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Finnish Forest Industries Federation (Metsäteollisuus ry)

FFIF

The Finnish Forest Industries Federation represents the pulp, paper, and wood products industry in Finland.

Lobbying Activity

Response to Land use, land use change and forestry – establishing trajectories towards 2030

12 Dec 2025

The Finnish forest industries support ambitious EU climate policy and contribute to climate solutions through bio-based products that replace fossil-intensive alternatives and store bio-based carbon. Based on domestic renewable raw materials, wood, the sector strengthens Europes self-sufficiency, resilience, economy, and employment. The vitality of forests requires active management, as passivation would weaken both climate and economic benefits of forests. With regard to the matter under review, FFIF notes that the proposed annual limit values for each Member State reflect the developments currently known in the land-use sector.
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Meeting with Sebastian Tynkkynen (Member of the European Parliament)

9 Dec 2025 · Metsäpolitiikan ajankohtaiset

Meeting with Eero Heinäluoma (Member of the European Parliament)

2 Dec 2025 · Ajankohtaiset metsäteollisuusasiat

Meeting with Anna-Maja Henriksson (Member of the European Parliament)

2 Dec 2025 · Forestry

Meeting with Sebastian Tynkkynen (Member of the European Parliament)

2 Dec 2025 · Keskeiset EU-asiat

Meeting with Sirpa Pietikäinen (Member of the European Parliament)

26 Nov 2025 · Relevant forest related files

Meeting with Aura Salla (Member of the European Parliament)

25 Nov 2025 · Fouding treaties, industry and investments in Finland's Eastern border, Working group on the coordination of nature restoration and national defence

Meeting with Eero Heinäluoma (Member of the European Parliament)

25 Nov 2025 · Ajankohtaiset metsäteollisuusasiat

Meeting with Elsi Katainen (Member of the European Parliament) and Stora Enso Oyj and UPM-Kymmene Oyj

25 Nov 2025 · Current issues in forestry policy and EU

Meeting with Maria Ohisalo (Member of the European Parliament)

21 Nov 2025 · 2040 climate target

Meeting with Elsi Katainen (Member of the European Parliament)

18 Nov 2025 · Forestry policy, EUDR

Meeting with Aura Salla (Member of the European Parliament)

18 Nov 2025 · Current legislation

Meeting with Pekka Toveri (Member of the European Parliament)

18 Nov 2025 · Current EU Agricultural topics

Meeting with Axel Hellman (Cabinet of Commissioner Jessika Roswall)

14 Nov 2025 · Nature credits

Meeting with Pekka Toveri (Member of the European Parliament)

15 Oct 2025 · Current EU Agricultural topics

Meeting with Eero Heinäluoma (Member of the European Parliament)

14 Oct 2025 · Tutkimus-, kehitys- ja innovaatiotoiminta, sekä korkeakoulutusasiat

Meeting with Katri Kulmuni (Member of the European Parliament)

2 Oct 2025 · Ajankohtaiset vesiasiat

Meeting with Katri Kulmuni (Member of the European Parliament)

1 Oct 2025 · Kiertotalousasetus, biotalousstrategia

Finnish Forest Industries urge strict rules for Nature Credits

29 Sept 2025
Topic — EU roadmap for creating a market in nature restoration and biodiversity credits.
Message — The federation demands that nature credit trading only occur after companies have minimized their own biodiversity harm. They want clear additionality criteria targeting valuable protected sites with proper monitoring.12
Why — This would protect their forest operations from competing biodiversity offset demands.34
Impact — Companies seeking cheaper biodiversity offsets lose flexible market access to credits.5
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Meeting with Elsi Katainen (Member of the European Parliament)

24 Sept 2025 · Topical forestry related issues

Meeting with Katri Kulmuni (Member of the European Parliament)

24 Sept 2025 · Ilmastolaki, muut ajankohtaiset ilmastoasiat

Meeting with Eero Heinäluoma (Member of the European Parliament)

24 Sept 2025 · EU:n 2040 ilmastotavoitteet

Meeting with Katri Kulmuni (Member of the European Parliament)

24 Sept 2025 · Metsäteollisuuden ajankohtaiset asiat

Meeting with Elsi Katainen (Member of the European Parliament)

24 Sept 2025 · Current forestry related issues

Meeting with Hanna Anttilainen (Cabinet of Executive Vice-President Stéphane Séjourné), Laia Pinos Mataro (Cabinet of Executive Vice-President Stéphane Séjourné)

