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Confederation of European Paper Industries

Cepi

Cepi is the European association representing the paper industry and wood-based fiber solution providers.

Lobbying Activity

Meeting with Kurt Vandenberghe (Director-General Climate Action)

14 Jan 2026 · Pulp and paper industry, forestry, climate

Meeting with Sabine Pelsser (Head of Unit Health and Food Safety)

12 Nov 2025 · Discussion on the topic of FCM regulation revision

Meeting with Stella Kaltsouni (Cabinet of Commissioner Dan Jørgensen) and Swedish Forest Industries Federation and

6 Nov 2025 · Decarbonisation and maintaining global competitiveness

Meeting with Astrid Van Mierlo (Head of Unit Taxation and Customs Union) and European Panel Federation

6 Nov 2025 · Meeting with EPF and CEPI

European Paper Industry Calls for Affordable Electricity to Enable Decarbonisation

9 Oct 2025
Topic — EU Action Plan to accelerate electrification and shift energy demand from fossil fuels to clean electricity.
Message — The industry requests lower electricity prices for industrial consumers, expanded grid capacity with faster permitting, and compensation for demand-side flexibility. They argue affordable fossil-free electricity is essential for viable electrification investments.123
Why — Lower electricity costs would improve returns on their 5 billion annual clean energy investments.45
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Paper Industry Warns Nature Credits Could Threaten Wood Supply

26 Sept 2025
Topic — EU framework to develop high-integrity nature credits for ecosystem restoration financing.
Message — The industry requests that nature credits remain voluntary, focus on results rather than prescriptive methods, and avoid taking land out of production. They emphasize the need to prevent wood supply shortages and ensure all sustainable forest management practices qualify for credits.123
Why — This would protect their access to European wood supply and prevent production restrictions.456
Impact — Environmental groups lose stronger biodiversity protections as credits enable continued harmful practices elsewhere.78
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Meeting with Alexandre Paquot (Director Climate Action)

26 Sept 2025 · Role of the pulp and paper industry in the green transition, bioeconomy, Innovation Fund calls and applications

Meeting with Aleksandra Baranska (Cabinet of Executive Vice-President Teresa Ribera Rodríguez), Terhi Lehtonen (Cabinet of Executive Vice-President Teresa Ribera Rodríguez)

25 Sept 2025 · ETS, indirect cost compensation

Cepi urges simplified rules and longer timelines for BioCCS

22 Sept 2025
Topic — The EU is establishing certification methodologies for permanent carbon removal activities like BioCCS.
Message — Cepi requests aligning biomass sustainability criteria with existing rules to avoid redundant reporting obligations. They propose extending activity periods to match a facility's technical lifespan for better investment certainty. Additionally, they call for simplified emissions calculations by excluding complex parameters like construction costs.123
Why — Longer certification periods would reduce administrative burdens and provide long-term investment security.45
Impact — Carbon farming projects would lose financial support if the voluntary compensation requirements are deleted.67
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European Paper Industry Urges Bioeconomy Support in 2040 Target

15 Sept 2025
Topic — The initiative will amend the European Climate Law to include the 2040 climate target.
Message — Cepi requests the integration of the bioeconomy into core EU policies and the maintenance of zero-rated biogenic carbon emissions. They demand a predictable framework that ensures access to affordable fossil-free energy to protect global competitiveness.123
Why — This would secure a stable investment environment and prevent the loss of industrial competitiveness during the transition.45
Impact — Other industrial sectors could lose the ability to use natural carbon sinks to offset their own emissions.67
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Paper Industry Urges Full Electricity Cost Compensation Amid Decarbonisation Push

5 Sept 2025
Topic — Update of EU guidelines on compensating industries for higher electricity costs from carbon pricing.
Message — The paper industry requests maintaining full sector eligibility for indirect cost compensation, discontinuing electricity efficiency benchmarks to allow full compensation for carbon costs, and removing additional conditionalities like mandatory decarbonisation investments.123
Why — This would reduce their electricity costs while allowing greater flexibility in decarbonisation investments.45
Impact — Environmental groups lose stronger incentives for energy efficiency improvements in heavy industry.6
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Paper Industry Urges Active Forest Management for Climate Resilience

4 Sept 2025
Topic — This consultation addresses an integrated framework for European climate resilience and risk management.
Message — Cepi calls for EU policies to encourage proactive management instead of limiting forest activities. They suggest using genetically improved trees and adjusting rules in protected conservation areas.123
Why — Loosening restrictions secures the industry’s long-term supply of renewable wood-based resources.4
Impact — Environmental protections in Natura 2000 sites could be weakened by increased human intervention.5
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European paper industry demands paper manuals remain in products

1 Sept 2025
Topic — The EU consultation explores allowing manufacturers to provide digital-only instructions for consumer products.
Message — The organization opposes digital-only instructions for consumer products. They argue that requiring shoppers to request paper copies creates unnecessary barriers and safety risks for those lacking digital skills.12
Why — Retaining printed manuals protects the core business interests of European paper mills.34
Impact — Manufacturers lose the cost-reduction and simplification benefits provided by removing paper instructions.5
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European paper industry urges faster grid connections for decarbonisation

31 Jul 2025
Topic — The EU is proposing measures to upgrade, digitalise and expand energy grid infrastructure.
Message — Cepi requests prioritized grid access and streamlined permitting for industrial decarbonisation projects. They also seek financial support for CO2 transport and incentives for voluntary demand-side flexibility.12
Why — Faster connections and easier grid access would remove barriers to electrification investments.3
Impact — Residential users and electric vehicle charging might face deprioritisation under differentiated planning.45
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Meeting with Alexandre Paquot (Director Climate Action)

8 Jul 2025 · Industrial decarbonisation of the pulp and paper industry

Meeting with Célia Dejond (Cabinet of Commissioner Wopke Hoekstra), Matthieu Moulonguet (Cabinet of Commissioner Wopke Hoekstra)

8 Jul 2025 · Carbon Border Adjustment Mechanism and Emissions Trading System

European paper industry urges ETS reforms to protect competitiveness and enable decarbonisation

7 Jul 2025
Topic — Review of EU Emissions Trading System rules affecting industrial installations, aviation, and maritime sectors post-2030.
Message — The paper industry requests full, unconditional free allocation without benchmark freezes or biomass penalties, removal of the Market Stability Reserve, and expanded innovation funding for all decarbonisation pathways including marginal improvements.12345
Why — This would reduce their compliance costs while maintaining carbon leakage protection and investment certainty.67
Impact — Climate advocates lose stronger emissions reduction pressure as the industry seeks to slow benchmark tightening and maintain free allowances.89
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Cepi urges Biotech Act to include forest-based industries

11 Jun 2025
Topic — The European Commission is proposing legislation to accelerate the transition of biotechnology products.
Message — Cepi urges the Commission to broaden the Biotech Act's scope to include high-potential sectors like the forest-based bioeconomy. They request that biorefineries and industrial biotechnology applications be fully integrated into the EU's regulatory and innovation frameworks.12
Why — Inclusion would provide the regulatory clarity and innovation incentives necessary for their biomanufacturing investments.3
Impact — Fossil-based producers may lose out as renewable bio-based alternatives replace their materials in the market.4
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Meeting with Elisa Roller (Director Secretariat-General)

11 Jun 2025 · The new Bioeconomy Strategy and related initiatives

Meeting with Aurel Ciobanu-Dordea (Director Environment)

5 Jun 2025 · Exchange of views on Bioeconomy Strategy

Meeting with Aurel Ciobanu-Dordea (Director Environment) and FoodDrinkEurope and

22 May 2025 · Discuss with interested stakeholders the practical aspects and challenges of ensuring compliance with Art.5(5) of the PPWR (concerning PFAS limits in food-contact packaging)

Meeting with Andrea Wechsler (Member of the European Parliament)

15 May 2025 · EU Energy and industry policy

Paper industry welcomes EUDR technical adjustments with language refinements

13 May 2025
Topic — Amendment of product scope under EU Deforestation Regulation.
Message — The organization requests alignment with packaging regulation language for excluded products and inclusion of labels in accessory materials exemptions. They also urge consideration of bamboo's inclusion to prevent forest conversion.123
Why — This would provide clearer legal certainty for packaging exemptions and reduce compliance complexity.45
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Meeting with Koen Van De Casteele (Director Competition)

13 May 2025 · Exchange of views on the new State aid rules being developed to accompany the Clean Industrial Deal.

European paper industry urges recognition for bio-based products

12 May 2025
Topic — A consultation on creating a circular, climate-neutral European bioeconomy strategy.
Message — Cepi requests that the EU recognize renewability and sustainably sourced renewable content as circular input in product legislation. They call for a Strategic Dialogue on the Bioeconomy to integrate bio-based solutions into all policy areas. They also urge the phasing out of direct financial subsidies for burning wood.123
Why — This would equalize virgin and recycled materials, creating new market demand for their products.45
Impact — The bioenergy sector loses financial support as the industry calls for ending wood-burning subsidies.6
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Meeting with Barbara Bonvissuto (Director Internal Market, Industry, Entrepreneurship and SMEs)

12 May 2025 · Exchange of views on the forest-based bioeconomy

Meeting with Heiko Kunst (Head of Unit Climate Action), Mette Koefoed Quinn (Head of Unit Climate Action) and

15 Apr 2025 · Exchange of views on the revision of the EU Emission Trading System and challenges faced by ceramic, glass and pulp and paper sectors.

Meeting with Kerstin Jorna (Director-General Internal Market, Industry, Entrepreneurship and SMEs) and

10 Apr 2025 · Impact of US tariffs

Meeting with Stéphane Séjourné (Executive Vice-President) and

10 Apr 2025 · Impact of US tariffs

Cepi urges EU for flexible, locally tailored water rules

3 Mar 2025
Topic — The EU is developing a strategy to ensure water security and resilience across member states.
Message — The industry requests that the EU avoids uniform targets and recognizes regional differences. They seek flexible waste water rules based on total pollutants rather than concentration. Finally, policy discussions must distinguish between water use and actual industrial water consumption.123
Why — This approach prevents new regulatory barriers and protects the competitiveness of efficient paper mills.45
Impact — Environmental advocates lose the protection of uniform, mandatory water extraction limits across the Union.6
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Meeting with Johannes Ten Broeke (Cabinet of Commissioner Wopke Hoekstra)

14 Feb 2025 · Exchange of views on the upcoming Clean Industrial Deal

Meeting with Giorgio Gori (Member of the European Parliament, Rapporteur) and The European Steel Association and

5 Feb 2025 · Exchange of views on resolution on energy intensive industries with the Alliance of energy-intensive industries

Meeting with Stefan Köhler (Member of the European Parliament, Shadow rapporteur) and WWF European Policy Programme

30 Jan 2025 · Politischer Austausch

Meeting with Niels Flemming Hansen (Member of the European Parliament)

13 Jan 2025 · Decarbonization of Industry

Paper Industry Opposes Stricter Carbon Accounting for Captured CO2

29 Jul 2024
Topic — EU regulation updating monitoring and reporting of greenhouse gas emissions under emissions trading scheme.
Message — The organization opposes new rules that would stop deducting chemically bound CO2 in calcium carbonate from emissions calculations. They argue this creates double-counting risks when paper is later incinerated, and penalizes investments in carbon capture.123
Why — This would preserve their ability to deduct captured carbon from emissions calculations, protecting previous investments in CO2 capture infrastructure.45
Impact — Climate accounting accuracy suffers as actual carbon release during incineration may not be properly tracked.6
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Meeting with Tom Berendsen (Member of the European Parliament) and European Chemical Industry Council and

23 Jul 2024 · Industrial policy

Meeting with Christian Ehler (Member of the European Parliament) and European Chemical Industry Council and

23 Jul 2024 · Industrial policy

Paper Industry Warns Against Penalising Carbon Capture in Production

15 Jul 2024
Topic — EU regulation on requirements for greenhouse gases permanently bound in products.
Message — Cepi requests that the delegated act should not differentiate between end applications of precipitated calcium carbonate. The current Monitoring and Reporting Regulation treats all PCC applications equally, and this approach should be maintained. Companies have invested in CO2 capture infrastructure that chemically binds carbon in PCC, preventing atmospheric release.123
Why — This would preserve their ability to deduct captured CO2 from emissions accounting and avoid being penalised for carbon capture investments.45
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Cepi Urges Rewarding Climate Benefits of Wood-Based Products

11 Jul 2024
Topic — This consultation evaluates the European regulation regarding carbon emissions and removals from land use.
Message — Cepi argues forests should not offset emissions from other sectors to ensure all industries decarbonize. They advocate for sustainable forest management and rewarding the climate benefits of wood-based products.123
Why — This approach would protect raw material supplies and prevent regulatory limits on commercial harvesting.4
Impact — Heavy polluters lose the ability to use forest offsets to meet their decarbonization requirements.56
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Meeting with Joan Canton (Cabinet of Commissioner Thierry Breton) and European Panel Federation and

4 Jun 2024 · Discussion on implementation of the EU Deforestation regulation

Meeting with Peter Van Kemseke (Cabinet of President Ursula von der Leyen)

