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European Panel Federation

EPF

EPF represents European manufacturers of wood-based panels including particleboard, MDF, OSB, and plywood across 30 countries.

Lobbying Activity

Response to Construction services Act

8 Dec 2025

Please find here attcahed EPF's Response to the Call for Evidence on the Construction Services Act.
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European Panel Federation urges harmonised EU wood recycling rules

6 Nov 2025
Topic — The European Commission's consultation proposes a new Circular Economy Act for sustainable production.
Message — EPF requests harmonised EU-level regulations for wood recycling and acceptance standards. They urge prioritising material recycling over energy recovery by removing bioenergy subsidies.12
Why — This would secure long-term wood supply and reduce industry administrative burdens.3
Impact — Bioenergy firms lose competitive advantages gained through public subsidies for early recovery.4
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Meeting with Astrid Van Mierlo (Head of Unit Taxation and Customs Union) and Confederation of European Paper Industries

6 Nov 2025 · Meeting with EPF and CEPI

European Panel Federation urges fair biogenic carbon rules

31 Oct 2025
Topic — The EU is establishing a framework to calculate building life-cycle emissions.
Message — EPF requests harmonized rules for biogenic carbon and realistic material data. They also seek simplified compliance pathways to reduce burdens for smaller companies.12
Why — These rules would protect the competitive position of wood-based construction products.3
Impact — Producers of high-carbon materials lose competitive advantage against natural, bio-based alternatives.4
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Meeting with Elsi Katainen (Member of the European Parliament)

16 Oct 2025 · Current issues in wood industry

European Panel Federation warns against burning wood for heating

7 Oct 2025
Topic — EU initiative to accelerate the decarbonisation of industrial and residential heating systems.
Message — The federation demands strict limits on burning wood to uphold the cascading use principle. They urge the EU to prioritize heat pumps and geothermal energy instead of biomass.12
Why — This approach secures raw material availability and reduces competitive pressure on wood prices.3
Impact — Producers of wood pellets and consumers using fuelwood would face restricted market access.4
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Meeting with Elsi Katainen (Member of the European Parliament)

2 Oct 2025 · Current issues in bioeconomy

Meeting with Paolo Garzotti (Head of Unit Trade)

29 Sept 2025 · Update on the trade agreement's impact on plywood imports into the EU.

Wood panel industry urges EU to protect timber from combustion

21 Sept 2025
Topic — EU consultation on certification methodologies for permanent carbon removals including BioCCS and biochar.
Message — EPF strongly recommends that paragraph 4.3.3 be deleted to prevent incentivising the burning of high-value woody biomass. They request that certification methodologies prioritise material-first applications of biomass into long-lived harvested wood products.12
Why — This would protect their raw material supply from being diverted to energy generation.34
Impact — BioCCS and biochar projects would lose the option to use high-quality saw logs.5
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European wood panel industry urges shift to timber-based housing

17 Sept 2025
Topic — A new EU strategy aims to address the housing supply gap and boost construction productivity.
Message — The federation calls for recognizing engineered wood as a climate-friendly material in housing policy. They urge officials to streamline permits for prefabricated wood systems and incentivize carbon-storing materials via public procurement.123
Why — The industry would see increased demand for its products and a stronger competitive position within Europe.45
Impact — Manufacturers of carbon-intensive materials like steel and concrete face reduced demand as wood substitutes replace them.67
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European Panel Federation demands CBAM exclusion for industrial urea

26 Aug 2025
Topic — This consultation addresses extending the carbon border adjustment mechanism to additional downstream products.
Message — The EPF requests the exclusion of technical-grade urea used for resins and adhesives from the CBAM scope. They propose either clarifying existing customs codes or creating a new one to distinguish industrial urea from fertilizers.12
Why — Excluding this material prevents new compliance costs and protects the competitiveness of resin producers.3
Impact — Furniture and construction sectors face higher costs and reduced competitiveness if this feedstock is included.4
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Meeting with Luis Planas Herrera (Cabinet of Commissioner Jessika Roswall)

26 Aug 2025 · Circular Economy Act and Bioeconomy Strategy

Response to Revision of the Standardisation Regulation

21 Jul 2025

Please find here attcahed EPF's Feedback on the Call for Evidence: Revision of the Standardisation Regulation.
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Panel manufacturers urge recognition of carbon storage in EU law

4 Jul 2025
Topic — The initiative aims to stimulate industrial investments and accelerate the EU's transition toward climate neutrality.
Message — The federation requests that wood-based panels be acknowledged as a key tool for carbon storage and fossil material substitution. They propose streamlining administrative requirements and updating accounting rules to reward the use of circular biomass.12
Why — Including carbon storage in incentives would boost the industry's competitiveness against energy-intensive materials.34
Impact — Producers of fossil-based products would lose market share to bio-based materials favored by new incentives.5
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Meeting with Nicolo Brignoli (Cabinet of Commissioner Valdis Dombrovskis)

30 Jun 2025 · Simplification

Meeting with Paulina Dejmek Hack (Cabinet of Commissioner Jessika Roswall)

27 Jun 2025 · To exchange views on the clean industrial deal.

European Panel Federation demands mandatory wood cascading rules

23 Jun 2025
Topic — A consultation on updating the EU strategy for a circular bioeconomy.
Message — The EPF calls for the cascading principle to become a mandatory legal requirement across all EU policies. They want to phase out subsidies for burning wood for energy to prioritize long-lived materials.12
Why — Mandatory rules would secure wood supply and lower raw material costs for panel manufacturers.34
Impact — Bioenergy producers would lose financial support and access to primary wood feedstocks.56
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Wood-based panel industry urges streamlined EU biotech regulations

10 Jun 2025
Topic — The consultation seeks to create a framework to accelerate biotechnology market transition.
Message — The federation requests streamlined regulations that distinguish industrial wood biotech from pharma. They also advocate for EU-level pilot funding and public procurement support.123
Why — This framework would lower compliance burdens and increase demand for wood-based products.4
Impact — Fossil-based material suppliers could lose market share to bio-based wood alternatives.5
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Meeting with Chiara Galiffa (Cabinet of Commissioner Maroš Šefčovič)

5 Jun 2025 · Wood-based panel industry

Response to European Affordable Housing Plan

4 Jun 2025

Please find here attached EPF's response to the Call for Evidence on the European Affordable Housing Plan.
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European wood panel makers urge priority for bio-based materials

7 Mar 2025
Topic — Evaluation of EU directives governing public procurement and concession contracts across various sectors.
Message — The EPF requests that procurement directives explicitly encourage or require the use of European bio-based materials. They suggest prioritizing wood-based products made from renewable or recovered resources to support the circular economy.123
Why — The proposal would use government purchasing power to increase market demand for the industry's specific wood products.45
Impact — Manufacturers of fossil-based and energy-intensive materials would lose market share to bio-based competitors.67
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European wood-panel industry urges flexible biomass monitoring rules

29 Jul 2024
Topic — The European Commission is updating rules for monitoring and reporting greenhouse gas emissions.
Message — EPF argues that the 'disproportioned costs' of expensive measurement systems for carbon emissions must be addressed. They claim their specific manufacturing processes make it 'impossible to develop' a standard carbon balance. They also request a 'homogenous application' of green standards across all EU countries.123
Why — This would protect manufacturers from excessive costs and unworkable reporting requirements.45
Impact — National governments would lose the flexibility to set their own specific sustainability criteria.6
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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

