European Organisation of the Sawmill industry
EOS
The European Organisation of the Sawmill Industry (EOS) is a Brussels-based non-profit association representing the interests of the European sawmilling sector and the benefits of its products.
ID: 024776016336-52
Lobbying Activity
Response to Roadmap towards Nature Credits
30 Sept 2025
The European sawmill industries are concerned about the absence of a clear framework on how nature credits will be developed in practice. Without proper safeguards, such schemes risk undermining the availability of raw materials for the wood-processing industries, which are the backbone of Europes bioeconomy. Instead, nature credits should be designed as a complementary instrument that strengthens both objectives: building more resilient forests and ensuring a reliable, sustainable, and even increasing supply of renewable raw materials. Wood processing industries are strongly depended from wood as this is the only raw material that they process. For this reason they require stable feedstock volumes to plan production, maintain employment, and meet contractual obligations. A sudden or widespread reduction in raw material availability can lead to supply bottlenecks, increased costs, and pressure to force our industries to source timber from other regions, potentially undermining the EU objective to be self-sufficient on raw material supply. Achieving decarbonization ambitions requires widespread switching from fossil carbon-containing feedstocks to sustainable low carbon solutions. Wood directly contributes to climate change mitigation by storing CO2 during growth, which remains sequestered in its products, and by substituting energy intensive materials. EOS considers essential that any nature credit schemes shall balance environmental objectives with the sustainable use of the forests while ensuring that wood processing industries continue to have access to the raw materials they need. Any EU framework for nature credits should be designed in full coherence with the principles of Sustainable Forest Management while including safeguards to prevent unintended reductions in wood supply that would weaken the EUs bioeconomy, undermine rural jobs, and increase dependency on imports. The multifunctional role of forests must remain at the core of EU policy. EOS stands ready to contribute to a balanced framework that supports both environmental and industrial objectives, ensuring that Europes forest-based industries continue to provide low-carbon solutions and maintain global competitiveness. - See full position, in the attached file.
Read full responseResponse to Towards a Circular, Regenerative and Competitive Bioeconomy
23 Jun 2025
The European Sawmill Industry urges the European Commission to fully integrate wood and wood-based products into the EU Bioeconomy Strategy, recognising wood as a key renewable, carbon-storing material essential for achieving climate neutrality, economic growth, and strategic autonomy. To this end, the document - here attached - presents a comprehensive set of policy recommendations that include: Prioritising wood in construction and public procurement to enhance carbon storage and reduce emissions; Establishing dedicated support mechanisms, such as a Hardwood Standardisation Fund and a WoodWorks Academy to boost innovation, education, and SME participation; Recognising biogenic carbon and the climate benefits of Harvested Wood Products (HWP) in EU climate accounting frameworks; Ensuring Sustainable Forest Management (SFM) is aligned with bioeconomy goals and not undermined by conflicting environmental regulations; Maintaining flexibility for the use of sawmill residues, avoiding prescriptive bans; Conducting urgent research on timber demand and availability to ensure future biomass supply aligns with climate and industrial policy targets. Overall, the paper calls for coherent, enabling, and science-based EU policies to unlock the full climate and economic potential of the forest-based sector within the bioeconomy.
Read full responseMeeting with Taru Haapaniemi (Cabinet of Commissioner Christophe Hansen) and European Confederation of Woodworking Industries
13 Mar 2025 · Availability of raw material (logs) in the coming years
Meeting with Joan Canton (Cabinet of Commissioner Thierry Breton) and Confederation of European Paper Industries and
4 Jun 2024 · Discussion on implementation of the EU Deforestation regulation
Meeting with Eero Heinäluoma (Member of the European Parliament)
31 Jan 2023 · Current EU issues for Sawmill industry
Meeting with Helena Braun (Cabinet of Executive Vice-President Frans Timmermans), Stefanie Hiesinger (Cabinet of Executive Vice-President Frans Timmermans) and
31 Aug 2022 · Implementation of the EU Forest Strategy for 2030, and the LULUCF proposal
Meeting with Helena Braun (Cabinet of Executive Vice-President Frans Timmermans) and Confederation of European Paper Industries and European Confederation of Woodworking Industries
24 Jun 2022 · Nature Restoration Law proposal
Response to New EU Forest Monitoring and Strategic Planning Framework
5 May 2022
Extract: The European Organisation of the Sawmill Industry supports the creation of an European forest monitoring system as tool swiftly react to ever-growing pressure from climate change on Europe's forests and provide additional knowledge to Members States in prepare their own strategic plans.