21 May 2024 · EU Deforestation

Response to Update of related legislation as a consequence of the new regulation on recycled plastic Food Contact Materials

15 Apr 2024

Please find Cepi's feedback to the draft amendment on Regulation (EU) No 10/2011 in the attached document.
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Cepi urges flexibility in new EU rules on bisphenol monitoring

7 Mar 2024
Topic — This consultation addresses proposed restrictions on bisphenols in materials intended for food contact.
Message — Cepi requests that monitoring focus only on materials used with moist or fatty foods. They advocate for flexibility in choosing monitoring methods and a transition period before new obligations begin.123
Why — This would decrease operational costs and avoid redundant testing of recycled paper products.45
Impact — Consumers may face prolonged exposure to bisphenols if monitoring and compliance documents are delayed.6
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Meeting with Laura Ballarín Cereza (Member of the European Parliament)

20 Feb 2024 · Industrial policy

Meeting with Pernille Weiss-Ehler (Member of the European Parliament, Shadow rapporteur)

14 Feb 2024 · Directive on substantiation and communication of explicit environmental claims (Green Claims Directive)

European Paper Industry urges focus on national forest inventories

5 Feb 2024
Topic — A proposal for an EU-wide framework to monitor and plan forest health.
Message — Use existing National Forest Inventories as the primary monitoring tool. Validate satellite imagery with ground data before public release to avoid misinterpretation. Oppose small-scale geo-referencing to protect forest owner privacy.123
Why — This prevents misleading data from triggering restrictive policies and maintains industry operational privacy.45
Impact — Transparency groups lose access to immediate, granular data about specific forest sites.67
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Meeting with Maroš Šefčovič (Executive Vice-President) and

2 Feb 2024 · Roundtable with associations of industrial users

Meeting with Dino Toljan (Cabinet of Vice-President Maroš Šefčovič)

23 Jan 2024 · 2040 targets and the role of the PPI in the decarbonization

Meeting with Nils Torvalds (Member of the European Parliament, Shadow rapporteur for opinion)

22 Jan 2024 · PPWR

Paper Industry Warns EU Carbon Market Changes Create Uncertainty

20 Dec 2023
Topic — EU updating free allocation rules for emissions allowances under revised ETS.
Message — The organization requests flexibility in climate-neutrality plan deadlines and investment calculations. They want clear thresholds for small installations and existing paper benchmarks preserved. They emphasize the need for consistent implementation to avoid legal uncertainty.123
Why — This would provide more time for compliance and reduce disproportionate investment costs.45
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Meeting with Kurt Vandenberghe (Director-General Climate Action)

27 Nov 2023 · How to stop rust belt spreading in Europe?

Meeting with Peter Jahr (Member of the European Parliament)

7 Nov 2023 · Green Claims Richtlinie

Meeting with Pernille Weiss-Ehler (Member of the European Parliament, Shadow rapporteur)

26 Oct 2023 · Directive on substantiation and communication of explicit environmental claims (Green Claims Directive)

Response to Waste Framework review to reduce waste and the environmental impact of waste management

25 Oct 2023

Cepi welcomes the revision of food waste and textile aspects of the EU Waste Framework Directive. In this response, we will focus on these aspects. However, Cepi deplores the limited scope of the revision and would like to comment on crucial issues such as the increased efficiency of waste management systems, higher quality secondary raw materials through separate collection and high-quality recycling that have not been addressed. Therefore, Cepi also raises its expectations on a future revision in this response. We welcome the Commissions intention to prevent the generation of food waste both in primary production, in retail and other distribution of food, such as in food services and to reduce the environmental and climate impacts associated with textiles by improving their waste management. With our renewable and recyclable products and experience we are key contributors in both objectives. Paper-based packaging helps prevent food waste by prolonging the shelf life and preserving food throughout the value chain. The paper and pulp industry produces wood-based cellulose fibres that are 100% renewable, recyclable and biodegradable. These fibres can be used in textile applications that contribute to more sustainable textiles and more recycled content in textiles. 1. Paper packaging has a role in food waste prevention: To prevent food waste the Commission proposes different measures, both quantitative and qualitative targets set under article 9a. We fully support those targets and we aspire to contribute in the prevention of food waste with our products. Nevertheless, we see that the imperative role of packaging in preventing food waste is not recognised in the proposed legal text. Packaging has an essential function in protecting and preserving food throughout the value chain, extending the food lifespan , and preventing food waste which contributes to resource efficiency . It also safeguards consumer safety and provides crucial nutritional information, telling us how to safely store and prepare the food it contains. Paper-based products, particularly, contribute to expanding the shelf-life of products, especially in the case of prepared food. Research conducted by the University of Bologna revealed that corrugated packaging could extend the shelf life of fresh food products by up to three days compared to reusable plastic crates and can significantly reduce contamination from pathogenic and spoilage microorganisms . In addition, packaging maintains the quality of sensitive products, such as milk and juices, which provide consumers with essential vitamins and nutrients. These can be lost if products are not properly treated or stored. This can be the case with the proposed reuse targets for these products as provided for in Article 26 (6), which could potentially lead to additional food waste. The use of packaging and innovation in packaging has been identified as one of the recommendations of the European Citizens Panel on Food Waste to speed up food waste reduction in the EU. For the above reasons we think that an additional provision should be added under paragraph 1 of article 9a; supporting innovation in packaging, taking into account the important role of food packaging in the food value chain to prevent the generation of food waste and ensure food safety. 2. Forest fibres can significantly reduce the environmental impact of textiles: As highlighted in the Communication an EU strategy for sustainable textile by the European Commission, the textile industry is a resource-intensive sector. Textile consumption is the fourth highest pressure category in the EU in terms of use of primary raw materials and water, and it is also its fifth source of greenhouse gas emissions. As a bio-product, forest fibres used in textiles, such as viscose or lyocell fibres, have the potential to avoid the significant environmental impacts. For more information on our position please see the attached document.
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Meeting with Pernille Weiss-Ehler (Member of the European Parliament, Shadow rapporteur) and Unilever and Lineage Dutch Coöperatief U.A.

27 Sept 2023 · Directive on substantiation and communication of explicit environmental claims (Green Claims Directive)

Meeting with Petros Kokkalis (Member of the European Parliament, Shadow rapporteur)

25 Sept 2023 · Green Claims

Meeting with Cyrus Engerer (Member of the European Parliament, Rapporteur)

31 Aug 2023 · Green Claims Directive

Paper Industry Urges Flexibility in EU Climate-Neutrality Plans

30 Aug 2023
Topic — EU rules for climate-neutrality plans under revised Emissions Trading System directive.
Message — The organization requests flexibility to concentrate investments on some installations rather than requiring all sites reach climate neutrality. They want evaluation shifted from installation-level to sub-installation level, and targets tied to measures and investments rather than emission reductions.123
Why — This would prevent penalties for efficient sub-installations when other parts underperform.4
Impact — Environmental advocates lose stricter requirements ensuring all industrial sites achieve climate neutrality.56
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European paper industry calls for realistic green claim rules

19 Jul 2023
Topic — A proposal requiring companies to verify environmental claims using standardized footprint calculation methods.
Message — Cepi urges alignment with existing EU laws and the recognition of established forest certification labels. They also request updates to calculation methods to better reflect sustainable forestry and carbon storage.12
Why — This would reduce administrative burdens and ensure environmental impacts are not unfairly calculated.34
Impact — Foreign exporters would lose their competitive advantage unless they meet the same strict verification standards.5
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Meeting with Francisco Guerreiro (Member of the European Parliament)

12 Jul 2023 · Green Claims Directive

Paper Industry Warns Against Unintended Kaolin CBAM Burden

11 Jul 2023
Topic — Carbon border adjustment mechanism rules for reporting during transitional period.
Message — The organization requests special attention to unintended impacts of including precursor products like kaolin on industries outside CBAM-covered sectors. Any future CBAM expansion should require thorough impact assessment and close consultation with affected sectors through ordinary legislative procedure.12
Why — This would protect them from administrative burden and charges for imported materials.34
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Meeting with Jorge Pinto Antunes (Cabinet of Commissioner Janusz Wojciechowski)

31 May 2023 · To exchange views on their policy recommendations and how they address the EU’s current sustainability challenges, while unlocking future opportunities to drive European competitiveness and resiliency.

Meeting with Jordi Solé (Member of the European Parliament)

23 May 2023 · Cross-sectoral industry coalition and the EU’s current sustainability challenges

Meeting with Barbara Glowacka (Cabinet of Commissioner Kadri Simson)

26 Apr 2023 · To present the recent investments in energy efficiency improvements and switching to renewable energy.

Meeting with Aleksandra Tomczak (Cabinet of Executive Vice-President Frans Timmermans), Antoine Colombani (Cabinet of Executive Vice-President Frans Timmermans), Helena Braun (Cabinet of Executive Vice-President Frans Timmermans), Riccardo Maggi (Cabinet of Executive Vice-President Frans Timmermans), Stefanie Hiesinger (Cabinet of Executive Vice-President Frans Timmermans)

26 Apr 2023 · Reinvest 2050

Paper industry urges evidence-based approach to EU packaging regulation

21 Apr 2023
Topic — EU regulation on packaging waste, recycling requirements, and reuse targets.
Message — The industry requests involvement in drafting Design for Recycling Guidelines through CEN, a mandatory 90% collection target for all packaging by 2030, and evidence-based policy decisions on reuse targets that consider lifecycle impacts and technological implications.123
Why — This would protect their role in packaging standards and avoid penalties for collection failures beyond their control.45
Impact — Mandatory reuse targets could harm parts of the fibre-based packaging industry and reduce renewable packaging use.67
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European Paper Industry Demands Recognition for Biogenic Carbon Storage

20 Mar 2023
Topic — The EU is developing a regulatory framework for certifying and monitoring sustainable carbon removals.
Message — The framework should "be explicit about different types of sustainable carbon sources" and define "renewable carbon." They want the "upcoming certification" to "recognise the substitution effects" of "renewable, bio-based products." They recommend "aligning the upcoming certification with existing EU methodologies" for assessing climate benefits.123
Why — This would create a market for renewable carbon, increasing the competitiveness of wood products.45
Impact — Fossil-intensive industries lose market dominance as policies incentivize wood-based materials as climate-friendly alternatives.6
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Meeting with Kurt Vandenberghe (Director-General Climate Action)

10 Mar 2023 · Green Deal Industrial Plan: integration between energy, climate, raw materials, technology, skills, funding, and trade will be crucial for moving to net zero.

Meeting with Luisa Regimenti (Member of the European Parliament, Shadow rapporteur) and Carlsberg Breweries A/S and JDE Peet's

8 Mar 2023 · PPWR

Meeting with Mauri Pekkarinen (Member of the European Parliament) and Finnish Forest Industries Federation (Metsäteollisuus ry)

8 Mar 2023 · Breakfast meeting on ESPR

Meeting with Katherine Power (Cabinet of Commissioner Mairead Mcguinness) and Finnish Forest Industries Federation (Metsäteollisuus ry)

8 Feb 2023 · Taxonomy and Forestry

Response to Review of cogeneration reference values

30 Dec 2022

Cepi, the Confederation of European Paper Industries, welcomes the opportunity to comment on the draft Delegated Regulation updating the Harmonised Reference Values. Cepi supports the proposed amendments for the natural gas and biomass values. However, the Commission should consider clarifying the grandfathering clause for existing power plants in line with the Energy Efficiency Directive (EED), Annex II, point f(3). Please find attached the detailed response to the consultation.
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Meeting with Anne Sander (Member of the European Parliament, Rapporteur for opinion)

7 Dec 2022 · Nature Restoration Law

Meeting with Caroline Boeshertz (Cabinet of Executive Vice-President Valdis Dombrovskis)

22 Nov 2022 · Draft proposal of a Regulation on Packaging and Packaging Waste (PPWR)

Meeting with Ralf Kuhne (Cabinet of Commissioner Stella Kyriakides)

18 Nov 2022 · VTC meeting on food packaging

Meeting with Helena Braun (Cabinet of Executive Vice-President Frans Timmermans) and logos public affairs and

26 Oct 2022 · Circular economy and the revision of the EU packaging rules

Paper Industry Warns Nature Law Threatens Raw Material Supply

22 Aug 2022
Topic — EU regulation proposing legally binding nature restoration targets for biodiversity protection.
Message — The organization requests proper impact assessment of effects on forest-based industrial ecosystem and raw material availability. They emphasize sustainable forest management should balance biodiversity with provision of renewable materials and energy. They question practical implementation requirements for proving continuous improvement in forest ecosystems.123
Why — This would preserve their access to European wood supplies for paper production.45
Impact — Biodiversity protection loses if industrial forestry interests override restoration objectives.6
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Response to Early Warning Report on Waste