Response to Amendment of protective measures against pests of plants

27 May 2024

We would like to request changing two points in the Regulation 2019/2072 (i) Amendment of point 86 of ANNEX VII concerning wood of Acer saccharum Marsh. Intended for the production of veneer sheets. The codes for already manufactured veneer (HS4 code 4408) are for unknown reasons included in this point that contains the description raw material (roundwood, HS4 code 4403), not the finished product. The product traded under this code (4408) is a finished product that has already undergone manufacturing, including double heat treatment. Therefore, HS code 4408 (sheets for veneering, commonly defined as wood veneer) and the related CN8 codes should be deleted from this item and being properly classified under point 85. (ii) Amendment of point 92 of ANNEX VII concerning wood of Betula spp. which hasn´t kept its natural round surface. This article relates to the pest Agrilus anxius Gory. The request relates to HS-4 code 4408 (sheets for veneering, commonly defined as wood veneer) and in particular to CN-8 code 4408 90 85. It is requested that this product should not be included under this point due to the size of the veneer, the heat treatment the product has gone through and the different treatment for this ppest vs point 87 where the trade codes for Agrilus planipenis do not include the CN code 4408 90 85
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Response to Evaluation of Standardisation Regulation (EU) No 1025/2012

28 Sept 2023

The European Panel Federation (EPF) welcomes the opportunity to provide feedback on the Call for Evidence on the European standardisation evaluation and EPF believes that it is important to thoroughly assess the challenges ahead for EU standardisation especially with regards to the circular, energy and digital transitions. Moreover, EPF considers that it is essential to ensure that standards are fit for use by manufacturers not only to meet regulatory needs but also to help the industry in terms of facilitating the production of quality products that meet the needs of customers and consumers alike whilst also enabling fair competition by providing transparent and known European assessment criteria. To this end, it is required to establish a standardisation environment that enables proper engagement from all relevant parties and proper due process to ensure that standards are fit for purpose and useable within the future circular and digital economies (areas that are amongst EPFs priorities). The CPR acquis processs success is key to unblocking the situation of harmonised standards under the Construction Products Regulation, it is therefore vital that the standardisation process properly facilitates this cooperation between Member States, the European Commission and CEN TCs in a way that creates good quality standards that meet the needs of all in a timely manner. In this respect, it is important that the EU standardisation process ensures proper harmonisation of standards to foster global competitiveness for EU companies while securing a level-playing field within the EU single market and beyond. Hence, EPF urges the Commission to proceed with the evaluation in a transparent, participatory and non-discriminatory manner. Involving the industry and industry associations in every step of the process will be of the utmost importance. In order to do so, EPF is looking forward to participating in the consultation process and expects to be invited for the upcoming targeted stakeholder surveys, interviews and validation workshop.
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Wood panel makers demand simpler bio-CO2 reporting rules

23 Aug 2023
Topic — The consultation updates rules for monitoring and reporting greenhouse gas emissions.
Message — The federation requests that reporting requirements account for the unique complexities of wood panel manufacturing. They propose allowing alternative estimation methods if standard rules are too expensive or technically impossible.12
Why — Industry players would avoid significant administrative burdens and high costs of compliance.345
Impact — Regulatory authorities would face less precise emissions data from wood product manufacturers.67
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European Panel Federation opposes recycled content for wood packaging

21 Mar 2023
Topic — Review of EU packaging requirements to support waste prevention and recycling.
Message — The federation opposes recycled content targets for lightweight wood packaging for food. They argue that plywood cannot technically be manufactured using recycled wood materials. They request that wood waste collection be mandated to support the board industry.123
Why — This would protect wood packaging manufacturers from being forced out of the market.45
Impact — Energy recovery companies would lose access to wood waste diverted toward recycling.67
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Wood panel industry seeks carbon certification for timber products

20 Mar 2023
Topic — This consultation proposes a new European framework for certifying and monitoring carbon removals.
Message — EPF requests including harvested wood products in the certification framework. They want rewards for carbon storage in furniture and construction. Policies should prioritize material use over burning wood for energy.12
Why — This would increase market demand for wood and provide new financial rewards.34
Impact — Conservationists lose as set-aside programs might be restricted to maintain timber supply.5
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Response to Review of the Construction Products Regulation

11 Jul 2022

The European Panel Federation (EPF) welcomes the possibility to provide feedback on the Proposal for a Regulation laying down harmonised conditions for the marketing of construction products, amending Regulation (EU) 2019/1020 and repealing Regulation (EU) 305/2011. EPF believes that the single market for construction products is essential, welcomes the improvements regarding how the single market for construction products should function and believes it is essential especially within the framework of the achievement of the objectives of the circular economy and of climate neutrality by 2050. The wood-based panels industry therefore especially welcomes the objective of integrating sustainability aspects and environmental characteristics into the CPR. Within the framework of the revision of the CPR, it is essential that the demands of the construction ecosystem can be heard and that a dialogue can be established between its representatives and the European institutions. In this respect, EPF calls on the Commission to consider the following general points as well as our more detailed comments and proposals (in annex) on the EC’s proposed revision of the CPR: • Ensure a harmonised European approach amongst Member States by effective implementation of the regulation. • The inclusion of renewable raw materials within the framework of the circular economy. • That administrative/financial burden is kept to an absolute minimum. • Industry’s data security and accuracy is of utmost importance from business and safety perspectives. • Ensure consistency with EPBD. • Ensure clarity in roles and responsibilities of each economic operator ‘placing’ or ‘making available’ on the market, enabling proper implementation of the regulation amongst economic operators responsible for those specific tasks, without over complicating the regulation; which in turn should be supported by a proper functioning market surveillance • Welcomes the acknowledgement of the climate benefits of biogenic + embodied carbon and the use of European standards relating to EPDs and the PEF method for this and operational carbon. • Has concerns regards the proliferation of delegated acts that do not include industry stakeholder engagement and calls for (based on EC guiding principles given in the CPR): o Cascading principle & waste hierarchy at the end of life to be the ‘best fit’ for each construction product sector by tailoring requirements through standardisation. o Technical and environmental solutions for each sector’s products made through standardisation. To conclude, the wood-based panel industry produces sustainably sourced circular products that can be used for energy-efficient and climate-friendly construction and renovation in technically demanding end uses. It is therefore of utmost importance that the CPR enables products to be properly assessed and declared for both technical and environmental related characteristics in a sound and harmonised manner. This would empower end-users to make the most sustainable and appropriate technical construction products choices for their projects in a clear and transparent way.
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European wood panel industry opposes industrial emissions revision

23 Jun 2022
Topic — Updating EU industrial emissions rules to improve environment and human health.
Message — The EPF argues that current geopolitical uncertainty makes this the wrong time for revision. They call for removing requirements to publish confidential permit details and chemical inventories online.123
Why — This would protect confidential business data and reduce significant administrative and financial burdens.45
Impact — Environmental NGOs lose the ability to scrutinize company transformation plans and performance.6
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Response to Sustainable Products Initiative

22 Jun 2022

Please find here attached the feedback from EPF & EPLF.
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European Panel Federation seeks carbon credits for wood products

27 Apr 2022
Topic — The European Commission is proposing a regulatory framework for certifying carbon removals.
Message — EPF requests certifying carbon storage in harvested wood products like construction and furniture. They advocate for active forest management instead of strictly protecting forest areas.12
Why — This would create new business models and increase market competitiveness for wood-based panels.34
Impact — Environmental groups lose if forest set-aside programs are deprioritized in favor of logging.5
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Response to Revision of the Energy Performance of Buildings Directive 2010/31/EU

30 Mar 2022

Please find here attached EPF feedback on the revision of the Energy Performance of Buildings Directive COM(2021)802.
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Response to Waste Framework review to reduce waste and the environmental impact of waste management

