COMMENT: Is the state of Germany’s land use sector a deal breaker for climate neutrality?

Published 16:13 on May 26, 2025  /  Last updated at 16:13 on May 26, 2025  /  EMEA, Nature-based, Voluntary

The climate targets in Germany’s land use sector (LULUCF) appear to be out of reach. However, abandoning targets for nature-based CO2 sinks would be equal to abandoning its climate neutrality goal, warns Milan Loose, who works as Policy Advisor on Negative Emissions at Bellona Deutschland.

The climate targets in Germany’s land use sector (LULUCF) appear to be out of reach. However, abandoning targets for nature-based CO2 sinks would be equal to abandoning its climate neutrality goal, warns Milan Loose, who works as Policy Advisor on negative emissions at Bellona Deutschland. While the European Commission is discussing how to set land-use climate targets for the period after 2030, other member states are confronted with similarly challenging prospects.

Germany’s Environmental Agency’s (UBA) latest climate projections show that the target shortfall in the land use sector (LULUCF), which has been forecasted for years, will increase drastically to 35 million tonnes (Mt) CO2e net emissions by 2045, instead of the envisaged net sink of 40 MtCO2e. Achieving the target is therefore unlikely, although not impossible. This fundamentally questions Germany’s ability to reach its climate targets – climate neutrality by 2045 and net negative emissions after 2050.

Without a sufficient level of negative emissions – natural sinks and engineered CO2 removal – Germany would have no way of balancing its expected residual emissions of 37 to 76 MtCO2e stemming from agriculture and otherwise unavoidable emissions from industry. The need for permanent CO2-removal for the period from 2045 theoretically results from what must be counterbalanced in addition to the LULUCF targets. Al, the European Commission estimates around 400 MtCO2e of remaining emissions by 2050, which would need to be counterbalanced with removals.

A key reason for Germany missing its target lies in the most significant sink in the land sector, forests. The extreme drought of 2018-2022 has damaged German forests in many ways. Added to this is the 50 percent increase in timber harvesting since 1995, which results from international demand for biomass, but has also temporarily increased due to natural disturbances.

Consequently, more biomass has been removed from forests than would be necessary to achieve the climate targets. Forests thus have become a net source of emissions of around 20 Mt. CO2 per year since 2018. Instead of acting as a net sink in 2045 of 40 MtCO2e as stipulated by Germany’s Federal Climate Law (KSG), the sector is expected to show a deficit amounting to 75 MtCO2e.

German politicians are therefore facing a climate policy dilemma as the new legislative term begins.

Other European member states encounter similar predicaments. Sweden has to address a shortfall of 14 MtCO2e in its LULUCF sector, while Finland confronts an even larger deficit of at least 46 MtCO2e in the absence of corrective actions by 2030. Consequently, the EU as a whole could miss its LULUCF targets by around 33 MtCO2e in 2030. More importantly current projections show that even with additional measures, the EU’s LULUCF sink will further decline towards an average of 224-240 MtCO2e up until 2050. This makes reaching net-sink targets of similar ambition beyond 2030 very unlikely and questions the EU’s ability is meet its climate goals.

Is climate policy thus at risk of failing due to physical limits of land use, or are effective measures to restore and expand natural sinks possible?

Adjusting the LULUCF targets to ‘reality’?

For some time now, calls from scientists and private forest owner associations have urged German policy makers to adjust targets for natural sinks, reducing target ambition to match to the “reality” of potential CO2 absorption.

From a climate science perspective, lowering the LULUCF targets is irresponsible. Achieving climate targets and an economically viable phase-out of fossil fuels has only become feasible through establishing goals for maintaining and enhancing natural sinks on a global level, particularly in forests. If, on the other hand, measures to halt the loss of the sequestration capacity of forests are not implemented, this could double the costs of climate action in key sectors.

Moreover, science shows that the loss of sinks can be attributed to increasing levels of harvesting on the EU level and that counter measures of reducing harvesting and implementing more sustainable forest management practices can help to mitigate the effects of climate change on forests´ sinks.

If the LULUCF targets and the contribution of forests to natural climate protection are removed from the equation, it is very unlikely that Germany’s contribution to climate action will be consistent with limiting global temperature increases to well below 2°C.

Nevertheless, Germany’s climate protection goals in the LULUCF sector will not be achieved by forests alone – but they could be achieved through a more intelligent use of biomass and land areas.

Focus on climate- and environmentally- friendly use of biomass

What is needed now is a stronger political focus on the connection between the use of biomass and climate targets. For this, policy instruments must be developed that limit biomass consumption in ways that the goals of climate and biodiversity protection and food security can be achieved. Focusing solely on changing the legal framework for forest and soil management, while necessary, falls short of enabling a socially acceptable and economically viable transformation of the land use sector.

A change in diets towards a more plant-based diet to free up land, the expansion of truly renewable and electrification-based heat to replace exceedingly high bioenergy consumption, as well as the substitution of fossil-based materials in the chemical industry, need to be sustainably fostered. For that, national biomass strategies are needed, to make the associated conflicts of objectives and need for action politically negotiable and controllable in their complexity. The EU’s upcoming review of its Bioeconomy Strategy needs to explicitly tackle these issues rather than avoiding them in the absence of an EU-wide Biomass Strategy.

The immediate reduction of emissions must continue to take increasing priority. Nature-based and permanent CO2 removals offer a realistic pathway to balance residual emissions only when such emissions are as low as possible.

2040 climate targets and where do we go from here?

Instead of questioning the LULUCF targets, policymakers in the EU and its member states must continue to commit to them and implement measures that have already been agreed and further instruments to achieve LULUCF targets. This requires the development and implementation of new instruments for a truly sustainable, intelligent and value-adding use of biomass.

Firstly, existing incentives to use bioenergy at current levels are stronger than the incentives to protect existing natural carbon sinks, which leads to perverse outcomes. Rebalancing this will require creating a “natural” demand for natural sinks with the associated co-benefits in nature restoration and biodiversity and adjusting incentives under RED II.

Secondly, LULUCF targets need to be operationalised by e.g. formulating quotas for the usage of biomass in different sectors and develop other sectorial measures on national levels, to be able to track progress in these sectors. Lastly, new business models for long-lasting and value-added usage of biomass need to be politically supported.

Milan Loose is a Policy Advisor on negative emissions at Bellona Deutschland

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