30 Jul 2022

The Confederation of European Paper Industries-Cepi welcomes the Commission’s intention to assess Member States’ progress towards reaching the recycling targets of municipal waste and packaging waste, and the 2035 landfill target. We endorse the policy maker’s intention to optimise waste management systems to support higher recycling rates, cleaner secondary raw materials (SRM), and to ensure high-quality recycling under the revision of the Waste Framework Directive. We would like to take this opportunity to reiterate the importance of well-functioning waste management systems and implementing separate collection of municipal waste in reaching our recycling targets. Harmonised separate collection is a pre-condition to reaching our recycling targets: For the paper and board industry, the biggest barrier in further increasing recycling rates and recyclability potential is the lack of implementation of separate collection at source. For this reason, we support the Commission’s intention to improve the separate collection of waste by clarifying and/or restricting the scope of derogations provided for in Article 10(3) (WFD). It is critical to ensure that all recyclables end up in a recycling operation and stay in the recycling loop. Separate collection of paper ensures that fibres are not lost and return in the paper loop, it enhances their quality by avoiding soiling of material from the source to the sorting line, ensures that materials end up in the appropriate recycling operation and this increases the valorisation of SRM which in turn can support more efficient EPR schemes. Furthermore, harmonisation of separate collection of municipal waste should be implemented to overcome the discrepancies found at the national and/or regional level and to foster a reliable flow of SRM both in terms of quality and quantity. In terms of quality, collection of all recyclables separately from each other is preferable. However, if a priority material needs to be selected, the total amount of the recyclable and the possible detrimental effects of commingling on each of recyclables need to be considered. Paper and board ranks highest in terms of priority material fraction for separate collection, as it represents the biggest share among recyclables. In addition many of the contaminants which inevitably come together in commingled collection would by large not interfere with the quality of other recyclables, but could possibly cause irreversible quality losses for the paper and board fraction and problems with the respective recycling processes, which would mean losing SRM that could have been recycled. Cepi developed a guidance on how to implement separate collection of paper and board and vision on paper collection and sorting in Europe (attached). For paper and board separate collection does not only mean separate from the residual waste, but also from other recyclables, such as plastic, metal or glass. The guidance includes a detailed table (2019) indicating how different categories of paper and board should be collected and sorted to reach the suitable recycling process. Nevertheless, the fast-paced industrial innovation in food service packaging (such as used coffee cups) can now support the collection of such packaging in a way that slightly diverges from the Cepi guidance. The Cepi guidance does not challenge existing well-functioning systems, but rather advises in situations where certain fractions of paper packaging are not yet separately collected. Last, endorsing the Commission’s intention to ensure high-quality recycling (not imposing restrictions to the use SRM and being consistent with food and health regulations), as referenced in the Commission Call for Evidence the paper and board industry have developed the 4EG Circularity by Design Guidelines (https://4evergreenforum.eu/wp-content/uploads/4evergreen-Circularity-by-Design-2.pdf) to support the value chain in the design of paper and board packaging that is recyclable.
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Meeting with Alina-Stefania Ujupan (Cabinet of Executive Vice-President Margrethe Vestager)

15 Jul 2022 · Deforestation Regulation and other forestry related issues.

Meeting with Michal Wiezik (Member of the European Parliament, Shadow rapporteur)

11 Jul 2022 · Industrial Emissions Directive

Meeting with Gints Freimanis (Cabinet of Executive Vice-President Valdis Dombrovskis) and European Aluminium AISBL and

7 Jul 2022 · Carbon Border Adjustment Mechanism

Meeting with Helena Braun (Cabinet of Executive Vice-President Frans Timmermans) and European Confederation of Woodworking Industries and European Organisation of the Sawmill industry

24 Jun 2022 · Nature Restoration Law proposal

Meeting with Elena Montani (Cabinet of Commissioner Virginijus Sinkevičius) and European Confederation of Woodworking Industries

24 Jun 2022 · to discuss the Nature Restoration Law proposal

Cepi warns against expanding industrial emissions directive scope

21 Jun 2022
Topic — A consultation on updating EU industrial emissions rules to align with Green Deal goals.
Message — Cepi requests that policymakers preserve technology neutrality and protect plant flexibility. They argue that broadening the directive's scope to include climate change would be detrimental.12
Why — Industry avoids unnecessary administrative complexity and the costs of unfeasible emission requirements.34
Impact — Environmental groups lose the benefit of mandatory enforcement of the strictest pollution levels.5
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Paper Industry Urges Flexible Rules for Renewable Hydrogen Production

17 Jun 2022
Topic — EU methodology for calculating greenhouse gas savings from renewable and recycled fuels.
Message — Avoid strict conditionality rules that disrupt energy supply and market efficiency. Ensure a level playing field between hydrogen production and direct electrification.123
Why — Flexibility ensures stable energy supplies and lower costs for industrial hydrogen investments.4
Impact — Electricity consumers and market participants face inefficiencies and potential pricing distortions.56
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Meeting with Jorge Pinto Antunes (Cabinet of Commissioner Janusz Wojciechowski) and Swedish Forest Industries Federation and

30 May 2022 · Meeting with Fibre Packaging Europe

Meeting with Dārta Tentere (Cabinet of Commissioner Mairead Mcguinness)

6 May 2022 · Taxonomy

Meeting with Miapetra Kumpula-Natri (Member of the European Parliament, Shadow rapporteur for opinion)

17 Mar 2022 · Meeting on European Commission´s proposal for a regulation on deforestation-free products

Meeting with Petri Sarvamaa (Member of the European Parliament)

4 Mar 2022 · Deforestation report

Response to Waste Framework review to reduce waste and the environmental impact of waste management

21 Feb 2022

The Confederation of European Paper Industries-Cepi welcomes the revision of Waste Framework Directive. We endorse the policy maker’s intention to optimise waste management systems to support higher recycling rates, cleaner secondary raw materials, to halve the amount of residual (non-recycled) municipal waste by 2030, and to ensure high-quality recycling. ' For Cepi it is a priority to increase the already high recycling rates, improve paper collection, and ensure the high-quality of our secondary raw materials, namely Paper for Recycling (PfR). PfR is a valuable secondary raw material and key in ensuring our transition to a Circular Economy. The paper and board sector have been very successful in maximising its utilisation, with 73.9 % recycling rate in Europe in 2020 and 49.6 Mt of PfR used to make new paper and board products constituting 56.3% of the total amount of paper and cardboard produced. Cepi wishes to comment on the policy options included in the Commission’s call for evidence: • Waste hierarchy: re-use and recycling should be complementary measures. We endorse the Commission's objective to safeguard the waste hierarchy, and implement measures supporting waste prevention. Turning waste into resources for a circular economy is key in waste prevention; this can be achieved both with recycling and re-use which are equally important in this process. Thus, the Commission should refrain from imposing horizontal targets and adopt a case by case approach taking into consideration the current recycling and environmental performance of each material stream. • Support measures for harmonised separate collection. We support the Commission’s intention to improve the separate collection of waste by clarifying and/or restricting the scope of derogations provided for in Article 10(3) of the Waste Framework Directive. For the paper and board industry, the biggest barrier in further increasing recycling rates and recyclability potential is the lack of harmonised application of separate collection at source of paper and board. Separate collection of paper ensures that fibres are not lost and return back in the paper loop and it enhances the quality of fibres by avoiding soiling of material from the source to the sorting line. • EPR fees based on net-cost principle. Cepi supports the idea of using EPR fee modulation as a means to facilitate and accelerate the transition towards a low carbon circular economy. Nevertheless, it is equally important that EPR fees are based on the net-cost principle. • EU-wide End-of-Waste criteria for paper not appropriate regulatory tool, instead the status of secondary raw materials needs to be clarified. The paper and board industry do not deem necessary the application of an End-of-Waste (EoW) status for paper-based products, as it is not the appropriate regulatory tool to help increase the quantity and quality of PfR. There are already high recycling rates and a well-functioning internal market for PfR without an EU-wide EoW application. 12 Mt of PfR have been circulated in the internal market in 2019, which is 22% of the total PfR collected. Nevertheless, in case an EoW application for paper, certain criteria should be met. (Find out more on Cepi position on EU-wide EoW criteria for paper here: https://www.cepi.org/wp-content/uploads/2021/10/Cepi-position_EU-wide-EoW-criteria-for-paper.pdf). • Paper recycling is high-quality recycling. We support the optimization of recycling processes in order to achieve higher recycling rates and secondary raw materials of higher quality. Nevertheless, we deem important that the Commission takes into consideration the already high quality recycling capability of certain waste streams when drafting a definition of high-quality recycling, in order to avoid unnecessary barriers in already well-functioning recycling processes, both in terms of environmental performance and high-quality product output. Please find out more in attached Cepi complete reply.
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Response to Evaluation and revision of the Weights and Dimensions Directive

17 Feb 2022

Cepi is the European association representing the paper industry. We offer a wide range of renewable and recyclable wood-based fibre solutions to EU citizens: from packaging to textile, hygiene and tissue products, printing and graphic papers as well as speciality papers, but also bio-chemicals for food and pharmaceuticals, bio-composites and bioenergy. We are a responsible industry: 92% of our raw materials are sourced in Europe and certified as sustainable, 91% of the water we use is returned in good condition to the environment. We are the world champion in recycling at the rate of 73.9%. At the forefront of the decarbonisation and industrial transformation of our economy, we embrace digitalisation and bring 20 billion value addition to the European economy and €5.5 billion investments annually. Through its 18 national associations, Cepi gathers 500 companies operating 895 mills across Europe and directly employing more than180,000 people. The main challenges to be faced by road transport relate to increasing costs, the shortage of drivers across Europe, the growing level of road congestion and the rising level of GHG emissions. Road transport costs have grown over the years because of rising fuel price, road charging and truck drivers working regulations and increasing wages. This impacts the price of raw materials and goods and consequently the overall competitiveness of the industry. Further cost increases are expected in the coming years due to further internalisation of external costs - to meet stricter emission targets, rising road charging and stricter minimum safety standards. Although road cannot carry everything, the ability of rail and other modes of transport to help overcome these challenges remains very limited. There is often no affordable and efficient alternative to roads unfortunately. Competitiveness and sustainability should be the key objectives when considering the review of the weight and dimensions rules enforced in the EU . It should aim at higher efficiency of the road transport to the benefit of the industry and the whole society by keeping our economy moving and enhancing the functioning of the internal market. The European paper industry makes use of the three basic modes - rail, road and water, but like many industry sectors, road is the main mode of transport for European distribution. Despite some efforts to rely more on rail, road transport is expected to remain dominant mode of transport in the future. A vast majority of the yearly 275 million tonnes of the paper industry raw materials and finished products is indeed transported by road in Europe. Here are below our key messages, which are further detailed in the attached document: - Current and future challenges related to transport need to be addressed to secure long-term competitiveness and sustainability. - Road is the predominant mode of transport for freight today and tomorrow. - Significant efficiency gains are possible and can deliver competitiveness and sustainability for road transport for shippers and the EU economy. - Trucks weight and dimensions’ limits are one of the main bottlenecks that need to be addressed. 44 tonnes should be considered as a minimum weight limit in all EU Member States. - European Modular System (EMS): let subsidiarity and innovation prevail! - Cross-border trips with higher capacity trucks and EMS should be allowed and only subject to agreement between the concerned Member States.
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Response to Measures to reduce microplastic pollution

18 Jan 2022

The Confederation of the European Paper Industries (Cepi) supports the Commission’s intention to follow up on its Plastics Strategy and address the unintentional release of microplastics into the environment. The commitment of our industry is to show that sustainability and competitiveness can go hand in hand and that we can contribute to protecting our environment and reducing marine litter, greenhouse gas emissions and the dependence on imported fossil fuels. Our fibre-based products, from wood-based textiles to packaging solutions, are essential for Europe’s steady and sustainable transition to a Circular Economy and a cleaner environment. We fully support the measures and the areas of intervention proposed in the inception impact assessment. However, we would also like to highlight that before promoting mandatory measures it will be crucial to act on reducing the knowledge gaps related to microplastics pollution and its prevention. As the Commission recognized, there are currently no harmonized methods for sampling, processing, data analysis and reporting about microplastics and we believe that before introducing design requirements and labeling schemes, it will be important to ensure all players along the value chains have the information and the adequate tools needed to assess and properly manage the releases of microplastics they are responsible for. While our industry is well-known for its bio-based products, such as pulp and paper packaging, it is also investing in the manufacturing of wood-based textiles and textiles recycling. Wood-based cellulose fibres are already commercially available, having the same level of malleability as synthetic fibres, while retaining the comfort typical for natural fibres. This kind of fibres should be promptly promoted as a highly sustainable alternative. By incentivizing the uptake of wood-based cellulose fibres, Europe could significantly decrease its dependence on imported raw materials and reduce GHG emissions. In Europe, the sourcing of forest biomass is framed by both European and national legislation, as well as market-based certification systems, which ensure the product is not contributing to deforestation or biodiversity loss, but rather to sustainable forest management, increasing the abilities of our forests to act as carbon sinks. Wood-based cellulose fibres are 100% renewable, recyclable and biodegradable. They also have a low water footprint during the growth phase and do not lead to soil depletion but are rather capable of reversing soil degradation and erosion. Keeping in mind the goal of achieving a fully circular system, where, instead of becoming waste, resources that have reached their end-of-life stage or are being discarded are used as material input, we would like to highlight the importance of preserving the material value of used textiles. Our Industry effort has made it possible to recycle old textiles, made also from non-wood-based fibres, using an innovative process that allows for the separation of synthetic fibres from cotton, or other plant-based fibres from mixed textiles, to make them a secondary raw material for new textiles. Overall, our industry will continue providing alternative solutions to support the Commission’s intention to act on unintentional microplastics release from tyre abrasion, plastic pellet loss and synthetic textiles. At the same time, we call for the development of accurate and harmonized microplastics sampling and data analysis methods.
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Meeting with Alina-Stefania Ujupan (Cabinet of Executive Vice-President Margrethe Vestager) and European Paper Packaging Alliance and

11 Jan 2022 · Sustainable Products Initiative

Meeting with Katherine Power (Cabinet of Commissioner Mairead Mcguinness)

16 Dec 2021 · Green Deal Agenda & Sustainable finance

Meeting with Virginijus Sinkevičius (Commissioner) and

30 Nov 2021 · To present commitments of CEPI in the context of the green transition, and in particular a new CEPI Sustainable Product Pledge; also to discuss the EU Green Deal agenda in general.

