Estonia may have exceeded its 2021–2025 greenhouse gas limits in the forestry and land use (LULUCF) sector, but officials say it is too early to draw firm conclusions about any financial impact.

According to the latest Environment Agency forecast, the sector's shortfall could total 4.6 million metric tons of greenhouse gases — or as much as 8.3 million metric tons if the European Union as a whole fails to meet its target. That could potentially translate into significant costs for the state, though Ministry of Climate officials have stopped short of linking the gap to a specific figure.

"In fact, we do not know whether there will be a shortfall," said Kristi Klaas, deputy secretary general for the green reform, pointing to ongoing technical discussions in Brussels. "At this stage, it does not make sense to talk about a shortfall."

Laura Remmelgas, head of the ministry's climate department, also declined to speculate on whether costs could exceed €100 million. "It is far too early to speculate on that," she said, adding that the European Commission must first approve member states' final reports.

Estonia and other member states are currently engaged in technical-level discussions with the European Commission to ensure that changes and trends in forestry and land use over the past five years are reflected as accurately as possible in the statistics.

Officials argue that current forecasts may overstate emissions and do not yet fully reflect factors such as the impacts of climate change, including spruce bark beetle damage, or the Russia-Ukraine war, which has increased logging pressure in Estonia as cheap lumber from Russia and Belarus is no longer available. Klaas said the aim is to ensure that "the changes that have actually taken place are reflected in a way that is comparable and transparent across all member states."

At the same time, Remmelgas did not rule out the possibility that actual forestry emissions could turn out to be higher than the Environmental Agency currently forecasts.

She said the European Commission does plan to review the forestry and land use regulation this year, but that concerns years in the next decade, while member states have no plans to amend the rules underpinning the 2021–2025 climate target.

A clearer picture is expected only after countries submit their final reports to the European Commission in the coming years.

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