23 Sept 2025 · FFI positions towards EU policies and instruments, in particular the upcoming revision of the EU Bioeconomy Strategy

Finnish Forest Industries urges support for eastern border economy

18 Sept 2025
Topic — EU initiative to strengthen resilience of eastern regions affected by Russian aggression.
Message — The organization requests stronger regional policies to support industrial investment and jobs in eastern border regions. They want measures to improve availability of European raw materials and address transport disruptions that harm exports. They emphasize security considerations for nature-value markets.123
Why — This would reduce raw material costs and restore export routes for their border operations.45
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Finnish Forest Industries Demand Easier Path for Waste-Based Fertilizers

17 Sept 2025
Topic — Evaluation of EU regulation on fertilizing products after two years of application.
Message — The Federation requests broader component material categories and clearer rules for using waste materials in fertilizers. They argue current requirements are too strict and resource-intensive, preventing forest industry sludges from being used despite being safe and established.123
Why — This would allow them to market forest industry sludges as fertilizer ingredients across Europe.45
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Meeting with Eero Heinäluoma (Member of the European Parliament)

16 Sept 2025 · Metsäalan ajankohtaisasiat

Meeting with Elsi Katainen (Member of the European Parliament)

10 Sept 2025 · Maa- ja metsätalouspolitiikka

Meeting with Elsi Katainen (Member of the European Parliament)

10 Sept 2025 · Current forest related issues

Meeting with Eero Heinäluoma (Member of the European Parliament)

10 Sept 2025 · Promoting Biobased and Circular Products

Meeting with Sirpa Pietikäinen (Member of the European Parliament)

9 Sept 2025 · Green Claims, Bioeconomy Strategy

Meeting with Eero Heinäluoma (Member of the European Parliament)

8 Sept 2025 · Biotalousstrategia

Finnish Forest Industries urge focus on local forest management

2 Sept 2025
Topic — New EU framework to improve climate resilience and manage accelerating climate risks.
Message — The federation calls for forest management strategies based on local conditions rather than centralized mandates. They also advocate for including genetically improved seeds to help forests adapt to longer growing seasons.12
Why — Focusing on adaptation helps secure the supply of domestic wood needed for climate-friendly products.34
Impact — Environmentalists favoring unmanaged ecosystems lose influence to a model prioritizing timber production and genetic engineering.5
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Finnish Forest Industries demands clear reporting exemptions for manufacturers

25 Jun 2025
Topic — The EU is defining reporting requirements for the disposal of unsold consumer products.
Message — The organization requests that reporting only covers products made available on the market, excluding manufacturing components. They also demand that responsibility for disclosure shifts to traders once products reach the retail stage.123
Why — This would prevent manufacturers from being penalized for standard industrial recycling of production surplus.4
Impact — Retailers and traders would face the entire administrative burden for unsold consumer products.5
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Finnish Forest Industry Urges Holistic Approach to EU Biotech Act

11 Jun 2025
Topic — Consultation on creating an enabling environment for biotechnology and biomanufacturing.
Message — The federation emphasizes the Biotech Act must adopt a comprehensive approach including the forest sector. Biomanufacturing should be defined technology-neutrally, including chemical and mechanical processing of biomass into products. EU funding must better support higher Technology Readiness Levels to facilitate commercialization and innovation.1234
Why — The industry would gain subsidies and market dominance by substituting fossil-based materials with wood.5
Impact — Fossil fuel companies lose market share as regulations move to prioritize renewable wood-based products.6
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Meeting with Katri Kulmuni (Member of the European Parliament)

3 Jun 2025 · ESPR:stä & Uudet biotalouden aloitteet

Meeting with Katri Kulmuni (Member of the European Parliament)

20 May 2025 · Suomen ja Ruotsin metsäteollisuus 30-v EU-jäsenyyttä

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

20 May 2025 · EUs klimat och skogspolitik

Meeting with Jessika Roswall (Commissioner) and

20 May 2025 · Forest issues

Meeting with Christophe Hansen (Commissioner) and

20 May 2025 · Forestry, EU bioeconomy strategy, improvement of the EU competitiveness while reaching the climate goals, and how the industry best can contribute to this work

Meeting with Karin Karlsbro (Member of the European Parliament) and UPM-Kymmene Oyj and Södra Skogsägarna ekonomisk förening

20 May 2025 · Sverige och Finland i EU

Meeting with Anna-Maja Henriksson (Member of the European Parliament)

20 May 2025 · Forestry

Meeting with Aura Salla (Member of the European Parliament)

14 May 2025 · Exchange of views, Clean Industial Deal & Bioeconomy

Meeting with Matthieu Moulonguet (Cabinet of Commissioner Wopke Hoekstra)

13 May 2025 · Forests, bioeconomy and climate objectives

Meeting with Sebastian Tynkkynen (Member of the European Parliament)

9 May 2025 · Metsäteollisuuden ajankohtaiset asiat

Response to EU Life sciences strategy

16 Apr 2025

Unlocking Europes Growth Potential Through the Forest Bioeconomy The Finnish Forest Industries Federation (FFIF) supports the European Life Science Strategy and urges that the versatile forest sector should be recognized as a key pillar within it. Europe, particularly Finland and the other North-Europe, is home to world-class research and development in the forest sector, including both public and private sectors. Europe also has a thriving ecosystem of growth-oriented forest industry companies with strong positions in global markets. Therefore, thanks to this well-established industrial base, Europe already has lot of the infrastructure needed to rapidly scale scientific breakthroughs into real-world applications. This foundation doesnt just support innovation - it accelerates it. It provides fertile ground for spin-offs and smaller research-driven companies to thrive, offering collaboration opportunities in areas such as raw material sourcing. In short, the forest sector is both a source of innovation and a platform for renewal. The forest bioeconomy advances Europes strategic autonomy. Its raw materials are predominantly European, and its products are developed, manufactured, and recycled within Europe. Forest industry biorefineries are more than production facilities - they are advanced industrial ecosystems that maximize resource and energy efficiency and produce a wide range of products. Unlike many other life science sectors that are centered around large urban areas, the forest sector stands out by creating jobs and generating income also in the rural regions, contributing to their vitality and resilience. Wood-based innovations are central to the green transition. The wood-processing industry delivers sustainable alternatives to fossil-based materials across many industries, from construction and packaging to textiles, composites, biomedicals, advanced biofuels, and bio-based chemicals and plastics. The forest industry also uses by-products very efficiently and some of the by-products find value even in high-tech applications such as battery components, coatings, and biostimulants. High-quality basic research alone is not enough. Achieving Europes goals for autonomy, sustainable growth, and climate leadership demands greater investment in scaling up and commercializing innovations. Like many other life science fields, the forest bioeconomy is highly capital-intensive. Taking promising research from lab to market through piloting, demonstrations, and first-of-a-kind industrial plants requires substantial funding. European research and innovation programmes must allocate more resources to the forest sector, with an emphasis on supporting projects at higher Technology Readiness Levels (TRLs). Yet despite the potential, market entry for bio-based products remains uncertain. Higher production costs, compared to fossil-based alternatives in addition to regulatory barriers, create demand-side risks. This uncertainty can stifle private investment and create a vicious cycle that hampers scaling. To break this cycle, the EU must actively enable market access for instance through ecodesign and public procurement policies that acknowledge and prioritize bio-based solutions. Finally, sustainable forest management is essential to Europes strategic autonomy and must be safeguarded. EU policy must ensure access to renewable raw materials by taking a holistic view of the regulatory landscape. A thorough cumulative impact assessment of existing and upcoming regulations affecting wood availability is urgently needed, as rough estimates hint to limited and downward wood availability in Europe.
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Meeting with Katri Kulmuni (Member of the European Parliament)

9 Apr 2025 · Kiertotalousasiat

Finnish Forest Industry Urges Realistic CO2 Standards for Heavy Lorries

2 Apr 2025
Topic — New CO2 emission standards for heavy-duty vehicles, specifically extra-heavy combination lorries.
Message — The federation requests more realistic driving profiles and increased payload values. They argue current simulations overestimate emissions for typical 76-tonne timber trucks.12
Why — Accurate standards would preserve market incentives for manufacturers to build specialized vehicles.3
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Meeting with Maria Guzenina (Member of the European Parliament)

27 Mar 2025 · Current affairs

Meeting with Elsi Katainen (Member of the European Parliament)

26 Mar 2025 · Forest initiatives

Meeting with Eero Heinäluoma (Member of the European Parliament)

26 Mar 2025 · Ajankohtaisaiheet

Meeting with Jussi Saramo (Member of the European Parliament)