22 Feb 2022

The European Panel Federation (EPF) welcomes the opportunity to provide feedback on the call for evidence for an impact assessment on the revision of the EU Waste Framework Directive (WFD). EPF believes that the sound implementation of the waste hierarchy established in the WFD favouring the prevention of waste and material use over disposal and early energy recovery is of the utmost importance to uphold the principles of circular economy, enhance carbon life cycles, resource efficiency and environmental sustainability. Furthermore, EPF considers that waste prevention and collection are key enablers of the climate neutrality objective while reducing the pressure on natural capital especially for woody biomass for which demand is expecting to rise given its role in climate mitigation, protection of ecosystemic services and the deployment of a resilient and circular bioeconomy. It is essential to “simplify waste management for citizens and ensure cleaner secondary materials for businesses” as announced in the Green Deal. In this respect, EPF calls on the European Commission to consider the following points while preparing the revision of the EU Waste Framework Directive: • Promote full implementation of the provisions of the waste hierarchy on waste prevention, preparation for re-use and recycling; • Provide clear guidance on waste-prevention provisions for efficient separate collection to improve waste re-use and preparation for re-use and recycling especially for construction & demolition waste; • Reduce waste generation by requiring where possible selective demolition and segregation at source; • Support collection schemes that keep the wastes separate, keeps them clean and makes them available to candidate recyclers in sufficiently large quantities by establishing well-functioning and competitive markets for secondary raw materials; • Ensure material use preference for woody biomass to enhance and maintain the carbon life cycle through the application of the cascading principle; • Establish a level playing field by avoiding market distortions from subsidies for early energy recovery from woody biomass.
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Response to Act amending Implementing Regulation (EU) 2018/2066 on the monitoring and reporting of greenhouse gas emissions

4 Jan 2022

The European Panel Federation (EPF) warmly welcomes the publication of the draft implementing regulation amending Article 38 of the Monitoring and Reporting Implementing Regulation (EU) 2018/2066. EPF believes that it is essential to ensure a robust, efficient and harmonised implementation of the provisions under Article 38 to guarantee fair access to the biomass raw material market for the continued development of innovative, high value-added carbon storing bio-based solutions, such as wood-based panels. In this respect, it is of the utmost importance to fully implement the principles of the circular economy, of biomass cascading use, and of the waste hierarchy to enhance carbon cycles in harvested wood products. The availability and sustainable supply of biomass to is critical to maintaining forest carbon sinks, ensuring predictability and unlocking the full potential of EU circular bioeconomy. As Member States are encouraged to use market-based instruments such as the EU Emissions Trading System (ETS), and since zero rate will apply to all biomass under the ETS, it is important to avoid negative environmental impacts by discouraging the use of unsustainable biomass in the ETS sectors. To ensure the avoidance of biomass market distortions, EPF proposed in 2020 to establish a consultation system at national, regional or local level to verify whether applicants for biomass energy support comply with the sustainability requirements of the Renewable Energy Directive (RED). Such a process could be implemented within the operational guidance for member states and operators on how to demonstrate compliance with the new sustainability criteria for forest biomass that is expected to be soon adopted. EPF believes that a coherent approach is necessary when reviewing the rules of RED together with the Forest Strategy, the Biodiversity Strategy, the revision of the LULUCF and the EU ETS. It is essential that future biomass availability is secured for all users on a level playing field basis, free from market distortions driven by subsidies. In order to ensure consistency between the different European policies impacting EU forests, it is of the utmost importance to ensure that there is enough biomass for the whole European circular bioeconomy ecosystem. This is needed to turn the built environment into a carbon sink by using nature-based materials and reach climate neutrality by 2050, as called for by EC President von der Leyen. A consultation process would help to deliver this.
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Response to Revision of the Renewable Energy Directive (EU) 2018/2001

16 Nov 2021

Please find here attached the feedback from the European Panel Federation (EPF) on the review of the EU renewable energy rules.
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Response to Updating the EU Emissions Trading System

8 Nov 2021

Please find here attached the feedback of the European Panel Federation (EPF) on updating the EU Emissions Trading System (Ref:2021-034).
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Response to Land use, land use change and forestry – review of EU rules

8 Nov 2021

Please find here attached the feedback of the European Panel Federation (EPF) on n the LULUCF review (Ref: 2021-035).
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Response to Restoring sustainable carbon cycles

7 Oct 2021

The European Panel Federation (EPF) warmly welcomes the possibility to provide feedback on the Roadmap on Climate change – restoring sustainable carbon cycles. Reaching net-zero greenhouse gases emissions by 2050 and negative emissions thereafter requires both important carbon emissions reductions and carbon removals from the atmosphere. The new 2030 EU target of net greenhouse gas removals in the sector covering the new EU Forest Strategy for 2030 and the LULUCF/RED II revisions is therefore of the utmost importance if we are to meet the objectives of climate neutrality. Given the urgency of the climate crisis and the certainty that the reductions and removals transition will not happen in time unless it is accelerated, it is indeed essential to establish incentives to enhance carbon stocks and increase removals in sustainably sourced harvested wood products especially for construction, renovation for energy efficiency and furniture allowing for the substitution of other carbon intensive materials. Developing sustainable streams of carbon from biomass is clearly the way forward. In this respect, EPF asks the Commission to consider the following points when finalizing its proposals on restoring sustainable carbon cycles: • Ensure that all forest biomass used for bioenergy with carbon capture and storage is sourced in full compliance with the sustainability criteria and in line with the cascading principle and the waste hierarchy to ensure the long-life cycle carbon storage and that the recycling of waste is always the priority option; • Foster recycling to maintain sustainable carbon cycles by establishing well-functioning markets for wooden secondary raw materials before eventual end of life energy recovery to avoid further pressure on natural resources and distortive effects on markets for by-products, wastes or residues; • Maximise resource availability by Introducing targets for the exclusion of bio-based materials from entering landfill; • Promote plantations and active forest management to increase carbon removals, create jobs in shrinking rural areas and support the EU forest-based bioeconomy; • Guarantee that carbon credits reward carbon storage in forest biomass only when the timber enters the market to help unlock the full potential and climate benefits of a sustainable and circular EU forest-based bioeconomy; • Develop a comprehensive, verifiable and science-based carbon removals certification system ensuring the authenticity of removals and rewarding carbon storage and substitution of other carbon intensive materials by climate friendly nature-based materials such as wood throughout their whole life cycle; • Ensure consistency with other EU climate policies to create a competitive industrial market for recycling and long-lasting storing carbon. To conclude, EPF believes that the carbon removal strategy should reward the carbon storage in harvested wood products to promote a sustainable forest bioeconomy and the transition to a more nature-based circular economy that will help to extend the carbon lifecycle in wood products, thus benefiting our climate. It holds indeed a huge potential especially in the framework of the implementation of the ‘Fit for 55’ package, the implementation of the Bioeconomy Strategy, the Renovation Wave Strategy and the New European Bauhaus initiative to help turn the built environment from a source of GhG emissions into a carbon sink, as specifically called for by EC President von der Leyen.
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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 European Bioeconomy Policy: Stocktaking and future developments

