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European Confederation of Woodworking Industries

CEI-Bois

The European Confederation of Woodworking Industries represents the industrial wood sector across Europe.

Lobbying Activity

European wood industry urges realistic circularity targets in Taxonomy

3 Dec 2025
Topic — The consultation reviews the EU Taxonomy Environmental Delegated Act to update technical screening criteria.
Message — The organization calls for lower recycling thresholds for wood products and financial aid for small businesses. They also want mandatory reporting of the carbon stored in buildings.123
Why — Lower thresholds allow wood products to more easily qualify for green investment status.45
Impact — Recycling firms lose the regulatory pressure needed to expand secondary wood infrastructure.6
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European woodworking industry urges bio-based focus for circularity

5 Nov 2025
Topic — The European Commission is seeking feedback on the forthcoming Circular Economy Act proposal.
Message — CEI-Bois requests that renewable content be recognized as circular input on equal footing with recycled content. They propose phasing out fossil-based materials and establishing mandatory targets for bio-based alternatives. Furthermore, they demand that extended producer responsibility schemes exclude construction products.123
Why — This framework would drive market adoption of wood products while preventing additional costs for manufacturers.45
Impact — Producers of fossil-based materials would lose market dominance through mandatory phase-outs and increased competition.67
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Woodworking industry demands recognition of biogenic carbon storage

30 Oct 2025
Topic — Establishing a Union framework for calculating life-cycle global warming potential.
Message — CEI-Bois requests that carbon stored in wood products be explicitly recognized and reported separately in building assessments. They advocate for dynamic life cycle assessments to reflect the climate benefits of long-lived timber. Additionally, they call for mutual recognition of environmental data across all EU member states.123
Why — This would improve wood’s market competitiveness by highlighting its carbon storage benefits.45
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European wood industries demand safeguards for raw material supply

30 Sept 2025
Topic — The consultation explores creating nature credits to finance conservation and restoration activities.
Message — CEI-Bois calls for nature credits to act as a complementary tool reinforcing sustainable forest management. They demand safeguards to prevent unintended reductions in wood supply that would weaken the bioeconomy.12
Why — This ensures a stable feedstock supply and protects the wood industry's competitiveness.3
Impact — Strict conservation measures would reduce the volume of wood available for industry.4
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Woodworking industry urges removal of saw logs from carbon rules

22 Sept 2025
Topic — The EU is establishing methodologies to certify permanent carbon removal activities.
Message — CEI-Bois demands removing rules that allow saw logs to be burned for carbon credits. They argue this diverts quality feedstock away from better solutions like physical wood products. The industry also calls for tighter implementation to prevent carbon leakage from biochar.12
Why — This would ensure wood processing companies maintain access to affordable timber supplies.3
Impact — Bioenergy firms lose the ability to use high-quality timber for carbon credits.4
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European woodworking industries urge timber-based solutions for affordable housing

17 Sept 2025
Topic — A consultation on the European Commission's strategy to improve productivity in housing construction.
Message — CEI-Bois recommends mainstreaming industrialized construction using bio-based materials to address the housing crisis. They call for regulatory simplification, faster permitting, and the modernization of national building codes. Additionally, they advocate for monetizing carbon stored in buildings through carbon storage credits.123
Why — This would drive demand for timber products and reduce compliance costs for wood-based businesses.4
Impact — Producers of carbon-intensive building materials face reduced demand as the strategy prioritizes bio-based alternatives.5
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Meeting with Christian Holzleitner (Head of Unit Climate Action)

15 Sept 2025 · Meeting with CEI_BOI and DG CLIMA on paragraph 4.3.3 of the Annex of the Delegated Act on Permanent Carbon Removals

Woodworking industry calls for wood-centric EU Bioeconomy Strategy

23 Jun 2025
Topic — This consultation addresses solutions for a circular and climate neutral EU bioeconomy strategy.
Message — CEI-Bois calls for the integration of wood products and carbon credits into the strategy. They also propose a fund to help smaller businesses with standardization and certification costs.12
Why — Proposed measures would reduce compliance costs for SMEs and incentivize private forest investment.3
Impact — Energy-intensive material producers like steel and concrete firms face increased competition and substitution.4
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Response to European Affordable Housing Plan