EOS welcomes an the creation of an EU Forest Monitoring System that is reconciled with existing national, European and international systems and encourage the exchange of information on the condition of harmonised and relevant forest parameters. Globally, the decade 2010-2019 was the warmest decade on record and strongly demonstrated the legacy of the continuously rising GHG concentration on our climate system and the various ecological and economic systems that are based on the environmental conditions. The observed temperatures increase with extreme summer heat and drought already started to alter forest ecosystems globally in manifold ways. Also, changes in European forests already have wide ranging consequences for the manifold forest ecosystem services and the forest and timber related bio-based economy. Throughout the last decade European forests experienced a series of abiotic and biotic disturbances which left unprecedented damages.
.....It should be noted as well that detailed forest inventories are already being conducted regularly in almost all European countries. It is therefore important that any effort to harmonise EU forest data does not lead to:
• redundant or parallel inventory systems, which are inefficient and could lead to inconsistencies.
• deny national competent authorities and managers the expertise to monitor, strategically plan and manage their forests;
• become a tool to apply “one size fits all approach” in forest managements.
The Forest Monitoring System should be the basis for a vibrant network, coordinated independently as an inter-service platform for all interested stakeholders, actors, and interested parties. The coordination team should be connected with all relevant units, expert specialist groups, and stakeholders. It is of utmost importance that the governance and neutral operation of the European Monitoring System are guaranteed while the EU Commission services should have a supervisor role. Finally, the forest monitoring system should be a tool aiming at facilitating long-term investments by the forest based industries having these a better knowledge of the forests condition.
Read full responseMeeting with Joan Canton (Cabinet of Commissioner Thierry Breton) and European farmers and
8 Nov 2021 · Forest based industries
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 European Bioeconomy Policy: Stocktaking and future developments
8 Aug 2021
The European Confederation of the Woodworking Industries and the European Organisation of the Sawmill Industry fully support the proposal of the EU Commission to publish an update of the Bioeconomy Strategy.
To be noted: comments reported below refer only to the forest-based bioeconomy.
The bioeconomy aims to contribute to climate protection, reduce energy production from fossil fuels, and reduce CO2 emissions. The bioeconomy can also produce products that store carbon. The benefits from forest products to a sustainable development and green growth have been widely acknowledged. The Paris Agreement and the recently adopted EU Forest Strategy highlight the contribution of forests and forest products to climate change mitigation and adaptation. Sustainable and legally harvested wood products play a key role in strategies for transitioning to low carbon economies. The forest-based sector is considered to be one of the best providers of possible 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 a bioeconomic transition.
In order to develop a new updated Bioeconomy European Confederation of the Woodworking Industries and the European Organisation of the Sawmill Industry emphasises the following aspects:
• the importance of an inclusive governance for building and implementing sustainable bioeconomy strategies;
• the need for policy coherence in order to ensure a sustainable trajectory for the bioeconomy and creating green jobs, improving quality of life and boosting a green growth;
• the importance of participatory process when/if defining sustainability indicators;
• the need to develop a comprehensive strategy aiming at ensuring a sustainable wood supply for the EU forest bio-based industries in respect of the EU environmental and social objectives. Moreover the impact on raw materials provision of environmental and climate policies should always be assessed;
• investments in R&D are needed to continuously increase material efficiency, applications and wood by-products uses; it is necessary to identify mechanisms that are needed to promote the development of new products and pathways to scale up new products;
• reducing bureaucratic procedures to encourage forest enterprise activities;
• the importance of education and training to build new skills for the forest based sector, particularly in rural areas;
• the interest of public/private partnerships to accelerate the rise of wood-based bioeconomy;
• the importance of facilitating a positive public acceptance of sustainable forestry and production and increasing awareness of its benefits for the environment, the society and the economy;
the need to engage youth to increase interest and participation in the forest bio economy.
