The prime ministers of Sweden and Finland have prepared a joint letter, which they have sent to the President of the European Commission, Ursula von der Leyen
On the land use, land use change and forestry sector (hereinafter – LULUCF)
in the European Union
15.09.2025.
First of all, we would like to thank you for the interest you have shown in Finnish and Swedish forestry. We greatly value our good cooperation.
As you know, forests and forestry are of great importance to both our countries. This applies not only to the economy and the environment, but also to culture and society. In Sweden, the export value of the forest sector accounts for more than ten per cent of total exports. In Finland's case, it accounts for almost a fifth of total exports. The sector's contribution to employment is substantial, creating jobs in our rural regions as well, and employing more than 200 000 Finns and Swedes in total. By absorbing carbon dioxide and replacing fossil-based products, it is clear that forests and forestry have an important role in meeting our climate commitments, but we would also like to emphasise the importance of national practices and know-how.
In this context, we wish to highlight our current problems relating to the LULUCF Regulation. Because of changes in the age structure of forests and the effects of climate change, such as periods of drought, pests and other factors, forest growth has declined in recent years. Russia's aggression against Ukraine has affected markets unpredictably, driving up prices and demand for domestic forestry products.
As substantial commitments have been set for our countries on the basis of the current European Commission guidelines, and according to the latest analyses, it is projected that both Finland and Sweden will be unable to meet their commitments. This applies to both the first and the second commitment period for LULUCF.
A significantly reduced volume of harvesting would have severe consequences for our economies and labour markets, and would also substantially affect the supply of timber and forest biomass throughout the European Union. Particularly in these uncertain times, this cannot be a viable solution. Even with far-reaching and active measures, meeting our commitments would still be highly uncertain, since the sector's natural variability offsets the effect of active measures.
We therefore welcome the Commission's initiative to work together with the Member States in order to prepare for the compliance process of the first LULUCF commitment period. We greatly appreciate your efforts to find solutions that genuinely take changing circumstances into account. In this process, we foresee the need to ensure that the flexibility provided for in the Regulation can be used. Moreover, the guidance on technical corrections to the forest reference level must be developed further, taking into account methodological changes, natural variation in the growth process, natural disturbances, increased emissions from organic soils and other aspects that affect the sector's net removals, including the impact of geopolitical changes on harvesting intensity. In this context, we are continuously working to improve monitoring methodologies and believe that this should also be done at European Union level.
Looking ahead, we see a need for wider recognition of substitution effects, so that we can make use of the full potential of forestry products for the green transition and a thriving bioeconomy.
Looking to the future, we look forward to the final adoption of the 2040 targets. We support the swift adoption of an EU-wide target of a 90% reduction in net emissions by 2040, covering both emissions and removals, provided that the Commission's further work gives sufficient consideration to the uncertainties in the land use sector, technology neutrality, cost-effectiveness and technological removal sources.
As you know, we are convinced that climate action and competitiveness are not opposing goals – they complement one another. We are committed to achieving our climate policy targets. In this process, forests and forestry will continue to play a decisive role. We believe the time has come to learn from the existing legislation and to take account of the uncertainty inherent in the land use sector. Exaggerated assumptions about this sector's contribution should be avoided. We are of course not the only Member States facing problems with the current LULUCF framework, and there is now an opportunity to create a system that works in practice without harming this important sector. In order to safeguard our climate work without harming our economies, we wish to stress the need to adopt legislation for the period after 2030 that takes into account the real potential of LULUCF removals and the uncertainty inherent in it. This sector plays a decisive role in ensuring access to biomass and in promoting a sustainable bioeconomy, and it has the potential to deliver long-term climate benefits by reducing dependence on fossil fuels and replacing them with bio-based materials.
Europe's successful future depends on a successful transition to clean energy, combining growth, jobs and emission reductions. We expect active forestry within the bioeconomy to be a central component of our climate agenda, while at the same time strengthening Europe's competitiveness. Finland and Sweden are committed to finding the best solutions in this field. And we wish to work together with the European Commission to achieve this.
Yours sincerely
Ulf Kristersson Petteri Orpo