3 Jun 2025

The European Confederation of Woodworking Industries (CEI-Bois) is thankful for the opportunity to participate in this Call For Evidence for the European Affordable Housing Plan. We believe that it is necessary to bring about a long overdue wave of new affordable and sustainable construction as the main answer to alleviating the EUs housing crisis. In view of this, we are proposing two solutions to increasing the supply of affordable and sustainable housing in Europe: a) Advancing the use of wood in construction; b) Mainstreaming industrialised construction, in particular offsite timber construction. Our detailed contribution can be found in the attachment, explaining the benefits of our proposed solutions, the challenges to their wider adoption, as well as suggestions on how these could be overcome.
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Meeting with Stefan Moser (Head of Unit Energy)

20 May 2025 · Exchange of views on housing policy, including the role of wood in the construction and renovation of houses

Meeting with Barbara Bonvissuto (Director Internal Market, Industry, Entrepreneurship and SMEs)

30 Apr 2025 · Ongoing discussions on a potential reporting format for the emissions of Volatile Organic Compounds (VOC) from construction products into indoor air.

Meeting with Taru Haapaniemi (Cabinet of Commissioner Christophe Hansen) and European Organisation of the Sawmill industry

13 Mar 2025 · Availability of raw material (logs) in the coming years

Meeting with Maroš Šefčovič (Executive Vice-President) and European farmers and

14 Mar 2024 · High level dialogue on forest-based bioeconomy

Response to Delegated Regulation under the Construction Products Regulation (EU) No 305/2011 (wood panelling)

22 May 2023

The European Confederation of Woodworking Industries (CEI-Bois) would like to submit its feedback on behalf of Europes timber industry as part of the European Commissions public consultation on the draft text Construction products reaction-to-fire performance of wood panelling and cladding (amendment). It is the view of the European woodworking industries that, prior to the final adoption of the proposed document, several points would need to be addressed, as outlined in the attached document.
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European Woodworking Confederation Seeks Realistic Green Building Standards

28 Apr 2023
Topic — The EU initiative establishes technical standards for identifying environmentally sustainable economic activities for investment purposes.
Message — The group requests lowering recycling targets and providing financial aid for small business carbon assessments. They also seek to align chemical safety limits with updated European Union environmental regulations.123
Why — This would reduce compliance costs and maintain access to sustainable investment markets for wood.4
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Response to European Year of Skills 2023

14 Dec 2022

The European Confederation of the Woodworking Industries, CEI-Bois, believes that skills are key for Europes growth, inclusiveness, and future prosperity. For this reason, CEI-Bois welcomes by the announcement of President Von den Leyer during her State of the Union address to tackle the shortage of skills in Europe by putting an emphasis on skills, investment on professional education, upskilling and attracting the right skills to help companies and strengthen Europe's growth by: 1. Investing in better skills 2. Making skills more relevant 3. Matching aspirations of companies and people 4. Attracting people from third countries We welcome the significant EU funding and technical support available to support Member States' investment in up- and reskilling. A European approach is important for mobility, benchmarking, best practices, recommendation, and PR campaigns. Member States and the Union should work towards developing a coordinated strategy for employment and particularly for promoting a skilled, trained, and adaptable workforce responsive to the economic and technological changes. Nevertheless, CEI-Bois stands for subsidiarity in education & labour market due to the correlated great differences between Member States. The woodworking industry encompass a wide range of professions, marked by innovation processes on different qualities and levels. The woodworking industry is an important player when it comes to meeting the EU Green Deal goals and ambitions by contributing to a low-carbon circular bioeconomy. Wood is a natural renewable bio-based resource with carbon storage properties and has an important role in leading the transition to a sustainable, green, and carbon-neutral Europe. The availability of well skilled personnel all over the processing chain is a priority for our industry. A highly qualified workforce, able to innovatively integrate new skills and competences - especially needed for the digital and ecological transition- into their traditional work processes, able to work with different materials, making intelligent use of the possibility of new combinations, is vital for a competitive woodworking. Therefore, it is essential to make sure the availability of well skilled personnel all over its processing chain.
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Response to Review of the Construction Products Regulation

12 Jul 2022

Please find attached the feedback of the European Confederation of Woodworking Industries (CEI-Bois) on the proposal for a revision of the Construction Products Regulation.
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Meeting with Elena Montani (Cabinet of Commissioner Virginijus Sinkevičius) and Confederation of European Paper Industries