Meeting with Caroline Boeshertz (Cabinet of Executive Vice-President Valdis Dombrovskis) and Metsäliitto Cooperative and UPM-Kymmene Oyj

23 Nov 2021 · EU paper industry views on the Green Deal strategy and industry’s vision for 2030

Response to Revision of the Renewable Energy Directive (EU) 2018/2001

18 Nov 2021

Cepi represents the European pulp and paper industry and gathers, through its 18 member countries, some 895 pulp, paper and board mills across Europe directly, employing more than 180,000 people. Our sector is investing at a rate of more than €5 billion per annum, increasing our production volumes while simultaneously reducing our carbon footprint. The European pulp and paper industry fully supports the EU objective to reach climate neutrality by 2050. We have already achieved a 29% reduction of carbon emissions from 2005 to date, making our sector’s direct emissions account for less than 0.7% of total EU GHG emissions: a leading performance amongst industrial sectors! By constantly investing in energy efficiency, our sector has achieved a remarkable decrease of over 12% in primary energy consumption over the period 2005-2018. At the same time, European forests remove 10% of Europe’s total CO2 emissions. Our industry is up to the climate challenge. We provide an ever-increasing range of solutions for today’s and tomorrow’s needs of our customers, other industries, and society at large. Our renewable and recycled wood-based fibre solutions are made in Europe from predominantly European sustainably growing forests and recycled in Europe. Building on our position as world champions in recycling, we are set to increase recycling even further to boost the circular economy. Wood-based products store CO2 and substitute fossil-based and fossil-intensive materials and energy. Forests and forest-based products remove a net of 806 million tons of carbon dioxide equivalents annually. his corresponds to 20% of all fossil emissions in the European Union! To continue doing so, political support will be critical. The ‘Fit for 55’ package represents an opportunity for policymakers to support measures enabling our sector to contribute – with decarbonised production, product substitution and sustainable forest management – to reaching the 2030 and 2050 goals. This position outlines the European paper industry’s stance on key aspects of the package. We expect the proposals to promote: 1. Stable, predictable and effective protection for our sector, including • Maintaining policy stability for a carbon-neutral production in Europe 2. Access to affordable climate-neutral energy sources for energy-intensive industries, including • Incentivising the production and use of all climate-neutral energy sources 3. Funds, incentives and long-term security for investments in climate-neutral technologies, including • Rewarding carbon benefits of all wood products • Creating new markets for renewable and recyclable bio-based products Please find attached Cepi's position paper on the ‘Fit for 55’ package.
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Response to Revision of the Energy Tax Directive

18 Nov 2021

Cepi represents the European pulp and paper industry and gathers, through its 18 member countries, some 895 pulp, paper and board mills across Europe directly, employing more than 180,000 people. Our sector is investing at a rate of more than €5 billion per annum, increasing our production volumes while simultaneously reducing our carbon footprint. The European pulp and paper industry fully supports the EU objective to reach climate neutrality by 2050. We have already achieved a 29% reduction of carbon emissions from 2005 to date, making our sector’s direct emissions account for less than 0.7% of total EU GHG emissions: a leading performance amongst industrial sectors! By constantly investing in energy efficiency, our sector has achieved a remarkable decrease of over 12% in primary energy consumption over the period 2005-2018. At the same time, European forests remove 10% of Europe’s total CO2 emissions. Our industry is up to the climate challenge. We provide an ever-increasing range of solutions for today’s and tomorrow’s needs of our customers, other industries, and society at large. Our renewable and recycled wood-based fibre solutions are made in Europe from predominantly European sustainably growing forests and recycled in Europe. Building on our position as world champions in recycling, we are set to increase recycling even further to boost the circular economy. Wood-based products store CO2 and substitute fossil-based and fossil-intensive materials and energy. Forests and forest-based products remove a net of 806 million tons of carbon dioxide equivalents annually. his corresponds to 20% of all fossil emissions in the European Union! To continue doing so, political support will be critical. The ‘Fit for 55’ package represents an opportunity for policymakers to support measures enabling our sector to contribute – with decarbonised production, product substitution and sustainable forest management – to reaching the 2030 and 2050 goals. This position outlines the European paper industry’s stance on key aspects of the package. We expect the proposals to promote: 1. Stable, predictable and effective protection for our sector 2. Access to affordable climate-neutral energy sources for energy-intensive industries, including • Limiting the impact of energy costs on the industrial production • Boosting the electrification of industrial processes, where technically and economically feasible • Incentivising the production and use of all climate-neutral energy sources 3. Funds, incentives and long-term security for investments in climate-neutral technologies, including Please find attached Cepi's position paper on the ‘Fit for 55’ package.
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Response to Review of Directive 2012/27/EU on energy efficiency

18 Nov 2021

Cepi represents the European pulp and paper industry and gathers, through its 18 member countries, some 895 pulp, paper and board mills across Europe directly, employing more than 180,000 people. Our sector is investing at a rate of more than €5 billion per annum, increasing our production volumes while simultaneously reducing our carbon footprint. The European pulp and paper industry fully supports the EU objective to reach climate neutrality by 2050. We have already achieved a 29% reduction of carbon emissions from 2005 to date, making our sector’s direct emissions account for less than 0.7% of total EU GHG emissions: a leading performance amongst industrial sectors! By constantly investing in energy efficiency, our sector has achieved a remarkable decrease of over 12% in primary energy consumption over the period 2005-2018. At the same time, European forests remove 10% of Europe’s total CO2 emissions. Our industry is up to the climate challenge. We provide an ever-increasing range of solutions for today’s and tomorrow’s needs of our customers, other industries, and society at large. Our renewable and recycled wood-based fibre solutions are made in Europe from predominantly European sustainably growing forests and recycled in Europe. Building on our position as world champions in recycling, we are set to increase recycling even further to boost the circular economy. Wood-based products store CO2 and substitute fossil-based and fossil-intensive materials and energy. Forests and forest-based products remove a net of 806 million tons of carbon dioxide equivalents annually. his corresponds to 20% of all fossil emissions in the European Union! To continue doing so, political support will be critical. The ‘Fit for 55’ package represents an opportunity for policymakers to support measures enabling our sector to contribute – with decarbonised production, product substitution and sustainable forest management – to reaching the 2030 and 2050 goals. This position outlines the European paper industry’s stance on key aspects of the package. We expect the proposals to promote: 1. Stable, predictable and effective protection for our sector 2. Access to affordable climate-neutral energy sources for energy-intensive industries 3. Funds, incentives and long-term security for investments in climate-neutral technologies, including • Ensuring long-term security for investments in Best Available Technologies • Facilitating the use of industrial waste heat Please find attached Cepi's position paper on the ‘Fit for 55’ package.
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Meeting with Jorge Pinto Antunes (Cabinet of Commissioner Janusz Wojciechowski)

15 Nov 2021 · forestry

Paper industry backs CBAM but demands protection for exports

12 Nov 2021
Topic — EU carbon border adjustment mechanism to prevent carbon leakage from climate policy.
Message — The industry requests CBAM complement rather than replace free ETS allowances and indirect cost compensation. They demand export adjustment mechanisms before extending CBAM to more sectors, and want level playing field measures across policy areas.123
Why — This would protect their competitiveness in export markets worth 22% of production.45
Impact — High-carbon producers in third countries lose market access to EU without equivalent climate policies.67
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European paper industry urges stable EU ETS rules and climate funds

8 Nov 2021
Topic — Review of EU Emissions Trading System and Market Stability Reserve for 2030.
Message — The organization requests maintaining Phase 4 EU ETS regulatory stability, continuing free allowances based on product benchmarks regardless of decarbonization method, and keeping current biomass sustainability criteria without new restrictions. They oppose excluding installations with over 95% biomass from EU ETS.1234
Why — This would protect their €5 billion annual investments and avoid regulatory disruption to mills already switching to renewable energy.56
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Response to Land use, land use change and forestry – review of EU rules

8 Nov 2021

Cepi represents the European pulp and paper industry and gathers, through its 18 member countries, some 895 pulp, paper and board mills across Europe directly, employing more than 180,000 people. Our sector is investing at a rate of more than €5 billion per annum, increasing our production volumes while simultaneously reducing our carbon footprint. Cepi welcomes the possibility to express few remarks on the Commission proposal for a revised LULUCF Regulation. Our comments focus on 4 main points: 1) Forests should not be used to offset emissions in “difficult-to-decarbonise” sectors 2) The 2030 net removals target may be challenging to achieve in the given timeframe 3) The full mitigation potential of forests and forest products should be rewarded 4) We support the development of new carbon storage products For more information, please see the paper attached.
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Meeting with Joan Canton (Cabinet of Commissioner Thierry Breton) and European farmers and

8 Nov 2021 · Forest based industries

Response to Policy framework on biobased, biodegradable and compostable plastics

27 Oct 2021

The Confederation of the European Paper Industries (Cepi) agrees with the Commission on the need to have clear definitions and overarching principles applying to both biobased plastics (BBP) and biodegradable and compostable plastics (BDCP). As not all bio-based plastics are biodegradable/compostable plastics, the development of widely accepted and clear definitions is extremely important because confused consumers might end up making decisions that could contaminate waste streams and have negative environmental and economic consequences. As any decision taken regarding compostable plastic packaging, may have an impact also on non-plastic compostable materials, such as paper and board, we believe a broad range of stakeholders must be consulted before developing a framework on biobased and biodegradable/compostable plastics. Cepi would like to point out that, while there are certain steps that need to be made to address the problems identified by the Roadmap, we should also fully rely on methods that are already available. Currently, there are different recognized testing schemes, which were developed for biobased products, such as the EN 17228:2019 for plastics; bio-based polymers, plastics, and plastics products - Terminology, characteristics, and communication. This standard refers directly to the standards listed in the attached which were developed within CEN/TC 411 and were mandated standardisation by DG GROW. We agree that the overarching principles that would need to be respected by both BBP and BDCP should be aligned with waste hierarchy principles. However, we do see space for improvement when it comes to the hierarchy framework as provided by the Packaging and Packaging Waste Directive (PPWD). Currently, under the PPWD: ‘recycling’ shall mean the reprocessing in a production process of the waste materials for the original purpose or for other purposes including organic recycling. The PPWD places on the very same level recycling and composting, whereas evidence proves that recycling allows for a higher valorisation of the residues compared to organic composting. Therefore, we are asking for the introduction of a reference to the hierarchy principle, which would recognize that composting is one step behind recycling and should be limited to cases where recycling is not possible. Additionally, the overarching principles should be based on considerations such as overall environmental impact (LCAs) as well as the origin of biobased feedstock, as it is important to notice that the environmental impact of a certain product and its sustainability are also determined by the origin of the raw materials it was made of. We call for the need to develop with the support of industry more certification schemes that will be able to ensure effective biodegradation, alignment with actual disposal infrastructure, and avoid consumer confusion while recognizing the benefits that biobased products have when they degrade. For instance, many testing schemes measure the breakdown of matter in CO2. However, this limiting accounting fails to recognize the benefits associated with having lignin released after the biodegradability process. Lignin is a natural substance occurring in which has important fertilizing properties, which should be taken into account by such testing schemes.
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Meeting with Cyrus Engerer (Member of the European Parliament)

26 Oct 2021 · Emissions Trading System and Paper

Meeting with Kadri Simson (Commissioner) and

14 Oct 2021 · High energy prices and how this is affecting the competitiveness of European companies in the energy intensive sectors.

