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"To build a sustainable, climate-resilient future for all, we must invest in our world's forests.”
– UN Secretary-General Ban Ki-moon
The European forest owners, managers, forest industry and professionals, represented by key stakeholders of the European forest sector: CEPF, Copa-Cogeca, ELO, EUSTAFOR, CEI-Bois, CEPI, FECOF, UEF and USSE, welcome the declaration by the UN General Assembly of the International Day of Forests on 21 March which this year has the theme “Forests and Water”.
Water is a vital element of all natural resources and essential to life, but nearly 80 percent of the world’s population is exposed to high levels of threat to water security. There is a growing imbalance between water supply and demand in the world, and also in Europe we increasingly need to ensure adequate water quality and quantity.
The European forest sector welcomes the opportunity to emphasize the role of forests and water. We consider that EU needs to better communicate the strong link between forests and water. Forests have a close relationship to our water resources and sustainable forest management is of crucial importance for ensuring a multitude of water-related benefits.
As representatives of the European forest sector we would like to highlight some of the important ways in which our forests enable access to this vital resource. Forested watersheds and wetlands supply 75 percent of the world’s accessible fresh water for domestic, agricultural, industrial and ecological needs. Forests influence the amount of available water and regulate surface and groundwater flows while maintaining highest water quality. Forests reduce the effects of floodings, and prevent and reduce dryland salinity and desertification. Forests act as natural water filters, minimizing soil erosion on site and reduce sediment in water bodies.
In the context of this year’s International Day of Forests, we also need to mention the impact that climate change has on water and the role of forests. Climate change is one of the major challenges facing today’s society. The impacts of climate change are an imminent threat to water security, and forests themselves are vulnerable to climate change. An increased frequency of extreme weather events has an impact on both forests and water, and may result in more catastrophic events like landslides, floods and droughts.
However, forests can also help reducing the impacts of such events. Europe’s forest sector is at the forefront of combatting climate change by contributing to both climate change mitigation and adaptation. Active forest management is crucial to enhance forests adaptive capacity, making them more resilient to meet a changing climate and maintaining the vital water-related services provided by forests.
CEPF – Confederation of European Forest Owners
Contact: Meri Siljama firstname.lastname@example.org, www.cepf-eu.org
COPA-COGECA – European Farmers European Agri-Cooperatives
Contact: Oana Neagu email@example.com, www.copa-cogeca.be
CEI-BOIS – Confederation of European Woodworking Industries
Contact: Ward Vervoort firstname.lastname@example.org, www.cei-bois.org
CEPI – Confederation of European Pulp and Paper Industries
Contact: Annie Xystouris email@example.com, www.cepi.org
ELO – European Landowners’ Organization
Contact: Ana Rocha firstname.lastname@example.org, www.europeanlandowners.org
EUSTAFOR – European State Forest Association
Contact: Gerd Thomsen email@example.com, www.eustafor.eu
FECOF – European Federation of Municipal Woodowners
UEF – Union of European Foresters
Contact: Michael Diemer firstname.lastname@example.org, www.european-foresters.org
USSE - Union des sylviculteurs du Sud de l'Europe
Contact: Isala Berria email@example.com, www.usse-eu.org
The sustainable forest management framework has evolved and strengthened over time balancing a market based demand for wood products and bioenergy with the other environmental and climate functions of the forest.
More recently, the EU policy framework to support the use of energy from renewable sources has led to a strong increase of bio-energy use within short timeframes. The increased demand has led to rising imports of wood. To ensure the sustainability of the policy induced increase of bioenergy use and wood imports, the following issues have to be considered:
• Do the needs for wood biomass lead to any of the following critical consequences: resource depletion, land conversion, negative impacts on biodiversity?
• Is the direct burning of wood biomass an efficient use of a raw material that could first be used for higher value purposes?
• How could monitoring, reporting and verification ensure carbon sustainability?
To address the increased use of wood for energy and to design a sustainable biomass policy framework for the post 2020 period, CEPI believes that the following criteria for the production of bioenergy counting towards EU renewable energy targets should be considered while taking into account the use of existing legal and market based instruments at national, EU and global level.
1. Biomass sourcing
Biomass should come from sustainable sources. Biomass is a renewable source of energy if it does not lead to harvesting beyond the sustainable level and preserves the other functions of forests according to the principles of Sustainable Forest Management (SFM).
a. Carbon sustainability:
Forest biomass shall come from countries with credible LULUCF accounting and reporting. If biomass is procured from non-LULUCF accounting countries, credible proof has to be given that there are systems for monitoring, reporting and verification in place ensuring that the harvesting rate in this country is below 100% in the long term and the biomass does not come from land conversion (leading to depletion of carbon stock). Where there is overharvesting at the country level, the energy producer has to give sufficient proof that there is no overharvesting at the relevant regional level of the biomass origin.
Reporting should continue to take place according to the instant oxidation principle. This ensures that the climate effect of the wood use is allocated to the country in which the forest is harvested.
b. Forest management
Forest biomass shall come from legal sources.
In order to ensure that the three main challenges relating to forest management – resource depletion, land conversion and loss of biodiversity – are addressed, the following trend indicators provide sufficient assurance:
1. Growing Stock: The felling rate (harvested volume/net annual increment) must be lower than 1 in the long term (information source: e.g. National Forest Inventories) in order to avoid overharvesting.
2. Gross Deforestation: The area under forest cover must be maintained (except if deforestation is the result of “land sealing” (infrastructue building, urban expansion, etc. which is limited in surface) (information source: e.g. NFI)
3. Biodiversity: No biomass harvesting can take place in protected forests, unless the protection decision allows management and harvesting.
Additional considerations on the proposed approach:
• The measurement of meeting the above indicators must take place within well defined spatial and time dimensions. As far as the spatial dimension is concerned, the country level is relevant. Choosing the appropriate spatial level will allow for robust reporting and monitoring, both in terms of carbon emissions and removals (LULUCF reporting), as well as in terms of forest inventory (fellings areas, etc.)
• A stand level and short-term horizon is not acceptable as it would make compliance with such indicators both impossible and irrelevant. Harvesting lowers the carbon storage in stand level for a certain period, but at the same time at the landscape level, carbon storage continues to be maintained or increased.
• The obligation of proof should be solely with the energy producer.
• Demonstrating compliance should be credible, but not too burdensome to the suppliers and the buyers. Red-tape leading to extra cost would be a disincentive to additional mobilisation of forest resources.
• Similar to the EU Timber Regulation an approach of risk assessment (via national/regional (where relevant) data according to the three indicators outlined) should be investigated. Only if the risk assessment at country level can not give thourough proof, the regional/landscape level should be adressed.
• New means of proof should avoid being a further burden when competing with other industries and products based on fossil and more carbon intensive raw materials as well as with forest industries based outside Europe.
• The tools developed by the forest sector should be used to proof the origin from sustainable sources along the chain of custody.
• In that context, different voluntary instruments and tools addressing forest management should be evaluated and recognised.
2. Biomass conversion
a. Greenhouse Gas Savings criterion:
There should be GHG savings compared to the average European fossil fuel based generation of electricity and heating and cooling.
• The GHG emissions reduction criteria should be based on the GHG emissions calculations methodology recommended by the Commission in 2010 (COM(2010)11) and confirmed in 2014 (SWD(2014)259).
• There should be coherence with the biofuels GHG emissions threshold (60%) as wood can be used to produce power, heat or biofuels.
• The methodology and default values should be established for at least the same period as the post-2020 RES target.
b. Conversion efficiency:
Heat and electricity based on solid and gaseous biomass should be produced at an overall efficiency of at least 70% (lower for small installations (e.g. < 1 MW) or where CHP cannot be applied). Member States should not support but further even avoid the use of biomass in new conversions of coal plants with the current low efficiencies. Supporting co-firing of biomass in coal plants at low efficiencies is an environmentally harmful subsidy.