3 Aug 2021

The European Panel Federation (EPF) warmly welcomes the possibility to provide a feedback on the roadmap on “European Bioeconomy Policy: Stocktaking and future developments” and would be glad to actively participate in the stakeholder workshop that will be organised as part of the preparation of the progress report on the implementation of the Bioeconomy Strategy. EPF believes indeed that the bioeconomy ought to play an important role in achieving the objectives of the Green Deal, support the transition towards a resource efficient circular economy and sustainable recovery and foster a green, digital and resilient recovery on the path to net neutrality by 2050. In 2018, the European Commission adopted its Communication “A sustainable Bioeconomy for Europe: Strengthening the connection between economy, society and the environment” where it estimated the European bioeconomy as representing 18 million jobs and € 2.3 trillion in turnover. The circular bioeconomy has indeed proven already to be a tool to reduce dependency on fossil fuels-based products and lead new and innovative nature-based materials and solutions such as sustainably sourced wood. It is therefore essential to unlock the full potential of the circular bioeconomy for our future especially for storing carbon in harvested wood products and substituting in tendency other energy intensive, non-renewable and fossil-based materials for construction, renovation, furniture, flooring and packaging. Moreover, for a circular bioeconomy to be genuinely sustainable, wood resources ought to be optimally utilised in line with the cascading principle and the preferred material use of the waste hierarchy to increase the carbon lifecycle and ensure high resource efficiency, as endorsed in the Fit for 55 set of proposals. Finally, EPF believes that the implementation of the Bioeconomy Strategy Action Plan should foster the support for harvested wood products to promote sustainable forest bioeconomy and the transition to a more nature-based circular economy that will help to extend the carbon lifecycle in wood products. It holds indeed a huge potential especially in the framework of the implementation of the Renovation Wave Strategy and the New European Bauhaus initiative to help turning the construction sector from a source of GhG emissions into a carbon sink.
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Response to Detailed implementing rules for the voluntary schemes recognised by the European Commission

27 Jul 2021

The European Panel Federation (EPF) warmly welcomes the possibility to provide a feedback on the draft implementing regulation on rules to verify sustainability and greenhouse gas emissions saving criteria and low indirect land-use change-risk criteria. EPF believes that it is essential to develop comprehensive and harmonised EU-wide rules to apply across the certification system, bringing about the necessary legal certainty on the rules applicable to economic operators and voluntary schemes with a view to ensure compliance with the sustainability and GHG emissions saving criteria. Supporting the development of voluntary schemes that set clear standards for the production of sustainable biofuels, bioliquids and biomass fuels is indeed key to substantiate sustainability claims. Overall, EPF welcomes the proposals encompassed in the draft implementing regulation especially with regard to biomass fuels to avoid critical non-conformities subject to certificate refusal under Article 29(3), (4) and (5) of the Renewable Energy Directive (EU) 2018/2001 such as fraudulent issuance of proof of sustainability, deliberate production of wastes or residues, for example, the deliberate modification of a production process to produce additional residue material, or the deliberate contamination of a material with the intention of classifying it as a waste. In this respect, it is important to secure that voluntary schemes apply the specific rules and exemptions for waste and residues set out in Renewable Energy Directive (EU) 2018/2001 only if such raw material falls within the scope of the respective definitions in Article 2 of that Directive. Therefore, voluntary schemes should provide economic operators with clear instructions on how they assess whether raw materials are considered waste and residues. Moreover, EPF supports the proposal on auditing of waste and residues to cover the whole supply including the economic operator where the waste or residue arises as well as the proposal on auditing of mass balance system to ensure compliance with the sustainability and greenhouse gas saving criteria by allowing mixing of raw material and fuel with differing sustainability characteristics only if raw material and fuels belong to the same product group. Finally, you can find here attached a proposal for a consultation system (already shared with the Commission back in December 2020) to help verifying whether projects by applicants for biomass energy support comply with the sustainability requirements of REDII and to evaluate any potential distortions of raw material markets prior to accepting such projects. Such a consultation system could indeed ensure that preferential material use of forest biomass in line with the cascading use and the waste hierarchy is a key principle that can at the same time help reduce increasing pressure on natural capital and assist in the fight against climate change by storing carbon in harvested wood products and substituting other energy intensive materials.
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Response to Guidance on REDII forest biomass sustainability criteria

28 Apr 2021

Dear Madam, Sir, Please find here attached the response of the European Panel Federation (EPF) on the consultation on the Draft 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. Many thanks in advance for taking our considerations into account. Yours sincerely, Kris Wijnendaele Technical Director European Wood-Based Panels Federation (EPF)
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Response to Revision of the Energy Performance of Buildings Directive 2010/31/EU

21 Mar 2021

The European Panel Federation (EPF) welcomes the Inception Impact Assessment on the revision of the Energy Performance of Buildings Directive 2010/31/EU as part of the “Fit for 55” package included in the Commission Work Programme 2021. The decarbonisation of the built environment is indeed essential to achieve the new 2030 Climate Target and climate neutrality by 2050.The wood-based panels industry believes that energy efficiency renovation of the built environment as set in the objectives of the Renovation Wave Strategy holds great potential for reducing GHG emissions and turning the built environment into a carbon sink by using carbon storing and climate friendly materials such as wood. Therefore, EPF favours strongly Option 3, namely, to amend the EPBD to translate the actions proposed in the Renovation Wave and the increased ambition towards building decarbonisation into legislation. In this respect, EPF calls on the European Commission to consider the following points when elaborating its proposals for the revision of the Energy Performance of Buildings Directive: • Promote the use of nature-based materials such as wood-based panels since they can play a crucial role underlining their double benefit of carbon storage in EU building stock and energy-intensive material substitution; • Implement green public procurement criteria for public buildings related to life-cycle carbon emissions and circularity of construction materials; • Develop a comprehensive methodology where carbon storage benefits can be accounted for thus allowing consumers to choose materials that offer carbon storage, such as long-lived harvested wood products; • Support off-site prefabricated modular solutions with locally sourced nature-based materials to hasten the rate of energy efficiency renovations especially for large-scale and deep renovation of social housing to tackle energy poverty; • Set-up mandatory minimum energy performance criteria for construction and renovation.
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Meeting with Eszter Batta (Cabinet of Commissioner Thierry Breton)

11 Feb 2021 · EU level initiatives important for the construction ecosystem

Response to Climate change mitigation and adaptation taxonomy

18 Dec 2020

Please find here attached EPF's comments on the Commission’s proposal for a delegated act on a classification system for green investments and sustainable finance.
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Response to Revision of the Energy and Environmental Aid Guidelines (EEAG)

8 Dec 2020

Please find here attached EPF Feedback on the Revision of State Aid Guidelines for environmental protection and energy (EEAG).
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Response to 8th Environment Action Programme

3 Dec 2020

The European Panel Federation (EPF), welcomes the possibility to provide a feedback prior to the adoption of the “8th Environment Action Programme - supporting the European Green Deal (8th EAP)”. The wood-based panels industry believes that, in the framework of the implementation of the objectives of the European Green Deal and of the Sustainable Development Goals, the mainstreaming and streamlining environmental principles is essential to ensure coherence and synergies between the different EU policies and actions. In this respect, EPF calls on the European Commission to consider the following points to feed the legislative debate: • Effective implementation of the New Circular Economy Action Plan and the Renovation Wave Strategy is of the utmost importance for the transition towards a climate-neutral, resource-efficient clean and circular economy in a just and inclusive way within the framework of a green and digital recovery; • Greenhouse gas emissions reductions and removals are both essential in order to attain climate neutrality by 2050 and thus appropriate accounting is a sine qua non condition to achieve climate targets; • According to a recent Study, the overall and positive climate effect of European forests and the forest-based sector is estimated at -806 million tons of carbon dioxide equivalents annually, this corresponds to c. 20% of all fossil emissions in the European Union; • In this respect, the substitution effect and the long-term storage of carbon in harvested wood products (such as wood-based panels) should be duly accounted when assessing sustainability considerations; • There is therefore a unique opportunity when implementing the New Circular Economy Action Plan and the Renovation Wave Strategy to shift towards a regenerative economy, creating sustainable jobs and turn the built environment into a carbon sink through the promotion of circular bioeconomy and the use wood and bio-based materials, nature-based solutions and recycled materials. EPF represents the manufacturers of wood-based panels being particleboard, dry process fibreboard (MDF), oriented strand board (OSB), hardboard, softboard and plywood. EPF has members in 32 European countries. The EU wood panel industry has a turnover of about 22 billion euro every year, creates over 100,000 jobs directly and counts more than 5,000 enterprises in Europe. The production of wood-based panels in the EU-28 (+EFTA) in 2019 was an estimated 59.2 million m³. www.europanels.org
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Response to Updating the EU Emissions Trading System