Bioeconomy can bring positive results particularly in the construction and renovation sectors. A lot of CO2 is produced in the housing and construction industry and this is something that must change.
See more in the attached file.
Read full responseResponse to Detailed implementing rules for the voluntary schemes recognised by the European Commission
26 Jul 2021
The European Organisation of the Sawmill Industry (EOS) supports the commendable drive of the EU institutions to increase the role that renewable energy plays in the EU energy mix. We believe that bioenergy was, is and must continue to be a vital renewable energy source: bioenergy is one of the most cost-efficient and versatile options we have and can complement variable renewables such as solar and wind power in order to bring stability to the grid. The European Sawmill Industries operates according the resource efficiency principle: Wood residues (derived from a manufacturing process), are commonly used for basic fuel purposes in manufacturing facilities (to produce energy through the burning of this waste) but can also be used as sources of raw material bioenergy processes.
Looking at the Commission proposal, regretfully, it should be noticed that the document includes several deviations from the Renewable Energy Directive text and could result in excessive administrative burden for market operators. For this reason, the sawmill Industry recommends the inclusion of the targeted amendments included in the table in the attached file.
EOS supports the swift adoption of a workable text, providing voluntary schemes and economic operators with the necessary guidance for demonstrating compliance with the sustainability criteria.
Read full responseResponse to Guidance on REDII forest biomass sustainability criteria
28 Apr 2021
The European Organisation of the Sawmill Industry (EOS) underlines the importance of a robust and harmonised implementation of the new sustainability criteria for forest biomass by Member States and economic operators.
Coherence in the interpretation of the measures and timeliness in transposition and implementation are of paramount importance in preventing the arising of barriers in the EU internal market. EOS regrets the delay in publication of such draft guidance, that has generated further uncertainty in the operators. The preparedness of the system and tools to certify compliance will be paramount to its functioning.
The proposed regulation appears to include new key elements regarding harvesting and forestry criteria, rather than being a guidance document for supporting economic operators in applying the REDII ‘s sustainability criteria.
This draft regulation in its current formulation, stretches the boundaries of the criteria as laid down in the Renewable Energy Directive, by adopting several recommendations from the 2021 Joint Research Centre report on woody biomass. EOS considers that the inclusion of these criteria should be avoided, particularly at this stage. Introducing additional requirements that are unfamiliar to member states and economic operators could jeopardize the implementation of REDII.
Moreover, it should be noted that sustainability criteria although related to bioenergy only, they actually impact the whole forest industry value chain and finally, the use of renewable energy in the EU. Further information in the attached file.
Read full responseResponse to Environmental claims based on environmental footprint methods
31 Aug 2020
The European Sawmill Organisation of the Sawmill Industry welcomes the new initiative of the EU Commission to substantiate green claims.
Keeping track of consumption footprints globally, which requires good supply chain data and accounting, is increasingly recognised as critical to an inclusive transition to sustainability.
Misleading claims on products and/or on business environmental and climate-related performances constitute an obstacle to the development of a sustainable green and circular economy and therefore create a distortion on the Internal market. This is particularly true for companies that operating on a global market are confronted with different “green claims”. When comparing a product or process with a competitor’s, it should make sure the claim doesn’t suggest an advantage over a rival product if there is no information to support the comparison. Currently, there is a high volume of different green claims on the EU market with and without independent verification. This creates confusion and negatively affect consumer confidence in the legitimacy of the claims.
In this respect, EOS calls on the European Commission to consider the following points when elaborating its proposals on environmental performance of products and businesses:
- Recommendation 2013/179/EU establishing the Product and Organisation Environmental Footprint (PEF and OEF) methods should be reviewed in line with the principles of the circular economy, resource efficiency and of energy efficiency;
o EOS favours Option 2: Establish a voluntary EU legal framework enabling companies to make green claims in accordance with the Environmental Footprint methods, as a complement to existing methods (developed by private or public entities, at national or international level).
AS first step, EOS considers that it is important 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. Moreover, 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 and potentially machine readable EPDs and Building Information Modelling (BIM).
