The integration of climate targets into EU forest governance is politically contentious, with policy actors pursuing conflicting objectives through justice-based claims of victimisation and marginalisation, often resulting in intractable conflicts. This paper examines how justice is framed and perceived by policy actors in political debates concerning the EU's Land Use, Land Use Change, and Forestry (LULUCF) Regulation. We answer three research questions: a) what just transition frames are employed by policy actors within the LULUCF discourse, b) who uses these frames, and c) how these frames relate to the official EU LULUCF policy framing. To address these questions, we analyse 101 stakeholder submissions from the EU's Have Your Say initiative and key EU LULUCF policy documents. Integrating frame analysis with environmental justice and political ecology theories, we identify five distinct just transition frames: Forestry first, Forests for climate, EU transition policy pragmatism, Biodiversity and climate first, and Addressing the periphery. Findings reveal significant structural power asymmetries, with economically dominant, industry-aligned frames being privileged in official policy texts. Conversely, ecological concerns, regional interests concerning Europe's periphery, and specific forms of practitioner knowledge remain marginalised or excluded. Such underrepresentation intensifies regional inequalities, ecological vulnerabilities, and socio-economic marginalisation. Across all identified frames, policy actors consistently highlight perceived procedural injustices, including limited transparency and inadequate participation opportunities. The paper concludes that addressing these perceived justice deficits requires recalibrating EU forest governance toward genuine procedural inclusivity, fairer distribution of policy burdens, and explicit recognition of both material and epistemic marginalisation.
Marzo et al. (Thu,) studied this question.