24 Jun 2022 · to discuss the Nature Restoration Law proposal

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

24 Jun 2022 · Nature Restoration Law proposal

European wood industry urges pragmatic sustainability due diligence rules

23 May 2022
Topic — The EU is consulting on a directive for corporate sustainability due diligence.
Message — The industry requests a pragmatic approach that recognizes existing certifications. They suggest limiting mandatory due diligence to first-tier suppliers.12
Why — This would maintain their competitiveness by preventing an overload of administrative tasks.3
Impact — Communities affected by abuses in deep supply chains lose oversight protections.4
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Woodworking industry seeks EU certification for carbon-storing timber

2 May 2022
Topic — The EU is developing a regulatory framework to certify and monitor carbon removals.
Message — CEI-Bois requests a standardized EU framework that rewards carbon storage in bio-based products. They also suggest expanding eligible categories to include materials like wood-based insulation.12
Why — A robust certification scheme would significantly expand market opportunities for the timber industry.3
Impact — Producers of carbon-intensive materials like cement may lose business to wood-based alternatives.4
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Meeting with Mauri Pekkarinen (Member of the European Parliament)

13 Jan 2022 · Discussion on forests

Response to Restoring sustainable carbon cycles

7 Oct 2021

The European Confederation of the Woodworking Industries and the European Organisation of the Sawmill Industry believe that in order to meet the Paris Agreement target to keep global warming “well below 2°C”, phasing out fossil emissions should remain a priority in Europe. To achieve net zero by 2050, a multi-faceted approach will be needed, including through carbon removals and storage. The European Forest Based Industry plays an important role in fighting climate change, by helping to achieve the balance between carbon sequestration, sustainable use of the forests’ resources to substitute for fossil-based products, and carbon storage in products. In this respect, it is essential to ensure that safeguards are put in place, so that increased carbon removals in the forestry sector are not used to compensate for continued high levels of fossil-based emissions in other sectors. The use of the forest as supplier of raw materials is important. In fact, wood offers a simple way to reduce the CO2 emissions that are the main cause of climate change, through the carbon storage effect of wood products and the substitution for carbon-intensive materials. Technological carbon removals such as Carbon Capture and Utilisation (CCU) or Bioenergy with Carbon Capture and storage (BECCS) could lead to negative emissions in coming decades. This requires technological development and scale-up to make carbon removals and utilization profitable to industries. The promotion of BECCS could lead to the creation of a voluntary carbon market that is coherent with current and comprehensive climate policy. Those are additional sinks which are easier to delimit outside of double accounting, a situation where two parties (eg. country and a company) claim the same carbon removal. Active forest management brings climate benefits by enhancing both the forest sink and amount and the quality of wood, which makes it fit for construction and other products substituting those with high CO2 emissions. The forest-based sector is one of the best providers of substitutions of fossil-based fuel sources, a producer of bio-based raw materials and a place for resource-efficient recycling. The use of sustainably managed forests’ resources and residues for construction, renovation, furniture, but as well for energy, bioplastics, textiles, biomedical products are central to transitioning to a sustainable, low-carbon society. Moreover, reusing and recycling forest-based products is an essential part of circular economy which prolongs the lifespan of the carbon in products. Wood construction has potential in developing voluntary carbon markets. The many forest owners will also benefit if the demand for climate-friendly timber construction increases. Forest damages can cause significant reductions in annual sinks and, at worst, reduce forest carbon stocks. Therefore, forests are not well-suited source to the needs of the voluntary carbon market. The stability/permanence of carbon stocks is very uncertain as climate change continues. They are stable in the models, but not in real life. Active sustainable forest management is crucial for disturbance risk prevention. Investments in sustainable forest management and utilization of wood are the best guarantee of ensuring the resilience in multifunctional European forests and climate change mitigation.
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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

Meeting with Mauri Pekkarinen (Member of the European Parliament)

13 Jan 2021 · Discussion on forests

Response to Climate change mitigation and adaptation taxonomy

17 Dec 2020

CEI‐Bois, the European Confederation of the Woodworking Industries, numbers 16 national organizations, 4 European Sector Federations as well as 1 Private Industrial Group. It is the organization backing the interests of the whole industrial European wood sector: close to 180.000 companies generating an annual turnover of 152 billion euros and employing 1 million workers in the EU. Please find our contribution attached.
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Response to EU Forest Strategy