- It is essential to elaborate and implement a reliable, EU-wide, and integrated method to appropriately quantify environmental and climate-related impacts of products and businesses to empower consumers and to ensure comparability and fair competition, thereby avoiding green washing. When making an environmental claim for a product, service or organisation, it should not be misleading suggesting a greater benefit than it does;
Further clarification, in the annex file.
Read full responseResponse to Review of the requirements for packaging and feasibility of measures to prevent packaging waste
5 Aug 2020
The natural qualities of timber make wooden packaging an environmentally friendly packaging solution. Wood pallets and wood-based packaging are almost completely made out of wood. And wood’s strong environmental credentials have been captured in various Life-Cycle Assessment studies and Environmental Product Declarations.
Generally speaking, wooden packaging as divided into two subgroups:
1. Custom made packaging solutions to protect and transport for instance large industrial pieces of equipment. The final destination for wooden packaging and the piece of equipment is, according to our experience, often outside of Europe, as exporting companies are large customers of wooden packaging. The packaging is used to protect the equipment, which normally has a very large value. The wooden packaging is easy to demount, but rarely it is reused in its form, since it is custom made. Once dismantled, wood can be used for different new applications, including building purposes or for bioenergy generation. Since the packaging market is global, a strict European perspective in packaging recycling and or reusing solutions might not be coherent with the reality.
2. More standardized products- meaning primarily pallets. Pallets are used to support and facilitate transportation. There are common European standards for pallets, but many logistics providers also have their own systems in place. Pallets are by definition reused as long as they provide the functionality needed, after that, the wood is often used for bioenergy generation. As export and import flows today are very global, a strict European perspective won’t reflect reality.
Additional considerations:
• As explained above, both the recyclability and “reusability” factor depend very much on the global market. Any mandatory demand in relation to these two concepts would be highly problematic. Moreover, restricting the use to certain packaging applications will be problematic and even lead to market distortions. For this reason, any possible restrictions should be first evaluated through an accurate and extensive market impact assessment and accompanied by scientific based evaluations regarding the environmental concerns.
• “Functionality” is also utterly important, especially for custom made wooden packaging. A packaging solution is chosen since it delivers what is needed concerning functionality, cost, etc.
• Mandatory recycled content could be a major obstacle, not only for wooden packaging, but for all paper and board products based on fresh fibres. As previously explained, many of the wooden packaging solutions are sold and transported outside EU. Getting back the wooden packaging solution e,g from China, would not make any economic or environmental sense. Regarding paper and board, recycling rates are already high. Both fresh fibres and recycled fibers co-exist in the same value chain. It’s not a matter of one or the other, instead both of them need each other to be successful. A demand for mandatory recycled fibres would actually mean that producers in North Europe - mainly running on fresh fibres- would have to import recycled fibers from continental Europe. Costs would go up as well as emissions from transport. Feedstock would be pulled away from those that are 100% recycled based and their business would be hampered.
• It goes without saying that having a “one size fits all” approach for the packaging solution is not possible for a both economical and environmental prospective. Different packaging materials need specific considerations and evaluations that shall not be disregarded.
• Minimum mandatory GPP would most likely not affect wooden packaging, as the public (authorities etc) are small buyers. Instead the dominant buyers are industrial and from the logistics sector. Sustainable and environmentally friendly packaging solutions, should be overall promoted and encouraged particularly in the private sector.
Read full responseResponse to Commission Communication – "Renovation wave" initiative for the building sector
8 Jun 2020
The European Sawmill Industry believes that a Comprehensive European Renovation Initiative, based on a realistic and ambitious approach, should be equally focused on reducing the energy consumption of the building stock and favour the use of sustainable and environmentally friendly construction products. Nowadays it is imperative to change the direction of the building sector towards sustainable & green choices. By using more energy-efficient, biodegradable and recyclable materials in renovation projects, youll lessen your impact on the environment.
