Developed in response to the fragmentation and inconsistency in current data on EU forests, the proposal seeks to improve the quality and consistency of forest data. The proposal reflects recent developments in monitoring technology (particularly satellite monitoring) and promotes better use of data to support risk preparedness and evidence-based decision-making.

While the FML has been proposed to address a range of goals, it has relevance for carbon dioxide removals (CDR). The Commission’s proposal highlights its potential role in enabling the adoption of carbon farming (low durability, land-based CDR) projects under the Carbon Removals and Carbon Farming Regulation (CRCF), by increasing farmers’ access to high-quality data that meets the threshold for participation in carbon markets.

The FML complements multiple EU instruments for the governance of forests and related policy areas, including the EU forest strategy for 2030, the biodiversity strategy for 2030, the biodiversity strategy for 2030, the LULUCF Regulation, the Deforestation Regulation, the bioeconomy strategy, and the Renewable Energy Directive.

The FML succeeds an earlier framework, the Forest Focus Regulation. The preceding regulation aimed at long-term monitoring of the condition of forests, including the current or potential future monitoring of characteristics such as air pollution effects, fires, soils, soil carbon, biodiversity and climate change impacts.

In addition to these key pillars, the proposal sets out requirements for quality control and the remedying of inaccurate data, coordination among member states to improve data quality and coverage, and the need for a “national correspondent” responsible for data preparation. The proposal also encourages the voluntary adoption by member states of integrated forest plans, ideally with a long-term perspective to 2040, 2050, and beyond.

Stakeholder responses to the proposal

The proposal for a forest monitoring system has been welcomed by stakeholders from the nature conservation landscape, including WWF, Fern and EEB. To improve the proposal, WWF has suggested additional indicators for data collection and argued for more streamlined reporting that brings alignment with existing requirements under the LULUCF Regulation and Renewable Energy Directive. Fern has called for national forest plans to be more strongly encouraged (rather than fully voluntary), by making them a pre-condition for EU funding. EUSTAFOR, the association for state forest companies, recommends a clearer definition of objectives, namely the promotion of state-of-the-art and cost-effective monitoring techniques.

The FML’s role in European CDR

The FML could bolster the role of forests in European CDR through the provision of clearer data on forest CDR performance. Improved monitoring of key forest characteristics can clarify CDR rates in different forest types, reveal the carbon impacts of forest loss and forest expansion, and highlight the risks facing forest carbon due to climate change, such as fires. Such information can help to identify appropriate actions to protect and enhance the forest carbon sink, particularly by improving forest health and recognising the twin crises of climate change and nature degradation faced by forests. This information can feed into both target-setting and progress tracking of forest-related emissions reductions and removals, namely under the LULUCF Regulation, which includes member state-level targets for CDR.

The FML legislative proposal and accompanying impact assessment both reference the FML’s potential to support carbon farming projects (which includes forestation projects) to participate in carbon markets and align with the CRCF. According to the impact assessment, the FML could help carbon project developers by clarifying the appropriate monitoring methods and data requirements, providing public data to support baselining, for example. This could lower the costs of setting up carbon projects. The IEEP suggests that improved monitoring could provide insights about any reversals that have occurred, informing appropriate remedial action to ensure overall climate benefits are upheld, as well as enhancing transparency and public trust in the CRCF as a whole.

Though they are less durable than other methods, afforestation and reforestation remain important to achieving EU climate goals as they can help balance biogenic emissions in the atmosphere as part of the like-for-like principle.

Managing what you measure

Monitoring and measurement is only the first stage in protecting European forests and enhancing the forest carbon sink. While “you can’t manage what you don’t measure”, clear incentives and obligations are additionally needed to ensure real action is taken. The FML will work in tandem with other instruments, like the Deforestation Regulation which sets rules for private companies to reduce the risk of deforestation and forest degradation in the supply chains of products sold in Europe, and the LULUCF Regulation, which sets rules for states to ensure that emissions and removals from land use, land use change and forestry activities are accurately accounted for in the EU’s climate targets. But there is scope to strengthen the requirements within the FML itself – for example, clarifying penalties for non-compliance, mandating the setting of long-term forest plans, or requiring disclosures of national forest plans within National Energy and Climate Plans.