1 Dec 2020

Please find the contribution of CEI-Bois in the document attached. CEI-Bois is the European Confederation of the Woodworking Industries. It counts as members 16 national organizations, 4 European Sector Federations as well as 1 Private Industrial Group. It is the organization backing the interests of the whole industrial European wood sector: close to 180.000 companies generating an annual turnover of 152 billion euros and employing 1 million workers in the EU.
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Response to Land use, land use change and forestry – review of EU rules

26 Nov 2020

The European Woodworking Industry is fully behind the objectives of the European Green Deal and offers the potential to decarbonise key economic sectors such as construction. Timber buildings are globally recognised as key allies in climate change mitigation strategies: they represent an immediate way to achieve long-term carbon storage in products - as mentioned in the 2020 Circular Economy Action Plan - and they allow to reduce the use of energy-intensive materials, which could lead to 100 Mt CO2 savings in Europe, according to a recent European Forest Institute report. At the time when the Commission wants to increase the ambition to intermediate 2030 targets, including in the LULUCF sector, the following suggestions should be taken into consideration: - A closer look at the accounting methodologies shows that these do not adequately value the climate benefit of harvested wood products. Wood products have many advantages over non-wood alternatives. The manufacture of wood products requires less fossil fuel than non-wood alternative building materials such as concrete, metals, or plastics. Moreover, use of wood products also results in emission saving where wood processing residues are burned for energy displacing fossil fuel. By nature, wood is composed of carbon that is captured from the atmosphere during tree growth. These two effects—substitution and storage—are why the carbon impact of wood products is favourable. - The substitution of fossil-based materials with bio-based ones (e.g. use of wood in construction and in renovation) should be better incentivised, as also acknowledged in the Inception Impact Assessment. While anthropogenic emissions and removals in the forest are captured in current the LULUCF accounting framework, it is more difficult to visualise the mitigation effect of forest-based substitution of fossil materials. This makes it complex to assess the climate benefit of circular bioeconomy in an integrated way and its enabling potential. According to some estimates the overall substitution effect of the European forest-based industries amounts to 410 Mt CO2 e/yr. Such benefit should be visible and explicitly recognised in the relevant sectors, such as construction and renovations. - One way to incentivise the use of long-lived harvested wood products could be by issuing carbon credits for the carbon stored in HWP or for emissions forgone for using wood rather than fossil-based materials. Credits should be granted on the basis of all emission savings associated with wood products, storage during the life time of the product and after disposal in landfill. - On the policy options suggested in section B: regardless of the option, the impact on harvest levels and the raw materials availability for the bioeconomy should be carefully assessed. In general, caution should be used in considering forest sinks as a way to offset emissions from other sectors, since ageing forests are vulnerable to climate change themselves, and active forest management is needed to prevent the ever-increasing damages caused by fires, storms, pests and other disturbances. Additionally, the carbon certification system should not indirectly increase the costs of raw material. For this reason, the European woodworking Industry calls for an impact assessment of the expected carbon certification system on the EU forest-based Industries. - Explore the potential of agroforestry specifically and more trees on farms generally both in significant woodlands and in hedgerows, along boundaries etc. The purpose of more agroforestry and more trees on farms generally would be drive up the amount of timber and woody feedstock available for the bioeconomy in its widest sense. The full statement with hyperlinks is available in attachment.
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Response to Sustainable Products Initiative

16 Nov 2020

Please see the document attached.
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Response to Commission Delegated Regulation amending Annex IV to the LULUCF Regulation