KEY RECOMMENDATIONS:
For the above-mentioned reasons, through its member federations and associated members, the European Organisation of the Sawmill Industry (EOS) call for:
1. Assessing the impact of renovation approaches including an impact assessment of the proposed policies and measures. Specifically:
a) Assessing the environmental and energy performance by categories of buildings, reflecting the results into a minimum green public procurement threshold for sustainable products to boost the use of biogenic carbon storing materials and solutions for better resource and energy efficiency;
b) Defining accurate accounting rules to measure and confirm the substitution effect of using biogenic products instead of carbon-intensive materials in order to extend carbon storage via greater use of natural products and increase the total harvested wood products’ carbon stock in the built environment. Such rules should consider the increased circularity of carbon through removals and storage in wood construction. As proposed by the new Circular Economy Action Plan, their integration in a “regulatory framework for certification of carbon removals” should be explored.
2. Calls on the EU Commission to adopt a life-cycle approach in line with the circular economy to maximise the reuse, recycling, and recuperation of materials in their procurement strategies;
3. Identification of the internal technical market barriers that might lead on discrepancies in the use of construction products within Member States;
a) The review of the Construction Products Regulation should ensure that the design of new and renovated buildings is in line with the needs of circular economy and lead to increase use of sustainable and climate friendly materials.
b) The limited availability of relevant and comprehensive data on building materials is still a challenge in a number of European countries. The comparability of data at EU level needs reinforcing.
c) Increasing off-site prefabrication of building components such as walls and roofs since it constitutes a very promising way to accelerate large scale renovations and constructions in a speedy and cost-efficient manner;
4. Designing new long-term financing mechanisms for renovation aiming to boost a green renovation wave.
a) In this respect Member States should be invited to set up financial tools for supporting renovation for private properties as well. In particular, attractive interest rates for renovation loans should be offered when private citizens invest in green renovation projects.
5. Engaging all relevant stakeholders (relevant government departments, building professionals, financial institutions, civil society, etc.) in the development of the green renovation wave.
Read full responseMeeting with Catherine Geslain-Laneelle (Cabinet of Commissioner Janusz Wojciechowski), Jorge Pinto Antunes (Cabinet of Commissioner Janusz Wojciechowski)
28 May 2020 · The need of policies creating the condition for resilient forests and enhancing the development of bioeconomy
Response to Climate Law
28 Apr 2020
Article 3 of the Regulation “Trajectory for achieving climate neutrality” should list the role of biobased solution to achieve the climate neutrality. Protecting the environment means ending our dependence on fossil fuels-based products. The European climate pact should build a legislative framework that create favourable conditions for placing on the market sustainable and climate friendly products and enhancing solutions that already exist such as the Bioeconomy.
Although some parts of the bioeconomy are already long-established, in recent years, due to new technological opportunities, the bioeconomy has proven to be a tool to reduce dependency on fossil fuels-based products and lead new and innovative bio-based solutions. In an increasingly tense geopolitical context, many bio-based solutions, unlike most fossil fuels-based products, also offer security of supply as raw materials can be sourced and produced in Europe. The EU Climate law should explore the development of a bio-economy vision focused on the production and utilisation of biological resources to generate high-value biobased products. Overall, the bio-economy encompasses the traditional bio-economy sectors, such as agriculture, forestry and forest-based industries, fisheries and aquaculture, as well as related processing and service industries, such as food, paper, textiles, construction, chemistry and biopharma. Demand for bioproducts is rapidly growing worldwide and represents an immediate and effective way to reduce carbon emissions. This is a major economic opportunity for Europe that shall not be missed.
Read full responseResponse to Climate change mitigation and adaptation taxonomy
20 Apr 2020
EOS welcomes efforts to mobilise the financial sector in accelerating the move towards a prosperous and sustainable Europe in 2050. To achieve this, a stable, fair and favourable investment framework in Europe will be key.
The future Taxonomy’s criteria and thresholds should be impact assessed prior to their application, to avoid unintended consequences for the sectors in which they will apply. The TEG report presents important inconsistencies as well as technical and methodological flaws that could prevent investors from making fully informed decisions on their investments. Therefore, the future Taxonomy should be above all internally consistent and conducive to a level playing field that allow businesses and investors to invest in sustainable solutions that meet their varying needs. Metrics and thresholds are essential elements in EU legislation and should thus be properly impact assessed prior to application and receive scrutiny by the co-legislators and stakeholders.