26 Mar 2025 · Clean industrial deal and Action plan for Affordable energy

Meeting with Elsi Katainen (Member of the European Parliament)

20 Mar 2025 · Forest issues

Meeting with Elsi Katainen (Member of the European Parliament)

20 Mar 2025 · External Affairs and defense policy

Meeting with Katri Kulmuni (Member of the European Parliament)

19 Mar 2025 · Metsien monitorointiasetus ja muut ajankohtaiset metsäasiat

Meeting with Elsi Katainen (Member of the European Parliament, Shadow rapporteur)

18 Mar 2025 · Forest monitoring

Meeting with Pekka Toveri (Member of the European Parliament)

18 Mar 2025 · EU forest legislation initiatives

Response to EU Start-up and Scale-up Strategy

17 Mar 2025

1. Do you agree that startups and/or scaleups face the hurdles identified in this document (access to finance, regulatory and bureaucratic burdens and fragmentation, access to markets, access to talent, and access to infrastructure, knowledge and services)? Yes, startup and scale-up companies face the challenges mentioned in this document. However, the the challenges faced by startups also vary by industry. For example, industrial manufacturing in the forest industry, which is at the heart of the bioeconomy in the Nordic countries and Finland, differs e.g. from the IT sector also in terms of start-ups and scale-ups. The bioeconomy sector is highly capital-intensive sector, these the aforementioned challenges in bioeconomy are typically even greater than in the IT sector. In particular, the amount of funding required for scaling up is significantly large in bioeconomy companies. Scaling up is also slower than in the IT sector, as the pilot and demonstration phases typically take several years. Additionally, the correctly identified regulatory burden is a major obstacle, especially for early-stage companies in the forest bioeconomy sector, due to uncertainties in raw material availability. However, it would also be very important to support start-ups in the bioeconomy sector, which are part of the export-oriented wood processing industry, as this will increase Europe's new sustainable growth opportunities. 2. Are there any additional hurdles faced by startups and/or scaleups? Especially when comparing startup and scale-up companies in the bioeconomy sector to those in many other industries, uncertainties regarding market entry and demand for bio-based products become apparent. This, in turn, creates a vicious cycle of uncertainty in securing the funding needed for scaling up. There is also room for improvement in the collaboration between early-stage companies and universities as well as other research organizations. 3. What actions do you think the EU and/or its Member States should take to address these hurdles? Public R&D funding, both at the EU level and within member states, should be increasingly directed toward scaling up research results, including piloting, demonstration phases, and supporting the establishment of first-of-a-kind production facilities. Particularly for companies in the bioeconomy sector, market entry and demand for bio-based products should also be facilitated through EU measures, such as public procurement. The uncertainty surrounding raw material availability, which particularly affects forest bioeconomy companies, should be reduced by establishing an EU regulatory framework that incentivizes and recognizes the climate benefits of wood-based products. Start-up and scale-up companies need the infrastructure and competitive global oriented export companies as well as well developed university ecosystem around bioeconomy to be able to succeed. In Finland, the forest sector forms a versatile ecosystem, in which larger companies, start-ups and public sector research and higher education organizations work in close collaboration. Regarding the collaboration between early-stage companies and universities or other research organizations, the conditions and practices for transferring and commercializing research results should yet still be improved. Companies should also be provided with information about research and technology infrastructures available in universities and other public sector organizations, and their access to these infrastructures should be facilitated. Universities should be encouraged to engage in industry collaboration through funding models, and they should internally incentivize researchers to commercialize their inventions.
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Meeting with Sebastian Tynkkynen (Member of the European Parliament)

12 Mar 2025 · Ajankohtaiset metsäteollisuuden aiheet

Meeting with Elsi Katainen (Member of the European Parliament) and Union de la Coopération Forestière Française

12 Mar 2025 · Topical forest issues

Meeting with Katri Kulmuni (Member of the European Parliament)

7 Mar 2025 · Yleiset vesiasiat

Finnish forest industry calls for tailored regional water policies

3 Mar 2025
Topic — This strategy aims to achieve a water-resilient Europe through cross-sectoral planning.
Message — The federation opposes a one-size-fits-all policy in favor of regional frameworks. They emphasize differentiating between water abstraction and actual consumption in industrial processes.12
Why — Avoiding uniform mandates would protect the industry from costs associated with unnecessary purification.3
Impact — EU regulators lose the ability to enforce uniform environmental standards across all member states.4
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Meeting with Katri Kulmuni (Member of the European Parliament)

27 Feb 2025 · Energia-asiat ja CID

Meeting with Sebastian Tynkkynen (Member of the European Parliament)

11 Feb 2025 · Ajankohtaiset metsäasiat

Meeting with Katri Kulmuni (Member of the European Parliament)

10 Feb 2025 · FP10

Meeting with Kamil Talbi (Cabinet of Commissioner Dan Jørgensen)

7 Feb 2025 · Forestry

Meeting with Maive Rute (Deputy Director-General Internal Market, Industry, Entrepreneurship and SMEs)

5 Feb 2025 · The forthcoming Bioeconomy Strategy Revision

Meeting with Katri Kulmuni (Member of the European Parliament) and Stora Enso Oyj

4 Feb 2025 · Ajankohtaiset metsäasiat

Meeting with Jussi Saramo (Member of the European Parliament)

30 Jan 2025 · FP 10 ja biotalous

Meeting with Eero Heinäluoma (Member of the European Parliament)

28 Jan 2025 · Biotech

Meeting with Morten Løkkegaard (Member of the European Parliament, Shadow rapporteur)

28 Jan 2025 · FP10 and Biotech

Meeting with Vilija Sysaite (Cabinet of Executive Vice-President Stéphane Séjourné)

23 Jan 2025 · Critical contributions and strategic priorities of the Finnish forest industry in the context of the EU Clean Industrial Deal.

Meeting with Miguel Jose Garcia Jones (Cabinet of Commissioner Wopke Hoekstra)

22 Jan 2025 · Discussion on the role of forests and the bioeconomy for the EUs competitiveness

Meeting with Katri Kulmuni (Member of the European Parliament)

16 Jan 2025 · Metsien monitorointi

Meeting with Aura Salla (Member of the European Parliament)

16 Jan 2025 · RDI and bioeconomy-related meeting

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

16 Jan 2025 · Exchange of views on the Clean Industrial Deal and upcoming Commission mandate.

Meeting with Bettina Doeser (Head of Unit Environment)

15 Jan 2025 · Discussion on nature restoration including forestry and nature funding

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

15 Jan 2025 · Discussion of the Commission's forthcoming work on forestry, nature restoration and nature funding.

Meeting with Taru Haapaniemi (Cabinet of Commissioner Christophe Hansen)

14 Jan 2025 · Forestry, bioeconomy, biomass

Meeting with Maria Guzenina (Member of the European Parliament)

14 Jan 2025 · Forest Policy

Meeting with Katri Kulmuni (Member of the European Parliament)

10 Jan 2025 · Metsäteollisuus ry opasti ajankohtaisiin EU-asioihin liittyen

Meeting with Alexander Bernhuber (Member of the European Parliament, Shadow rapporteur)

18 Dec 2024 · EU Waldmonitoringrahmen

Meeting with Eero Heinäluoma (Member of the European Parliament, Shadow rapporteur)

12 Dec 2024 · Biotech and Biomanufacturing

Meeting with Maria Guzenina (Member of the European Parliament)

12 Dec 2024 · Forest Policy

Meeting with Sebastian Tynkkynen (Member of the European Parliament)

11 Dec 2024 · Metsäteollisuuden vaikuttaja-akatemia

Meeting with Katri Kulmuni (Member of the European Parliament)

10 Dec 2024 · Metsäteollisuuden ajankohtaiset EU-asiat

Meeting with Mika Aaltola (Member of the European Parliament)

6 Nov 2024 · Forest Policy

Meeting with Ville Niinistö (Member of the European Parliament)

6 Nov 2024 · EU affairs

Meeting with Eero Heinäluoma (Member of the European Parliament) and Foundation for a Living Baltic Sea - Baltic Sea Action Group

6 Nov 2024 · Ajankohtaisaiheet

Meeting with Taru Haapaniemi (Cabinet of Commissioner Janusz Wojciechowski)

5 Nov 2024 · Bioeconomy.

Meeting with Katri Kulmuni (Member of the European Parliament)

16 Oct 2024 · Metsäteollisuuden ajankohtaiset asiat

Meeting with Aura Salla (Member of the European Parliament)

15 Oct 2024 · Metsä Group's development work and bioeconomy

Meeting with Elsi Katainen (Member of the European Parliament)