14 Sept 2020

CEI-Bois, the umbrella Confederation representing the European Woodworking Industry, wishes to submit its comments on the Commission Draft Delegated Regulation amending Annex IV to Regulation (EU) 2018/841 of the European Parliament and of the Council as regards the forest reference levels to be applied by the Member States for the period 2021-2025. • As a Member of the Expert Group on Land Use, Land Use Change and Forestry (LULUCFEG) with Observer status, CEI-Bois expresses its appreciation for the transparent and participatory process that led to the establishment of forest reference levels for EU Members States. The Confederation does not wish to raise objections to the final FRLs as proposed in the Draft Delegated Regulation. • At the same time the Confederation reminds that the full climate mitigation potential of the forest sector and forest-based industry is best pictured by taking into account the action of forests and harvested wood products as a carbon sink and carbon stock, and the substitution effect of wood products. According to a recent study the overall climate effect of the European sector amounts to -806 million tons of carbon dioxide equivalents annually, corresponding to 20% of all fossil emissions in the EU, and calculated as follows: sum of net sink in forests + prevented fossil emissions by substituting fossil-based materials and energy – emissions caused in the forest sector value chain. • Therefore, the Confederation encourages the Commission to better recognise the full mitigating potential of the EU forest-based sector in the framework of future policy on the contribution of the land use and forestry sectors to the climate objectives of the Green Deal, including the upward revision of the 2030 climate targets. This would allow to better make use of the “enabling” potential of the bioeconomy, as defined in the Taxonomy Expert Group Final report (Annex I, p.42). • One suggested option for better highlighting the role of Harvested Wood Products (HWP) is to present both figures (Forest Reference Levels with and without HWP) in the table annexed to the final Delegated Regulation, accompanied by a definition of both categories. CEI-Bois is the European Confederation of the Woodworking Industries. It represents 21 European and National organisations from 15 countries and is the body backing the interests of the whole industrial European wood sector: more than 180.000 companies generating an annual turnover of 142 billion euros and employing 1 million workers in the EU. Please see the statement attached for more details.
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Response to Environmental claims based on environmental footprint methods

31 Aug 2020

CEI-Bois fully supports the ambition of the EU to reduce significantly the environmental footprint of products consumed in the Union and to attain the carbon neutrality target by 2050. CEI-Bois also agrees with the aim of moving towards a more harmonised approach for providing reliable product environmental information. For what concerns specifically the building sector – one with the highest impact in terms of carbon emissions and resource use - the wood industry supports the mainstreaming of LCA-based approaches in product policy, and welcomes the suggestion to shift towards a “whole life carbon thinking” approach put forward in the Commission Document “Sustainable Products in a Circular Economy - Towards an EU Product Policy Framework contributing to the Circular Economy”. More recently, in the 2020 Circular Economy Action Plan, the European Commission has announced the intention to explore “the appropriateness of setting of carbon reduction targets and the potential of carbon storage” in buildings, which is also strongly encouraged by the wood industry. To do so, the first step is to perform LCA analysis of construction products with an harmonised methodology. To this aim, if any legal obligation is to be imposed, the wood industry recommends to use the revised EN15804, which was revised to align with the PEF methodology, and to use PEF as a complementary method for other products categories (Option 2). This would minimise the costs that the industry would incur should it need to adapt to a new methodology for producing Environmental Products Declaration. This factor becomes even more relevant considering that the vast majority of companies in the sector are small and medium enterprises. Another relevant advantage is that in EN15804 biogenic carbon is displayed for each part of the life cycle and so the quantity stored in the product is shown and can be used for further calculation. It furthermore provides a platform for presenting the benefits of construction products to other levels: calculations in the standard for the building level, potentially machine readable EPDs and Building Information Modelling (BIM). For this a breakdown of impacts from the product life cycle is required to make bespoke calculations. PEF Declarations, or a database based on them, cannot provide enough granular data to supply this demand for BIM as assumptions regarding the life cycle have already been enforced unless this methodology can be amended first. Finally, customers use digital platforms to compare and make decisions based on a multitude of factors. The EU should support the development of EPD information and digital platforms where this information is made broadly available via API (Application programming interface) for decision making tools and methodologies like BIM. The EPD information on the database is easy accessible via the GTIN Barcode identification of the product; for example, it could be collected and interpreted via App on the smartphone.
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Response to Commission Communication – "Renovation wave" initiative for the building sector

8 Jun 2020

CEI-Bois welcomes the European Commission’s announcement to launch a “Renovation wave” initiative as part of the EU Green Deal. The European Woodworking Industry is a strong advocate of the role of sustainable construction for a climate-neutral European economy and supports the use of timber construction as an immediate way to achieve long term carbon storage in products, as also recognised in the 2020 Circular Economy Action Plan. It is estimated that timber construction could store between 10 million to 700 million tons per year, while also reducing emissions due to the production of alternative materials such as steel and concrete, according to a recent study . Wood applications also have a role in the renovation of the existing building stock. First of all, wood is an inherent insulant, so the ideal material for the low energy building: wood’s unique cellular structure makes it 10 times more insulating than concrete, 400 times more than steel and 700 times more than aluminium. A 2.5cm thick timber wall panel provides better thermal resistance than an 11.5cm brick wall . Consequently, besides timber producing better insulating walls, multi-glazed windows perform better in wood frames, while timber floors also provide better thermal insulation than concrete. Secondly, wood products used in renovation require less energy in manufacturing and transport, thereby reducing the final embodied energy in the building. Thirdly, timber can be used in roof extensions or for adding storeys to an existing building. This application proves to have a range of advantages over alternatives. Thanks to their low weight, civil engineers often choose wood for top-ups, because the load-bearing structure and the foundation do not usually have to be reinforced. Prefabricated wooden elements can be lifted to the top floor with a mobile crane. This reduces the effort on site and the rooms can be occupied quickly. In consequence residents and the neighbourhood are hardly disturbed by noise and dust. One recent example is the Green House office building in central London, where the combination of retrofitting and extension of a 1960 concrete block with cross laminated timber and glue-lam allowed to provide additional space while decreasing GHG emissions by half . Recommendations: - CEI-Bois welcomes the initiative and suggests that incentives are directed at renovation of both residential and non-residential buildings (such as offices and retail buildings); - CEI-Bois supports the proposal to foster deep renovation of buildings while also looking at complementary dimensions to energy efficiency such as climate resilience and circularity. In particular, the Renovation strategy should not just focus on the energy performance of buildings during operation but should also take into account the embodied carbon of the products used in renovation works, taking as inspiration the targets set by the World Green Building Council: “By 2030, all new buildings, infrastructure and renovations will have at least 40% less embodied carbon with significant upfront carbon reduction, and all new buildings are net zero operational carbon. By 2050, new buildings, infrastructure and renovations will have net zero embodied carbon, and all buildings, including existing buildings must be net zero operational carbon”. - Finally, the Strategy should tackle the issue of renovation not only as a way for improving the energy performance of the building stock, but also as an occasion for promoting the densification of the existing settlement areas, that is, generating more living space without using mor land. (see paper attached for references and hyperlinks)
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Response to Climate change mitigation and adaptation taxonomy

20 Apr 2020

CEI-Bois welcomes the fact that the sustainable finance initiative recognizes the significant contribution provided by the forest sector to the overall objectives of a carbon neutral Europe, a commitment that is also displayed in our “Forest-based Industries 2050 Vision”. In fact, the full climate mitigation potential of the forest sector is best achieved by taking into account both the action of forests and harvested wood products as a carbon sink and carbon stock, and the substitution effect of wood products. For example, timber buildings are key allies in decarbonising construction: 1m3 of wood stores almost 1 ton of CO2 (average density) and allows to save on average another 1 ton of CO2 compared to functionally equivalent materials. This is partially recognised in the TEG Final Report, Annex I, where the suggestion is made to assess the “enabling” potential of long-lived and harvested wood products for climate mitigation. CEI-Bois recommends to follow this suggestion. On Forestry criteria, CEI-Bois recommends using the forest biomass sustainability approach (risk-based approach) of the recast of the Renewable Energy Directive (REDII), which relies on Member State legislation as a first step instead of developing an additional new system of screening criteria for forests and forestry. As regards the GHG balance, the forestry sector’s positive contribution to the EU climate and energy goals must be considered in the context of the entire life cycle phases of any given forest and the multifunctionality of forest management. In this context, assessment should be done at country level, in line with the LULUCF Regulation. This would also prevent additional burden and inconsistencies in the legislative framework concerning forestry in Europe. On Construction criteria, Embodied GHG emissions metric should be used to get a true picture of a building’s energy and carbon impact. This should account for GHG emissions embodied into building materials during production, transportation and construction (modules A1-A5) and end of life (modules C1-C4 and D) according to CEN/TC350, expressed as kgCO2eq/m2. Available tools are specific or generic Environmental Product Declarations for Construction Products as regulated by EN 15804:2012+A1:2013/FprA2.
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Response to 2030 Climate Target Plan

