FAQs from the Stakeholders

1. What is the main objective of the EU 3 Billion Trees Pledge?
Announced in the new Biodiversity Strategy and Forestry Strategy, the EU 3 Billion Trees Pledge is a commitment to promote the planting of at least 3 billion additional trees in the EU by 2030. It aims to increase the total number of trees in the EU in order to achieve a wide range of benefits, including carbon sequestration, biodiversity protection and safeguarding other ecosystem services. These 3 billion trees are in addition to those that would be planted under a business-as-usual scenario between 2020 and 2030. In order to be part of the Pledge, the trees planted must meet a number of conditions, including compliance with ecological principles and sustainability criteria (see Q3).
The dedicated corporate identity can be used by registered initiatives for promotion and awareness-raising (see Q30). Financing support may also be obtained from EU and/or national budgets, and a set of guidelines will be published by the end of the year on possible funding opportunities.

2. What is this project?
Milieu Consulting is leading a project, with partners Ecologic Institute and Stritih, to support the Commission to implement the EU 3 Billion Trees Pledge. The project aims to identify initiatives that fit the conditions of the EU Pledge to plant 3 billion additional trees by 2030. A questionnaire was distributed in January 2023 and can be found in Milieu’s webpage to gather information on potential tree-planting initiatives.
A series of events is planned to promote and discuss about the EU 3 Billion Trees Pledge and its objectives. They include three webinars per year (on issues of common interest), two workshops per year (on issues of local interest) and an annual conference (on preliminary results of the project). The project will also promote networking and exchange of information among the Commission and stakeholders.
The first webinar took place on 28 February to answer questions about the EU 3 Billion Trees Pledge (presentations from the webinar can be viewed on Milieu’s website). The second webinar is scheduled for 19 April and will present the Commission’s Guidelines on Afforestation, Reforestation and Tree-Planting published in March 2023.

The conditions for tree-planting initiatives to be part of the Pledge are explained in the Commission’s EU 3 Billion Trees Pledge document. Guidelines on Afforestation, Reforestation and Tree-Planting were also published, which explain the criteria in more detail (e.g. native species).

3. What are the criteria for participation in the EU 3 Billion Trees Pledge
In order to count towards the pledge, tree-planting initiatives must fulfil the following conditions:
• Comply with the principle of additionality;
• Benefit biodiversity and climate change objectives, in line with the no-significant-harm principle, and exclude the planting of invasive alien species (see List of Invasive Alien Species of Union concern);
• Plant only native tree species, unless it can be demonstrated that they are no longer adapted to projected climatic and pedo-hydrological conditions. Climate adapted species and varieties in full respect of ecological principles go along the concept of native tree species.
One of the requirements of the Pledge is that trees will not be cut for several decades. Although the timeframe is not specified, ideally these trees should not be planted to be cut and, if they do have to be cut, this should not happen for at least 80 years.

4. When does the EU 3 Billion Trees Pledge start? Can trees be counted retroactively?
The Pledge was announced in the new Biodiversity Strategy on 20 May 2020 – every tree planted after that date can be counted.

5. ‘Planting the right tree in the right place at the right time’ – what does this mean?
Simply planting trees is not sufficient to contribute to the 3 Billion Trees Pledge. The Commission aims on a tangible and positive impact on the environment, the climate, the economy and quality of life of EU citizens. Therefore, it is of utmost importance that trees are planted in full respect of ecological principals and consideration of the socio-economic circumstances.

6. How can we scale-up land availability?
Planting 3 billion additional trees is an ambitious goal that requires sufficient land. Land ownership is very fragmented across the EU and has proven to be a barrier to scaling-up reforestation efforts. Finding and accessing the right land is complicated, with stakeholders already spending a lot of time speaking to landowners about identifying the right areas and facilitating access to the land. Permits are sometimes difficult to obtain, partly due to changes in legislation linked to the value of the CO2 offsetting credits.
Evidence suggests that there is sufficient land availability in the EU. However, there is considerable competition for land and it is not always easy to find suitable land for tree-planting. The recent Guidelines on Biodiversity-Friendly Afforestation, Reforestation and Tree Planting give advice on identifying suitable land and considering local conditions. Several factors play a role, including financial incentives for the owners, forest management plans, and legislative requirements in the Member States.

7. Is the Pledge only for trees or are other layers of vegetation also counted?
Shrubs, bushes and everything biologically classified as a tree can be counted.