The future Taxonomy should better tackle environmental sustainability but also the social and economic pillars of sustainability. Focusing mainly on carbon emissions reduction, the TEG report needs to tackle better concepts such as circular economy, resource efficiency and energy efficiency for their significant environmental and health benefits (e.g. lower ecological and resource depletion,
better air quality) as well as economic benefits (e.g. independent, secure and reliable supply of raw materials and energy, reduced dependence on imports, improved competitiveness). Not doing so risks compromising the very notion of (all-around) sustainability, which is essential to make fully informed and successful investment decisions for the future. On the contrary, integrating those dimensions into the Taxonomy would render it more comprehensive and better aligned with other major EU policy priorities, including fostering reindustrialisation and employment in Europe, and help make the move to a sustainable society an economic success for Europe.
Forests are at the heart of the transition to low-carbon economies. Forests and forest products have a key role to play in mitigation and adaptation, not only because of their double role as sink and source of emissions, but also through the potential for wider use of wood products to displace more fossil fuel intense products.
Evidence from numerous life-cycle assessments (LCAs) of wood-based products in the construction sector indicates that, typically, wood-based materials have a lower emission footprint than competing materials over the complete life cycle of the product (including use and disposal), and the production stage of wood-based materials results in lower GHG emissions than the production stage of functionally comparable non-wood materials.
In the elaboration of the delegated acts, EOS stresses the need to ensure policy coherence with the existing legislations (such as the LULUCF Regulation and the recast of the Renewable Energy Directive) and avoid significant burdens on the undertakings. In the framework of sustainable forest management, EOS calls for the recognition of both PEFC and FSC as equally reliable certification systems in order to prove responsible management of forests.
Read full responseResponse to 2030 Climate Target Plan
13 Apr 2020
The Commission intends to propose an increasing of the EU’s GHG emission reductions target for 2030 to at least 50% and towards 55% compared with 1990 levels. In this respect, the EOS response focuses on the role of biomass-based products and nature-based solutions in achieving a sustainable, circular and environmental-friendly economy. According to the Regulation on Land Use, Land Use Change and Forestry (Regulation EU 2018/841), EU Member States are requested to comply with the so called “no debit rule”, which requires EU Member States to ensure that emissions from the LULUCF sector do not exceed removals from 2021 to 2030. Meaning: the LULUCF sector shall not become a net source of GHG emissions. Today more than two-fifths of Europe is tree-covered. Between 1990 and 2015, the area covered by forests and woodlands increased by 90,000 square kilometres - an area roughly the size of Portugal. In Europe, 33 % of the total land area (215 million ha) is covered by forests, with a positive trend of increase for the forested areas. Other wooded lands cover an additional area of 36 million ha. 113 million ha are covered by coniferous forests, 90 million ha by broadleaved ones and 48 million ha by mixed forests. (Source: JRC). Many of Europe’s forests are managed to produce wood to make paper, or timber for construction, or as fuel. As trees in those forests are felled, more are planted, and European forests expand by an area the size of 1,500 soccer pitches every day. (Source: the World Economic Forum).
Nevertheless, forests might be negatively affected by climate change causing an increase of the forest disturbances. Climate change have an effect on important abiotic ( re, drought, wind, snow and ice) and biotic (insects and pathogens) disturbance agents. Warmer and drier conditions particularly facilitate, drought and insect disturbances, while warmer and wetter conditions increase disturbances from wind and pathogens. Widespread interactions between agents are likely to amplify disturbances, while indirect climate effects such as vegetation changes can dampen long-term disturbance sensitivities to climate. Future changes in disturbance are likely to be most pronounced in coniferous forests and the boreal biome.
THE EUROPEAN SAWMILL INDUSTRY CALLS FOR:
1. IN THE FRAMEWORK OF THE “2030 CLIMATE TARGET PLAN” THE EU COMMISSION SHOULD TAKE INTO CONSIDERATION THE NEGATIVE IMPACT OF CLIMATE CHANGE ON FORESTS AND MOBILISE EU R&D RESOURCES IN ORDER TO TACKLE THEM, BEARING IN MIND THAT EU FORESTS CONDITIONS VARY SUBSTANTIALLY ACROSS COUNTRIES.