Meeting with Helena Braun (Cabinet of Executive Vice-President Frans Timmermans)

12 Oct 2021 · Contribution of the sector to the European Green Deal

Response to Restoring sustainable carbon cycles

7 Oct 2021

Cepi represents the European pulp and paper industry and gathers, through its 18 member countries, some 895 pulp, paper and board mills across Europe directly, employing more than 180,000 people. Our sector is investing at a rate of more than €5 billion per annum, increasing our production volumes while simultaneously reducing our carbon footprint. Cepi welcomes the possibility to comment on the roadmap to publish the communication “Restoring sustainable carbon cycles”. Our response to the inception impact assessment focusses on the following aspects: · Carbon removals from forests play a key role in achieving the EU climate objectives but should not compensate for lower ambition in fossil emissions reduction. The full mitigation potential of forests and forest products should be rewarded. · More clarity is needed on the interaction between the LULUCF regulatory framework and the proposed certification of carbon removals and on the impact on raw materials availability. · It is important to recognise the contribution of all carbon storage products. · The deployment carbon capture, storage and utilisation, also in combination with bioenergy, should be incentivised. For the full contribution, please see the document attached.
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Meeting with Caroline Boeshertz (Cabinet of Executive Vice-President Valdis Dombrovskis), Cristina Rueda Catry (Cabinet of Executive Vice-President Valdis Dombrovskis), Sofja Ribkina (Cabinet of Executive Vice-President Valdis Dombrovskis) and

17 Sept 2021 · Upcoming Russian export ban on logs

Response to Detailed implementing rules for the voluntary schemes recognised by the European Commission

27 Jul 2021

Comments: The implementation of the renewable energy directive, including the rules to verify sustainability and greenhouse gas are of utmost importance to achieve a secure environment for investments in the forest based sector including its investments in renewable energy technologies. It is therefore necessary for the secondary legislation to be limited to what it is: an implementing regulation on the rules for verification. The draft however diverts on several instances from provisions in the recast renewable energy directive 2018/2001/EU and its annexes that have been agreed in the legislative process between the co-legislators. The proposed implementing regulation seems to anticipate changes of rules that the Commission intends to propose in future revisions. This is not appropriate but needs to be agreed again between the co-legislators. In addtion, administrative and financial burden for the operators should be limited. Therefore, sufficient time for the implementation of the bass balance system should be granted. Also, operators need to have a sufficient choice between voluntary schemes. Therefore it is not appropriate to exclude certification bodies that had business relationship with the operators. Finally, sufficient time for the implementation of the requirements need to be granted, especially as this implementing regulation will be published with a significant delay. Background: The European Paper Industry is a major contributor for the European Union to meet climate neturality by 2050. It provides society with renewable materials, products and fuels substituting fossil based alternatives. The European paper industry is a major user and producer of bio-energy: In 2019, 62,5% of its energy consumption was from renewable sources. Sustainable sourcing is of utmost importance for the European paper industy: more than 91% of wood used by the industry is from the European Union. The EU Member States have implemented the Forest Europe principles for sustainable forest management into national legislation. 83% of wood, chips and sawmilling residues originate from forests certified under international forest management standards. Also beyond sustainable forest management, voluntary certification schemes are widely used in the paper industry to proof compliance with set criteria and rules. Building on this experience about sustainable sourcing of wood for products and energy, we would like to give the following comments on the draft Commission implementing regulation on rules to verify sustainability and greenhouse gas emissions saving criteria and low indirect land-use change-risk criteria and its annexes.
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Meeting with Helena Braun (Cabinet of Executive Vice-President Frans Timmermans)

11 Jun 2021 · European Green Deal and the preparation of the EU Forest Strategy

Meeting with Antoine Colombani (Cabinet of Executive Vice-President Frans Timmermans) and The European Steel Association and

7 Jun 2021 · Carbon Border Adjustment Mechanism

Meeting with Joan Canton (Cabinet of Commissioner Thierry Breton)

27 May 2021 · Sustainable products initiative, Fit for 55

Meeting with Gints Freimanis (Cabinet of Executive Vice-President Valdis Dombrovskis) and The European Steel Association and

3 May 2021 · Carbon Borden Adjustment Mechanism

Response to Guidance on REDII forest biomass sustainability criteria

26 Apr 2021

Draft Implementing Regulation on guidance on the sustainability criteria for forest biomass should give guidance and not revise the criteria agreed by the co-legislators Implementing acts are governed by Article 291 TFEU and adopted when there is a need for uniform requirements for implementing legally binding Union acts. The proposed implementing regulation on establishing operational guidance on the evidence for demonstrating compliance with the sustainability criteria for forest biomass laid down in Article 29 of Directive (EU) 2018/2001 of the European Parliament and of the Council does provide guidance leading to uniform requirements. It does however also affect the substance of the legal framework in several cases, which must be avoided: Article 3 (1) B) (ii): The second part following “… harvesting operation,” introduces a new requirement (national laws to ensure there is no biodiversity degradation in the regenerated area) rather than giving guidance and should therefore be deleted. In addition, the time for regeneration should remain flexible between countries. Article 3 (1) (B) (iii): The text changes the meaning of the criterion in the directive: the word “in” needs to be added between “including” and “wetlands” Article 3 (1) (B) (iv): While the text of the directive 2018/2001/EC requires “that harvesting is carried out considering maintenance of soil quality and biodiversity with the aim of minimising negative impacts”, the proposed implementing regulation requires national or subnational legislation to minimise negative impacts on soil quality and biodiversity. Furthermore, the second part of the paragraph (following “habitats,” goes beyond the criterion and includes elements the inclusion of which into directive 2018/2001 has been rejected by the co-legislators. Article 3.1. B) (v): The last sentence after the semi-colon is not part of the productive functions of forests and should be deleted. We encourage the European Commission to revise these provisions of the implementing regulation as well as the related definitions in article 2. Similarly, in Article 4 there are provisions that are going beyond guidance and introduce new definitions in the field of forest management, which should not be regulated through secondary legislation of the RED2, e.g. when it comes to forest definitions. Finally, we encourage the European Commission to use the expertise of the Standing Forest Committee before submitting the proposal for scrutiny by the representatives of Member States in the Committee.
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Meeting with Stefanie Hiesinger (Cabinet of Executive Vice-President Frans Timmermans)

22 Apr 2021 · Exchange on the upcoming revision of the EU ETS and the position of the pulp and paper industry

Meeting with Kadri Simson (Commissioner) and

15 Apr 2021 · Presentation of CEPI 2030 Industry Manifesto. Discussion on energy efficiency and renewable energy pathways for the paper industry.

Meeting with Thierry Breton (Commissioner) and

24 Mar 2021 · Commissioner Breton meeting with CEOs from Energy Intensive Industries on Industrial strategy & fit for 55.

Response to EU strategy for sustainable textiles

1 Feb 2021

Sustainable textiles: the European pulp and paper industry is part of the solution There is a huge untapped potential within the European textile industry to foster sustainable economic growth, to improve the competitiveness of our industries and to build more resilient supply chains. We believe that the European pulp and paper industry has the capability to be part of the solution, as explained in a study recently published and dedicated to biorefineries. Cepi acknowledges that this potential needs to be tapped into through a coherent policy framework, that provides businesses with certainty to invest in long term sustainable solutions, that will benefit our European industry, our citizens and our environment. As the choice of the fibres and the product’s design not only define the textile product properties and performance, but also determines the environmental impact of the resulting product, we believe the European Commission should take measures to ensure more sustainable and recycled material inputs are the starting point of a more sustainable and circular European textiles industry. Wood-based cellulose fibres are already commercially available, having the same level of malleability as synthetic fibres, while retaining the comfort typical for natural fibres. This kind of fibres should be promptly promoted as a highly sustainable alternative. By incentivising the uptake of wood-based cellulose fibres, Europe could significantly decrease its dependence on imported raw materials and reduce GHG emissions, arising both from the transport and the manufacturing of textiles in extra-EU counties. In Europe, the sourcing of forest biomass is framed by both European and national legislations, as well as market-based certification systems, which ensure the product is not contributing to deforestation or biodiversity loss, but rather to sustainable forest management, increasing the abilities of our forests to act as carbon sinks. Additionally, the uptake of wood-based cellulose fibres can also deliver on other important environmental objectives, such as the need to control and prevent pollution. Wood-based cellulose fibres are 100% renewable, recyclable and biodegradable. They also have a low water footprint during the growth phase and do not lead to soil depletion but are rather capable of reversing soil degradation and erosion. The European pulp and paper industry is a key player in the transition towards a more circular economic model and is committed to retaining the value of the materials used in the loop for as long as possible. This effort can also be recognised in the different solutions our industry has developed to improve the circularity performance within the textiles industry. See attached the full Cepi contribution.
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Response to Revision of EU rules on food contact materials

28 Jan 2021

Cepi welcomes the on-time publication of the Commission’s Inception Impact Assessment on the Revision of the EU rules on food contact materials. We believe this revision is crucial and supports securing a high level of protection of human health, protects the interests of consumers and ensures the effective functioning of the internal market and is in line with further harmonisation of all Food Contact Materials (FCMs). Please see our detailed feedback in the attachment.
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Response to Contingency plan for ensuring food supply and food security

16 Dec 2020

The Confederation of European Paper Industries (Cepi) and its Members welcome the Commission’s proposal for a contingency plan that will ensure food supply and security across the EU in times of crises. The Covid-19 outbreak highlighted the need to build more resilient supply chains within the Union. We are also pleased to learn that the Commission plans to build an EU-wide food crisis response mechanism that will be consistent with the overall objectives outlined in the European Green Deal and further developed in the Farm to Fork Strategy, to pursue increased environmental, economic, and social sustainability. Cepi and its Members support the development of products fit for a climate neutral, resource efficient and circular economy, that will help Europe increase its material efficiency and at the same time reduce its environmental impact and its waste generation rates. Paper and board packaging solutions, including food contact materials, are increasingly proving themselves as a more sustainable alternative to many fossil- based products, preventing each year significant release of CO2 emissions through simple material substitution with paper and board. In addition to the environmental benefits related to the uptake of fibre-based products, we believe the European paper and board industry can provide a valuable contribution in the establishment of an EU-wide contingency plan for ensuring food supply and food security, due to the resilient nature of our supply chains. Up to 92% of the raw materials used by our members, who operate 895 mills across 18 European countries directly employing 180000 people, is sourced in Europe and is certified as sustainable, hence not hindering other important objectives such as biodiversity preservation. During the pandemic, the paper and board industry has played a key role in ensuring the safety of millions of European citizens, by continuously ensuring the supply of essential items such as tissues for hygiene and health care, filter materials for personal protection and respirators, and paper and board cartons for food and pharmaceutical packaging as well as food and pharmaceutical ingredients. As we believe that our industry is fit to ensure Europe achieves a more sustainable future, we want to contribute to the development of a set of broad guidelines and recommendations to improve coordination at EU and Member State level on how better to monitor and respond to crises affecting the EU’s food supply and food security. Increasingly digitally integrated up- and downstream, sourced, manufactured and recycled in Europe, with European technology, our industry can truly contribute to green and digital resilience to the agri-food chain. Already leading in the food packaging material sector, we believe our experience could contribute to the establishment of principles that will ease the negative consequences of future crises on EU food supply and security, while at the same time not putting additional pressure on our environment and its resources.
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Response to Climate change mitigation and adaptation taxonomy

15 Dec 2020

Please find eclosed Cepi feedback on forestry elements in the draft delegated regulation on a climate change mitigation and adaptation taxonomy. Cepi is the European association representing the paper industry. We offer a wide range of renewable and recyclable wood-based fibre solutions to EU citizens: from packaging to textile, hygiene and tissue products, printing and graphic papers as well as speciality papers, but also bio-chemicals for food and pharmaceuticals, bio-composites and bioenergy. We are a responsible industry: 92% of our raw materials are sourced in Europe and certified as sustainable, 91% of the water we use is returned in good condition to the environment. We are the world champion in recycling at the rate of 71,6%. At the forefront of the decarbonisation and industrial transformation of our economy, we embrace digitalisation and bring 20 billion value addition to the European economy and €5.5 billion investments annually. Through its 18 national associations, Cepi gathers 500 companies operating 895 mills across Europe and directly employing more than 180,000 people.
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Response to Revision of the Energy and Environmental Aid Guidelines (EEAG)

8 Dec 2020

Please find attached the feedback from Cepi, representing the European pulp and paper industry.
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Cepi urges EU Forest Strategy to promote wood-based products

30 Nov 2020
Topic — The European Commission is developing a strategy to protect and restore EU forests.
Message — The organization requests that the strategy cover the entire forest-based value chain to promote wood products as fossil fuel alternatives. They want the Standing Forestry Committee to manage sustainability guidelines to respect national control over forest policy. They also call for legislative reviews to remove contradicting policies hindering the sector.123
Why — This would expand the market for paper and reduce administrative regulatory conflicts.45
Impact — Fossil fuel industries would see their market share decline to wood-based alternatives.67
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European Paper Industry Demands Carbon Leakage Protections and Stability

26 Nov 2020
Topic — Revision of the EU Emissions Trading System to meet higher 2030 climate targets.
Message — The paper industry requests that the EU prioritise free emission credits to prevent carbon leakage and ensure regulatory stability. They strongly oppose including road transport and buildings in the existing trading system, suggesting a separate system instead.123
Why — Securing more free allowances would protect their profitability and reduce exposure to international competition.45
Impact — Consumers and society could face higher costs if transport and buildings are integrated into the current system.67
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Response to Land use, land use change and forestry – review of EU rules

