1. Forest management plan or equivalent instrument
1.1. The activity takes place on area that is subject to a forest management plan or an equivalent instrument, as set out in national law or, where national law does not define a forest management plan or equivalent instrument, as referred to in the FAO definition of ‘forest area with long-term forest management plan’(40).
The forest management plan or equivalent instrument covers a period of 10 years or more and is continuously updated.
1.2. Information is provided on the following points that are not already documented in the forest management plan or equivalent system:
a. management goals, including major constraints(41);
b. general strategies and activities planned to reach the management goals, including expected operations over the whole forest cycle;
c. definition of the forest habitat context, including main existing and intended forest tree species, and their extent and distribution;
d. definition of the area according to its gazetting in the land registry;
e. compartments, roads, rights of way and other public access, physical features including waterways, areas under legal and other restrictions;
f. measures deployed to maintain the good condition of forest ecosystems;
g. consideration of societal issues (including preservation of landscape, consultation of stakeholders in accordance with the terms and conditions laid down in national law);
h. assessment of forest related risks, including forest fires, and pests and diseases outbreaks, with the aim of preventing, reducing and controlling the risks and measures deployed to ensure protection and adaptation against residual risks;
i. all DNSH criteria relevant for forest management.
1.3. The sustainability of the forest management systems, as documented in the plan referred to in point 1.1, is ensured by choosing the most ambitious of the following approaches:
a. the forest management matches the applicable national definition of sustainable forest management;
b. the forest management matches the Forest Europe definition(42) of sustainable forest management, and complies with the Pan-European Operational Level Guidelines for Sustainable Forest Management(43);
c. the management system in place shows compliance with the forest sustainability criteria set out in Article 29(6) of Directive (EU) 2018/2001, and as of the date of its application with the implementing act on operational guidance for energy from forest biomass adopted under Article 29(8) of that Directive.
1.4. The activity does not involve the degradation of land with high carbon stock(44) .
1.5. The management system associated with the activity in place complies with the due diligence obligation and legality requirements laid down in Regulation (EU) No 995/2010.
1.6. The forest management plan or equivalent instrument provides for monitoring which ensures the correctness of the information contained in the plan, in particular as regards the data relating to the involved area.
2. Climate benefit analysis
2.1. For areas that comply with the requirements at forest sourcing area level to ensure that carbon stocks and sinks levels in the forest are maintained or strengthened over the long term in accordance with Article 29(7), point (b), of Directive (EU) 2018/2001 the activity complies with the following criteria:
a. the climate benefit analysis demonstrates that the net balance of GHG emissions and removals generated by the activity over a period of 30 years after the beginning of the activity is lower than a baseline, corresponding to the balance of GHG emissions and removals over a period of 30 years starting at the beginning of the activity, associated to the business-as-usual practices that would have occurred on the involved area in the absence of the activity;
b. long-term climate benefits are considered demonstrated by proof of alignment with Article 29(7), point (b), of Directive (EU) 2018/2001.
2.2. For areas that do not comply with the requirements at forest sourcing area level to ensure that carbon stocks and sinks levels in the forest are maintained or strengthened over the long term in accordance with Article 29(7), point (b), of Directive (EU) 2018/2001 the activity complies with the following criteria:
a. the climate benefit analysis demonstrates that the net balance of GHG emissions and removals generated by the activity over a period of 30 years after the beginning of the activity is lower than a baseline, corresponding to the balance of GHG emissions and removals over a period of 30 years starting at the beginning of the activity, associated to the business-as-usual practices that would have occurred on the involved area in the absence of the activity.
b. the projected long-term average net GHG balance of the activity is lower than the long-term average GHG balance projected for the baseline, referred to in point 2.2, where long term corresponds to the longer duration between 100 years and the duration of an entire forest cycle.
2.3. The calculation of climate benefit complies with all of the following criteria:
a. the analysis is consistent with the 2019 Refinement to the 2006 IPCC Guidelines for National Greenhouse Gas Inventories(45). The climate benefit analysis is based on transparent, accurate, consistent, complete and comparable information, covers all carbon pools impacted by the activity, including above-ground biomass, below-ground biomass, deadwood, litter and soil, relies on the most conservative assumptions for calculations and includes appropriate considerations about the risks of non-permanence and reversals of carbon sequestration, the risk of saturation and the risk of leakage.
b. the business-as-usual practices, including harvesting practices, are one of the following:
i. the management practices as documented in the latest version of the forest management plan or equivalent instrument before the start of the activity, if any;
ii. the most recent business-as-usual practices prior to the start of the activity;
iii. the practices corresponding to a management system ensuring that carbon stocks and sinks levels in the forest area are maintained or strengthened over the long term as set out in Article 29(7), point (b), of Directive (EU) 2018/2001.
c. the resolution of the analysis is proportionate to the size of the area concerned and values specific to the area concerned are used.
d. emissions and removals that occur due to natural disturbances, such as pests and diseases infestations, forest fires, wind, storm damages, that impact the area and cause underperformance do not result in non-compliance with Regulation (EU) 2020/852, provided that the climate benefit analysis is consistent with the 2019 Refinement to the 2006 IPCC Guidelines for National Greenhouse Gas Inventories regarding emissions and removals due to natural disturbances.
2.4. Forest holdings under 13ha are not required to perform a climate benefit analysis.
3. Guarantee of permanence
3.1. In accordance with national law, the forest status of the area in which the activity takes place is guaranteed by one of the following measures:
a. the area is classified in the permanent forest estate as defined by the FAO(46);
b. the area is classified as a protected area;
c. the area is the subject of any legal or contractual guarantee ensuring that it will remain a forest.
3.2. In accordance with national law, the operator of the activity commits that future updates to the forest management plan or equivalent instrument, beyond the activity that is financed, will continue to seek the climate benefits as determined in point 2. Besides, the operator of the activity commits to compensate any reduction in the climate benefit determined in point 2 with an equivalent climate benefit resulting from the conduct of an activity that corresponds to one of the forestry activities defined in this Regulation.
Within two years after the beginning of the activity and every 10 years thereafter, the compliance of the activity the substantial contribution to climate change mitigation criteria and the DNSH criteria is verified by either of the following:
a. the relevant national competent authorities;
b. an independent third-party certifier, at the request of national authorities or the operator of the activity.
In order to reduce costs, audits may be performed together with any forest certification, climate certification or other audit.
The independent third-party certifier may not have any conflict of interest with the owner or the funder, and may not be involved in the development or operation of the activity.
5. Group assessment
The compliance with the criteria for substantial contribution to climate change mitigation and with DNSH criteria may be checked:
a. at the level of the forest sourcing area(47) as defined in Article 2, point (30), of Directive (EU) 2018/2001;
b. at the level of a group of holdings sufficiently homogeneous to evaluate the risk of the sustainability of the forest activity, provided that all those holdings have a durable relationship between them and participate in the activity and the group of those holdings remains the same for all subsequent audits.
Further information and explanations of the footnotes can be found on the EU Taxonomy website: