EAFRD), under the CAP. Forest owners have a direct and practical stake in this mid-term evaluation to bring current feedback and forward-looking insights.
Administrative burden and simplification
Forest owners welcomed the 2024 simplification measures, such as easier adaptations of CAP Strategic Plans during the funding period, but consider that administrative burden remains a significant barrier, particularly for small-scale owners. Evidence from forest owners across several Member States, gathered in previous funding periods, shows that planning a forestry project can take up to two years, and that the time between application and payment has in some cases reached three years. Costly external consultants are frequently required, and interpretation discrepancies between authorities and advisors cause further delays and reduced grants.
While implementation falls partly to Member States, EU-level regulations contribute to this complexity. For upcoming funding periods, introducing binding maximum timeframes between application and payment would provide essential planning certainty. Eligibility criteria should be clear, consistent across regions, and proportionate to the scale of the operation.
EU added value
There is a reasonable case for EU-level coordination on challenges that cross administrative boundaries, such as disaster prevention, forest health, and conservation of genetic resources. Where Member States use CAP instruments supporting forestry in such challenges, EU frameworks can facilitate knowledge exchange across different forest contexts in ways difficult to organise at national level alone. That said, while forestry remains a national competence under the subsidiarity principle, added value of EU involvement can be generated in certain cases of cross-national relevance. The added value itself depends entirely on how well instruments serve owners on the ground. Regarding the upcoming funding period, forest owners note with concern that cooperation and knowledge exchange measures are not included in the ring-fenced CAP budget under the proposed future architecture, and urge that this be addressed.
Continued relevance and forward-looking concerns
The CAP remains a relevant instrument where Member States deploy it, but structural shortcomings risk worsening under the proposed 2028-2034 architecture. Forest owners welcome that the Commission's proposal continues key interventions, including environmental and climate actions, Natura 2000 compensation, afforestation, resilience investments, and support for renewable raw materials and rural employment. Their continuity is essential.
Budget allocations for forestry within EAFRD have been insufficient relative to the demands placed on forests by EU climate, biodiversity, and nature restoration objectives. Co-financing rates are widely regarded as inadequate, and competition between forestry and agricultural measures has limited forestry's share in several Member States.
The proposed integration of CAP funding into National and Regional Partnership Plans for 2028-2034 risks further diluting forest-relevant funding. Forest owners share concerns raised by the European Court of Auditors, several Member State governments, agriculture ministers, and the European Parliament's Committee on Budgets co-rapporteurs, all cautioning against weakening the European dimension of agriculture and rural policy. The Commission's amendment to include a 10% rural target is a welcome step, but further safeguards are needed.
Forest owners urge that CAP funding remains clearly ring-fenced within any future architecture, that rural development retains a distinct and protected budget line, and that cooperation and knowledge exchange measures are included in that ring-fenced envelope. Funding schemes must remain voluntary, accessible, and administratively workable, with co-financing levels reflecting the longer investment horizons and real management costs specific to forestry.
European forest owners stand ready to contribute further evidence and expertise to the evaluation process.