26 Nov 2020

The European Commission highlights the importance of just and inclusive the transition towards the climate neutrality. Cepi welcomes the climate neutrality target 2050. Even though the climate target 2030 has been increased to 55%, Cepi stresses the need to avoid relying on the sink function of the forest to meet the target. Instead, Cepi is of the view that the revision of the climate policy pillars of the EU should consider the inclusion of the substitution effect in the accounting and reporting of emissions and removals. Currently available flexibilities between the LULUCF and ESR provide other sectors a way of not reducing their emissions by taking advantage of the sink in forests. Potential flexibilities between the ETS and LULUCF bear the risk that sectors outside the forest-based value chain use the sink function of forests as a compensation rather than reducing their emissions. Cepi supports the initiatives of creating more forests in Europe. Therefore, potential carbon farming schemes - if related to forests - should incentivize solely afforestation. Moreover, it is necessary to ensure sustainable supply of home-grown raw materials from actively and sustainably managed forests. It is crucial to avoid possible carbon leakage effects and in the worst case deforestation outside the Union caused by increased raw material imports in case European sources cannot be utilized for the bioeconomy in their full potential. A second risk of too strong reliance on the forests’ sink function is due to the likelihood of increased natural disturbances in near future. Moreover, it is of utmost importance that the initiative takes into account the ongoing COVID -19 crises and the recovery by emphasizing the importance of economic and social benefits of the increased wood mobilization. Cepi welcomes the Commission’s aims at finding solutions to simplify the LULUCF accounting rules and addresses the importance of impact assessment of different policy options including regarding the transition to the bioeconomy. The implementation of the EU biodiversity strategy on forestry and forest in non-EU countries should be well taken into account prior making the proposals that could possibly hinder the use of local home grown sustainably managed forest resources. These initiatives include promotion of uses such as nature-based solutions and closer-to-nature-forestry mentioned in the inception impact assessment. Cepi highlights the importance of supporting active and timely sustainable forest management which ensures the delivery of multiple ecosystem services European forest provide. Cepi would like to emphasize that the acceleration of CO2 sequestration is an important part of the climate benefits of forests and the forest-based sector alongside with the carbon storage in products and material substitution. This should be properly taken into account. Future accounting and reporting of Harvested Wood Products (HWP) should incentivize all future innovative products from packaging to textiles, beyond current saw wood, panels and paper LULUCF HWP categories. As regards the policy options under investigation, Cepi would like to highlight the importance of the current LULUCF target, encouraging the emissions and removals from the LULUCF sector should be in balance by 2050. A potential LULUCF target focusing on the sink while not taking into account the substitution effect could lead to trade-offs with the circular bioeconomy. This would prevent the European forest and forest-based sector* in tapping into its full climate change mitigation and adaptation potential. *https://www.cepi.org/wp-content/uploads/2020/07/Cepi_-study.pdf
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Response to Sustainable Products Initiative

2 Nov 2020

The Confederation of the European Paper Industry (Cepi) welcome the opportunity to comment on the EU Commission’s Sustainable Products initiative, acknowledging the importance of ensuring the placement of more sustainable products on the internal market to support Europe’s transition towards a more circular economy and achieve the goals set under the European Green Deal. Please see our detailed reply in the attachment.
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Response to EU Action Plan Towards a Zero Pollution Ambition for air, water and soil

28 Oct 2020

Cepi, the Confederation of European Paper Industries understand that the objective of this action plan is to secure clean air, water and soil, healthy ecosystems and a healthy living environment for Europeans. We appreciate the opportunity to share our views on the Inception Impact Assessment of the Zero Pollution Action Plan. Please consult the attachment that contains our feedback.
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Meeting with Helena Braun (Cabinet of Executive Vice-President Frans Timmermans) and European Paper Packaging Alliance

28 Oct 2020 · circular economy and single-use products

Response to Revision of the Renewable Energy Directive (EU) 2018/2001

15 Sept 2020

Climate change is a global challenge that demands urgent action and requires every actor in society to play his/her part in responding to the challenge. We, in the paper industry, are strongly convinced that, with the help of the new European Green Deal, we can reduce our impact on climate change while increasing production in Europe. Our industry has therefore a strategic interest in being at the forefront of the decarbonisation efforts for 2050. We are an integral part of the bioeconomy and we operate as a strategic element of the forest-based industry value chain. Cepi takes note of the Commission intention to increase the 2030 climate target, resulting in the review of the legislation setting 2030 energy and climate related targets. Changes to the current regulatory framework need to be anchored around the key principle that investments in low carbon technologies and solutions need to be promoted and rewarded. In this context, it is important to stress that the pulp and paper industry is characterised by long investment cycles and that 2030 is very close in terms of investment horizon. It is therefore of primary importance to secure stability in the regulatory framework. This allows for optimal planning of investment decisions. In this respect, it should be noted that Member States are still in the process of transposing the recently agreed review of the Renewable Energies Directive (Directive 2018/2001) into national legislation. And operators are still in the process of adjusting to the agreed regulatory framework. Re-opening these provisions will create regulatory instability for several years, having a negative impact on investments. We therefore consider inappropriate and premature introducing changes in the just agreed regulatory framework. New legislative provisions introduced by the recently agreed Renewable Energies directive should not be subject to revision. Instead, focus should be paced on addressing non-regulatory barriers, particularly in the field of financing investments and infrastructures, to reduce the overall system costs. Specifically, in all scenarios assessed by the European Commission electricity produced from renewable energy sources is expected to significantly grow. In this respect, the lowering cost of electricity production should effectively results into low electricity prices for end-users. Moreover, a special reference needs to be made on renewable gases, key in fostering the decarbonisation of the gas demand. So far policies to promote biogas production and consumption have been rather erratic. A more strategic approach is needed. Particularly for what concerns the use of biogas to replace natural gas supply. This should be done in the most cost-efficient way. Biogas can be relatively cost-competitive with natural gas, if used directly in combined heat and power generation. It becomes rather expensive if biogas is upgraded to biomethane and then injected in the gas infrastructures. We certainly need to step up biomethane production, but we also need to avoid a situation whereby incentives are dispersed in a myriad of small biomethane producers, injecting biomethane in the grid, when the consumer next door could have directly used biogas in the first place. The most sensible way forward is to prioritise biogas production in locations where the direct use of biogas is possible. This would avoid unnecessary costs and strengthen economic value-chains at local level. Moreover, it strengthens the business case for high efficient CHP, thus delivering energy savings for the energy system as a whole. Lastly, we are of the opinion that reaching the 2030 targets required a holistic approach for what concerns clean energy (generation, infrastructures, consumption), more sustainable consumption patterns and lifestyle behaviour changes. The national energy and climate change plans are the right place where all these policies would have to be assessed, complemented and support each other.
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Response to Review of Directive 2012/27/EU on energy efficiency

15 Sept 2020

Climate change is a global challenge that demands urgent action and requires every actor in society to play his/her part in responding to the challenge. We, in the paper industry, are strongly convinced that, with the help of the new European Green Deal, we can reduce our impact on climate change while increasing production in Europe. Our industry has therefore a strategic interest in being at the forefront of the decarbonisation efforts for 2050. We are an integral part of the bioeconomy and we operate as a strategic element of the forest-based industry value chain. Cepi takes note of the Commission intention to increase the 2030 climate target, resulting in the review of the legislation setting 2030 energy and climate related targets. Changes to the current regulatory framework need to be anchored around the key principle that investments in low carbon technologies and solutions need to be promoted and rewarded. In this context, it is important to stress that the pulp and paper industry is characterised by long investment cycles and that 2030 is very close in terms of investment horizon. It is therefore of primary importance to secure stability in the regulatory framework. This allows for optimal planning of investment decisions. In this respect, it should be noted that Member States are still in the process of transposing the recently agreed review of the Energy Efficiency Directive (Directive 2018/2002) into national legislation. And operators are still in the process of adjusting to the agreed regulatory framework. Re-opening these provisions will create regulatory instability for several years, having a negative impact on investments. We therefore consider inappropriate and premature introducing changes in the just agreed regulatory framework. New legislative provisions introduced by the recently agreed Energy efficiency directive should not be subject to revision. Instead, focus should be paced on addressing non-regulatory barriers, particularly in the field of financing measures. In this respect, special attention should be placed on measures supporting CAPEX intensive projects in industry. This is a concern that is particularly relevant in view of the need to steer investment in the coming few years while the impact of COVID-19 can result in long-lasting weak balance sheets, thus impacting investment decisions and/or capability to attract financing. Lastly, we are of the opinion that reaching the 2030 targets required a holistic approach for what concerns clean energy (generation, infrastructures, consumption), more sustainable consumption patterns and lifestyle behaviour changes. The national energy and climate change plans are the right place where all these policies would have to be assessed, complemented and support each other.
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Response to Environmental claims based on environmental footprint methods

31 Aug 2020

Joint paper value chain reply on the EU Consultation on Green Claims : In December 2019, the European Commission presented its ambitious Green Deal roadmap, a comprehensive strategy aimed at putting Europe on the right track for climate neutrality in 2050 while encouraging sustainable economic growth. In this strategy, the role of consumers is clearly recognized: this transition won’t happen without them. The paper value chain associations recognize green washing is a threat to the involvement of consumers: they won’t be able to make more sustainable choices if they don’t receive reliable, comparable and verifiable information. In the meantime, a proliferation of methods is observed which are used to measure and assess environmental impacts as well as a proliferation of labels and claims related to environmental information, which goes hand in hand with a proliferation of misleading environmental, including climate-related, claims. For that reason, the European Commission has decided to leverage the Product Environmental Footprint (PEF) method to distinguish between valid green claims and green washing. The foundations of the PEF work were established in 2013, the idea was to develop a harmonized method to evaluate the environmental friendliness of products, focusing on their carbon footprint and related GHG emissions. However, while we agree that green claims should be substantiated by a reliable and verifiable methodology and datasets, we still feel that there are areas that should be improved in the PEF methodology. These include: • Further development of the land use impact methodology that reflects sustainable forest management realistically and the circularity formula. • We would also welcome developing rules on how intermediate product footprint results will be linked to the final product calculations. • PEF data are currently not up-to-date for several product categories. In the case of paper intermediate products we would welcome a collaboration to ensure the PEF data are updated and reliable. This should also include the secondary data for each product category. This data update should precede any consideration of legislative action. • In relation to packaging, a holistic approach should be taken, which includes both the product and the packaging.This will help consumers make accurate choices and prevent unintended consequences especially around food waste. • We support a harmonised approach, which uses the Single Market as the legal basis. We also believe a voluntary approach should be adopted for a green claims legal framework in coherence with international standards, as this will facilitate the dynamic improvement in PEF databases and methodology; which will itself support continued innovation. • The framework should apply to all products whether produced in the EU or imported so as to ensure a level-playing field. It is to be welcomed that consumers are seen as enabling stakeholders in the Circular Economy Action Plan 2.0. Consumers do however obtain their information from many sources, not just information from producers. Green claims should therefore extend to information provided by the media or other stakeholders. This will help prevent imperfect information and market failure. We are committed to work further with the EU institutions on the development of the PEF and OEF (Organisation Environmental Footprint) methodologies complementing international standards, and will continue to work to provide up to date datasets that can be used by the value chain.
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Meeting with Camilla Bursi (Cabinet of Commissioner Virginijus Sinkevičius), Rozalina Petrova (Cabinet of Commissioner Virginijus Sinkevičius)

8 Jul 2020 · VC meeting to discuss Forest-Based industries’ contribution to the Green Recovery agenda, EU Biodiversity strategy 2030, European Commission guidance on how to implement the SUPD

Response to EU rules on industrial emissions - revision

20 Apr 2020

Cepi would like to share the following feedback on the IED inception impact assessment: IED was able to deliver on its main objectives (emissions reduction); European pulp and paper sector has reduced considerably its emissions to the environment in the last decades. The Industrial Emissions Directive (IED) and sector specific BAT was one of the legislative instruments that contributed to its reductions with its implementation. Global competitiveness should be taken much more into account in future processes of IED and BREF. So far, the compliance and operational costs associated with BAT techniques haven't been considered enough. The IED has increased the burden, both financially and administratively, with different intensity across Europe, at almost all levels from permitting to reporting. It is important to acknowledge the great emission reductions that have been achieved in the industry and not continuously seek for major further reductions. It is also important that industry is not always put on the spot.The implementation of the Industrial Emissions Directive and the sector-specific BAT documents is still ongoing. For example, the environmental permits of the pulp and paper industry have recently been updated on the basis of the BAT conclusions, updated a few years ago. BAT conclusions of certain sectors are still being prepared or still to be revised; Continuous environmental improvement is achievable in the current IED framework, The established revision and updated of BREF documents and BAT conclusion is an effective way to push for environmental performance;It is important that the cost impacts of possible emission reduction measures are reasonable in relation to environmental benefits. Unbalanced ambition in the IED or on deriving BAT conclusion leads to a reduced competitiveness of the industry without the effective environmental gain leading to the conclusion that the all IED/BREF process must be balanced between the different sustainability pillars. In fact, overly strict regulations (with the consequence of higher production costs compared to non-EU-countries) increase pressure on EU companies and could lead to migration of companies to countries with lower environmental standards;The BREF process should still be improved. There has been some improvement in identifying key parameters in the BREF process, but prioritization is still needed. In deriving the BAT-AELs a clear methodology should be used instead of using a statistical approach, which has been the case in many occasions. The economic realities should also be remembered in the BREF process. The 15.4. derogation tool has proved to be effective ways to avoid disproportionate costs and even allow different technological approaches with an overall benefit; The IED has contributed to achieving a level playing field within the inner market, but there is to our understanding still differences in the implementation of the BAT conclusions. The problem is the execution: it is a fact that compliance checks and control of compliance in the Member States are differing quite a lot. It would be more important to tackle this in the future in order to achieve a level playing field than to revise the IED;The IED should keep its defined focus and not to enlarge too much its scope because of increasing the risk of overlapping with other existing legal requirements e.g. the Circular Economy Strategy.Moreover the Green Deal intends to review the process of how to address pollution from large industrial installations looking at the sectoral scope of the legislation and at how to make it fully consistent with climate, energy and circular economy policies.
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Response to Climate change mitigation and adaptation taxonomy

