Call for evidence on the EU Land Use, Land Use Change and Forestry (LULUCF) Regulation

Carbon Market Watch argues that the EU's net carbon sink is declining rapidly and that the current LULUCF Regulation contains loopholes, such as offsetting flexibility and reliance on forest biomass, that undermine climate goals. The organization recommends removing offsetting mechanisms, preventing double counting between national inventories and corporate claims under the Carbon Removal Certification Framework (CRCF), limiting forest harvesting for bioenergy, and strengthening synergies between LULUCF targets and the Common Agriculture Policy (CAP) and Nature Restoration Law.

• The EU net carbon sink has decreased significantly, with the European Scientific Advisory Board on Climate Change (ESABCC) reporting that by 2021 it had fallen to a third of its 2005 total. Consequently, the EU is not on track to meet its Union-wide net carbon removal target for 2030.
• The flexibility mechanism allowing emissions to be offset with removals between the Effort Sharing Regulation (ESR) and LULUCF should be deleted, as it causes mitigation deterrence and diverts attention from restoring natural sinks.
• The Carbon Removal Certification Framework (CRCF) creates a risk of double counting where countries account for carbon storage in products as removals under LULUCF while companies sell those same units on the voluntary carbon market to claim climate neutrality.
• Increased forest harvesting is a primary driver of the EU forest sink decline, with harvested forest area and biomass loss increasing by 49% and 69% respectively between 2016-2018 compared to 2011-2015. Only 10% to 20% of harvested forest biomass is used for long-lived harvested wood products (HWP), with the majority used for bioenergy and short-lived products.
• EU member states are failing to integrate LULUCF targets with other policies; over half of member states have delayed mandatory CAP requirements to preserve wetlands, and there is inadequate uptake of CAP eco-schemes for wetland restoration.

APA

Carbon Market Watch (2024). Call for evidence on the EU Land Use, Land Use Change and Forestry (LULUCF) Regulation. https://carbonmarketwatch.org/wp-content/uploads/2024/07/CMW-feedback-to-call-for-evidence-on-LULUCF-Regulation-July-2024.pdf

Chicago

Carbon Market Watch. Call for evidence on the EU Land Use, Land Use Change and Forestry (LULUCF) Regulation. 2024. https://carbonmarketwatch.org/wp-content/uploads/2024/07/CMW-feedback-to-call-for-evidence-on-LULUCF-Regulation-July-2024.pdf.

Wikipedia

{{cite press release |author=Carbon Market Watch |title=Call for evidence on the EU Land Use, Land Use Change and Forestry (LULUCF) Regulation |date=7 November 2024 |url=https://carbonmarketwatch.org/wp-content/uploads/2024/07/CMW-feedback-to-call-for-evidence-on-LULUCF-Regulation-July-2024.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@misc{carbonmarketwatch2024call, author = {{Carbon Market Watch}}, title = {{Call for evidence on the EU Land Use, Land Use Change and Forestry (LULUCF) Regulation}}, publisher = {Carbon Market Watch}, year = {2024}, month = nov, url = {https://carbonmarketwatch.org/wp-content/uploads/2024/07/CMW-feedback-to-call-for-evidence-on-LULUCF-Regulation-July-2024.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }