Executive Summary

The Swedish Forest Industries Federation (SFIF) represents the Swedish forestry sector, which processes wood resources into bio-based products, such as pulp, paper, cardboard, packaging material, timber, refined wood products, and modern biofuels. The core business of SFIF members is the industrial processing of timber sourced from sustainably managed forests. As SFIF members include some of the largest private forest holdings in Europe, European Union policy related to forests is of vital importance.

SFIF members take pride in the fact that their forests are managed sustainably. For a long time, the main focus has been on reforestation and intensive silviculture, resulting in a doubling of Sweden's forest resources from the early 20th century to the present day. In this same period, the volume of timber harvested is four times greater than the resource levels of 1923. Since the early 1990s, a broader view of sustainability has prevailed, encompassing biodiversity and social aspects as well. Today, the conservation and enhancement of biodiversity is an integral part of SFIF members' forest management measures. By engaging in forest certification, Sweden has become one of the largest suppliers of timber from sustainably managed forests.

When analysing the EU Biodiversity Strategy for 2030 (hereinafter — Strategy) from the perspective of forest owners and forest-related industries, SFIF found that it lacks a comprehensive policy perspective. Furthermore, questionable reference points could lead to unnecessary, costly, and unproductive measures. SFIF also found that the competence of member states in the field of forest-related policy is clearly threatened and that the contribution of the European forest industry to sustainable forest management is not recognised. Finally, SFIF concludes that the parameters intended to promote the achievement of goals lack scientifically sound and universally accepted definitions.

Therefore, SFIF urges the European Parliament and EU member states to:

— ensure that EU policy resulting from the strategy is not counterproductive, but is balanced with other policy instruments that are equally important for achieving the goals of the European Green Deal;

— clarify that EU policy resulting from the strategy must be based on actual European conditions and, preferably, even more specific, i.e., relevant member state and/or regional conditions;

— establish that the goals for forest product production and conservation can be achieved simultaneously and are not contradictory; promote the creation of biodiversity monitoring systems appropriate to trends and developments in the situation;

— emphasise the long-term perspective necessary in working with forest biodiversity;

— ensure member state competence regarding EU policy that directly or indirectly affects forests and forestry;

— recognise and continue to emphasise sustainable forest management carried out daily by European forest owners, and its great importance in carbon dioxide sequestration in well-managed forests and the supply of products that store carbon and replace other products based on fossil raw materials;

— grant forest owners a leading role in the implementation of the strategy and cooperate with them in continuing to develop sustainable forest management;

— protect the status of the Standing Forestry Committee;

— ensure that conservation targets cover a wide range of conservation measures and areas, including those managed in accordance with good forest management practices;

— ensure a fair distribution of responsibilities related to conservation targets among member states, taking into account differences in definitions and methods relating to forest land and protected forest areas;

— recognise the leading role of member states in work related to the conservation and protection of habitats and species, as there is no universal solution due to the diversity of European forests;

— entrust member states with any work on definitions, concepts essential for achieving goals, and guidelines;

— ensure that the revised EU Forest Strategy is a separate policy.

The Strategy lacks an important comprehensive perspective and could hinder the forest's contribution to sustainable development. SFIF believes that the Strategy has been developed too much in isolation, focusing on biodiversity without sufficiently taking into account the interaction with other policy areas. The targets aimed at legally protecting at least 30% of the EU's land area and strictly protecting at least one third of it will lead to more forests being left fallow and less forest area being available to achieve economic and social as well as environmental protection goals of sustainable development.

The aim of the European Green Deal is to build a “fair and prosperous society with a modern, resource-efficient and competitive economy where net greenhouse gas emissions in 2050 are reduced to zero and economic growth is decoupled from resource use”. To achieve these goals, the European Union must actively and well manage its forests, and transform wood resources into bio-based products. Conversely, if forests are managed less, the EU's ability to achieve the goals of the Green Deal will diminish, as will revenues from forest management, which would allow for investments, for example, in growth promotion, carbon dioxide absorption improvement, biodiversity enhancement, and forest restoration.

Another example — once the Strategy is implemented, larger forest areas will be left fallow (neglected, not managed). This will reduce the ability of forest products to replace fossil and emission-intensive alternatives. To ensure the forest sector's contribution to climate change mitigation, the remaining forest areas would have to be managed more intensively, which could have a negative impact on biodiversity. In this context, it is important to understand that leaving larger areas fallow is not a universal solution — on the contrary, it will negatively affect other Green Deal goals and contribute to various conflicts. Moreover, leaving more European forest areas fallow could increase demand for wood and wood products from other parts of the world, where they would most likely be produced less sustainably. In the long term, leaving more areas fallow could increase the use of fossil resources — materials and energy — which is in complete opposition to the goals of the European Green Deal.

SFIF would highly appreciate it if the strategy included three key findings. First, the goals for forest product production and conservation can be achieved simultaneously. Second, biodiversity can also develop in managed forests, and third, huge investments in promoting forest growth, as well as improved availability of wood raw materials, are necessary for achieving the EU's climate neutrality goal.

Based on the above, SFIF urges the European Parliament and member states to:

ensure that EU policy resulting from the strategy is not counterproductive, but is balanced with other policy instruments that are equally important for achieving the goals of the European Green Deal.

The Strategy's reference points are questionable. The Strategy sets goals and future direction for European Union work in the field of biodiversity conservation and enhancement. For the Swedish forest industries, this means measures for conserving and enhancing forest biodiversity. SFIF believes that for the Strategy to be appropriate and effective, it must be based on correct reference points.

To a large extent, the Strategy's problem description is based on the state of biodiversity globally. SFIF agrees that there is a global crisis in the field of biodiversity, and together with the COVID-19 crisis, it is being used as a basis for the argument that nature must be given more space. SFIF believes that European forests, which are in a better condition compared to the global average, need a more tailored approach. For example, over the last 30 years, forest land area in Europe has increased, which is in stark contrast to the situation, for example, in Asia and Africa. Furthermore, Europe provides almost 40% of certified forests worldwide, while Sweden provides approximately 20% of the EU's certified forests. In addition, the area of pristine forest biodiversity is large, especially in northern Europe and mountainous areas (1).

The Strategy rapidly moves from a global context to setting European goals, the impact of which has not yet been carefully assessed from environmental, economic, and social perspectives. SFIF believes that the European Union should inspire and guide everyone towards sustainable forest management, but with this strategy, it risks reducing the contribution of the forest sector.

For example, in point 1, it is stated that “(..) nature is in a state of crisis”. This might be true on a global scale, but SFIF does not agree that this statement applies to Swedish forests. On the contrary, in recent decades, the quantity of structures and elements important for biodiversity, such as deadwood, old-growth forests, and old, rugged deciduous trees, has increased. This has been achieved by taking various measures, such as including nature conservation in all forest management activities and voluntarily leaving larger land areas fallow, thus supplementing the state-owned forest reserves. Furthermore, biodiversity is by its nature managed at a more local and regional scale rather than a global one, so applying a global perspective to EU policy will not be effective. In this respect, biodiversity differs from, for example, climate change, where local, regional, and national efforts can make a clear contribution to global climate change mitigation.

In point 2.1 of the Strategy, it is stated that “biodiversity is higher in protected areas”. Regarding forests, SFIF does not agree with this statement for two reasons. Firstly, it implicitly suggests that biodiversity cannot develop in managed forests, which is not true. As mentioned above, the quantity of structures and elements important for biodiversity has increased in Sweden since the last revision of the Swedish Forestry Act in 1995, as well as the implementation of large-scale management of certified forests. Secondly, the statement implicitly suggests that the goals of forest product production and biodiversity are mutually contradictory, yet SFIF believes that both can be achieved simultaneously and that responsible forest management reduces the need for formal protection. Since the mid-nineties, conservation-oriented forestry has been the most commonly used forest management model in the Nordic countries. Using this model, we strive to recreate natural elements in commercial forests, such as deadwood and old trees. Estimates made in Sweden show that the amount of trees left fallow in commercial forests will be twice the amount of trees left fallow in protected areas by 2050.

Assessing biodiversity is a difficult task due to its complexity, scale, and time lag, and to a large extent, the Union lacks common monitoring systems that could accurately reflect the state and development of species over time. Moreover, data availability varies greatly between different member states. This means that a reference point for the status of biodiversity is often lacking. Despite these complexities, the strategy includes strictly set targets regarding the future development of species and/or habitats. It is not clear to SFIF how to evaluate the achievement of goals if there is a large lack of trend-appropriate monitoring systems. Furthermore, SFIF believes that differences in data availability reinforce the need for specific indicators and targets for member states.

The Strategy does not take into account that there is always a time lag when working on biodiversity conservation or enhancement. Measures taken today, for example, regarding the conservation status of certain species, do not have an immediate positive effect — instead, it may take several decades. By setting goals or using indicators with a short-term perspective, such as by 2030, you are effectively not working according to long-term perspectives in the field of forest management. Instead, such goals and indicators can be counterproductive and thus reduce the forest owner's involvement.

Based on the above, SFIF urges the European Parliament and member states to:

* clarify that EU policy resulting from the strategy must be based on actual European conditions and, preferably, even more specific ones, i.e., on member state and/or regional conditions;

* establish that the goals for forest product production and conservation can be achieved simultaneously and are not contradictory;

* promote the creation of biodiversity monitoring systems appropriate to trends and developments in the situation;

* emphasise the long-term perspective necessary in working with forest biodiversity.

Member state competence is clearly threatened

In SFIF's opinion, the Strategy clearly expands the European Union's competence in environmental matters related to forests, and several policy proposals/goals clearly limit the competence of member states in the field of forests and forestry. SFIF believes that member states must continue to decide on forestry and forest policy, including measures for their conservation, protection, and restoration, as there is no common forest policy in the European Union under the Treaty of Lisbon. The development of forest policy is a competence of member states, as national and regional laws and regulations based on long-term planning have long been in force.

Based on the above, SFIF urges the European Parliament and member states to:

# ensure member state competence regarding EU policy that directly or indirectly affects forests and forestry.

The contribution of the European forest industry to sustainable forest management is not recognised. In point 2.2.4 of the Strategy, it is stated that “forest managers have a key role to play in ensuring sustainable forest management and restoring and maintaining forest biodiversity”, and SFIF agrees with this statement, but we cannot find any acknowledgement of the European forest industry's contribution to Sustainable Forest Management (SFM), including efforts to improve biodiversity. SFIF believes that forest owners should be given a leading role in the implementation of the strategy, as only forest owners can combine biodiversity management and conservation. SFIF wishes to emphasise that companies owning forests have for decades integrated biodiversity measures into their management practices. As already mentioned, this includes, for example, preserving deadwood, larger broadleaf trees, and high-cut stumps, as well as leaving valuable areas fallow and creating structures specifically important for biodiversity.

In this context, SFIF wishes to emphasise that SFM is a comprehensive goal for all our members. Sustainable Forest Management is defined by Forest Europe — a Europe-wide collaboration structure consisting of 46 European countries and the European Union. At the EU level, the Standing Forestry Committee has long experience in reconciling the various characteristics of countries and applying a comprehensive approach in implementing SFM.

SFIF members fully support the concept of SFM, which recognises that forests have economic, environmental, social, and cultural value. Revenue for the forest owner/manager is generated by the value attributed to the wood when it is sold as a raw material. From this revenue, payment is subsequently made for maintaining forest growth, expanding ecosystem services, and conserving forests. Timber produced in commercial forests and the value chain in which this timber is used provide jobs, sustainable prosperity in rural areas as well, and the development of a bio-based circular economy. Investments in sustainable and active forest management are also an effective way to prevent forest damage and promote the vitality and adaptation of forests to changing conditions. In other words, in the short term, wood products will replace fossil, non-renewable products and energy. In the long term, SFM will increase production capacity and the area of forests that are more viable and less susceptible to natural disasters in which carbon dioxide is released.

Based on the above, SFIF urges the European Parliament and member states to:

— recognise and continue to emphasise the important work in the field of sustainable forest management carried out daily by European forest owners, and its great importance in carbon dioxide sequestration in well-managed forests and the supply of products that store carbon and replace other products based on fossil raw materials;

— grant forest owners a leading role in the implementation of the strategy and cooperate with them in continuing to develop sustainable forest management;

— protect and strengthen the status of the Standing Forestry Committee.

Nature conservation goals must be clarified and reported uniformly

The Strategy stipulates that 30% of the EU's land area must be legally protected by 2030. Furthermore, at least one third of this, i.e., 10%, must be strictly protected, including all remaining EU primary and old-growth forests.

SFIF believes that the language of the strategy regarding protection is unclear, as some areas must be “legally protected”, while others — “strictly protected”. These concepts are already interpreted and implemented differently in member states. Furthermore, all areas that are protected or where effective conservation measures are implemented are not always legally protected — they can also be left fallow voluntarily. More than five per cent of Swedish forests have been exempted from management on such a voluntary basis in order to conserve and enhance biodiversity in accordance with forest certification schemes. This must be counted towards the fulfilment of the strictly protected forest target. Therefore, SFIF believes that the targets must cover various areas, including those managed in accordance with good management practices.

The Strategy does not define the distribution of responsibilities related to conservation goals among member states. SFIF emphasises that the distribution must be based on the principle of proportional measures and the characteristics of member states must be taken into account. The distribution of responsibilities must not limit the opportunities for economic activity and good living conditions in all EU member states in the future.

Based on the above, SFIF urges the European Parliament and member states to:

* ensure that conservation targets cover a wide range of conservation measures and areas, including those managed in accordance with good forest management practices;

* ensure a fair distribution of responsibilities related to conservation targets among member states, taking into account differences in definitions and methods relating to forest land and protected forest areas;

Setting an EU Nature Restoration Plan requires broad cooperation with forest owners

The Strategy stipulates that after preparing an impact assessment, the Commission will come forward with a proposal for legally binding EU nature restoration targets in 2021. Furthermore, the Commission will ask member states to ensure that the conservation trends and status of no protected habitat and species deteriorate by 2030, and will support them in performing this task.

As this will be the first time that the European Union sets legally binding EU nature restoration targets, it is important that preparatory work is carried out and interaction with relevant stakeholders, namely member states and forest owners, is ensured before submitting the proposal.

SFIF believes that the Strategy currently raises more questions than answers about forest restoration, for example:

Which areas should be restored? What must be achieved and why? Should restoration be aimed at the forest's ability to improve carbon dioxide absorption or biodiversity? Or both goals? Depending on the answer, actions will differ. Who determines which areas should be subject to measures? How to ensure that the criteria for selecting areas to be restored are scientifically sound? How are restoration results evaluated and who does it? What happens to the area after restoration? Can management be carried out in the restored forest area? Or must the restored area be preserved? Nature is dynamic, not static, after all, so the status of such an area will effectively change over time. Who will pay for the restoration? How will the characteristics of member states and forest types be respected?

From a forest perspective, SFIF recommends basing the restoration plan on a solid scientific foundation that is recognised and respected by researchers who are well-versed in the diverse conditions of European forests. For example, forest ecology and dynamics must be determined at the member state or regional level. Furthermore, definitions, measures, and evaluation of results must also apply to a specific member state and/or region. SFM must be the main instrument for achieving goals, and such management must be adaptable. The plan must ensure strong involvement of forest owners. Moreover, it should stipulate that the main task is to achieve multiple goals simultaneously, such as restoration, climate change mitigation, and wood production.

Regarding concerns about ensuring that the conservation trends and status of no protected habitat and species deteriorate, as mentioned above, the Union lacks monitoring systems that could accurately reflect the state and development of species over time. SFIF also reiterates that biodiversity is by its nature managed at a local and regional, sometimes national, but not global scale. Therefore, all goals set by the Commission to increase the level of implementation of existing biodiversity conservation legislation must be achieved in very close cooperation with member states. Moreover, such work must be based on a deep understanding of the fact that forests in Europe are very different. Therefore, there is no universal solution; instead, adjustments must be made, taking into account local and regional differences, and this will be best done by member states.

Based on the above, SFIF urges the European Parliament and member states to:

# recognise the leading role of member states in work related to the conservation and protection of habitats and species. This is very important, as there is no universal solution due to the diversity of European forests.

Relevant definitions and guidelines must be decided at the member state level

The Strategy stipulates that the Commission must return to definitions of important concepts, such as primary forests, old-growth forests, restoration, and conservation. Furthermore, the Strategy indicates that the Commission plans to develop guidelines on biodiversity-friendly afforestation and reforestation, as well as closer-to-nature forestry practices.

As mentioned above, there are very large differences in forest types and ownership in the European Union, as well as in the forest policy of member states. Therefore, it is clear that a single European definition or definitions will not help here. Moreover, forestry practice is determined by member state legislation. If the Commission believes that greater consistency is needed between practices used in member states, such discussions should be entrusted to the Standing Forestry Committee, which is a consultative forum where the Commission familiarises itself with the experience of member states regarding forest-related initiatives implemented in various EU policy areas, such as rural development and the environment.

Regarding the concepts of “primary forest” and “old-growth forest”, SFIF points out that there are several definitions, such as those developed by the CBD, the UN, and the IUCN. However, these definitions overlap, and it is clear that there is no single formulation that would be applicable to all European forests. For these concepts to be applied, their interpretation must be managed at the member state or even regional level; otherwise, the immense diversity of European forests cannot be respected.

In the Strategy, the importance of old-growth forests is incorrectly explained in several ways. Old-growth forests absorb significantly less carbon dioxide compared to younger ones (2). Furthermore, the carbon balance can be negative if trees in old-growth forests are felled by storms or destroyed by insect-borne infections, or fires, as is currently happening in large parts of Europe. By refraining from felling trees in old, managed forests, the substitution effect is also lost. This effect is, in principle, immediate, reducing the volume of fossil emissions.

Due to the complexity (diversity, differences) and variety of European forests, it is important that forestry practice be adapted to local conditions. For example, the Strategy is based on the assumption that “closer-to-nature forestry” is a universal method that solves all problems. This, of course, is neither true nor scientifically sound. A large part of boreal forests in northern Europe, especially pine forests, are naturally adapted to periodically occurring disturbances, such as forest fires. When implementing closer-to-nature forestry, such disturbances in forests must be imitated, which has also been an important reference point for SFM adapted to local conditions, mostly without fires. Such examples of closer-to-nature forestry should also be recognised in the future, as they combine the utility of forest resources while preserving biodiversity and combating the effects of climate change. Instead of supporting unified management methods, the European Union should promote measures adapted to regional conditions.

Based on the above, SFIF urges the European Parliament and member states to:

— entrust member states with any work on definitions, concepts essential for achieving goals, and guidelines

The EU Forest Strategy for the period after 2020 must be a separate policy

The Strategy stipulates (envisages) that in 2021 the Commission will propose a dedicated EU Forest Strategy in line with the Union's broader biodiversity and climate neutrality ambitions.

SFIF fully supports the revision of the EU Forest Strategy because the political landscape has changed significantly since the last revision in 2013. Today, more and more EU policy areas are setting ever-increasing demands on forests and forest products. For example, climate change mitigation and adaptation, as well as sustainability, are highlighted much more in today's political environment than almost ten years ago. Furthermore, there is a significantly increased understanding that it is urgent to transition from a linear economy based on fossil fuel use to a bio-based circular economy. Therefore, the need to reconcile sectoral policy areas is great and growing.

Although the Treaty on the Functioning of the EU contains no references or specific provisions regarding EU forest policy and since there is no common EU forest policy, the correct coordination instrument is a revised Forest Strategy. The Strategy must perform the important task of achieving a comprehensive and multifunctional perspective, while respecting the subsidiarity of member states. For the revised EU Forest Strategy to be appropriate, the applied perspective must include forests and all forest-related value chains.

SFIF emphasises that the revised EU Forest Strategy must be a separate policy, and we believe that this is exactly what the Commission wants to achieve by stating that the strategy must be in line with biodiversity and climate neutrality ambitions.

Based on the above, SFIF urges the European Parliament and member states to:

* ensure that the revised EU Forest Strategy is a separate policy that is not subject to any other EU policy in areas related to, for example, climate, biodiversity, or the circular economy.
Sources:
1. S. Hill et al. (2019). Measuring Forest Biodiversity Status and Changes Globally. https://doi.org/10.3389/ffgc.2019.000701
2. S. Luyssaert et al. Old-growth forests as global carbon sinks. Nature 455, pp. 213–215. (2008). https://doi.org/10.1038/nature07276
3. www.forestindustries.se