Meeting the conversion efficiency and GHG savings criteria should be verified by schemes similar to biofuels sustainability criteria. The obligation of verification should be with the energy producer. Mutual recognition of schemes should be ensured to limit red tape.
A background paper accompanying the position can be downloaded here.
CEPI, together with INTERGRAF (European Federation for Print and Digital Communication) published a press release commenting on the implementation report of the EU Timber Regulation (EUTR) published by the European Commission last week. Judging it as a missed opportunity, the two associations are disappointed that the inclusion of printed products is not recommended strongly enough in the regulation’s scope. CEPI and INTERGRAF urge the Commission once again to amend the annex of the EUTR and include products under the chapter 49 of the Combined Nomenclature. The non-inclusion of printed products will lead to circumvention. There is a risk that illegally-logged wood will be traded to countries with less stringent legal rules, before being traded to the EU.
Read our press release.
Read more about the EU Timber Regulation on the Commission website.
Exported jobs, illegal timber: EUTR implementation report fails to tackle loophole on printed products
The implementation report of the EU Timber Regulation (EUTR) published yesterday is a missed opportunity. It does not recommend the inclusion of printed products strongly enough in the regulation’s scope.
Marco Mensink, CEPI Director General: “Not including printed products in the scope is wrong. Products printed and produced in Europe comply with EU law to be proven legal. Products printed outside Europe do not have to comply at all. This is very odd, as the risks of illegal logging are much larger in the regions exempted. The EU promotes printing outside Europe and exports jobs. We fail to understand why”.
Beatrice Klose, INTERGRAF Secretary General: “Illegal logging damages the reputation of printed products and the European Union must ensure that all products on the European market are safe from illegal logging. The only way to do this is to include printed products in the scope of the European Timber Regulation.”
The annex of the EUTR contains a list of timber and timber products under the scope of the regulation, but does not contain products under chapter 49 of the Combined Nomenclature i.e. printed products. This is inconsistent and should have been addressed more clearly in the report. CEPI and INTERGRAF urge the Commission once again to amend the annex of the EUTR and include products under the chapter 49 of the Combined Nomenclature.
In 2014 the volume of trade in printed products imports into the EU amounted to €3 billion. This greatly impacts our European industry from a competitive perspective. The non-inclusion of printed products will lead to circumvention: There is a risk that illegally-logged wood is traded to countries with less stringent rules on legality, before being traded to the EU.
Furthermore the paper and printing industries see a need for consistent enforcement among Member States and clearer guidance. However, the Commission’s vague reference to a possible expansion of the product scope is disappointing.
For more information, please contact:
• Ulrich Leberle, CEPI Raw Material Director at firstname.lastname@example.org or
• Laetitia Reynaud, Intergraf Policy Advisor on Economic and Environmental Issues at email@example.com
Note to the Editor
CEPI aisbl - The Confederation of European Paper Industries
The Confederation of European Paper Industries (CEPI) is a Brussels-based non-profit organisation regrouping the European pulp and paper industry and championing industry’s achievements and the benefits of its products. Through its 18 member countries (17 European Union members plus Norway) CEPI represents some 505 pulp, paper and board producing companies across Europe, ranging from small and medium sized companies to multi-nationals, and 920 paper mills. Together they represent 23% of world production. More at www.cepi.org
Intergraf represents 22 national printing federations in 20 countries in Europe. Intergraf's main task is to promote and protect the interests of the printing and related industries, working with the European Institutions, and to enhance the sector's competitiveness through lobbying, informing and networking. More at www.intergraf.eu
Contribution by CEPI to the review of the EU Timber Regulation (995/2010/EC)
In the ongoing review of the EU Timber Regulation, the European Commission should
• Include printed products in the scope of the regulation
• Strengthen the role of forest certification schemes in the risk assessment
• Coordinate consistent enforcement among Member States
• Align with other world regions with legislation on timber legality
Illegal logging has negative effects on the populations depending on forests and the timber and timber products they sell to sustain their livelyhoods. Illegal logging is a driver of climate change and deforestation. Illegal logging also tarnishes the image of companies sourcing timber responsibly. Cheap imports of illegal timber and timber products distort competition at a global level. CEPI has welcomed proportionate measures against the illegal logging and trade of timber and welcomed the EU Timber Regulation introduced in 2010. CEPI believes similar legislation and responsible sourcing requirements should be applied to all raw materials, not only to wood and wood based products.