15 Apr 2020

Cepi supports the overall aim of the taxonomy for sustainable finance to direct private investments to sustainable economic activities that have an impact on the environment. The European pulp and paper industry mainly uses locally produced certified wood and the industry is firmly committed to contribute to the EU Climate Action. Forest-based value chain begins with Sustainable Forest Management (SFM) and it provides substantial contribution to the climate change mitigation and adaptation objectives. Bio-based circular economy offers further solutions to environmental objectives of the taxonomy regulation via providing sustainable alternatives for fossil-based raw materials, products and energy. In order to tap into the full climate change mitigation and adaptation potential of forests and the forest-based sector, policy coherence and coordination are needed. Any forest and forestry-related provisions in the upcoming Delegated Act should be in line with 2030 EU climate and energy framework, especially the LULUCF Regulation and the recast of the Renewable Energy Directive (REDII). It should be highlighted that the 2050 EU Climate Strategy, updated EU Bioeconomy Strategy and the EU Forest Strategy address the importance of the benefits stemming fibre-based solutions. As noted in the impact assessment, the initiative will need to be developed in accordance with the Taxonomy Regulation, in particular with the principles in Article 14. It should be noted that the TEG proposal on forestry is not in accordance with the Taxonomy Regulation, in particular with the principles in Article 14. E.g. when comparing the TEG proposal to the paragraph 1 (a) the proposed forest management criteria undermine the long-term benefits of forestry over time and the fact that active forest management with regular biomass removals ensure vitality and healthy of forest ecosystems in future. The criteria itself should highlight that the carbon stock in forests shall increase over time and the accounting and verification should be done at country level by using data from National Forest Inventories. Cepi would like to reiterate that the evaluation of CO2 balance should be done at national level and not narrowing down to a holding level where it may lead to counterproductive results as it comes to other climate benefits of the sector, namely substitution of fossil-based raw materials and storing more carbon in fibre-based products. Regarding the compliance of the TEG proposal and the Article 14 Paragraph 1 (c), the upcoming Delegated Act should take into account the long-term nature of forests and benefits of sustainable forest management by using qualitative criteria that provide meaningful and more feasible implementation solutions than quantitative criteria. Quantitative criteria can mainly be used as it comes to forest cover, growing stock, natural disturbances and other features that can be measured based on well-established and science-based monitoring systems and approaches in place. On the Article 14 Paragraph 1 (d), it should be noted that REDII includes a two-step approach to verify sustainability of forest biomass. However, the TEG proposes another approach and a set of criteria that significantly differs from the principles agreed in REDII or the LULUCF Regulation. Therefore it is justified to claim that the TEG proposal is not taking into account the relevant existing EU legislation. Cepi would like to highlight the importance that measurement and reporting shall not result in burden to operators that may benefit from private investment. The taxonomy should not duplicate the reporting requirements or verification approaches that will be implemented in the LULUCF Regulation and REDII. However, the voluntary certification schemes provide a useful tool to showcase sustainable forestry and the use of forest certification should be accepted as a proof to verify sustainability.
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Response to 2030 Climate Target Plan

15 Apr 2020

Please find attached the Cepi response to the Inception Impact Assessments on 2030 Climate Target Plan. Cepi is the European association representing the paper industry. Through its 18 national associations, Cepi gathers 500 companies operating 895 mills across Europe and directly employing more than 180,000 people. Climate change is a global crisis that demands urgent action and requires every actor in society to play his/her part in responding to the crisis. We, in the paper industry, are strongly convinced that, with the help of the new European Green Deal, we can reduce our impact on climate change while increasing production in Europe. Our industry has therefore a strategic interest in being at the forefront of the decarbonisation efforts for 2050. We are an integral part of the bioeconomy and we operate as a strategic element of the forest-based industry value chain. Cepi takes note of the Commission intention to increase the 2030 climate target, resulting in the review of the legislation setting 2030 energy and climate related targets. Changes to the current regulatory framework need to be anchored around the key principle that investments in low carbon technologies and solutions need to be promoted and rewarded. In this context, it is important to stress that the pulp and paper industry is characterised by long investment cycles and that 2030 is very close in terms of investment horizon. On this basis, proposals around the 2030 climate target would need to focus on these three aspects: (1) Complement existing 2030 framework with tools enabling industry to decarbonise (2) Preserve regulatory stability (3) Role of forests These aspects are more extensively addressed in the attached document.
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Response to Revision of the Energy Tax Directive

1 Apr 2020

Cepi represents the European pulp and paper industry. Our response to the inception impact assessment focusses on two main aspects: (1) industrial competitiveness and double taxation; (2) considerations on the concept of tax exemptions, as addressed in the inception impact assessment. (1) Industrial competitiveness and double taxation Europe is one of the regions in the world with the highest environmental and social standards. A competitive industry delivers benefits in terms of employment (direct and indirect), the development of industrial activities along the whole value-chain, thus contributing to the overall welfare. Therefore, from an economic, environmental and social perspective, it is in Europe’s own interest to promote competitive industrial production in Europe. The pulp and paper industry is an energy intensive industry covered by the Emission Trading System (ETS). The industry is also included under the scope of the Energy Taxation Directive (ETD). The ETS prices carbon emissions. In the paper industry, carbon emissions are almost entirely generated by energy combustion. The paper industry is therefore under double energy taxation: the ETD, for the energy component, and the ETS, for the carbon component from direct and indirect energy combustion. To avoid the double taxation (which in our case becomes even a triple taxation, as we are also electricity producers given that we auto-generate part of our electricity consumed via high-efficient co-generation), the paper industry is eligible for exemption from the ETD. The exemption requires proving that voluntary agreements on energy efficiency would achieve the same results as it would have happened under minimum levels of energy taxation. But the ETS is already promoting energy efficiency, by placing a carbon price on energy combustion. We therefore find this approach extremely bureaucratic, cumbersome, and source of regulatory risk due to uncertainties caused by state aid approval. Specifically on state aid approval, exemptions from the ETD are dealt under the same procedure that applies for non-harmonised environmental taxation according to the Guidelines on State aid for environment protection and energy 2014-2020 (2014/C 200/01), In other words, from a practical point of view, there is no difference between being excluded from the ETD, or being eligible for exemption from the ETD. It just makes it administratively more complex. It would just be common sense to find a way to exclude from the scope of the ETD energy intensive industries exposed to the risk of carbon leakage, as it is the case for the pulp and paper industry. This is, de facto, already happening for many other energy intensive industries excluded from the scope of the ETD. (2) Considerations around the concept of exemptions The Inception impact assessment states that “The wide range of exemptions and reductions are de facto, forms of fossil fuel subsidies, which are not in line with the objectives of the European Green Deal.” We disagree with this statement. Exemptions are made for a variety of economic and social reasons that are not necessarily related to fossil fuels. For instance, exemptions from high electricity prices address issues like industrial competitiveness or energy poverty. These concerns apply regardless of the fossil fuel needed to produce electricity: they just target the impact of the final electricity price. Moreover, for the sake of argument, looking at the international dimension, if industry would be subject to zero taxation on energy/climate on Country A (extra-EU), and subject to a reduction from high levels of taxation on energy/climate in Country B (in the EU), it would be wrong to conclude that Country B is granting a fossil fuel subsidy while Country A is not.
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Paper industry urges wider timber rules to stop unfair competition

27 Feb 2020
Topic — This consultation evaluates EU regulations aimed at combating illegal logging and its global impacts.
Message — Cepi calls for the Commission to extend the regulation's scope to include products like printed matter. They advocate for better recognition of forest certification schemes to verify raw material origins.12
Why — Expanding the scope would prevent non-EU competitors from bypassing legality requirements and harming market reputation.3
Impact — International exporters of uncertified wood products would lose their ability to freely access the European market.4
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European paper industry urges targeted actions on imported products

25 Feb 2020
Topic — This consultation addresses products contributing to global deforestation and forest degradation.
Message — The industry requests targeted actions on imported products from outside the forest sector. They also want the EU Timber Regulation expanded to include printed products.12
Why — They avoid new administrative burdens while protecting the reputation of European paper.34
Impact — Foreign importers of non-forest products face higher scrutiny than European producers.5
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Response to Climate Law

6 Feb 2020

Climate change is a global crisis that demands urgent action and requires every actor in society to play his/her part in responding to the crisis. We, in the paper industry, are strongly convinced that, with the help of the new European Green Deal, we can reduce our impact on climate change while increasing production in Europe. Our industry has therefore a strategic interest in being at the forefront of the decarbonisation efforts for 2050. We are an integral part of the bioeconomy and we operate as a strategic element of the forest-based industry value chain. The Climate Law will set the principles that will have to be streamlined, coordinated and integrated into European and national policies. In this respect, Cepi would like to highlight four central considerations for our sector that the Climate Law should particularly address: 1) The Climate Law must stimulate investments for a transition to carbon-neutrality in all businesses. This could be achieved by simultaneously stimulating demand for low carbon products and boosting supply of these products. On the demand side, policies should particularly focus at improving market access for recyclable wood fibre products coming from sustainable managed forests. On the supply side, policies should specifically focus on supporting the development and deployment of cost effective decarbonising production technologies and processes in all industries. 2) All building blocks of the EU Green Deal and of the EU Long Term Strategy need to be specifically pursued, in particular, the goal of delivering a circular economy that gives a central and growing role to wood fibre raw material from sustainable sources, as well as at increasing raw material and energy efficiency. It should be a key component of the integrated national energy and climate plans. Governments should implement policies aimed at increasing the availability and access to sustainable wood fibre products, support energy saving measures and promote sustainable consumers behaviour. 3) A strategy – with clear milestones – to cost-effectively phase-out combustion of fossil fuels in energy generation, needs to be urgently defined. This is particularly relevant for industry using natural gas for which, so far, no structural solutions to decarbonise natural gas are available, from a technical and/or economical perspective. As one of the main consumers of natural gas, our industry needs to know what type of decarbonised gas is expected to be supplied, in which timeframe, and whether adjustments to our equipment will be needed. Given the long investment cycles in our industry and the need to accelerate investments to meet the 2050 objective, it is of paramount importance to reduce to a minimum the risk of stranded assets. 4) The carbon sink of forests should be seen as a part of a forest system which acts as a carbon sink, while storing carbon in products and substituting fossil-based materials, products and fuels. The preliminary results from a Cepi EU-wide study show that the overall positive climate effect of the European forestry sector amounts to more than 700 MtCO2e/year which corresponds to more than 16% of EU fossil emissions. However, forests should not be seen only for their carbon sink function and as an offset for emissions from other sectors: this would miss much of their full potential as sustainable source of fibers for renewable and recycled products, while bearing the risk of forests becoming a source of emissions in the long run. The objective should be to encourage secure investments into sustainable forest management to grow European forests further, adapt them to climate change and restore them where they are already affected by it.
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Response to A new Circular Economy Action Plan