25 Nov 2020

The European Panel Federation (EPF), welcomes the Inception Impact Assessment on the Amendment of the EU Emissions Trading System (EU ETS) and the opportunity to provide feedback. The wood-based panels industry believes that this initiative will be a key element in implementing a coherent framework to allow the objectives of the European Green Deal to be achieved, to combat climate change and to achieve climate neutrality by 2050. EU ETS as the world’s largest carbon market is an important tool for reducing greenhouse gas emissions cost-effectively. EPF Members are preparing to return to the carbon leakage list in Phase IV (2021-2030) following the 2018 revision and in this respect, EPF calls on the European Commission to consider the following points when elaborating its proposals: • Ensure that decisions are made as soon as possible to allow linear and rapid business planning and stability for at least the next five years; • Provide economic operators with the final decisions on the the benchmarks (especially the heat benchmark), the Cross-Sectoral Correction Factor and the number of allowances for every company under ETS • Guard against unforeseen impacts of the Carbon Border Adjustment Mechanism (CBAM) and ensure that it remains complementary to ETS; • Ensure that CBAM should not be seen as an alternative to the existing carbon leakage measures under the ETS which are competitiveness measures; • Guarantee stability of the legal framework so that investments in areas such as high-efficiency Combined Heat & Power (CHP) are made sustainable in the long-term; • Confirm that the new proposals ensure a level playing field and the minimisation of the regulatory and administrative burden for economic operators.
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Response to Land use, land use change and forestry – review of EU rules

25 Nov 2020

The European Panel Federation (EPF), welcomes the Inception Impact Assessment on the Amendment of the Land Use, Land Use Change and Forestry Regulation and the opportunity to provide feedback on the intended initiative. The wood-based panels industry believes that this initiative will be a key element in implementing a coherent framework to allow the objectives of the European Green Deal to be achieved and to combat climate change. Sustainable land and forest management together with carbon removals via sequestration in forests, storage in harvested wood products and substitution of fossil-based and energy intensive materials is indeed essential to achieve the new 2030 climate targets and reach climate neutrality by 2050. This is the 3S framework of the forest-based industry that today makes a positive climate contribution equivalent to 20% of all EU fossil emissions. In this respect, EPF calls on the European Commission to consider the following points when elaborating its proposals: • Acknowledge the multifunctionality of EU forests to unleash the full potential of the sustainable circular bioeconomy; • Guarantee a level playing field by avoiding unnecessary market distortions to ensure wood availability for increased pools of sustainably sourced harvested wood products; • Foster fossil-based and energy intensive material substitution with bio-based products and solutions; • Develop and implement a solid methodology for evidence-based accurate calculation of carbon removals that takes into account the climate benefits of material substitution(1); • Implement further the sustainability criteria to promote material use over early energy recovery in line with the principles of circularity and of the waste hierarchy; • Empower consumers through the development of labels promoting climate smart products and solutions. (1) According to a recent Study “Climate effect of the forest-based sector in the European Union” The European forests and the forest-based sector provide integrated solutions to the global climate challenge on a very large scale. The overall and positive climate effect is estimated at -806 million tons of carbon dioxide equivalents annually. This corresponds to c. 20% of all fossil emissions in the European Union.
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Response to EU Forest Strategy

17 Nov 2020

The European Panel Federation (EPF), welcomes the opportunity to provide feedback on the Roadmap on the EU Forest Strategy. The wood-based panels industry believes that an independent and self-standing EU Forest Strategy for the post-2020 period, built on a comprehensive understanding of Sustainable Forest Management, is the way forward to enable the European forests and forest-based industries to tap into the potential of the EU forest-based bioeconomy(1) to mitigate climate change and to create sustainable jobs. In this respect, EPF calls on the European Commission to consider the following points when elaborating its proposals for the future EU Forest Strategy: - Acknowledge carbon storage in wood products(2) that can help decrease the amount of CO2 emissions in the atmosphere by developing a mechanism that rewards “CO2 saving” when revising the relevant legislation; - Promote the use of climate positive products (such as wood-based panels) which provide a robust and immediate solution for reaching a carbon-neutral EU economy, thanks to the effects of carbon storage in wood-based products and substitution of fossil-based and energy intensive materials; - Avoid unnecessary market distortions for wooden raw materials from support schemes for early energy recovery from biomass in line with the principle of resource efficiency, circularity and the waste hierarchy; - Stimulate the cascade use of harvested wood products to promote resource efficiency, waste reduction and the extension of the carbon life cycle for the deployment of a sustainable forest-based bioeconomy; - Develop 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 such as bark beetles, forest fires and storms on wood availability and forest health. (1) The Forest-based bioeconomy brings jobs and growth mainly in rural areas: the number of employees in the Woodworking Industries alone should be estimated at substantially more than 2.1 million, for a total number of 180.000 companies and a production value of €240 billion in 2018. (2) According to a recent Study “Climate effect of the forest-based sector in the European Union” The European forests and the forest-based sector provide integrated solutions to the global climate challenge on a very large scale. The overall and positive climate effect is estimated at -806 million tons of carbon dioxide equivalents annually. This corresponds to c. 20% of all fossil emissions in the European Union.
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Response to Sustainable Products Initiative

13 Nov 2020

The European Panel Federation (EPF), warmly welcomes the Inception Impact Assessment on the Sustainable Products Initiative and the review of the Ecodesign Directive. The wood-based panels industry believes that this initiative will be a key element in implementing a coherent framework allowing for achieving the objectives of a resilient circular economy and climate neutrality while strengthening the role of consumers in the green and sustainable transition. In this respect, EPF calls on the European Commission to consider the following points when elaborating its legislative proposals to ensure that products placed on the EU market more sustainable: • Ensure that the Sustainable Products Initiative allows for the efficient implementation of circular bioeconomy throughout the Union; • Acknowledge that - while durability, resource efficiency and eco-design are desirable qualities - the key element is the nature of the raw materials used; • Promote therefore the use of naturally renewable, locally sourced and climate smart (carbon storing) raw materials, products and solutions; • Acknowledge and account for material substitution to avoid the use of energy-intensive materials especially for sustainable construction and renovation for energy efficiency of the built environment; • Develop well-functioning markets for secondary raw materials in line with the principles of the waste hierarchy and material use preference to enhance resource efficiency through multiple downcycling in cascades; • Ensure that product-specific targets for recycled content is applied only when technically feasible in order to take into account the specific characteristics of different categories of products; • Safeguard the preference for ‘made in EU’ sustainable products through green public procurement rules especially with respect to the Renovation Wave and the Sustainable Built Environment Initiatives; • Ensure the empowerment of consumers choices through adequate sustainability labelling, digital passports and other information on environmental footprints of products and solutions.
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Response to Industrial pollution - revision of the European Pollutant Release and Transfer Register

21 Oct 2020

The European Panel Federation (EPF), welcomes the Inception Impact Assessment on the revision of the Regulation on the European Pollutant Release and Transfer Register (E-PRTR). The wood-based panels industry believes that all industrial sectors should contribute, in line with the Industrial Emissions Directive (IED), to ensure better control and reduce the impact of industrial emissions on the environment and on the quality of life in the EU. In this respect, EPF calls on the European Commission, when elaborating its proposals for the revision of the the Regulation on the European Pollutant Release and Transfer Register, to: Ensure that lower emissions from industrial production is done through an integrated and balanced approach; Guarantee that, while reviewing the scope of the E-PRTR Regulation, no market sensitive information (e.g. production volumes) will be incorporated into the database; Confirm that the revision will genuinely help contribute to the circular economy and decarbonisation of the EU industrial sectors in order to progressively move towards the zero-pollution objective; Ensure simplification and that no unnecessary burden and costs are imposed on companies, especially SMEs. EPF represents the manufacturers of wood-based panels being particleboard, dry process fibreboard (MDF), oriented strand board (OSB), hardboard, softboard and plywood. EPF has members in 32 European countries. The EU wood panel industry has a turnover of about 22 billion EUR every year, creates over 100,000 jobs directly and counts more than 5,000 enterprises in Europe. The production of wood-based panels in the EU-28 (+EFTA) in 2019 was an estimated 59.2 million m³. www.europanels.org
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Response to Review of Directive 2012/27/EU on energy efficiency

21 Sept 2020

The European Panel Federation (EPF), welcomes the Inception Impact Assessment on the review of the Directive 2012/27/EU on energy efficiency and the related more ambitious targets for the reduction of the EU’s greenhouse gas emissions by at least 50% to 55% by 2030. Enhanced energy efficiency is indeed a key objective of the Green Deal in the framework of the incoming Renovation Wave Initiative in mid-October and in our recovery from the COVID-19 crisis. The wood-based panels industry believes that it is especially essential to foster energy efficiency of the EU building stock. In this respect, EPF calls on the European Commission to consider the following points when elaborating its proposals for the review and evaluation of the EU energy efficiency directive: • The review of the energy efficiency directive ought to rise to the challenge of climate neutrality objective by 2050 and the 2030 milestone; • Improving energy efficiency should work hand in hand with resource efficiency in line with the principles of the circular economy, the waste hierarchy and the carbon neutrality target; • There is a need to foster well-functioning markets for secondary raw materials from recycled construction and demolition materials that are free from distorting subsidies to avoid further pressure on natural resources; • Ambitious investment should be mobilised in the renovation of residential and commercial buildings and tourist accommodation in order to improve the energy performance of the EU building stock as well as to stimulate the recovery; • The rate of building renovation needs to be increased, as the existing building stock represents the single biggest potential sector for energy savings; • The capacity to store carbon in wood-based construction products and to substitute energy-intensive and fossil-based products for construction and renovation should be duly accounted when assessing sustainability considerations; • Based on embedded carbon levels and insulation properties, green public procurements should be implemented to foster the use of sustainable nature-based products for construction and renovation; • Cost and energy effective approaches for renovation should be identified such as off-site prefabrication of building components such as timber frame construction to accelerate large scale renovations and reduce waste; • NECPs should duly reflect the results of the review of the energy efficiency directive to ensure proper implementation. EPF represents the manufacturers of wood-based panels being particleboard, dry process fibreboard (MDF), oriented strand board (OSB), hardboard, softboard and plywood. EPF has members in 32 European countries. The EU wood panel industry has a turnover of about 22 billion euro every year, creates over 100,000 jobs directly and counts more than 5,000 enterprises in Europe. The production of wood-based panels in the EU-28 (+EFTA) in 2019 was an estimated 59.2 million m³. www.europanels.org
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Response to Revision of the Renewable Energy Directive (EU) 2018/2001

21 Sept 2020

The European Panel Federation (EPF), welcomes the Inception Impact Assessment on the revision of the Directive (EU) 2018/2001 on the promotion of the use of energy from renewable sources (RED II). The wood-based panels industry believes that the promotion of the use of renewables and the transition towards a decarbonised European society are key to achieving the objectives of the Green Deal and ought to play a fundamental role in the post COVID-19 recovery. In this respect, EPF calls on the European Commission to consider the following points when elaborating its proposals for the revision of the Directive on the promotion of the use of energy from renewable sources: • The revision of the RED II should be in line with the principles of the circular economy, the waste hierarchy established in Directive 2008/98/EC and the carbon neutrality target; • Key outcomes from RED II should not be lost, especially Recital 21 and the obligation on Member States to ensure that their support schemes do not create market distortions on raw material markets (including wood); • The cascade use of wood principle should be applied to ensure the long-life cycle carbon storage and that reuse and recycling are always the priority options; • There is a need to establish well-functioning markets for wooden secondary raw materials before eventual end of life energy recovery to avoid further pressure on natural resources and distortive effects on markets for (by-)products, wastes or residues; • The revision of the Directive should focus on the full compliance with the sustainability criteria laid down in Article 29(2) to (7), the energy efficiency criteria and the greenhouse gas emissions criteria. EPF represents the manufacturers of wood-based panels being particleboard, dry process fibreboard (MDF), oriented strand board (OSB), hardboard, softboard and plywood. EPF has members in 32 European countries. The EU wood panel industry has a turnover of about 22 billion euro every year, creates over 100,000 jobs directly and counts more than 5,000 enterprises in Europe. The production of wood-based panels in the EU-28 (+EFTA) in 2019 was an estimated 59.2 million m³. www.europanels.org
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Response to Commission Delegated Regulation amending Annex IV to the LULUCF Regulation

14 Sept 2020

The European Panel Federation (EPF), welcomes the possibility to provide a feedback on the draft Delegated Act on “Greenhouse gas emissions from land use and forestry – CO2 offsets” - amending Annex IV to Regulation (EU) 2018/841 as regards the forest reference levels to be applied by the Member States for the period 2021-2025. The wood-based panels industry believes that all sectors should contribute to the new EU 2030 emissions reduction target. It is important indeed to find right balance between CO2 emissions and removals while setting up the forest reference levels that each country must apply between 2021 and 2025. In this respect, EPF calls on the European Commission to consider the following points in the framework of the finalisation of its Delegated Act “Greenhouse gas emissions from land use and forestry – CO2 offsets”: • Although harvested wood products (HWP) are included in the draft delegated act, we believe that more emphasis should be put on the capacity to store carbon in HWP and to substitute energy-intensive and fossil-based products especially for construction and renovation; • According to a recent Study “Climate effect of the forest-based sector in the European Union” The European forests and the forest-based sector provide integrated solutions to the global climate challenge on a very large scale. The overall and positive climate effect is estimated at -806 million tons of carbon dioxide equivalents annually. This corresponds to c. 20% of all fossil emissions in the European Union; • The substitution effect and the long-term storage of carbon in HWP should hence be duly accounted when assessing sustainability considerations; • The cascade use of wood principle should be applied to ensure the long-life cycle carbon storage and that the recycling of waste is always the priority option to avoid early CO2 emissions; • There is a need to establish well-functioning markets for wooden secondary raw materials before eventual end of life energy recovery to avoid further pressure on natural resources and distortive effects on markets for (by-) products, wastes or residues; • Finally, we strongly believe that the European Forest-based Industries ought to be positioned as integral contributors to achieving the climate and sustainability objectives of the European Green Deal.
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Response to Environmental claims based on environmental footprint methods

