Verification of the Assumptions of the Polish State Forest Policy in the Context of the New EU Forest Strategy 2030

Abstract

Despite the lack of legal tools to interfere in the forest policy of the member states, the European Union has initiated the New EU Forest Strategy 2030 (NFS), which emphasizes the protective functions of forests, modifying the interpretation of sustainable forest management. The aim of the study was to compare the State Forest Policy (SFP) in Poland with the assumptions of the New UE Forest Strategy 2030, identifying challenges for Polish forestry. The compliance of both documents was verified, taking into account their objectives, implementation methods, and differences. The analysis showed the coherence of the direction of both policies, while the differences in the methods of achieving the objectives result from divergent interpretations of the concept of sustainable forest management. It is necessary to develop a new definition taking into account the conditions of EU countries and to develop a system of measures enabling the comparison of the degree of implementation of this goal. Previous EU strategies had minimal impact on national legal systems. Diverse concepts of forest management in EU countries make it difficult to implement a common long-term strategy, giving subsequent documents a general character. NFS is a theoretical document presenting a vision of forests from the perspective of EU policy, and SFP serves as a historical document that can be a reference point for modifying assumptions based on contemporary realities. Creating normative acts without taking into account contemporary conditions may be contrary to the direction of development of forestry in Europe. A bottom-up approach, based on consensus of member states, to creating a coherent forest policy at the EU level is more justified.

1. Introduction

Historically, the paradigm of forest utilization in Europe has transitioned from direct exploitation towards an appreciation for the intangible benefits provided by forests [1,2]. In the last two decades, concepts such as “sustainable development”, “multifunctionality”, and “biodiversity” have gained prominence, many of which have been incorporated into national forest legislation and European Union (EU) forest policies. Despite inconsistencies and antinomies, these terms shape the current vision of forestry [3,4]. The forests in the EU cover an area of 160 million hectares, 39% of the total area, with Poland ranking seventh place in the EU in terms of forested area, possessing 9.46 million hectares (Figure 1) and a forest cover of 30% [5]. Both in the European Union and in Poland, an increase in forest resources and forest area is being observed.

The Forest Act adopted by the Polish Parliament in 1991 reoriented the objectives of forest management in Poland from production-focused to multifunctional and sustainable [7], outlining a new concept for Polish forestry that aligns with international legal frameworks [8,9,10]. In 1997, the primary directions for the development of forestry in Poland were defined in a document adopted by the Ministry of Environment, Natural Resources, and Forestry (MENRF) titled “State Forest Policy” (SFP) [11]. This was the first document of its kind in Poland, aimed at establishing more enduring foundations for Polish forestry than statutory regulations. It delineated organizational, economic, and legal conditions for the implementation of forest policy, along with expected outcomes and a timeline for execution [12,13]. Strategies and tactics for managing and utilizing forest resources were defined, incorporating international trends in forest policy [14].

Poland, as a full member of the European Community since 2004, is obligated under Article 291 [1] of the Treaty on the Functioning of the European Union (TFEU) [15] to adopt all domestic legal measures necessary to implement legally binding acts of the EU. Although there are no direct references to forests in European treaties, and the EU does not have a common forest policy [16], this policy is integrated within programs such as the Common Agricultural Policy, which remains a primary source of European funding for forests. EU legislation pertains to areas concerning environmental protection and agriculture, with forest management being part of these frameworks [17,18]. Under primary law, the EU has limited implementing powers, as the execution of EU law has been delegated to the member states [19], with EU forest management characterized by a polycentric structure and managed by national and regional actors [20]. However, this does not imply that forest management is solely dependent on national conditions; it is also influenced by various local and global factors [21]. The linking of policies within the EU’s shared competences (Article 4 TFEU) [15] related to forests constitutes a wide range of regulations aimed at protecting forests [22]. Despite the EU’s official lack of competencies [23] and involvement in a unified forest policy, it establishes “hard” law through directives and regulations and guidelines while also creating long-term strategies for forestry applicable in member states [24,25]. The increasing competencies of the EU, which limit the existing autonomy of member states regarding forest management, and the varying interpretations of this management remain a central point of intra-communal dispute [26].

Currently, EU policy is evolving towards greater integration within various sectoral policies [27]. This trend is evident in a range of initiatives, culminating in several significant acts, such as the Renewable Energy Directive [28] the European Union Solidarity Fund [29], the LIFE program [30], the LULUCF (Land use, land use change, and forestry) Regulation on emissions and removals of greenhouse gases [31], the Regulation establishing a framework to facilitate sustainable investments [32], and the Regulation on products that do not cause deforestation [33]. The leading political initiative at the pan-European level remains Forest Europe (Ministerial conference for the protection of forests in Europe). The introduction of new legislation aimed at implementing national and international obligations has led to changes in the forest sector in Europe. The effect of these changes has been to blur the clear line between Western countries and former socialist countries in terms of national forest management systems. Thanks to the harmonization of legal regulations and integration with the European Union, forest management systems in Europe have been unified, eliminating previous differences.