17 Jan 2020

The Confederation of European Paper Industries (Cepi) welcomes the upcoming adoption of a new Circular Economy Action Plan that aims at accelerating the transition towards a circular economy. It should be noted that circularity begins with the renewability of virgin materials and that all raw materials are legally and sustainably sourced. Therefore, it would be crucial that interlinks would be sought between the circular and the bioeconomy in order to enhance policy coherence and effectiveness of these two policies. The future sustainable product policy is an example of the synergy between circular economy and bioeconomy , which should encourage use of products and materials with climate benefits and boost design for circularity (recently published guidance on recyclability of paper-based packaging can be found at http://www.cepi.org/recyclability_guidelines). Cepi also welcomes that the Commission will seek to effectively communicate the environmental impacts of products to the consumer while avoiding false green claims. Cepi has been following the evolution of the PEF and together with the paper value chain and interested stakeholders, has submitted category rules for calculating the environmental footprint of paper products according to the method developed by the European Commission. Therefore it would be desirable to understand what the role of the PEF will be in the Sustainable Product Policy in link with existing policies e.g. EU Ecolabel. Paper is a well-functioning example as it comes to circularity and closing the loops. In 2018, it has reached a recycling rate of 71,9% (even 84,6% in paper-based packaging). Working closely with the entire value chain and along the entire life cycle in a three-year project 4evergreen (http://www.cepi.org/4evergreen) , the paper industry is set to speed up the industry is set to speed up the transition, close remaining loops and use the untapped potential. Separate collection for paper and board must be further promoted. CEPI appreciates the Commission’s plans to take further action on this issue (Cepi’s guidance: http://www.cepi.org/separate_collection_guidance). It would be essential that targeted actions for high-impact sectors or materials would not negatively influence further improvement of circularity in well performing sectors and materials or innovation and investment opportunities in them. E.g. setting requirements on mandatory recycled content might be useful in specific sectors to balance market failures there, but it could lead to counterproductive effects as it comes to paper and board. Regarding waste prevention and re-use new requirements should only be set following a thorough assessment of the environmental impacts, including hazardousness in a risk-based approach. Further action on re-use should be limited to products that are not designed for recycling. Moreover, Cepi supports the announced objective of using secondary raw materials domestically and modernisation of certain waste laws. Therefore it is crucial that the review of the regulation on waste shipments would contribute to completing the single market for waste and ensure waste and secondary raw materials can be shipped between EU countries to close loops within Europe. Further information about the above mentioned suggestions that support the continuity and uptake of circular solutions in the paper industry can be found at: http://www.cepi.org/topics
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Response to Fitness Check on endocrine disruptors

9 Jul 2019

The need of establishing a coherent approach in all the fields having in the focus the protection of human health and of the environment (by minimising the overall exposure to EDC) is certainly of great importance. In fact, a legal definition for EDs exists for biocides and plant protection products, but not for other key sectors, such as for example REACH chemicals, cosmetics, food additives, food contact materials and toys. In order to achieve a proper identification of endocrine disruptors we think it is required to have: a) a cross sectoral and overall definition for EDs that now only exists for plant protection products and biocides; b) a guidance document explaining how to apply the definition on the basis of test results and scientific literature to identify EDs; c) EU could list and define a set of tests covering all ED modalities in different ED applications (*) d) clear EU guidance to use these tests in application dossiers e) an EU wide sectoral review, could identify possible sectors with very likely human exposure because of EDs (*) The EU’s guidance document for implementation of new criteria on EDs for Plant protection products and biocides was assessed by (Demeneix and Rémy, 2019) and the main conclusion was that the most significant problems can be expected to arise due to data gaps in testing, because the ED criteria states that the identification should be done mostly on the basis of existing data.
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Meeting with Jocelyn Fajardo (Cabinet of Commissioner Violeta Bulc)

17 May 2019 · Road transport issues

Meeting with Risto Artjoki (Cabinet of Vice-President Jyrki Katainen) and Metsäliitto Cooperative

5 Mar 2019 · Bioeconomy

European paper industry urges stable and full carbon cost compensation

17 Jan 2019
Topic — This consultation updates rules for Member States to compensate industry for electricity price hikes.
Message — Cepi insists there be no differentiated treatment among exposed sectors regarding carbon leakage protection. They recommend using regional CO2 emission factors and argue that maximum compensation levels should not decrease.123
Why — Maintaining high compensation levels reduces electricity costs and protects the industry's international competitiveness.4
Impact — Environmental objectives are undermined if compensation is not tied to mandatory energy efficiency improvements.5
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Meeting with Dominique Ristori (Director-General Energy) and FuelsEurope and

23 Nov 2018 · clean energy transition and decarbonisation

Response to Reducing marine litter: action on single use plastics and fishing gear

13 Jul 2018

CEPI, the European forest fibre and paper industry, believes that the Commission’s proposal lacks clarity regarding its scope and can lead to disproportionate implementation, far and beyond its stated objective, or the impact of different scenario that were assessed. In particular, the proposed definition of plastic which “can function as a main structural component,” and explanation provided in recitals remains subject to interpretation and could extend the scope of the directive to any single-use food packaging item. Paper, board or beverage carton container packaging systems commonly use polymer coatings, linings or layers for functional, hygiene or food protection purposes. The plastic coating, liner or layer do not function as a “structural“ element of the products. Those products are considered on the market as paper products, are covered by the EN 643 standards for paper for recycling and contribute to the high recycling rate of paper-based packaging (90% target set under the revised Packaging and Packaging Waste Directive). As per European Environment Agency latest records, no paper or board articles whether using or not some polymers, are listed amongst of most commonly found items on European beaches and they only account for 3% of the littered items. Yet the scope and definition of the proposed Directive (article 3, recital 8) remain surprisingly vague and could be interpreted as covering any products using any plastics for any type of use. For the purpose of this Directive, industry considers it is indispensable to provide a clear definition of what are plastic products, to avoid unwarranted classification of some paper and board products as plastics otherwise raising conflicting interpretations and blurring the implementation of long established EU Internal Market legislation. Products using polymeric layers and liners that do not function as “main structural“ element of the product should therefore be more clearly excluded from the scope of this Directive (Article 3) on Single-use plastics.
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Response to Update of the 2012 Bioeconomy Strategy

20 Mar 2018

• The European pulp and paper industry welcomes the Strategy update as an opportunity to unleash the bioeconomy potential of the EU and sees itself as a key/core player in a European sustainable and circular bioeconomy. • Along the line of the review of the current Strategy, CEPI believes that the emphasis must be put on a limited number of concrete, actionable and measurable actions, keeping in mind that only an enabling and predictable policy context will create the conditions for the bioeconomy to blossom in Europe, • In that context, CEPI believes that it is important to select actions that are focused on the sole objective of a competitive European bioeconomy that provides jobs and growth, rather than on actions that relate to the process, in other words, focus on the “what” more than on the “how”. • This leads to a call for adjusting some of the 8 very relevant areas that the initiative aims to achieve: o When it comes to mobilising investments, it must be reminded that the BBI-JU is a success story. Besides exploring new financial instruments, the continuity of well-functioning existing ones should be guaranteed o When it comes to supporting the creation of markets for bio-based and circular products, the exemplary and “pump priming” role of public buyers must be considered via an update and adjustement of the public procurement policies o Next to the understanding and resilience of land and sea, it is of critical importance to ensure the productive management of forest, land and sea together with the sustainable domestic availability and mobilisation of responsibly managed biomass. • In addition to these 8 areas, it is also of utmost importance to overcome misconceptions and misunderstandings concerning the bioeconomy. Ensuring the rapid availability of undisputable data and facts on the expected environmental, climate, social and economic benefits of the bioeconomy and bio-based products, is a must in order to raise awareness and promote the bioeconomy across Europe’s society at large.
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Paper industry urges robust methodology for carbon leakage list

13 Nov 2017
Topic — The consultation defines industrial sectors at risk of carbon leakage until 2030.
Message — The industry requests that carbon leakage assessments reflect how fossil fuel plants impact electricity prices. They also suggest treating the rest of the world as a single block for trade calculations.12
Why — This methodology would provide the regulatory stability needed to invest in low-carbon solutions.34
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Meeting with Nele Eichhorn (Cabinet of Vice-President Cecilia Malmström)

2 Oct 2017 · Export ban of timber from Ukraine

Meeting with Sarah Nelen (Cabinet of First Vice-President Frans Timmermans) and European Environmental Bureau and

7 Feb 2017 · EU Ecolabels

Meeting with Grzegorz Radziejewski (Cabinet of Vice-President Jyrki Katainen) and Bureau Européen des Unions de Consommateurs and

7 Feb 2017 · EU Ecolabels

Meeting with Shane Sutherland (Cabinet of Commissioner Phil Hogan)

24 Jan 2017 · Biomass

Meeting with Juho Romakkaniemi (Cabinet of Vice-President Jyrki Katainen)

18 Oct 2016 · Industrial emissions

Meeting with Juergen Mueller (Cabinet of Vice-President Karmenu Vella)

18 Oct 2016 · Air Quality, LCP BREF

Meeting with Kaius Kristian Hedberg (Cabinet of Commissioner Elżbieta Bieńkowska)

13 Apr 2016 · Bio-based Large Combustion Plant

Meeting with Nele Eichhorn (Cabinet of Vice-President Cecilia Malmström)

4 Mar 2016 · Anti dumping measures on coated woodfree paper

Meeting with Vytenis Andriukaitis (Commissioner) and

29 Feb 2016 · EU harmonisation measures on food contact materials

Meeting with Nathalie Chaze (Cabinet of Commissioner Vytenis Andriukaitis)

24 Nov 2015 · Non-harmonised food contact materials

Meeting with Lowri Evans (Director-General Internal Market, Industry, Entrepreneurship and SMEs)

27 Oct 2015 · Presentation of the sector, industrial policy, innovation, energy, circular economy.

Meeting with Maria Asenius (Cabinet of Vice-President Cecilia Malmström), Nele Eichhorn (Cabinet of Vice-President Cecilia Malmström) and The Navigator Company, S.A.

30 Sept 2015 · Anti-dumping investigation

Meeting with Bernd Martenczuk (Cabinet of First Vice-President Frans Timmermans) and The European Steel Association and

17 Sept 2015 · Market economy status for China

Meeting with Kaius Kristian Hedberg (Cabinet of Commissioner Elżbieta Bieńkowska) and The European Steel Association and

17 Sept 2015 · Presentation of a study

Meeting with Maria Asenius (Cabinet of Vice-President Cecilia Malmström), Miguel Ceballos Baron (Cabinet of Vice-President Cecilia Malmström), Nele Eichhorn (Cabinet of Vice-President Cecilia Malmström) and

17 Sept 2015 · AEGIS presenting new study on consequences of granting MES to China

Meeting with Edward Bannerman (Cabinet of Vice-President Jyrki Katainen) and The European Steel Association and

17 Sept 2015 · EU-China trade relations

Meeting with Peteris Ustubs (Cabinet of High Representative / Vice-President Federica Mogherini) and Confederazione Generale dell'Industria Italiana and

3 Sept 2015 · AEGIS Europe and MES China

Meeting with Markus Schulte (Digital Economy)

31 Aug 2015 · Digitisation of industry

Meeting with Rolf Carsten Bermig (Cabinet of Commissioner Elżbieta Bieńkowska)

17 Jul 2015 · High level group of energy intensive industries

Meeting with Nele Eichhorn (Cabinet of Vice-President Cecilia Malmström)

6 Jul 2015 · Paper industry trade cases

Meeting with Juho Romakkaniemi (Cabinet of Vice-President Jyrki Katainen) and Metsäliitto Cooperative

30 Jun 2015 · Energy Union

Meeting with Jocelyn Fajardo (Cabinet of Commissioner Violeta Bulc)

2 Jun 2015 · Meeting with CEPI

Meeting with Heidi Jern (Cabinet of Vice-President Jyrki Katainen) and Metsäliitto Cooperative

1 Jun 2015 · Circular Economy and Energy Union

Meeting with Peter Van Kemseke (Cabinet of Vice-President Maroš Šefčovič)

18 May 2015 · ETS

Meeting with Phil Hogan (Commissioner) and Metsäliitto Cooperative

24 Apr 2015 · Bio Economy

Meeting with Shane Sutherland (Cabinet of Commissioner Phil Hogan) and Metsäliitto Cooperative

24 Apr 2015 · Bio economy

Meeting with Juraj Nociar (Cabinet of Vice-President Maroš Šefčovič)

14 Apr 2015 · Energy Union

Meeting with Heidi Jern (Cabinet of Vice-President Jyrki Katainen)

13 Apr 2015 · Bioeconomy

Meeting with Jyrki Katainen (Vice-President)

13 Apr 2015 · Paper Industry; Competitiveness

Meeting with Sarah Nelen (Cabinet of First Vice-President Frans Timmermans)

16 Mar 2015 · Circular Economy

Meeting with Aurore Maillet (Cabinet of Vice-President Karmenu Vella), Heidi Jern (Cabinet of Vice-President Jyrki Katainen)

16 Mar 2015 · Circular Economy

Meeting with Nele Eichhorn (Cabinet of Vice-President Cecilia Malmström)

5 Mar 2015 · Situation and developments in the European Paper Industry

Meeting with Elżbieta Bieńkowska (Commissioner) and

23 Feb 2015 · Paper industry challenges

Meeting with Miguel Arias Cañete (Commissioner) and

19 Feb 2015 · Competitiviness, Energy Union and ETS review

Meeting with Kaius Kristian Hedberg (Cabinet of Commissioner Elżbieta Bieńkowska), Rolf Carsten Bermig (Cabinet of Commissioner Elżbieta Bieńkowska)

9 Feb 2015 · Introductory meeting

Meeting with Aura Salla (Cabinet of Vice-President Jyrki Katainen)

3 Feb 2015 · Paper Industry

Meeting with Silvia Bartolini (Cabinet of Vice-President Miguel Arias Cañete)

13 Jan 2015 · NER 400

Meeting with Shane Sutherland (Cabinet of Commissioner Phil Hogan)

16 Dec 2014 · Forestry