14 Aug 2020

The European Panel Federation (EPF), welcomes the Inception Impact Assessment on environmental performance of products and businesses. The wood-based panels industry produces sustainably sourced circular products with a low environmental footprint. We believe that misleading claims on product and business environmental and climate-related performances constitute a genuine obstacle to the development of a sustainable green and circular economy and therefore in turn form a barrier to a better European society as envisaged in the European Green Deal. In this respect, EPF 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, of the waste hierarchy, of resource efficiency and of material and energy efficiency; • It is essential to elaborate and implement EU-wide a reliable 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 greenwashing; • An EU legal framework should be established to ensure that green claims are duly substantiated within the framework of an integrated, comprehensive and unique methodology; • EU common formats should be further developed to help consumers make sustainable and climate-friendly choices in order to foster the green transition towards a climate-neutral, resource-efficient and circular economy; • Green public procurement methods should be applied to promote the use of the most sustainable and climate-friendly materials, products and solutions; • Unnecessary administrative burden should be avoided especially for SMEs. EPF represents the manufacturers of wood-based panels being particleboard, dry process fibreboard (MDF), oriented strand board (OSB), hardboard, softboard and plywood. EPF has members in 32 European countries. The EU wood panel industry has a turnover of about 22 billion euro every year, creates over 100,000 jobs directly and counts more than 5,000 enterprises in Europe. The production of wood-based panels in the EU-28 (+EFTA) in 2019 was an estimated 57.6 million m³. www.europanels.org
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Response to Review of the Construction Products Regulation

13 Aug 2020

The European Panel Federation (EPF), welcomes the Inception Impact Assessment on the review of the Construction Products Regulation EU No 305/2011. The wood-based panels industry produces sustainably sourced bio-based circular products that can be used for energy-efficient and climate-friendly construction and renovation. It is therefore of utmost importance that the CPR enables products to be properly assessed and declared for all characteristics, including those related to a truly sustainable and circular economy at a European level. This will aide end-users to make the best construction products choices for their projects in a clear and transparent way. The issue of hENs not being cited in the Official Journal of the European Union (OJEU) is one that needs to be unblocked with a degree of urgency as this stifles industry in being able to adapt to market needs as well as regulatory needs. We believe this can be done with the current regulatory framework but do accept that there will be necessary legal adaptations following legal precedents being set. We believe this can be done mainly through better co-operation and working with all the relevant, fully engaged actors (broadly speaking Option I). We support the streamlining of the DoP and CE marking information and also recognise that electronic information should be the future means to integrate with information gathering systems used throughout the building process and ultimately to end of life. This will enable well-functioning markets for secondary raw materials from recycled construction and demolition materials to reduce pressure on natural resources. The current CPR has helped Europe through its harmonisation of building practices, codes and markets. Recently this has been threatened in certain Member States. Any review of CPR should avoid further regionalism and fragmentation by securing a level European playing field, thereby benefitting Europe’s half a billion citizens. EPF represents the manufacturers of wood-based panels being particleboard, dry process fibreboard (MDF), oriented strand board (OSB), hardboard, softboard and plywood. EPF has members in 32 European countries. The EU wood panel industry has a turnover of about 22 billion euro every year, creates over 100,000 jobs directly and counts more than 5,000 enterprises in Europe. The production of wood-based panels in the EU-28 (+EFTA) in 2019 was an estimated 57.6 million m³. www.europanels.org
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Response to Review of the requirements for packaging and feasibility of measures to prevent packaging waste

3 Aug 2020

Please find here attached the contribution from the European Panel Federation.
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Response to Commission Communication – "Renovation wave" initiative for the building sector

4 Jun 2020

The European Panel Federation (EPF) warmly welcomes the Renovation Wave initiative for public and private buildings. EPF strongly believes that the renovation of the built environment across the European Union should at the same time enhance energy efficiency and foster the use of sustainable and climate-friendly products and solutions. In this respect, the construction sector ought to be supported to embrace the principles of the circular economy, of the waste hierarchy and resource efficiency. In order to ensure the transition towards a resilient and sustainable economy, EPF calls for the following recommendations to be addressed: • Assessing the impact of renovation approaches including an impact assessment of the proposed policies and measures by: o 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; o 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. • Adopting a life-cycle approach in line with the circular economy to maximise the reuse, recycling, and recuperation of materials in their procurement strategies; • Ensuring that bio-based materials used for construction and renovation, including all wood wastes, should return to the value-chain by fostering eco-design, increasing recycling targets and favouring wherever possible the use of secondary raw materials for construction and renovation products(without compromising product safety and performance standards) ahead of eventual end of life incineration; • Identifying the internal technical market barriers that might lead on discrepancies in the use of construction products within Member States; • Ensuring that 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. • Increasing the availability of relevant and comprehensive data on building across the European Union; • Fostering off-site prefabrication of building 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; • Designing new long-term financing mechanisms for renovation aiming to boost a green renovation wave; • Setting up, at Member States level, financial tools for supporting renovation for the private-owned residential and tertiary built environment through attractive interest rates for green renovation loans; • Engaging all relevant stakeholders in the development of the green renovation wave. The renovation of existing buildings using wood-based products can contribute significantly to sustainable urban development, energy efficiency and to climate change mitigation. The renovation of building envelopes, such as façades and roofs, with highly insulated wooden components, can reduce heat losses and related energy demand significantly. When legally harvested and sourced from sustainable managed forests, wood is the only material capable of reducing carbon dioxide emissions and thus can play a vital role in climate change mitigation. Moreover, wood-based products need less energy in their manufacturing process and thus have a lower environmental impact than other materials throughout the
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Response to 2030 Climate Target Plan

14 Apr 2020

The European Panel Federation (EPF) warmly welcomes the initiative to propose a clear Roadmap to prepare the EU for the transition towards climate neutrality by 2050 in parallel to the public consultation of the Climate Law. In this framework, EPF calls on the European Commission to: • Avoid unnecessary market distortions from support schemes for bioenergy to guarantee a level playing field; • Ensure that bio-based materials, including all wood wastes, return to the value-chain by fostering eco-design, increasing recycling targets and favouring wherever possible the use of secondary wooden raw materials for products ahead of eventual end of life incineration; • Take action to enhance carbon removals and storage into natural sinks and boost the use of biogenic carbon storing materials for better resource and energy efficiency especially for construction and renovation of the built environment to increase the total harvested wood products’ carbon stock; • Ensure appropriate carbon accounting of removals and emissions while considering the carbon displacement factor in the Land Use, Land Use Change and Forestry Regulation; • Promote resource efficiency, waste reduction and extension of the carbon life cycle into low embodied carbon bio-based products and solutions; • Improve green public procurement rules to include energy efficiency and circular economy criteria; • Foster the selection of sustainable and climate-friendly building materials to ensure they are recyclable and/or recycled, locally sourced and with low embodied carbon; • Increase, together with construction companies, manufacturers and building designers, off-site prefabrication of building components such as walls and roofs since it is one of the most promising ways to accelerate renovations in a cost-efficient manner; • Empower consumer choices for favouring sustainable and climate-friendly products and solutions. Wood-based panels (WBP) are a model of circular and sustainable economy and can provide, for instance in construction and renovation (prefabricated WBP), about 60% less CO₂ emissions than traditional heavy housing. Studies have shown that an increased use of harvested wood products for construction and renovation could result in avoided emissions of 11 Million tons of CO₂ equivalent per year on average. It represents avoided emissions equivalent to more than 2,3 million passenger vehicles driven for one year EPF represents the manufacturers of wood-based panels being particleboard, dry process fiberboard (MDF), oriented strand board (OSB), hardboard, softboard and plywood. EPF has members in 32 European countries. The EU wood panel industry has a turnover of about 22 billion euro every year, creates over 100,000 jobs directly and counts more than 5,000 enterprises in Europe. The production of wood-based panels in the EU-28 (+EFTA) in 2019 was an estimated 57.6 million m³.
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Response to Carbon Border Adjustment Mechanism