8. Does transformation of low productive forest/shrub forest into productive forest/high forest meet the requirement of additionality?
It depends on the situation. Assessing additionality can be difficult; for example, new trees are not additional if they are planted to replace cut trees. However, trees can be planted in areas that burned: if the old forest was monoculture and/or poor in biodiversity and will be substituted with a very biodiverse forest, these new trees are additional because the forest has qualitatively improved.

9. Does supplementary planting in forests count as additional if it improves species and contributes to higher carbon sequestration?
Species composition should always be favourable to biodiversity (see Guidelines on Biodiversity-Friendly Afforestation, Reforestation and Tree Planting). This means that initiatives to plant trees in order to ensure higher carbon sequestration do not count if they are detrimental to biodiversity. Put simply: biodiversity trumps carbon sequestration.

10. Will preference be given to species that are native in the EU?
Yes. However, other species that are viable for ecological purposes can also meet the criteria.

11. Which species are considered native – those that are native now or those anticipated to become native due to climate change?
Native species are those that are native now, as it is difficult to predict which species will adapt. Other species can be planted for biodiversity objectives, extending the range beyond native species.

12. How are alien species defined?
The Regulation on Invasive Alien Species contains a list of List of Invasive Alien Species of Union concern. This List is referenced in the declaration of honour to be signed by initiatives seeking to be part of the EU 3 Billion Trees Pledge. There are some grey areas in the Regulation (i.e. some invasive species, such as black locusts, are exclude despite being invasive), which will require participants to take account of the ecology of tree-planting or ecosystems.

13. Are trees planted for carbon offsetting counted?
Yes, they are counted, provided all of the other conditions/requirements are respected (right tree at the right place, additionality, biodiversity, etc.).

14. How do we ensure that there is enough diversity in the planting?
There is no obligation to ensure tree diversity in the EU. Bio-geographic regions have adapted for different trees, making it unlikely that all initiatives in the Pledge will plant the same tree. The mixing of trees is preferred for resilience, environment and biodiversity, but it is not an enforceable obligation.

15. Could planting trees in abandoned forests be considered part of the Pledge?
The management of existing forests does not count, as the EU 3 Billion Trees Pledge aims to plant additional trees. Nevertheless, these kinds of management initiatives are a crucial part of the Forestry Strategy.

16. Can an entity be involved in the Pledge by providing trees to be planted?
As such activity is not ‘planting trees’, it cannot be part of the EU Pledge. However, it is helpful to increase the tree-planting capacity beyond the Pledge.

17. What is the EU 3 Billion Trees Pledge Registry for?
The Registry identifies the planting initiatives and actors and tracking progress towards the 3 billion trees goal. It provides a visual of the areas where additional trees have been planted and recognises those involved in the planting of trees for ecological reasons. The Registry is managed by the European Environmental Agency.

18. How can I register an initiative? What steps do I need to take to register and what am I committing to?
Registering is a simple procedure and all of the steps are outlined on the 3 Billion Trees Pledge website. Firstly, you may want to write to env-3billiontrees@ec.europa.eu to be added as a ‘lead reporter’. Being part of the Pledge requires you to report the trees planted, which is done through an account on Reportnet 3.0, the European Environment Agency’s e-reporting platform for environment and climate data. Once you have set up your account, you simply complete a submission form, which will be reviewed by the EEA before publication and may involve a short exchange of correspondence.
You will also need to sign a declaration of honour, committing to complying with the criteria. The Pledge is trust-based and there is no Commission verification system.
More information is available in a short YouTube tutorial: How to register planted trees as part of the EU 3 Billion Trees Pledge – YouTube

19. Is the European Environment Agency website only in English?
Yes, the website is only available in English.

20. Could the EU 3 Billion Trees Pledge Registry be linked to other registries for biodiversity and climate objectives?
Yes. For example, the Walloon region in Belgium has linked its registry for offsetting CO2 emissions for climate change purposes when the initiatives include biodiversity objectives. Thus, the tree-planting initiatives complying with the ecological requirements of the Pledge are entered in both registries.
Other tree-planting registries exist for offsetting CO2 emissions or for biodiversity objectives. As yet, however, the Walloon example is the only one linked to the EU 3 Billion Trees Pledge Registry. These national registries must allow for initiatives in line with EU requirements to be considered for registration in the EU registry as well. Planting trees initiatives developed by companies and registered in the national registry are not automatically integrated in the EU 3 Billion Trees Pledge but only if they comply with the Pledge conditions.