European paper Industry and timber legality
The European paper industry has a longstanding commitment to sourcing legal and sustainable timber. In 2005, CEPI introduced a Code of Conduct on Legal Logging, which included six principles to follow in wood purchasing to ensure only legal timber is procured. But to go beyond legality and to support sustainable forest management and demonstrate the responsible sourcing of raw materials from them, European Paper Industry has put in place instruments to secure wood is not only sourced from legal origin, but from sustainably managed sources. European Paper industry is strongly involved in third party verified certification. In 2012, 64,6% of wood chips and sawmilling by-products delivered to European mills were forest management certified. 74,7% of pulp delivered to paper and board mills in Europe were forest management certified.
CEPI recommendations for the review of the EU Timber Regulation
The EUTR is applicable since March 2013. In the ongoing review of the EUTR, the European Commission should make use of the experience gained to turn it more effective in combating illegal logging. The EU Timber Regulation should continue addressing timber legality and not be expanded to other forest related issues. However, CEPI has identified the following main issues to be tackled in the review:
1. Extend the scope
The annex of the EUTR contains a list of Timber and Timber products under the scope of the regulation, but does not contain products under chapter 49 of the Combined Nomenclature. This is inconsistent and needs to be addressed. In 2014 the volume of trade in printed products imports into the EU amounted to € 3 billion. CEPI believes that the non-inclusion of printed products can lead to circumvention: There is a risk that illegally logged wood, instead of being traded to the EU in the form of wood, pulp or paper, is traded to countries with less stringent rules on legality before being traded to the EU in the form of printed products. Due to this risk of circumvention, the problem the EUTR is trying to address may remain in the countries of origin, while manufacturing jobs are delocalised from the EU to countries with less stringent rules on timber legality.
- CEPI urges the Commission to amend the annex of the EUTR and include products under the chapter 49 of the Combined Nomenclature.
2. Clarify and strengthen the role of certification in the due diligence system
Article 6b of the EUTR stipulates that operators may only assess the first of five criteria in the risk assessment part of their due diligence system: assurance of compliance with applicable legislation. CEPI believes that the forest certification schemes offer the appropriate tools to address also the remaining risk assessment criteria of article 6b. These are prevalence of illegal harvesting of specific tree species, prevalence of illegal harvesting or practices in the country of harvest and/or sub-national region where the timber was harvested, sanctions imposed by the UN Security Council or the Council of the European Union on timber imports or exports and the complexity of the supply chain of timber and timber products.
- CEPI urges the European Commission to clarify and strengthen the role of forest certification schemes by expanding their applicability to all risk assessment criteria and assess third party certified material as negligible risk.
3. Coordinate consistent enforcement
The level of enforcement is greatly varying between Member States. While essential elements of the regulation such as the level of fines are in the Member States competence, stronger coordination between Member States is needed to avoid the risk of entry points for illegal timber and timber products. Also, Member States interprete provisions of the regulation in their enforcement. This leads to increased administrative burden for companies operating in several EU countries.
- The European Commission should coordinate more consistent enforcement of the EU Timber Regulation
4. Align internationally
Other world regions have introduced measures to curb the trade in illegally logged timber and timber products such as the US and Australia. While the legislations of these world regions address the same issue, the provisions of legislation are greatly varying. This weakens the international efforts to curb trade in illegal logging.
- To strengthen the effectiveness of these instruments in the fight against illegal logging internationally, the EU should seek alignment with these trade partners.