31 Mar 2020

The European Panel Federation (EPF), warmly welcomes the Impact Assessment of the carbon border adjustment mechanism. Such a mechanism is a fundamental tool for the implementation of an effective climate policy in a globalised economy and to ensure international competitiveness of European industries. The support of appropriate carbon pricing should send a clear message for long-term sustainable investment to back the transition to carbon neutrality by 2050 while preventing employment and market shares losses within the European Union. In this respect EPF calls on the European Commission to consider the following points when elaborating its proposals for a carbon border adjustment mechanism: • Since the actual calculation to decide whether an industry can be included into the carbon leakage list is based on the direct and indirect carbon costs of its products, the actual embodied carbon content of imported products should similarly be considered within the framework of the BCA mechanism; • In order to avoid delocalisation and to promote effectiveness in carbon leakage prevention, all products’ related carbon emissions should be taken into account and specifically those related to transport. More specifically, the ‘cradle to gate’ approach for raw materials (EN 15804) within the framework of the Environmental Product Declaration fails to reflect transport carbon emissions. A common EN standard should therefore be developed to encompass transport related emissions for both EU manufactured and imported products; • More stringent measures should be considered for imported products manufactured in non-EU countries that are not signatories of international climate agreements such as the Kyoto Protocol and the Paris Agreement; • Attention should be given to potential attempts to bypass the carbon border adjustment mechanism for imported semi-finished products. Exporters may try to bypass the mechanism by moving up or down the value chain to trade precursors or derivatives instead of the product itself. Action should therefore be taken to discourage this type of behaviour; • The scope and levels of the carbon border adjustment mechanism should comply with EU, WTO and other international rules; • Unnecessary administrative complexity and compliance costs should be avoided. EPF represents the manufacturers of wood-based panels being particleboard, dry process fibreboard (MDF), oriented strand board (OSB), hardboard, softboard and plywood. EPF has members in 32 European countries. The EU wood panel industry has a turnover of about 22 billion euro every year, creates over 100,000 jobs directly and counts more than 5,000 enterprises in Europe. The production of wood-based panels in the EU-28 (+EFTA) in 2019 was an estimated 57.6 million m³.
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Response to Climate Law

5 Feb 2020

The European Panel Federation (EPF) warmly welcomes the European Green Deal ambitions to deliver climate neutrality by 2050 together with a circular innovative industry for a successful green transition. In this respect, and in order to help achieve the Green Deal objectives, EPF calls on the European Commission within the framework the future Climate Law to: • encourage the the cascading use of harvested wood products; • increase recycling targets to promote resource efficiency, waste reduction and to extend the carbon life cycle; • extend the carbon cycle via greater use of natural products such as wood-based panels thereby increasing the total carbon stock; • avoid unnecessary market distortions from support schemes for renewable energy. • develop green public procurement and other supportive schemes for sustainable bio-based products for construction and renovation, boosting the use of biogenic carbon storing materials for better resource and energy efficiency; • define accurate accounting to measure and confirm the substitution effect of using biogenic products instead of carbon-intensive materials; • secure that bio-based materials, including all wood wastes, return to the value-chain to favour recycling over energy recovery.
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Response to A new Circular Economy Action Plan

20 Jan 2020

EPF, the European Panel Federation, has members in 25 countries and represents the manufacturers of particleboard, MDF, OSB, hardboard, softboard and plywood. The European wood-based panels industry has an annual turnover of about 22 billion euros, creates over 100,000 jobs directly and counts more than 5,000 enterprises in Europe. Our response is attached.
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Meeting with Timo Pesonen (Acting Director-General Internal Market, Industry, Entrepreneurship and SMEs)

3 Sept 2019 · Present EPF and their priorities

Response to Commission Regulation amending the CLP Regulation (EC) 1272/2008 and correcting Commission Regulation (EU) 2018/669

7 Feb 2019

EPF, the European Panel Federation, has members in 25 countries and represents the manufacturers of particleboard, medium density fibreboard (MDF), oriented strand board (OSB), hardboard, softboard and plywood. The European wood-based panel industry has an annual turnover of about 22 billion Euros, creates over 100,000 jobs directly and counts more than 5,000 enterprises in Europe. EPF welcomes the European Commission’s Better Regulation Consultation on the proposal to classify titanium dioxide (TiO2) as a suspected (category 2) carcinogen by inhalation, as a part of the 14th adaptation technical progress (ATP) of the EU’s classification and labelling (CLP) Regulation. EPF is a downstream user of speciality papers containing TiO2. These are often used as coatings, especially in decorative furniture applications. EPF is very concerned about the proposed classification which it has followed primarily through TDMA, the titanium dioxide manufacturers association. EPF, on behalf of its members, wishes to oppose this proposal for three principal reasons. Firstly, there are more proportionate and effective regulatory options available. The EU proportionality Principle requires that the Commission chooses the least burdensome regulatory measure to achieve the objective pursued. In the case of TiO2, alternative regulatory options are available which would address the potential particle inhalation concerns more effectively and proportionally, including EU harmonised occupational health and safety measures or the introduction of a new specific hazard class for particle toxicity in the CLP. These alternatives have been brought forward by Member States themselves and industry, and they merit further investigation for their proportionality. Secondly, the basis for the proposed classification is precedent setting. “Particle toxicity” as the basis for hazard classification has not received an appropriate level of scientific scrutiny, expert input, practical evaluation, or legal analysis to justify and support the application of such a concept in the CLP regulatory framework. CLP is allowed only for intrinsic hazards, which this is not. Better regulation warrants that further and extensive analysis and careful study of this hazard basis is required before it can be applied effectively, proportionally, and without undue discrimination in the regulatory framework. Thirdly, the full impacts of the classification are not fully understood. There is not yet satisfactory analysis of the interpretation or application of the listing. The inevitable outcome will be uncertainty and ambiguity in the practical application of the regulation to various manufacturing and downstream use application and workplaces. Moreover, the reservations raised by Member States and interested parties indicate that the classification is anticipated to have significant impacts in downstream legislation, notably on waste. The impact on waste concerns EPF members greatly. European wood-based panel producers have fully embraced the circular economy and recovered waste is now a significant raw material and energy source. Current procedures of reusing waste would be massively affected if paper waste or dust particles containing 1% TiO2, were to be classified as hazardous. Waste from these streams currently merges with other wastes and feeds into a recovery process (material and energy). Classifying these as hazardous would have a very detrimental effect on resource efficiency (and could only be achieved at tremendous cost). The Commission should undertake an impact assessment to bring full clarity ahead of any potential classification. Therefore, for reasons of proportionality, precedence and impact, and especially on unnecessarily threatening valuable circular waste streams, EPF urges the Commission to reject the inclusion of TiO2 in the 14th ATP of the CLP, pending deeper consideration of alternative regulatory options.
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Meeting with Dominique Ristori (Director-General Energy)

10 Apr 2018 · Energy policy

Meeting with Daniel Calleja Crespo (Director-General Environment)

16 Nov 2016 · Wood panel sector, circular economy, cascading use of wood