As part of its climate promises, the EU has committed to an EU-wide “removals” target for CO2e uptake by forests and other lands of 310 Mt CO2e per year by 2030, with specific targets for each Member State. The targets are set out in the Land Use, Land Use Change and Forestry (LULUCF) Regulation. Achieving the targets will require Member States to manage forests and other lands in a way that reverses the ongoing decline in net CO2 uptake by the land sector.
The EU Climate Law requires Member States to submit National Energy and Climate Plans (NECPs) that, among other things, are supposed to include information on how they plan to meet carbon removal targets. The NECP guidance, and new rules in the Renewable Energy Directive (RED), particularly require Member States to provide data on the amounts and sources of forest biomass fuels, and how use of forest biomass will affect the forest carbon sink.
A 2024 review of the draft NECPs found that Member States had failed across the board to provide the required information. As of May 2025, the situation has not really improved, as shown by the European Commission’s (EC) review of the final NECPs and data on an even more basic requirement: simply having a plan to hit the land carbon sink target. Four countries – Belgium, Estonia, Poland and Slovakia – did not submit their final NECPs by the deadline. “Insufficient” is the most important word for 15 other countries. Only 8 countries submitted plans that do not fall short of their country-specific targets. When adding up the LULUCF commitments of the 23 NECPs, we see a gap of almost 42 Mt CO2 compared to the 310 Mt target.
Unless the delayed 4 MSs provide significant overachievement – very unlikely – the EU is going to miss its carbon removal target at the first possible opportunity: the setting of national targets (let alone their implementation).
What can be done?
- The EU must enforce the Member States LULUCF targets as MSs are currently acting as if there are no repercussions for allowing their carbon sinks to deteriorate.
- Stop incentivising biomass use for energy. More than half the wood harvested in the EU each year is burned for energy. Policymakers should reform the RED to exclude forest biomass as a renewable energy source. This would reduce logging pressure on forests and increase forest carbon sinks (and potentially also make more biomass available for material uses).
- Reduce consumption. The Joint Research Center calculates that reducing consumption from today’s 1.1 m3of wood products per person per year, to 0.9 m3, could help meet carbon sink targets whilst continuing to meet consumption demand.
- Implement the Nature Restoration Law to increase C sinks through the restoration of degraded habitats such as forests, wetlands, and especially peatlands.
Member States are not taking land carbon sink targets seriously. Will policymakers at the EU level act?