Viewing forest management as both a conservation activity and a means of utilizing forest resources, characterized by a significant share of public goods and services, legitimizes state interventionism in conducting appropriate forest policies to meet societal needs. The EU articulated its initiative in the 1998 EU Forest Strategy [34]. Clear attention was drawn to the areas of EU competency [35], including general guidelines for EU forest policy aimed at coordinating other forestry-related policies in the EU. Key principles of sustainable forest management (SFM) were applied within the strategy, addressing aspects such as competitiveness, job creation, forest conservation, and the provisioning of ecosystem services through a multifunctional approach. Currently, the forests of EU member states also remain a focus of interest, resulting in the development of the New Forest Strategy 2030 [36]. Embedded within the European Green Deal (EGD), it is grounded in the EU’s Biodiversity Strategy for 2030 [37,38], replacing the 2013 Forest Strategy [39] while enhancing the protective functions of forests and concurrently promoting a sustainable forest economy [40]. Unlike the 2013 Strategy, the New Forest Strategy aims for greater EU control over the forest policies of member states [40]. It positions expectations concerning forests in the context of a changing environment and socio-economic needs [38]. The Green Deal represents a plan detailing the community’s ambitions to transform the EU into a modern, resource self-sufficient, competitive economy by 2050, initiating a series of changes in the current EU legislation, aiming to transform political commitments into legal frameworks [41,42], with particular attention to environmental protection. Contemporary understandings of environmental stewardship not only pertain to sectors utilizing natural resources but also encompass entire economies and human communities, resulting in a justified interest in the concept of a green economy among international organizations and global institutions, which the EU aligns with. The EGD concept involves the greening of the economy, implementing the paradigm of inclusive development based on sustainable practices and ecological balance restoration [43].

The role of forests is perceived as central and multifunctional, with the involvement of managers and the forestry value chain aimed at achieving a sustainable and climate-neutral economy by 2050. In this context, the EU seeks both mandatory and voluntary trade measures with third countries, establishing a common platform for the trade of goods that embody a high rate of deforestation—FRCs (forest risk commodities) [44]. The primary objective of the New Forest Strategy is the protection of European forests, which play a significant role in achieving a 55% reduction in greenhouse gas emissions by 2030. It also outlines specific actions to increase the area, quality, protection, restoration, and resilience of forests. An essential goal is the adaptation of forests to new conditions and extreme weather phenomena as well as the uncertainties resulting from ongoing climate changes.

Expectations regarding forest products, rural development, and innovation are significant for both policymakers and citizens. Equally important is the protection of forest biodiversity and the endeavor to mitigate the impacts of climate change. Political documents often overlook the complexity of achieving multiple, sometimes conflicting objectives. Hence, discussions have arisen concerning how forest resources should be managed and why this is crucial in Europe [45,46]. The European Commission has proposed the New EU Forest Strategy 2030 to harmonize European forest policy with the European Green Deal and fulfill its environmental objectives. This strategy has garnered both supporters and detractors, prompting debates in several countries, including Sweden, Finland, Germany, and Poland, on the role of forests and the impact of EU policy on forest management [40,47,48]. This is primarily due to member states possessing national sectoral policies that regulate and promote the provision of a wide range of ecosystem services.

In many EU countries, attempts have been made to assess the compatibility of EU law with national forestry legislation and to compare forest policies among member states, particularly concerning the realization of sustainable and multifunctional forest management [26,49,50,51,52]. Caicoya et al. [53] analyzed the coherence of policies supporting landscape management and multifunctional forestry in Germany. In Sweden, both opponents and proponents of the Strategy assessed the implemented policies as the most environmentally friendly [47]. The harmonization of Polish forestry law with EU legislation has been the subject of investigations by Paschalis-Jakubowicz et al. [54]. A significant challenge lies in creating a new model of forest policy that integrates the forest policies of individual member states with EU policies [55]. Pertinent questions remain regarding whether to aim for the balancing of functions performed by forests, how to establish hierarchies, or whether to favor specific functions and, if so, based on which criteria [56].

This study aimed to conduct a comparative analysis of the assumptions outlined in the New EU Forest Strategy of the 2030 and the Polish State Forest Policy, focusing on the functional aspects of both and their means of implementation. The central theme of the comparative analysis was to verify the compatibility and synergy of both documents concerning the functions they fulfill, their methods of achieving goals, and an attempt to justify the reasons for the existing differences. The validity of the assumptions was also assessed in the context of the challenges facing Polish forestry. The following research questions were formulated: To what extent does the Polish SFP fit into the goals and assumptions of the EU NFS 2030? In what areas is the Polish SFP consistent with the EU NFS? The aim of the study was to compare the assumptions of both policies and to identify the challenges facing the Polish State in terms of updating and adapting the national policy to the EU NFS framework.