14 Apr 2020

The European woodworking industry is fully behind the objectives of the European Green Deal. This is clearly displayed in the Forest-based Industries 2050 Vision, in which the forest-based value chains commit to climate neutrality, circular bioeconomy, resource efficiency, economic growth and employment creation, and lay out pathways to reach those goals. Therefore, we welcome the fact that the European Commission will assess, among other things, “how the EU can increase the absorptions of CO2 emissions over time, including in its natural sinks and the role of biomass-based products and nature based solutions” within a 2030 horizon. To this aim, CEI-Bois would like to put forward some remarks: • The full climate mitigation potential of the forest sector is best achieved by taking into account both the action of forests and harvested wood products as a carbon sink and carbon stock, and the substitution effect of wood products. While anthropogenic emissions and removals in the forest are captured in the LULUCF accounting framework, it is more difficult to visualise the mitigation effect of forest-based substitution of fossil materials. This makes it complex to assess the climate benefit of circular bioeconomy in an integrated way and its “enabling” potential, as defined in the Taxonomy Expert Group Final report (Annex I, p.42). Such potential should be explicitly recognised in the relevant sectors, such as construction. • Timber buildings are key allies in climate change mitigation strategies. The average impact of building with 1 ton of wood instead of 1 ton of concrete could lead to an average reduction of 2.1 tons of carbon dioxide emissions over the complete life cycle of the product (including use and disposal), as recognised in the 2018 EU Bioeconomy Strategy. According to a recent EFI briefing1, increasing the market share of wood construction from current level to 20% could lead to 100 Mt CO2 savings in Europe. The Impact Assessment should therefore evaluate the potential contribution of wood products in the construction sector at EU level, using embodied carbon metrics. • Forest sinks should not be seen as a way to offset fossil emissions from other sectors. Leaving fossil materials into the ground is a guaranteed way to prevent CO2 emissions. In fact, ageing forests are vulnerable to climate change themselves, and active forest management is needed to prevent the ever-increasing damages caused by fires, storms, pests and other disturbances. • Finally, the economic and social impact of climate policies should be carefully assessed when evaluating the role of forests and forest-based sector towards the 2030 climate goals, and especially in the light of the economic shock caused by the current Covid-19 sanitary crisis. Today the forest-based sector represents around 420.000 enterprises for a total turnover of over 520 billion euros and around 3,5 million workers; the woodworking industry alone includes 170.000 companies and employs 1 million workers. Recovery plans in Europe should conjugate the fight against climate change with safeguards to employment and competitiveness of businesses.
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Response to Illegal logging – evaluation of EU rules (fitness check)

28 Feb 2020

CEI-Bois wishes to provide the inputs of the European Woodworking Industry to the EU Timber Regulation and FLEGT fitness check. EU Timber Regulation The EU added value of this instrument is undeniable: only a uniform set of rules valid for all EU countries and a coordinated enforcement can make an impact against illegal logging worldwide. However, order to be effective, the Regulation must ensure a real level playing field between operators and countries and minimize the risk of loopholes. This can be done in two ways: 1) Extend the scope of the EU Timber Regulation to include all wood products, printed products and furniture products currently outside the scope, except for recycled materials and wood packaging for transport. This would increase the coverage of imports of “high-risk” wood by almost 30%1 and would deliver the highest environmental benefit. This measure has been called for by the entire European Forest-based sector in an open letter signed on July 2018. 2) Ensure a consistent implementation and enforcement by EU Member States. Different levels of stringency of the controls performed by Competent Authorities lead to an uneven playing field and ultimately undermine the goal of the Regulation. Finally, improved communication to operators, e.g. through guidelines, can be helpful to improve due diligence systems. More inspections can increase the effectiveness of the instrument, but only at the condition that it is clear what is expected from the operators. FLEGT: The woodworking industry fully supports the FLEGT system and recommends the EU to speed up the process with producing countries in order to increase the volumes of FLEGT-licensed wood available for the European market. Moreover, EU also needs to promote FLEGT and to increase the awareness about this system, to keep motivation high in producing countries involved in Voluntary Partnership Agreements negotiations or implementation. For example, a study by the International Market Monitor reveals that misconceptions about tropical timber persist in public procurement bodies and that the understanding of the benefits of Voluntary Partnership Agreements (VPAs) and FLEGT is still limited. Increasing the recognition of FLEGT licensed timber in national Public Procurement policies as a mean of verification of compliance with legality requirements would send a positive signal to countries engaged in VPA processes.
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Response to Evaluation of six Euro-Med FTAs

18 Dec 2017

Dear Madam, Dear Sir, Please note that CEI-Bois, the European Confederation of the Woodworking Industries, fully supports the arguments set by its member EOS, the European Organization of the Sawmill industry. Should you have any question, please do not hesitate to contact us. Best regards, Isabelle Brose
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