'Fit for 55' package: Revising the Regulation on land use, land-use change and forestry (LULUCF)

Briefing 22-02-2022

This briefing provides an initial analysis of the strengths and weaknesses of the European Commission’s impact assessment (IA) accompanying the proposal to amend the land use, land use change and forestry (LULUCF) Regulation (EU) 2018/841. Despite the effort involved, the IA contains a number of shortcoming that significantly limit its potential to usefully inform policy-making. The impacts of the preferred option, its costs and benefits remain unclear, despite the estimates provided in the IA. Moreover, the baseline used in this IA does not appear to be dynamic or harmonised with the 'fit for 55' package, while one of the options does not appear to be a real alternative. Finally, the proposal does not seem to follow the recommendations of the IA, which suggests that relatively less ambitious LULUCF targets under Option 2 combined with ESR-LULUCF flexibility would be more coherent if the ESR targets are significantly raised (which is the preferred option in the ESR IA and the proposal for ESR revision).