2. Materials and Methods

This study uses a comparative legal methodology, focusing on the analysis of similarities and differences between the Polish State Forest Policy (SFP) and the New EU Forest Strategy 2030. The study included a detailed analysis of the assumptions of both documents and their compliance with relevant legal acts in Poland and the EU. The documents were assessed based on a functional (purposive) interpretation, which means that the purpose of the analysis was to understand the intentions of their authors and the goals to be achieved by the SFP and NFS. The functional interpretation assumes that the interpretation of the documents should take into account not only the literal wording of the provisions but also the intended political goal and the socio-economic effects of implementing these policies. In addition, a literal (grammatical) interpretation was considered and applied, focusing on the literal meaning of their content, as well as a systemic interpretation, taking into account the context of the entire system of their functioning. Concerning the justification for the choice of legal interpretations, borrowing these interpretations from the legal system was necessary for a full assessment of both policies. The use of functional, literal, and systemic interpretation in comparing the forest strategy with the forest policy allows for a fuller understanding of the goals, assumptions, and compliance of both documents with the broad legal, political, and social context, which allows for an assessment of their coherence and effectiveness in achieving sustainable development and environmental protection. The functional interpretation allowed for an understanding of the main political goals of the documents and their compliance with the long-term goals of environmental protection, sustainable development, and combating climate change. The literal interpretation was helpful in analyzing the literal wording of their content, which allowed for drawing conclusions regarding their comprehensibility and unambiguity. In turn, the systemic interpretation allowed for taking into account the context in which these documents function, analyzing their compliance with other regulations of national and EU law. First, a general description of both documents was made, including their objectives, assumptions, and main provisions. Then, they were compared in terms of similarities, which allowed for assessing their compliance and contemporary significance in the context of the goals of sustainable development and environmental protection. The next stage was an analysis of the differences in the way both policies are implemented, including the approach to implementation, monitoring methods, and the role of institutions responsible for their implementation. Then, the observed differences were compared, which allowed for a fuller understanding of the potential challenges related to the implementation of both policies. In addition, an analysis was carried out of documents confirming the current state of forestry in Poland, such as reports, studies, and statistical data on forests, referring to the state and regulatory assumptions in the EU and taking into account existing documents and EU policies on forest protection and the implemented climate policy. The verification carried out was limited to the analytical framework covering the period from the creation of the SFP document to the creation of NFS 2030, which allowed for the assessment of the relevance of policies in the context of their implementation in Poland and the EU. Data sources included (1) national documents: State Forest Policy, Forest Act, and national legal acts; (2) EU documents: New EU Forest Strategy 2030 and EU directives on forests and biodiversity protection; and (3) other sources: scientific publications, reports of non-governmental organizations, and statistical data. The period covered by the study allowed for the assessment of the relevance of policies in the context of their implementation in Poland and the EU.

3. Results

3.1. Forest Policy in Poland and the EU: Assumptions and Strategic Priorities

The State Forest Policy (SFP) delineates the trajectory for forestry development in Poland. This document articulates the objectives and priorities of forest policy while characterizing the organizational, economic, and legal conditions [10]. Expected outcomes are defined, accompanied by a timeline for the implementation of tasks within this framework [57]. In the SFP, special emphasis is placed on protected areas—national parks and forest reserves—due to the need to protect natural ecological processes. The document emphasizes the importance of multi-faceted functions performed by forests (ecological, production, and social) and also recognizes potential conflicts between these functions as well as their complementarity or the origin of one function from another. The role that forests play in the country’s ecological security gives them strategic importance, identifying them with military, social, and energy security. In addition, it presents important features of forests that are important for the formulation of forest policy. The relationships between forestry, society, other sectors of the national economy, and entities cooperating with forestry are emphasized. The sustainable utility of all forest functions was set to be achieved through appropriate forest management and governance practices as key means of shaping and protecting forest ecosystems. In the SFP concept, forest management should aim to promote harmony between different forest functions, strengthening their complementary character. The need for regionally differentiated forest policies was emphasized, which take into account different ecological conditions, the specific role of forests in landscapes, the growing threats to forests, and the needs and expectations of local communities, which may differ from the needs and expectations in other parts of the country. The issue of differentiated policies is emphasized, taking into account such issues as landscape type, environmental condition, role of forests, functions of the area, local social needs, and interactions with the timber industry and timber consumers. Achieving the objectives set out in this ecological, economic and social policy requires prior analysis of the condition of forests and setting development directions that take into account the limitations on the implementation of all forest functions; its health condition; anthropogenic and natural factors; forest management in private forests; the need to increase afforestation; the transformation of Polish forestry, especially the state forests, towards sustainable and multifunctional forest management; and the protection of forests close to the primeval as well as the economic conditions of forestry regardless of the ownership structure. Factors determining the implementation of the SFP, taken into account during its formation, include demographic growth, social expectations regarding forests, the level of social awareness, and the definition of the legal framework positioning Poland as a nation obliged to comply with international law, conventions, agreements, and treaties. The realities of a changing climate and extended wood production cycle, research on changes in environmental conditions, and the relationships between forests and their functions, and definitions and parameterization consistent with indicators and criteria for sustainable management of European forestry, together with the need for consistent monitoring of forest conditions and threat levels in order to reliably forecast changes in these elements, were taken into account. The concept of the state forest policy is based on the perception of forest management through the prism of ecological, economic, and social policies in an intersectoral framework, with the aim of achieving the objectives of these policies. One of the priorities of the forest policy was to establish a comprehensive set of actions that would facilitate the shaping of human relationships with forests in the field of maintaining multifunctionality. The guidelines were defined in response to social expectations regarding a significant expansion of forest benefits resulting from forests. Directions of actions were defined to strengthen the functions (ecological, productive, and social) of forests, with particular emphasis on public forests. Attention is also paid to the regeneration of stands and the rehabilitation of ecosystems within private property. Finally, the conditions for the implementation of the adopted priorities and tasks of the forest policy, the expected effects, and the schedule for their implementation were defined.

In the introduction to the New EU Forest Strategy 2030, dated 16 July 2021, referred to hereafter as COM (2021) 572 final [36], the European Commission highlights the role and nature of forests covering the territory of EU member states. The non-productive roles of forests are emphasized, manifesting through their impact on human health and well-being, job preservation, food security, cultural heritage maintenance, effects on air and water and soil, their role in preserving the biodiversity of plants and animals, perceiving forests as allies in combating climate change and aiding in adaptation to ongoing changes, as well as the increasing pressure on forest ecosystems caused not only by anthropogenic factors but also by natural processes. It has been demonstrated that the protection status of forests in the most protected areas requires significant improvement, with one-century monocultures recognized as particularly threatened.

