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The non-paper jointly drafted by the French and British government on tiered free allocation arbitrarily determines which sector has a future in Europe and which sector has a future outside Europe.
Specifically, the proposal has three major critical points:
1. It is unjustified from both an economic and a fairness perspective
The proposal pretends to adequately ensure protection against the risk of carbon leakage. However, it reduces the share of free credits to the vast majority of industrial sectors, without providing any evidence of the impact of additional costs on their competitiveness. The proposal particularly lacks of any cost comparison between a given European and a non-European sector.
The proposal reduces the amount of free credits to certain sectors, as a supposedly fair gesture towards some others who would otherwise receive too little protection. Yet, some other sectors would unjustifiably be excluded from such a “solidarity clause”. This is far from being a fair approach.
2. It penalises competitive industries investing in low-carbon technologies
Protection against the risk of carbon leakage should provide the regulatory certainty for industries in transition towards a low-carbon economy.
However the tiered approach rewards the most carbon intensive and least profitable sectors. This is intrinsic in the formula used, which rewards high carbon intensity combined with low value added (GVA).
On the contrary, the formula punishes a sector investing in carbon emission reductions by giving a lower protection against the risk of carbon leakage as a direct consequence of these investments.
3. It hampers innovation
The ETS is expected to ultimately promote the substitution of high-carbon with low-carbon production. In this respect, solutions may come from within a given sector or as a cross-fertilisation of ideas coming from other sectors. One example is the potential coming from the bioeconomy or circular economy to provide solutions to decarbonise other sectors.
However, the proposed tiered approach provides different carbon cost exposure to different sectors, with the paradox that the most carbon intensive will bear the least carbon costs. As a consequence, the investment signal from the ETS will be totally jeopardised.
Sectors which successfully invest in decarbonising their processes are systematically at risk of being pushed outside the EU.
Alternatives to the tiered approach
Discussions on tiered free allocation are triggered by the need to avoid the application of the Cross-Sectoral Correction Factor (CSCF). The timing and magnitude of the CSCF are far from being certain, as it depends on a combination of factors (production levels, changes in the market, technological developments, innovation, development of international carbon markets, etc.).
Rather than picking one scenario and fixing the rules for the next 15 years accordingly, the EU should:
1. Define a regulatory framework that stimulates and rewards investments in low-carbon technologies, as a way to reduce the demand for free credits;
2. Support programmes to accelerate the market-readiness of breakthrough technologies for industrial installations;
3. Secure a sufficient amount of free credits to allow for low-carbon economic growth in energy intensive industries exposed to international competition;
4. Set rules to predictably assess potential shortages in the supply of free credits and, when the case, explore all possible options to preserve industrial competitiveness.
For more information, please contact Nicola Rega at firstname.lastname@example.org mobile: +32(0)485403412.
The Dutch Presidency of the Council of the European Union organised a field trip for Industry and Environment Council working group members to illustrate the Circular Economy, one of the Presidency’s top priorities. The Presidency chose the state-of the-art paper mill in Roermond, The Netherlands. The mill is operated by Smurfit Kappa and its raw material is 100% paper for recycling, making it the perfect example of circularity. The visit was co-organised with the Confederation of European Paper Industries (CEPI) and the Royal Dutch papermaking association VNP.
“We are very happy to be given the opportunity to demonstrate that paper is at the heart of the Circular Economy”, said CEPI Acting Director General Jori Ringman. “The paper industry champions many aspects of circularity from reusing water to industrial symbiosis, from including the whole value chain in advancing circularity to working towards clean and safe cycles. Whilst the recycling starts already at homes and offices and is a chain of many important actors, it is vital that EU legislation acknowledges the final recycling where the material is physically transformed to start a new cycle; this is what the participants saw today in practice”, he added.
Europe is a world champion when it comes to paper recycling, achieving a 72% recycling rate in 2014.
The Roermond mill is a great example of Circular Economy. It processes 600 000 tonnes or one million bales of waste paper into new paper rolls every year, which is more than 25% of the annual collected amount of paper for recycling. “The companies in our sector produce products in a very high tech and sustainable way, products that play a very important role in everyday life. The participants of the field trip could closely experience that in Roermond,” said Gerrit Jan Koopman, Director of Royal VNP.
For more information, please contact:
Jori Ringman, CEPI Acting Director General at email@example.com, mobile: +32 478 25 50 70
Rutger van Dijk, VNP Communication and PR at firstname.lastname@example.org, mobile +31 6 45 79 02 60
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. For further information see http://www.cepi.org/
Royal VNP – Koninklijke Vereniging van Nederlandse Papier- en Kartonfabrieken
The Dutch paper and board association represents the interests of the Dutch paper and board industry with an active lobbying focused on solutions, on current policies, legislation and sustainability. They provide services to their members and initiate policy-supporting studies. In this way they help to connect the companies’ needs and developments in society (customers, employees, government, NGOs and society in general). For further information see www.vnp.nl.
"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 email@example.com, www.cepf-eu.org
COPA-COGECA – European Farmers European Agri-Cooperatives
Contact: Oana Neagu firstname.lastname@example.org, www.copa-cogeca.be
CEI-BOIS – Confederation of European Woodworking Industries
Contact: Ward Vervoort email@example.com, www.cei-bois.org
CEPI – Confederation of European Pulp and Paper Industries
Contact: Annie Xystouris firstname.lastname@example.org, www.cepi.org
ELO – European Landowners’ Organization
Contact: Ana Rocha email@example.com, www.europeanlandowners.org
EUSTAFOR – European State Forest Association
Contact: Gerd Thomsen firstname.lastname@example.org, www.eustafor.eu
FECOF – European Federation of Municipal Woodowners
UEF – Union of European Foresters
Contact: Michael Diemer email@example.com, www.european-foresters.org
USSE - Union des sylviculteurs du Sud de l'Europe
Contact: Isala Berria firstname.lastname@example.org, 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.
The European paper industry was invited to collaborate with the World Economic Forum (the Forum), the Ellen MacArthur Foundation and the McKinsey Center for Business and Environment on Circular Economy to produce a white paper with guidelines on design and management for circularity. The new publication provides essential guidance to all actors in the supply chain through simple ecodesign rules for paper products, without limiting innovation and the introduction of new techniques. This is a product of the three pilots under Project MainStream, launched during the 2014 summit in Davos.
Although highly recyclable, paper is usually converted by industries that add chemicals to it through printing inks and other auxiliary materials. This can lead to problems in subsequent circular chains, as these chemicals cannot easily be removed from the paper before re-entering the mill. Furthermore, the already highly-optimised recycling process cannot follow the speed of the evolution of inks and toners.
The publication summarises the key choices to be made by direct (printers, papermakers, collectors) and indirect (such as local authorities, ink producers, equipment manufacturers) stakeholders. More specifically, it identifies the choices that can influence businesses ordering a fibre-based product - printed paper, packaging or other.
Read the press release on the topic.