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25.02.2026 environment

Cepi calls for balanced approach in post-2030 LULUCF Regulation

The European pulp and paper industry has reiterated its full support for the EU objective of achieving climate neutrality by 2050, underlining its contribution through decarbonised production, sustainable forest management and fibre-based products that store biogenic carbon while substituting fossil-intensive alternatives.

According to Cepi, the sector has reduced its CO₂ emissions by 46% since 2005 and continues to play a central role in the forest-based bioeconomy, which represents one in five manufacturing sites in Europe and relies predominantly on EU-grown raw materials. Fibre-based products provide citizens with low-carbon solutions that help decrease dependence on fossil-based materials and energy.

Cepi stresses that climate change is primarily driven by fossil fuel emissions, while natural and technical carbon sinks can help mitigate impacts through removals. At the same time, forest sink capacity across Europe is under pressure. Many Member States are struggling to meet 2030 sink targets due to forest age dynamics, increasing wildfires, droughts, pest outbreaks and higher harvest levels linked to salvage logging and geopolitical developments.

Active and sustainable forest management is considered essential to enhance forest resilience, stimulate growth and secure the supply of climate-friendly raw materials, thereby maximising overall climate benefits. Cepi defines active sustainable management as forest management adapted to local conditions, ensuring regeneration and increased growth while delivering wood-based products and other ecosystem services. This also includes testing and deploying species and varieties better suited to withstand more extreme climatic conditions.

In view of the 2040 climate targets, Cepi calls for a revision of the LULUCF Regulation to ensure realistic and balanced sink targets that accommodate both long-term carbon sinks (2050 and beyond) and the development of a growing bioeconomy, as recognised in recent amendments to the EU Climate Law. A balanced approach between production and conservation forestry is regarded as crucial to achieving Europe’s decarbonisation objectives. Scientific evidence indicates that forests managed for both conservation and sustainable production can prevent long-term sink saturation by combining carbon sequestration, carbon storage in products and substitution of fossil-intensive materials and energy.

Key messages

Forests should not offset emissions in hard-to-decarbonise sectors

Cepi acknowledges the key role of forest carbon removals in achieving EU climate objectives but warns that they should not be used to dilute emission reduction efforts in other sectors. Overreliance on forest offsets risks being counterproductive, inefficient and inequitable. The primary EU focus should remain on reducing fossil emissions, while simultaneously optimising the mitigation potential of the forest sector through active management and bioeconomy development.

Set an indicative target range instead of annual LULUCF targets

Based on lessons from the previous reporting period, Cepi argues that annual targets do not adequately reflect the natural variability and climate-related uncertainties affecting forest sinks. An indicative range for post-2030 sink targets would provide Member States with guidance while allowing flexibility to account for disturbances or force majeure events.

Recognise trade-offs between short- and long-term objectives

Post-2030 policies should avoid short-term measures that artificially increase sinks by limiting active forest management, such as delaying or foregoing harvests, at the expense of long-term resilience. Incentivising reduced harvesting could lead to sink saturation over time, negative socio-economic consequences for the forest sector and the bioeconomy, and increased harvest leakage if domestic demand shifts to non-EU raw materials.

Expand Harvested Wood Products (HWP) categories and update half-life values

Cepi calls for updating the half-life values used in LULUCF accounting for harvested wood products—currently limited to sawnwood, panels and paper—and for including additional product categories. Existing default values, based on the 2006 IPCC guidelines, do not reflect improvements in recycling rates or product innovation. Fibre-based products now remain in use longer due to multiple recycling cycles, and new products such as wood-based textiles, chemicals, by-products and residues are increasingly available. Updated or new half-life values could be aligned with the ISO 13391 Greenhouse Gas Dynamics standard.

Include substitution benefits as a formal reporting category

Cepi highlights that the current LULUCF Regulation does not account for the substitution effect of wood-based products, despite its importance. Substitution benefits apply not only to long-lived products but also to fibre-based applications, with substitution factors ranging from 1–1.5 kg C/kg C for packaging and chemicals to up to 2.8 kg C/kg C for wood-based textiles. Member States should measure and report these effects to better reflect the climate contribution of the forest-based bioeconomy, encourage the shift away from fossil-based materials and strengthen Europe’s competitiveness and resilience. The ISO 13391 Greenhouse Gas Dynamics standard is considered a suitable methodology for calculating the climate benefits of wood products, including substitution effects.

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