Climate change has distinctly outlined vulnerable areas, exacerbating the effects of both biotic and abiotic stressors. It was pointed out that forest area loss due to extreme weather events and intensified logging for economic purposes has progressed over the last decade. The Commission’s commitment to forest restoration and protection not only in Europe but globally, as well as collaboration with partners in this regard to promote sustainably managed forestry, reaffirms previously established assumptions and earlier prioritized protective goals. Furthermore, a legislative initiative has been undertaken to adopt a legislative proposal aimed at ensuring the origin of products from the EU or third countries sold in the community market that do not contribute to global deforestation. The European community will promote an approach to forests that considers supply chain management (cascading use of wood) and their sustainability and legality. The importance of biodiversity and local community engagement in implementing adopted assumptions while ensuring its income remains significant. Objectives outlined by the European Commission align with the actions of the European community concerning climate action programming and the implementation of the Biodiversity Strategy 2030 [37].

The level of change in sustainable forestry can be monitored using sustainability indicators (e.g., changes in forest area or protected forest area). A comparison of the area of protected areas, forests, and nature conservation activities (taking into account selected economic factors and the role of Poland in the EU) is presented in

Table 1. Quantitative indicators of sustainable forestry and implementation of conservation tasks in the EU and Poland. Source: EEA, EUROSTAT (2022).

Category	EU	Poland
Forest area	About 160 million ha (39% of the EU area)	About 9.4 million ha (30% of the country’s area)
Area of Natura 2000 areas	18% of the EU area	20% of the country’s area
Area of National Parks	3% of the EU area	1% of the country’s area
Area of nature reserves	4% of the EU area	0.6% of the country’s area
Protection of primeval and old-growth forests	Less than 0.5% of the EU area	3% of the country’s area
Protective measures	Conservation of biodiversity, protection of old and primeval forests, and sustainable forest management.	Striving to preserve biodiversity and sustainable forest management.
Meeting the goals in quantitative and qualitative participation	Expanding the network of protected areas, including Natura 2000, and implementing actions to improve the health of forest ecosystems, with an emphasis on preserving biodiversity and protecting old, primeval forests.	Development of the Natura 2000 network, expansion of the area of national parks and nature reserves, as well as protection of old and primeval forests while ensuring sustainable forest management and biodiversity.
Environmental protection investments of total economy	0.40%	0.50%
Percentage of environmental taxes in total revenue from taxes and social security contributions	5.30%	8.12%
Net greenhouse gas emissions of the Land use, land use change, and forestry (LULUCF) sector	Year 2019 (−240 983 t) Year 2020 (−240 779 t) Year 2021 (−240 885 t) Year 2022 (−236 401 t)	Year 2019 (−22 561 t) Year 2020 (−23 330 t) Year 2021 (−23 916 t) Year 2022 (−35 644 t)
Contribution to the international USD 100 billion commitment on climate-related expenses (million EUR)	Year 2019 16 205, 77 Year 2020 18 103, 89 Year 2021 17 977, 97 Year 2022 21 920,86	Year 2019 12.88 Year 2020 22.49 Year 2021 8.44 Year 2022 19.45
Protected areas (mln km2)	Year 2021 1076 Year 2022 1080	Year 2021 0.123 Year 2022 0.123

.

3.2. Position of the NFS and SFP Within Their Respective Organizational and Legal Frameworks (Legal Implications of Policy Implementation)

Policies and strategies do not generate legal effects in legal systems, but they can influence these systems by shaping and promoting a specific concept. They are a set of guidelines and constitute a theoretical framework for creating legal regulations. In this context, the SFP is the general, long-term course of action, while the NFS strategy comprises the specific plans to achieve the political goals. Their implementation depends on reaching a consensus on their adoption, which must ultimately lead to a legislative process undertaken by the relevant legislative bodies. Both documents present desired visions of forest policy, although they differ in their genesis and history of creation as well as in their institutional background. The compliance of the EU strategy with the applicable EU regulations is obvious, while the SFP requires updating due to the evolving priorities in the management of forest resources. In addition, the lack of a clear political framework does not strengthen the position of Polish forestry and forest management in relation to other sectors of the national economy. Adjusting Poland’s forest policy to the EU goals requires changes towards strengthening the role of forestry in the protection of ecosystems and the involvement of local communities in educational processes and environmental protection. NFS has a stronger link with European regulations and has a greater impact on the creation of forest policy in Poland, while SFP in Poland requires harmonization with EU regulations. The Polish Forest Policy and the New EU Forest Strategy are based on common assumptions regarding the protection and sustainable management of forests. The implementation of their objectives depends on the implementation of appropriate legal systems and regulations supporting sustainable forestry and limiting climate change. Effective implementation of policy assumptions requires close cooperation of public administration at various levels of management, development of an acceptable consensus in forest management, and adoption of appropriate legal regulations. This is a common feature of these two documents. The key differences and similarities between SFP and NFS are illustrated in Figure 2.

3.3. Comparative Analysis of the Priorities of the New EU Forest Strategy 2030 and the State Forest Policy

A comparison of both strategies in terms of their chosen direction demonstrates compatibility and alignment in their stated objectives. Based on the document analysis, it has been shown that the directions established in the SFP coincide with the concept defined in the NFS. Discrepancies were found in terms of achieving desired objectives 3, 4, 5, 6, and 7 of the NFS, which are articulated in the SFP in terms and conditions (Table 1). In this context, the coherence of the established objectives can be considered aligned.

