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Billerud AB

Billerud offers innovative packaging solutions and sustainable packaging materials made from natural cellulose fibre.

Lobbying Activity

Meeting with Raffaele Fitto (Executive Vice-President) and Swedish Forest Industries Federation and

22 May 2025 · Round table discussion concerning bio economy and its implications on regional policy

Meeting with Karin Karlsbro (Member of the European Parliament) and Swedish Forest Industries Federation

21 May 2025 · EU:s klimatlagstiftning

Meeting with Emma Wiesner (Member of the European Parliament) and Swedish Forest Industries Federation

29 Apr 2025 · EUs handel med utsläppsrätter

Meeting with Taru Haapaniemi (Cabinet of Commissioner Christophe Hansen) and Swedish Forest Industries Federation

29 Apr 2025 · The upcoming bioeconomy strategy and the so-called substitution effect in relation to it

Response to Climate change mitigation and adaptation taxonomy

18 Dec 2020

Properly designed, the Taxonomy is an important policy tool. The proposed delegated act (hereinafter the act) and its technical screening criteria in Annex 1 and 2 (hereinafter the criteria) provide, however, an impediment to the Taxonomy achieving its aims and risks slowing down the societal transition. B By its broad scope and high complexity, the act goes way beyond the ordinary scope of a delegated act. Thereby, the act will be a strong formative element in the future European industry policy. The degree of complexity makes it very hard for an operator to interpret the proposed criteria, which in turn will make implementation difficult and risks resulting in legal uncertainty. As currently drafted, the act would exclude existing sustainable forest management from the Taxonomy – which is equivalent to neglecting a positive carbon dioxide (CO2) abatement from European forests and forest-based products of more than 800 million tons per annum. Of that, the contribution from the Swedish forest-based sector is above 90 million ton per annum. Biomass from existing sustainable forest management offers products and solutions that help other industries make the transition to a carbon-neutral economy. By excluding existing sustainable forest management, the forest-based industries’ contribution to several European Green Deal objectives will be hampered. This means that the EU is less likely to meet objectives such as greening our building; a clean and circular economy; clean, affordable and secure energy; increased climate ambitions; preserving and restoring ecosystems and biodiversity; clean and smart mobility and green growth. By only concentrating on NACE codes 02.10 (Silviculture and other forestry activities) and 02.30 (Gathering of wild growing non-wood products), the act does not encompass the full width of existing sustainable forest management. BillerudKorsnäs asks for the act to be revised in a transparent and inclusive way. The following concerns need to be addressed: Throughout the act: • The complexity of the criteria should be considerably reduced. In the act’s sections referring to forest activities: • The reference to “improved forest management” should be replaced with “existing forest management”. • NACE codes 02.10-02.40 should be encompassed. • The criteria outlined by the Technical Expert Group (TEG) in its final report should be reinserted after the following adjustments: o It should be clarified that national or sub-national/regional level is adequate for demonstrating forest carbon sink development. o It should be defined as voluntary to use a forest management plan (or equivalent instruments) for demonstration of permanence and steady progress. • Any references to close-to-nature management should be removed, as this concept lacks a scientifically based and broadly agreed definition. • Any reference to “additionality” should be removed, as this excludes existing sustainable forest management from being sustainable. In the act’s sections referring to energy: • Forest-based bioenergy should be classified as other renewable energy sources and not as a transitional activity
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