The Confederation of European Forest Owners (CEPF) acknowledges the opportunity to comment on the revised technical screening criteria of the EU taxonomy climate delegated act. In our feedback we will focus on the forest-related activities, particularly forest management. While the revision addresses some concerns, fundamental barriers remain.
CEPF has already previously noted the very limited uptake of the taxonomy among forest owners and the broader forestry sector. Reporting in accordance with the taxonomy is both unappealing and financially infeasible for many forest owners due to administrative burden and significant costs of monitoring, reporting, and verification that are unlikely to be covered by any potential additional income. Forest owners want to contribute to climate change mitigation and adaptation, but the taxonomy does not bring them any added value to support them in these efforts. While some changes in the draft act are steps in the right direction—such as the possibility of stacking taxonomy audits with other audits—their practical impact remains uncertain.
Although we appreciate the explicit recognition of more diverse supporting documentation to demonstrate compliance, we find this unlikely to have an actual simplification effect. A regular forest management plan generally does not fulfil all the requirements set by the technical screening criteria of the taxonomy, so a separate management plan for taxonomy purposes would be needed regardless. CEPF also notes that not all forest owners have a forest management plan, and as having one should not be mandated by EU policy, it also should not be an eligibility criterion. National forestry programmes and other such broader instruments that provide equivalent assurance of sustainable forest management should be explicitly acknowledged as alternatives for demonstrating compliance as well.
To achieve meaningful simplification, CEPF suggests establishing a general default that recognises forest management plans prepared in accordance with national law, especially those prepared within certified forest management systems, rather than assessing equivalence on a case-by-case basis. In this context, CEPF welcomes the inclusion of voluntary certification to support compliance, but encourages still stronger integration with well-established certification schemes to reduce administrative burdens. Sourcing area, regional, or national level should always be a priority for a climate benefit analysis, as on a plot level the benefit is much harder to demonstrate, especially given the 30-year monitoring period that is often not long enough to demonstrate the benefits in forests with much longer rotation periods.
CEPF is concerned about the removal of the reference to the Forest Europe definition of sustainable forest management (SFM). The Forest Europe framework represents a well-established, pan-European consensus on SFM as a practical standard already in wide use for decades, and replacing this with shoddily defined best practices seems like backpedalling. Using this established reference would enhance policy coherence, and provide a clear and recognised benchmark for practitioners and investors. We strongly urge the Commission to revert back to explicitly referencing SFM.
Seeing the many new references to various policies, we have remarks regarding policy coherence. First, we’d like to note that the reference to the EU Deforestation Regulation (EUDR) is unnecessary and counterproductive from a simplification perspective as compliance with the EUDR is a legal obligation that applies independently of the taxonomy. It also brings to question whether the taxonomy needs to be reopened to add a reference whenever there is a new possibly relevant policy, which is neither desirable nor sensible. Second, the compliance pathway via the Carbon Removal Certification Framework is positive in principle, but its practical application possibilities are currently highly limited. While an afforestation methodology is close to adoption, the development of a forest management methodology has barely started and should thus not be relied on too early in the process. Third and last, we take issue with the biodiversity DNSH criteria that adds references to the nature restoration regulation and the nature directives. DNSH should require compliance with applicable environmental law, not create a parallel, ill-defined additional standard. "No deterioration" overestimates capacities under climate change and the favourable conservation status criteria are unworkable given the one-out-all-out logic. Site-level obligations are already governed by Natura 2000 management plans. Furthermore, concepts such as "specifically sensitive to biodiversity loss" and "no deterioration of conservation status" are not legally defined and will create interpretive gaps.
CEPF expects these concerns of European forest owners to be regarded carefully and remains available to support further developments.