3.4. Methods for Achieving Objectives Outlined in the SFP and NFS

The analysis revealed differences in the methods proposed for achieving the stated objectives. Concerning support for socio-economic functions of forests (objective 1), the NFS emphasizes cascading use of wood, utilizing the amended LULUCF regulation [30], with further elaboration on legal regulations that facilitate access to support systems [32,58] and aid funding, treating forests as CO₂ sinks (

Table 2. Comparison of the Compatibility of NFS Objectives with the SFP in Terms of the Adopted Direction.

New EU Forest Strategy 2030	State Forest Policy
Purpose	Reference to SFP
Supporting the socio-economic functions of forests for thriving rural areas and boosting a forest-based bioeconomy within the limits of sustainable development.	Yes
Supporting a sustainable forest bioeconomy for sustainable wood products.	Objective 8b—strengthening the productive function of forests.
Ensuring the sustainable use of wood-based resources for energy use.	Objective 2—ensuring the sustainability of forests and their multifunctionality. Objective 8b—strengthening the productive function of forests.
Promoting a bioeconomy based on non-timber forest products, including ecotourism.	Objective 5—improving the condition and protection of forests. Objective 6—promoting and protecting biodiversity throughout the entire forest management and management process. Objective 8b—strengthening production functions. Objective 8c—strengthening the social functions of forests.
Developing skills and empowering citizens in a sustainable forest-based bioeconomy.	Objective 5—improving the condition and protection of forests. Objective 8 c—strengthening the social functions of forests.
Protecting, restoring, and expanding EU forests to combat climate change, reverse biodiversity loss, and ensure resilient and multifunctional forest ecosystems.	Yes
Protecting the EU’s last remaining primary forests and old-growth forests.	Objective 6—the need to provide statutory protection for all forests. Objective 8a—strengthening the ecological functions of forests.
Ensuring forest restoration and strengthening sustainable forest management to adapt to climate change and increase forest resilience.	Objective 5—improving the condition and protection of forests. Objective 6—promoting and protecting biodiversity throughout the entire forest management and management process. Objective 7—continuation of the forest promotional complexes program. Objective 8b—strengthening the production functions of forests. Objective 8c—strengthening social functions by integrating forestry goals with sustainable development goals.
Reforestation and reforestation of biodiversity-rich forests.	Objective 3—increasing forest resources. Objective 4—increasing forest resources. Objective 8a—strengthening all important types of forest functions, especially their ecological functions.
Financial incentives for forest owners and managers to improve the quantity and quality of forests in the EU.	Mentioned in the theses—building legal and financial mechanisms encouraging forest owners and managers to invest continuously. Objective 9—the need to establish appropriate legal, economic and organizational bases for owners of private forests. Indicated in the conditions.
Strategic forest monitoring, reporting, and data collection.	Mentioned in terms and conditions.
A comprehensive research and innovation program to improve knowledge about forests.	Objective 6—theoretical and experimental studies on the new forest model. Objective 8c—ecological and forest social education. Mentioned in terms and conditions.
A coherent and inclusive EU forest management framework.	Mentioned in terms and conditions.

). The achievement of the same objective in SFP is based on the concept of implementing sustainably managed forestry, synergy between forestry and the wood industry, and promotional activities related to wood use. A common intent of both concepts is raising environmental and forestry awareness among the public. The objective of protecting, restoring, and increasing forest areas in the Forest Strategy (objective 2) is expressed in percentage terms concerning the area under legal protection as well as quantitatively determining the number of trees to be planted and emphasizing the need for promoting forest ecosystem services, support systems, payments to forest owners, public support, and a certification system. The direction taken in the SFP focuses on developing new forest models and forestry management systems considering multifunctional forestry while simultaneously ensuring legal protection for all forests, particularly primordial and ecologically valuable forests, comprehensively addressing the importance of enhancing both productive and social functions during forestry planning stages. Notably, emphasis has been placed on achieving objectives through appropriate management practices (defined in the Principles of Forest Management of, Forest Management Guidelines, Ministry of Environment regulations, and internal directives of State Forests-(SF), with minimal legislative intervention from the state.

A common feature of both the NFS and SFP is the expansion of entities covered by forest management plans and international cooperation. Strategic monitoring and reporting in the NFS (objective 3) focus on unifying the reporting system and data collection and utilizing new technologies for forest observation, encompassing a larger number of private forests in the management planning process. Both strategies are similar in the way they achieve the goal.

Achieving the aim referred to as scientific research and reporting within the Forest Strategy (objective 4) focuses on programmatic support from “Horizon Europe”, promoting the use of functionalized wood, information campaigns concerning knowledge about primordial forests and old-growth stands, ecosystem service topics, research on agroforestry systems and trees outside forests, technological innovations in rural areas, and private investments in a circular economy. The SFP proposes scientific research on a new model of forest management. Both strategies underscore the necessity for public education at every level of instruction and throughout life stages.

The attainment of the objective concerning forest management in the EU fostering social inclusion (objective 5) in the NFS is contingent upon an updated management system that integrates expert groups. In the SFP, emphasis is placed on public consultations. Achieving the goal represented in item 6—enforcement and implementation of EU legal standards—does not differentiate both strategies’ approaches beyond promoting geopolitical surveillance (

Table 3. Comparison of NFS with SFP according to the intended methods of achieving the established objectives.