2. THE CREATION OF AN EU FOREST RESOURCE MONITORING SYSTEM AIMING AT PROVIDING REAL-TIME INFORMATION ON THE EUROPEAN FOREST RESOURCES AND AIMING AT FORECASTING THE IMPACT OF NATURAL DISTURBANCES ON WOOD AVAILABILITY.
3. THE EUROPEAN SAWMILL INDUSTRY BELIEVES THAT WHILE THE REGULATION EU 2018/841 IS AN ADEQUATE INSTRUMENT FOR CALCULATING THE EMISSION FROM THE LULUCF SECTOR, IT COULD BE FURTHER EXTENDED. PRODUCT SUBSTITUTION SHOULD BE CONSIDERED AS AN EFFECTIVE LONG-TERM CLIMATE CHANGE MITIGATION STRATEGY THAT COMPLEMENTS THE FOREST CARBON SEQUESTRATION.
4. IN ORDER TO ACHIEVE THE GHG EMISSION REDUCTIONS TARGET FOR 2030 TO AT LEAST 50% AND TOWARDS 55%, THE EU COMMISSION SHOULD PUT IN PLACE A MECHANISM THAT REWARDS THE CARBON NEUTRALITY OF WOOD PRODUCTS AND THE CLIMATE BENEFITS OF MATERIAL SUBSTITUTION. As first step, the EU Commission should launch a comprehensive study in order to explore potential mechanisms to allocate carbon units for storage in wood products.
Full answer in the attached file.
Read full responseResponse to EU 2030 Biodiversity Strategy
20 Jan 2020
Please see the attached file.The European Organisation of the Sawmill Industry (EOS) use and purchase wood coming only from the European Forests – EU territories; for this reason the considerations made in relation to the EU Biodiversity Action Strategy are related only to the EU forests. EOS believes that the Strategy should support Member States with evidence‐based knowledge about the current conditions for the effective wood production and biodiversity conservation. By using wood products - legally harvested from sustainably managed forests - Europe can achieve several of the objectives presented in the recently adopted “The European Green Deal” and become the world’s first climate-neutral continent by 2050
Read full responseResponse to Draft Commission Regulation establishing the “PRODCOM List” of industrial products
6 Jun 2019
Dear Sir/Madam,
Please see attached file.
Kind regards,
Diego Benedetti
EOS Economic and Policy Advisor
24 rue Montoyer, Box 20, B-1000, Brussels
Mobile: +32 471 72 51 83
Tel: +32 3 287 08 76
E-mail: diego.benedetti@eos-oes.eu
Website: www.eos-oes.eu
Read full responseResponse to Towards an EU Product Policy Framework contributing to the Circular Economy
4 Jun 2018
European Organisation of the Sawmill Industry: Who We Are
The European Organization of the Sawmill Industry (EOS) is a Brussels-based non-profit association representing the interests of the European sawmilling sector on European and International level. Through its Member Federations and Associated Members, EOS represents some 35.000 sawmills in 12 countries across Europe manufacturing sawn boards, timber frames, glulam, joinery, and several other wood products. The European sawmill industry processes both softwood and hardwood and is responsible for a turnover of almost 37 billion EUR, employing over 250.000 people in the EU.
EOS is glad to have the possibility to voice its views on the important initiative of the EU Commission “Towards an EU Product Policy Framework contributing to the Circular Economy”.
Considerations: Towards an EU Product Policy Framework contributing to the Circular Economy.
1. EOS encourages the EU Commission to design policies which contribute to economic performance, productivity growth and economic prosperity. In doing so, economic and environmental considerations must go hand in hand.
2. An effective European Product Policy should avoid unnecessary regulatory burdens. It should create a coherent business policy in order to encourage long-term business investment in new technology and products’ innovation.
3. The EU Product Policy should be simultaneously based on a sector-by-sector approach and should consider the interdependencies of the the different policy frameworks currently in place.
