Deadwood has become an indicator in EU law

Cubic metres per hectare, written into a regulation

The forest article of Regulation (EU) 2024/1991 — the nature restoration regulation, dated 24 June 2024, published in the Official Journal on 29 July 2024 and measured from 18 August 2024 — opens its list of biodiversity indicators with two entries a mycologist reads differently from a forester. Article 12(3) requires each Member State to achieve "an increasing trend at national level of at least six out of seven" forest indicators, and the first two are standing deadwood and lying deadwood. Annex VI defines them in almost identical words, one covering non-living standing woody biomass and the other non-living woody biomass lying on the ground, both in forest and other wooded land, and gives each the same unit: m3/ha. The text is on EUR-Lex.

The counting method is borrowed rather than invented. Annex VI points to the approach developed and used by FOREST EUROPE in State of Europe's Forests 2020, and to the description of national forest inventories in Tomppo and colleagues (Springer, 2010), then adds that the methodology set out in Annex V to Regulation (EU) 2018/1999 must be taken into account, in line with the 2006 IPCC guidelines for national greenhouse gas inventories. Deadwood was in fact already a quantity EU law obliged countries to measure: Regulation (EU) 2018/841 lists dead wood among the carbon pools that may not be left out of the accounts for managed forest land, and Article 20(7) of the newer regulation requires the two deadwood indicators, along with the stock of organic carbon, to be monitored consistently with what Regulations (EU) 2018/841 and (EU) 2018/1999 already demand. What has changed is the purpose. For the first time the same volume carries a biodiversity trend obligation, rather than appearing only as tonnes of carbon.

The one sentence that mentions fungi

Recital 62 is unusually candid about why the list looks as it does. "In the absence of a common method for assessing the condition of forest ecosystems" that would allow specific restoration targets to be set, the legislator chose a general obligation, and measures compliance through the common forest bird index and a selection of the other quantities. Deadwood is on that list because every country can count it the same way, not because the law holds an opinion about decay.

The word "fungi" appears exactly once in the English text of the regulation, in the Article 3(1) definition of an ecosystem as a dynamic complex of plant, animal, fungi and microorganism communities and their non-living environment, interacting as a functional unit. No indicator, target or annex names a fungus. A volume of deadwood is a proxy for the habitat of wood-decay fungi; it is not a measurement of the fungi themselves.

The duty is also narrower than it first sounds. No Member State has to raise all seven of the Article 12(3) indicators: it picks at least six, and not freely, since they must be "chosen on the basis of their ability to demonstrate the enhancement of biodiversity of forest ecosystems within the Member State concerned". Deadwood can therefore be left out of a country's six altogether. Article 12(2) separately, and without any choice, requires an increasing trend in the common forest bird index, which is why Annex VI actually describes eight indicators rather than seven. No threshold in m3/ha appears anywhere either: the obligation is a rising trend until satisfactory levels are reached, and those levels are set by each Member State by 2030 under Article 14(5), not by the regulation itself. Annex VII, which does propose increasing the amount of lying and standing deadwood, is headed as a list of examples of restoration measures, and Article 14(16) says Member States may draw on them. It is a menu, not a mandate.

Why a rising volume is not a rising habitat

For fungi that live on dead wood, volume is one variable among several. The same figure in m3/ha can describe a few recently snapped spruces, or a scatter of large-diameter beech logs that have been rotting, and being colonised, for decades. Tree species, diameter, decay stage, moisture and exposure decide which fungi can occupy a given piece of wood at all, and the continuity of the supply over time often matters more than the quantity standing in any one inventory year. A national trend can rise honestly and still miss the wood that the scarcer species need. That distinction is worth stating plainly rather than burying, because it is exactly what a single headline figure hides.

From draft to plan

Article 16 set the date: each Member State was to send the Commission a draft national restoration plan by 1 September 2026. The Commission marked the day with a news item whose opening line says Member States submit their drafts today, and which gives no number at all. The following day Eunews reported that seven countries had met the deadline — Austria, Bulgaria, Ireland, Luxembourg, the Netherlands, Portugal and Spain — and that twenty had not, which between them account for all 27. Eunews hangs that count on reporting dataflow 1906 in Reportnet 3, which is run by the European Environment Agency rather than by the Commission. It is the position on 1 September 2026, and it could not be re-checked on 17 September, because the public view of that dataset is built in the browser and returns nothing to a plain request.

These remain drafts. Under Article 17 the Commission assesses each plan within six months of receiving it, may address observations to the Member State within the same six months, and the Member State then has six months from those observations to finalise, publish and submit the plan. The regulation lets the Commission call on experts or on the European Environment Agency for that assessment; it is the September news item, not the statute, that promises the Agency's support. Summarising the sequence as completion within one year, as that item does, compresses two six-month steps into a single phrase; the Commission's topic page follows the process as it develops. What arrives at the end is more interesting than the deadline. Article 20(8) requires Member States to make the data their monitoring generates public, so within a few years the cubic metres of deadwood in a national forest will be a number anyone can look up and hold against what a walk through that forest actually shows: a stump, an uprooted root plate, and a log with brackets growing along it.