	New EU Forest Strategy 2030	State Forest Policy
NSL goals	Method of achieving the goal.	Method of achieving the goal.
1. Supporting the socio-economic functions of forests for prosperous rural areas and stimulating a forest-based bioeconomy within the limits of sustainable development.	Cascading use of wood, legal regulations enabling access to support systems, and aid funds treating the forest as a CO2 absorber.	Implementation of permanently sustainable forest management, synergy of forestry with the wood industry, and promotion of the use of wood.
2. Protecting, restoring, and expanding forests in the EU to combat climate change, reverse biodiversity loss, and ensure resilient and multifunctional forest ecosystems.	Percentage of land under legal protection, quantification of the number of trees to be planted, promotion of forest ecosystem services, support systems, fees to forest owners, public support, and a certification system.	New models of forest and forest management taking into account its multifunctional role and the legal protection of all forests taking into account primary forests, especially valuable ones (comprehensive approach at the stage of forest management planning) and strengthening its production and social functions, achieving the goal using appropriate economic practices.
3. Strategic monitoring, reporting, and data collection in the field of forests.	Unification of the reporting system, data collection and use of new technologies for data acquisition, forest observation, and covering more private forests with forest management plans.	Extension of competences, BUL, and GL for forests regardless of the form of ownership, traditional monitoring of forests and the functions they perform.
4. A comprehensive research and innovation program to improve knowledge about forests.	Program support, promotion of EGD, information campaign on primary forests and old-growth forests, ecosystem services, research on agroforestry systems and trees outside the forest, technical innovations introduced in rural areas, private investments in the circular economy.	Scientific research on a new forest model, public education, Olympiads, development of educational chambers.
5. A coherent and inclusive EU forest management framework	Updating the management system integrating expert groups.	Public consultations and cooperation with associations, local governments, and social organizations.
6. Intensifying implementation and enforcement of the existing EU acquis	Review of EU legal acts, updating guidelines on the interpretation of regulations for their consistent enforcement in cooperation with member states, promotion of geospatial intelligence, and the role of civil society.	Legal protection of forests of all forms of ownership and improvement of mechanisms and methods for Poland’s compliance with signed international conventions, agreements, and understandings.

).

Based on the comparative analysis (Table 3), key criteria were selected for assessing the compatibility between the NFS and the assumptions presented in the SFP.

Both strategies are consistent in terms of social, educational, and technological activities and cooperation with local authorities and society, and they also take into account the issues of private ownership of forests. However, differences appear in the implementation of protective and productive functions of forests as well as in the dependence of NFS on external financial support, which constitutes a significant divergence in the approach to achieving the goals.

4. Discussion

The achievement of ambitious objectives outlined in the European Green Deal involves a range of actions impacting forests and forestry, highlighting numerous issues and threats associated with forestry while rarely mentioning the potential opportunities it can offer. The realization of the New EU Forest Strategy by 2030 is expected to be feasible through the concept of sustainable forest management that takes into account the multifunctionality and diversity of forests, based on its three pillars. However, it lacks a holistic perspective on forests [48] as well as cooperation between the European Commission, member states, and stakeholders during its development [59]. From the perspective of EU forestry policy coherence, the objectives defined are insufficient, and the new EU forest strategy will not enhance the quality and consistency of the law [35,60]. The comparative analysis of both documents indicated differences in the perception and interpretation of the concept of sustainably managed forests. The NFS does not appear to reflect the principles of multifunctional sustainable forest management, distancing itself from existing scientific achievements and practices [61]. The principles of the State Forest Policy align with the ecological policy of the state and the 1991 Forest Act, grounded in the principles of sustainable forest management [9]. These principles stem from long-term forecasts and socio-economic development strategies that were in place at the time of their creation [14]. The concepts of sustainable development [62,63,64] and sustainable use [65] are terms that operate within the Polish legal system. The notion of sustainably managed forests is well established in forestry practice and academia, remaining at a relatively advanced stage [66]. Furthermore, the concept of sustainably managed forests complements forest management principles with objectives and directives based on the constitutionally affirmed principle of sustainable development [67]. Full understanding of the need to maintain forest durability within the landscape has been articulated by the Polish legislator in the Forest Act [7,68]. Guidelines for implementing multifunctional forest management have also been reflected in instructions, principles, and regulations from the Ministry of the Environment and directives issued by forest managers [69,70]. The complexity of the multifunctional roles of forests results from the connections between forestry and a growing number of groups and entities interested in accessing specific forest functions.

The authors of the SFP produced a document that addresses ecological, social, and economic issues, a direction that remains relevant today and is also reflected in the currently presented EU Forest Strategy 2030. The compared documents differ in their visions and proposed methods of implementation. For instance, the objective of increasing forest resources is quantified in the New Strategy as the planting of 3 billion trees by 2030, whereas the SFP expresses this goal as increasing the forest cover of the country to 30% by the year 2020, a target that has been almost achieved [71]. Another example is the EU’s proposal to designate 30% of the land area in the EU as protected areas, with 10% classified as strictly protected. This goal is again specified quantitatively. In the SFP, achieving a similar goal is linked to legal protection measures, cultivation indicators, forest utilization, and the application of appropriate technologies. In the New EU Forest Strategy 2030, regarding CO₂ sequestration, emphasis is placed on the cascading use of timber as an active carbon sink, aimed at broadly substituting its high-emission counterparts in the product life cycle. One of the outcomes aimed for in the SFP by the year 2020 is an increase in CO₂ sequestration and accumulation of approximately 10% and 20% by the mid-21st century. The goals and priorities defined in the State Forest Policy were neither incorrectly nor overly optimistically specified at the time but faced implementation barriers arising from various causes. The authors themselves contingent its success on “consistent implementation”.

