Policy Briefing #15 (v5) Defining forests and agroforests in the EU

Policy Briefing #15 (v5) welcomes the EU Deforestation Regulation (EUDR), noting that it excludes current areas of agriculture and agroforestry. However the EUDR Guidelines place too much faith in the ability of satellite data to distinguish forests from agriculture.  We therefore stress the importance of land-use and cadastral registers, and the need to use the methods for deforestation reporting already developed by all signatories to the UN Framework Convention on Climate Change (UNFCCC) as part of their Land Use, Land-Use Change and Forestry (LULUCF) inventories. The section in the EUDR Guidelines which says the satellite information should “prevail over” land-registries should be removed and replaced with clear reference to existing LULUCF methods.  We demonstrate the importance of this with data from Extremadura in Spain, showing that only 20% of the “forest” identified through EU-JRC satellite records is recognised as forest in the Spanish land-use-registry (SIGPAC).  An additional point is that new data on afforestation and agroforestation in the EU is not well recorded. We suggest that public and private sector planting should be integrated in the EU MapMyTree portal, which in turn can form part of the upcoming EU carbon removals registry, and national Land Parcel Identification Systems (LPIS).  “Forests” should be  defined as in Annex II of the EU LULUCF Regulation. “Agroforests” can in turn be defined as “parcels classified as agriculture, including boundaries, with more than 5% tree-cover, or with tree-planting or management which is intended to exceed 5% cover.  Shrubs may also be present”.