21. As a coordinating body for several regional forestry management offices, how can we report regional tree-planting activities that might comply with the criteria of the Pledge?
It is probably easiest and best if each region reports each of its different initiatives separately, in order to have a clear description of the activities in each region. However, a coordinating body could try to centralise data, provided those data are not duplicated.

22. What is the ‘Map my Tree’ app?
It is a web up which enables reporting on the planted trees of registered initiatives. It is linked to the MapMyTree counter which was launched on 9 December 2021 and counts the trees that comply with the criteria of the 3 Billion Trees Pledge, since the adoption of the EU biodiversity strategy in May 2020. The accompanying map provides different options to view where trees have been planted in the EU. It is also possible to modify the information uploaded and add more trees as the initiatives evolve.

23. How can I prevent duplication of information about planted trees in the ‘Map my Tree’ application?
The EU 3 Billion Trees Pledge is entirely voluntary, and reporting is dependent on participants’ goodwill. As an honour-based system, there will be no checks or controls on the conditions/requirements. Accordingly, it is participants’ responsibility to verify that any tree-planting initiatives they register were not already reported.
Flanders provides a useful example of good practice to avoid double reporting: participants report directly to the government, which has its own counters, and the government will then report to the EU 3 Billion Trees Pledge Registry.

24. What if there is already a platform where organisations register their planting initiatives? How can this information be integrated with the ‘Map my Tree’ application?
It is possible to link an existing reporting system with the EU 3 Billion Trees Pledge Registry. If you wish to do this, please contact the European Commission at: env-3billiontrees@ec.europa.eu.

25. Does the Commission use satellites for monitoring?
Satellites cannot pick up trees in their first 10-20 years of life because they are too small, so it is not possible to rely on them for monitoring.

26. How about general monitoring? What if the trees die?
Managing, monitoring, caring for and nurturing the planted trees is one of the conditions of the Pledge and pledgers should monitor ongoing respect of the requirements as part of their ‘after-care’.

27. What about the risk of greenwashing?
There is a risk of greenwashing, but it is complicated to monitor. However, as participants are required to report their trees publicly, the exposure of any greenwashing risks their reputation and credibility.

28. Can I include planting initiatives outside the EU that use EU funding?
No, the EU 3 Billion Trees Pledge is solely for trees planted inside the EU. However, the reverse is possible: organisations registered outside the EU that plant trees inside the EU can be counted as part of the Pledge.

29. Will the EU 3 Billion Trees Pledge promote access to national or EU funding to those registered?
Registration itself does not give the right to funding. There is no dedicated budget for the Pledge, but there are several funds that could potentially be used (e.g. LIFE, agricultural and rural development funding). As the EU 3 Billion Trees Pledge is a priority for the EU, registered initiatives will be more visible and might have more opportunities to obtain funding from EU or national sources. Guidelines on funding will be published by the end of the year in order to support participants in identifying funding opportunities.

30. What are the mechanisms at EU level to recognise funders?

Stakeholders will want to ensure that the people/companies/organisations supporting or funding the planting of trees work are recognised. Public credit to those funding the tree-planting is a motivating element to continue or increase the number of funders.
Alongside the ambitious overall conditions for the Pledge, the Commission has issued a Communication toolkit to support individual projects and highlight their participation. The branding elements developed include:

• Social media visuals: main visual, geographical visuals, seasonal visuals
• Social media header images
• Editable social media visual templates – these templates need to go together with two other products for users to insert into the templates:
o Slogan in all EU languages
o Title in all EU languages
• Word template
• PowerPoint template
• Sign-off in all EU languages
• Graphical charter
• Brochure in all EU languages

31. Will those registered benefit from specific support or promotional actions, e.g. links to other potential donors/funders?
In addition to the use of the dedicated corporate identity, entry on the EU 3 Billion Trees Registry means that participants are recognised in the following communication channels:

• EU-login to Reportnet 3.0
• Forest Information System Europe – monitoring platform
• MapMyTree app

Other promotional elements linked to Milieu’s project include events during 2023 to 2025 including webinars workshops and an annual conference (on preliminary results of the project).

32. Will it be possible to match an offer and demand (e.g. an offer of land/funding and the demand for tree planting)?
The promotional activities will facilitate this kind of matching. Webinars and conferences can also help to foster networking between stakeholders and make this kind of match possible.

33. Is it possible to access the contact details of other entities to foster networking?
The list of participants/stakeholders to the events will be uploaded to the EU 3 Billion Trees Pledge website. Data protection prevents sharing email contacts directly, they can be provided on request.