4. The circular economy strategy aims at reducing both input of non renewable virgin materials and output of wastes by closing economic and ecological loops of resource flows. Using renewable virgin wood is good for the environment. To maintain or improve the health and productivity of a forest, foresters use a number of management techniques, including harvesting. The increased demand for responsibly sourced wood products (labelled with PEFC, FSC or CoC) can result in an increase of sustainable -managed forests and plantations on marginal or cleared land. Moreover, the amount of energy used to harvest, transport, convert and recycle wood is minimal compared with other materials, as over 75% of the energy used for manufacturing wood products is produced from non industrialwood residues and recovered wood.
5. EOS would like to caution against simplistic assumptions by which recycled products are by definition superior to not-recycled products. The ease of material disassembly, separation or recyclability is relevant to consider in a circular economy perspective.
6. In a competitive and interconnected world, any policy which proposes costly modifications in the attainment of demanding standards has to ensure that products which enter the European market from outside the EU comply with those standards. Otherwise, the unintended effect of regulation would be to put the European producers in a position of competitive disadvantage.
7. EOS calls for enacting a policy framework which keeps into account the carbon storage in wood products. The CO2 uptake of wood should be a priority for policymakers throughout Europe: wood products should not be discriminated against in public procurement, and more architects need to be educated on the benefits of using wood as a building and every-day material.
(Further information in the attached file)
Read full responseResponse to Evaluation of six Euro-Med FTAs
14 Dec 2017
European Organisation of the Sawmill Industry: Who We Are
The European Organization of the Sawmill Industry (EOS) is a Brussels-based non-profit association representing the interests of the European sawmilling sector on European and International level. Through its member federations and associated members, EOS represents some 35.000 sawmills in 13 countries across Europe manufacturing sawn boards, timber frames, glulam, joinery, and several other wood products. The sawmill industry processes both softwood and hardwood and it represents a turnover of almost 37 billion EUR, employing over 259.000 job in the EU.
EOS welcomes the opportunity to contribute to the “Evaluation of the trade component of the EU’s Euro-Mediterranean Association Agreements with six Mediterranean partner countries (Algeria, Egypt, Jordan, Lebanon, Morocco and Tunisia)”, especially in view of the recent license system for importing wood products introduced by the Algeria Government.
The Issue
Since April, Algerian importers of wood products need a license to be able to import wood products in the country. These measures have negatively impacted the European sawmill industry. Not only does EOS strongly regret the introduction of the system itself, but we also have concerns about the implementation of this system. As it has been recognized by the Commission in a report published on 17 November (Trade and Investment Barriers in the Euro-Mediterranean Region), the Algerian authorities have provided very little indications about the methods used to allocate the licenses, which, for several months had not been granted at all. The first licenses were given to state importers in the Summer, and starting from the October private importers have also been given licenses. However, the licenses so far granted do not cover the need of local importers and end users. Moreover, the licenses system, which per se represents a violation of the Association Agreement between the EU and Algeria signed in 2002 and entered into force in 2005 , puts further obstacles on the way of importers: an importer of goods resold without further processing must make a cash deposit of 120% of the value of the purchased good at the bank servicing the transaction at least 30 days before the good is shipped.
Concerns expressed on behalf of the EOS Members
EOS has voiced the concerns of its Members to the European Commission. Two meetings took places on 25 April and on 20 July with representatives of DG Trade to present the negative impact of the licenses systems on the European sawmill sector. Data regarding the exports of sawnwood to Algeria is available in the annex to this document. The Algerian market is vital for many European sawmills as it absorbs 12% of exports in a barrier-free context. In addition to exchanging information with the representatives of DG Trade, EOS has also sent a letter to the Algerian government - stressing that free trade would benefit both sides - without obtaining any answer. EOS is sympathetic with the economic challenges that the Algerian government is confronted with, but believes that its exports can help the Algerian economy cope with its fast demographic expansion and urgent need of housing.
Conclusion
EOS is grateful for the efforts of the European Commission to tackle the current challenges and it remains committed to contributing with data and information which could help to bring an end to this regrettable situation, which is taking a heavy toll on many sawmills across Europe.
Based on our latest information, the Algerian authorities do not wish to return to the status quo ante any time soon; nevertheless, the EOS Members hope that a concerted action of European stakeholders can bring achievements
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