The New EU Forest Strategy 2030 is a collection of defined factors and processes that led to its formulation, serving as an instrument for initiating changes in forestry across EU countries [38]. Its legal character classifies it as soft law, where established guidelines do not impose legally binding obligations. Nevertheless, depending on the political context, they may encourage compliant behavior on the part of the addressees [19].

Despite its noble intentions, the NFS raises justified concerns and numerous controversies among member states [40]. These involve economic issues and the resulting economic implications for states and societies [47,61,72]. It has also faced criticism from the European Council regarding insufficient dialogue with stakeholders [38], exacerbating the ongoing polarization between the protective and economic functions of forests [26].

Furthermore, the isolation of the European Community on the international stage as a leader in this direction is apparent. It is paradoxical that the ecosystems that best preserve biodiversity are the subject of the widest-ranging EU plans. The reasons for this situation are attributed to a lack of compensation and restitution for lost benefits for state forests (as opposed to private ownership), treating these as a cost-free experiment [8,61]. The absence of a compensation system for lost benefits due to alternative forest management practices and nature conservation financing is likewise present in Polish legal order. In the plans for planting 3 billion trees, the NFS does not consider the potential conflicts arising from alternative land uses and concepts for their development related to climate change mitigation [73]. The establishment of protected areas on 30% of the EU’s land area is controversial, as this could result in a reduction in timber extraction, consequently affecting the economic condition of forest service providers and the timber industry.

Forests serve as a source of livelihood for many Europeans; the sectors linked to forestry provide employment for 4 million residents across 27 member countries [22]. Environmental, natural, and political factors limit the supply of timber, resulting in an observed upward trend in the price of this commodity under such conditions. This directly impacts the competitiveness of the timber industry domestically and raises the prices of timber products. As noted by Ossowska and Janiszewska [74], Poland is already among the countries with the lowest timber extraction levels, considering the multifunctional nature of its forests. Long-term comparisons show that in the state forests over the last 20 years (2002–2021), in the case of felling, permanent possibilities were used in 97.1% [75]. Managing forests based on the principles of sustainable growth implies negative changes in the cost structures of economies, leading to higher operational costs and lower gross added value [76].

Forestry not only plays a vital role in rural development [77] but can also be of critical importance to local communities depending on the region [78], with employment in the forestry sector exceeding 300,000 people [79]. Research shows that as the economic level (GDP/capita) rises, the share of forestry in its raw material significance diminishes in favor of non-productive functions [80]. According to the formulated principle of social justice, consensus relies on achieving a balance; it is not justified to increase the level of one function at the expense of decreasing another under circumstances of lacking public acceptance. The “wake theory” posits that sustainably managed forestry concerning timber production simultaneously represents an optimal state for achieving other forest functions [81]. It has been confirmed that the technical–economic dimensions of forestry affect short-term economics, dynamics, sector development prospects, supply chain organization, interfirm relationships, and investment strategies, while forestry practices protect species and habitats while supporting sustainable wood production [82].

Currently, timber production determines the revenues of forest managers and owners [83]. Competing against the public functions of forests defines the scope and strength of the interdependencies between the market and public forestry sectors [84]. In assigning a confrontational direction to production and non-production functions, the concept of sustainably managed forests, where the legislator intends to reconcile conflicting elements, loses meaning [66,85].

Adapting forests in light of current social needs requires continuous improvement in forest management practices [70]. Protective and social functions have so far remained the domain of public forests [74]. The predominance of private forest ownership is generally associated with reinforcing the productive function of forests, seen as income-generating assets. The purely utilitarian aspect of biodiversity conservation stems from the potential to meet current and future generations’ needs, encapsulating the necessity to consider various constitutional values and appropriately balance them. Many authors contend that the belief in nature’s stability and persistence in its original form without human intervention is misguided [76,86,87]. Human intervention in forest ecosystems can be an effective means of maintaining and restoring biodiversity, provided that balance is maintained. A forest does not serve as a source of isolated goods and services; this ecosystem fulfills numerous roles that change over time and space as the forest matures, and an elaborate interdependence system should be considered as a whole. The engagement of forest function beneficiaries and stakeholders is a necessary process that can lead to an understanding of sustainable management in forestry [38]. The absence of indicators for sustainable forest management in Poland, alongside a lack of references to Forest Europe (a process shaping forest policy across Europe, initiated as the Ministerial Process for the Protection of Forests in Europe (MCPFE)) criteria, complicates the assessment of the realization of sustainable forestry principles [13].

