Sweden and Finland have called on the European Commission to revise components of the EU’s Land Use, Land-Use Change and Forestry (LULUCF) Regulation to "ensure access to the use of flexibilities within the regulation" and a "greater recognition of the substitution effects", arguing that current guidance and obligations would have “dire consequences” for their forest industries and labour markets.
In a joint letter to Commission President Ursula von der Leyen on September 15, 2025, Prime Minister of Sweden Ulf Kristersson and Prime Minister of Finland Petteri Orpo said a “much decreased” harvest would have “dire consequences” for their economies and the supply of timber and forest biomass across the EU.
The EU’s current framework for forest use, known as LULUCF, is a major problem and, if not revised, would lead to unreasonable and unjustified restrictions on Swedish forestry, said PM Kristersson on X.
Citing lower forest growth linked to natural disturbances and market disruptions following Russia’s full-scale invasion of Ukraine, which has increased demand for Nordic wood products in the EU, the Nordic PMs stated that the recent guidance and obligations under the LULUCF make it unlikely that the countries will meet targets for the 2021–25 and 2026–30 commitment periods.
The two have urged the Commission to reassess the contribution of net carbon removals expected from the Nordic forestry sector, and to “ensure access to the use of flexibilities within the regulation” in the ongoing compliance process for the first commitment period.
In the letter, PM Kristersson and PM Orpo have also called for “further work” on the Forest Reference Level technical corrections guidance to improve monitoring methodologies affecting the net carbon removals from the sector, such as “natural variability in growth, natural disturbances, increased emissions from organic soils, and the impact of geopolitical changes on harvest intensity.”
The signatories highlight a need for a “greater recognition of the substitution effects” to harness the “full potential of forest products in the green transition and a thriving bioeconomy”, while emphasizing support for a “swift adoption of an EU-wide net emission reduction target of 90 percent for 2040, covering both emissions and removals, provided that the Commission’s further work takes sufficient account of uncertainties in the land use sector, technology neutrality, cost-effectiveness and technological sinks.”