The SFP has been subject to numerous assessments over its more than 20-year period, during which it has not been updated or adapted to the changing socio-economic condition in the country and globally. It does not account for Poland’s accession to the European community or the advancing globalization and the development of climate change policies [88]. An analysis conducted three years after its introduction revealed that many goals and tasks defined in the document are not being realized to a sufficient degree or not at all [88] mainly due to inadequate institutional support, relevant documents, and executive programs. Limited compatibility with some international commitments, including the “Forest Strategy for the European Union” from 1998, was also identified. The response to this situation was the adoption of the National Forest Program (NFP 1) in 2000. This program was to be grounded in Regional Operational Programs for the Forest Policy of the state (ROP-SFP), developed for each Regional Directorate of the State Forests (rdSF). This effort aimed to incorporate the principles of the State Forest Policy into the activities of the forestry sector within each rdSF. The outcome of this work was an evaluation of the existing State Forest Policy, identifying the problem areas included in the ROP-SFP. In the working drafts of these studies, the weakest assumptions of the SFP were identified, culminating in the previously mentioned evaluation and outlining the problematic areas in the ROP-SFP, which led to the development of program theses [89]. The result of the analyses conducted in 2016 was a set of recommendations for the National Forest Program, which were forwarded to legislators (environment ministries). The final version of the program has yet to reach a definitive form. Subsequent amendments to the Forest Act [7] established a provision (Article 5b) that creates a legal basis for developing a future NFP. According to many authors, it is expected to be more of a political document than a legal one [10]. Actions taken by legislators based on the literal interpretation of this provision, however, may have a facultative character. The unfavorable position of the SFP concerning adaptation to changes in forestry at the EU level was counterbalanced by introducing forest-related priorities into various intersectoral documents [57]. This is typically how the adaptation of national regulations to community objectives takes place [14].

Over the past quarter-century, the changes resulting from the previously indicated premises could only be made through evolution, and at present, the SFP may serve as a reference point for establishing new provisions that incorporate holistic solutions to address the challenges of the 21st century and the trends and directions set by the European Community [90]. It is necessary to develop and implement a new National Forest Program that will adhere to the principles accepted for Polish forestry while simultaneously fulfilling universal EU law. In the case of the SFP, the need to condition the achievement of objectives requires political regulations at the legislative level [91].

Forestry policy in the 21st century will be shaped in the context of significant environmental and economic uncertainty. Its subjective interpretation may arise from various levels of prosperity, organizational and legal forms of forest enterprises, forest ownership structures, and the diversity of energy portfolios in individual EU countries. This is the direct cause of the preference for protective functions at the expense of production roles in forests regarding NFS. An additional complicating factor is the shifting geopolitical situation in the immediate vicinity of the EU. One such factor is the sudden and unpredictable increase in greenhouse gas emissions due to the war in Ukraine, which reaches far beyond its borders [92]. Canceled contracts with Russia as a timber supplier may also impact the EU’s engagement in forest-based bioeconomy strategies aimed at achieving planned climate goals, compelling forest managers to seek economic practices that achieve a balance among the various possible forms of forest use [93]. The war has necessitated a revision of the previously set goal of 40% renewable energy consumption to 45% by 2030 [94]. The proposed solution list may include opposing options or those difficult to implement [89], and the sustainable use of biomass and its promotion in the energy, construction, and transport sectors must go hand in hand, remaining top priorities in ensuring food supply and security [95].

So far, global climate policy has proven ineffective, as the overall level of CO₂ emissions continues to rise. Although the EU is not its principal producer, it significantly leads in formulating initiatives in the climate and energy sectors [96]. International environmental law has so far been unable to adequately respond to the changes in climate and land use, which are the primary causes of deforestation and forest degradation [43]. According to estimates from the Commission, even if the full commitments of the European Green Deal regarding the reduction in greenhouse gas emissions in the atmosphere are fulfilled, their concentration will continue to rise alongside increasing average temperatures. The diversity of patterns of supply and demand for forest ecosystem services (FES) across the EU underscores the need to consider variations in national and local regulations regarding the management of FES supplies in EU forestry policy. There should also be an emphasis on establishing priorities “from the bottom up” concerning the ecosystem services required by local communities that forests can provide [97]. Individual EU member states are implementing their strategies tailored to their needs while considering their own decision-making spaces, which also necessitates the EU’s diversified approach to implementing soft policy instruments [98]. Integration of policies depends on many factors, including the prioritization of forest values and forest management systems. Policy integration does not occur at a single moment but throughout the policy cycle; the role of co-decision-making entities and subsystems in formulating and implementing policy is also paramount [52,99]. Nabuurs et al. [100] advocated for implementing an investment program for EU forests, which would enhance the coordination and coherence of forest strategies, particularly regarding the preservation of forest biodiversity and the strengthening of the circular economy. The implementation of the EU Green Deal should occur in a holistic manner, encompassing all sectors of the economy. Encouraging and promoting enterprises toward not only positive environmental actions but also technological advancement can ensure a just transformation across all dimensions: economy, ecology, and information [82,101].

5. Conclusions

The comparative analysis of the EU Forest Strategy 2030 and the State Forest Policy using a functional interpretation showed the general coherence of the assumptions of both documents, but they differ in their methods of achieving production and protection goals, which are the subject of disputes within the EU. Analysis of the literal wording of the provisions allowed us to draw conclusions regarding their comprehensibility and unambiguity. The systemic interpretation allowed us to take into account the context that these documents occupy within the legal systems. Both strategies are based on sustainable forest management, but its definition requires adaptation to the specifics of individual member states. It is necessary to develop a new definition and a system of indicators that will facilitate the assessment of the implementation of sustainable forest management. In the past, difficulties were encountered in implementing previous strategies, which had minimal impact on the legal framework. Due to the changing realities and diversity of approaches among EU countries, creating a single, coherent, long-term strategy for the entire community is difficult. Therefore, subsequent documents should define general objectives and directions of action. Currently, the NFS is rather a vision of EU policy, and the SFP serves as a historical document. Creating normative acts on its basis, without taking into account contemporary conditions, may clash with the direction of development of forestry in Europe. For this reason, a bottom-up approach, based on consensus among member states and aimed at creating a coherent forest policy at the EU level, is more justified.