27 Sept 2024 · EU Deforestation Regulation - state of play

Meeting with Maria Ohisalo (Member of the European Parliament)

26 Sept 2024 · Metsät

Meeting with Mika Aaltola (Member of the European Parliament)

26 Sept 2024 · Forest Policy

Meeting with Aura Salla (Member of the European Parliament)

24 Sept 2024 · Circular Economy and Product Policy in the Forest Industry

Meeting with Katri Kulmuni (Member of the European Parliament)

24 Sept 2024 · Kiertotalous ja tuotepolitiikka

Meeting with Mika Aaltola (Member of the European Parliament)

18 Sept 2024 · EU Affairs

Meeting with Aura Salla (Member of the European Parliament)

18 Sept 2024 · Introductory meeting, discussing the starting term,

Meeting with Sebastian Tynkkynen (Member of the European Parliament) and Maa- ja metsätaloustuottajain Keskusliitto – Central Union of Agricultural Producers and Forest Owners

18 Sept 2024 · Metsäalan ajankohtaisasiat

Meeting with Eero Heinäluoma (Member of the European Parliament) and Maa- ja metsätaloustuottajain Keskusliitto – Central Union of Agricultural Producers and Forest Owners

18 Sept 2024 · Ajankohtaisaiheet

Meeting with Maria Guzenina (Member of the European Parliament)

17 Sept 2024 · Environmental policy

Meeting with Elsi Katainen (Member of the European Parliament)

5 Sept 2024 · Ajankohtainen metsä- ja energiapolitiikka

Meeting with Eero Heinäluoma (Member of the European Parliament)

4 Sept 2024 · Ajankohtaisaiheet

Finnish Forest Industries Federation opposes new carbon reporting rules

29 Jul 2024
Topic — Update of EU rules for monitoring and reporting greenhouse gas emissions under ETS.
Message — The federation opposes rules differentiating between end applications of precipitated calcium carbonate. They request to subtract carbon chemically bound in products from installation emissions.12
Why — This would allow paper producers to avoid higher carbon compliance costs.3
Impact — Waste incinerators lose by being responsible for reporting eventual carbon releases.4
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Meeting with Anna-Maja Henriksson (Member of the European Parliament) and Confederation of Finnish Industries EK

16 Jul 2024 · Upcoming mandate

Meeting with Aura Salla (Member of the European Parliament)

16 Jul 2024 · Forest policies

Meeting with Eero Heinäluoma (Member of the European Parliament)

16 Jul 2024 · Ajankohtaisaiheet

Finnish Forest Industry urges uniform treatment of carbon-binding products

15 Jul 2024
Topic — New EU rules defining when greenhouse gases are permanently chemically bound in products.
Message — The industry requests that all applications of precipitated calcium carbonate remain eligible for emission subtractions. They argue carbon is chemically bound in these stable products regardless of end use.123
Why — This prevents increased emission costs for paper producers and protects existing technology investments.45
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Meeting with Taru Haapaniemi (Cabinet of Commissioner Janusz Wojciechowski)

3 Jul 2024 · Exhibition presentation in FFIF Brussels' Office and general discussion about EU forest issues in the future.

Meeting with Alviina Alametsä (Member of the European Parliament) and Technology Industries of Finland (Teknologiateollisuus ry) and Chemical Industry Federation of Finland (Kemianteollisuus ry)

26 Jun 2024 · Exchange of views

Finnish foresters urge EU to count industrial carbon storage

25 Jun 2024
Topic — The European Commission is evaluating its land use and forestry climate regulation.
Message — The industry wants recognition for carbon stored in wood products and biogenic capture. They propose reporting technological removals under the regulation to help meet targets.12
Why — This would increase market demand for wood products and industrial bioenergy solutions.34
Impact — Fossil fuel companies would be prevented from purchasing forest-based carbon removal certificates.5
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Meeting with Thomas Woolfson (Cabinet of Executive Vice-President Margrethe Vestager)

10 Jun 2024 · Discussion on deforestation regulation

Meeting with Suvi Leinonen (Cabinet of Commissioner Jutta Urpilainen)

2 May 2024 · practical application of the deforestation regulation (EUDR)

Meeting with Elsi Katainen (Member of the European Parliament)

23 Apr 2024 · General EU forest policy

Meeting with Elsi Katainen (Member of the European Parliament)

19 Apr 2024 · Measuring forest diversity

Meeting with Nils Torvalds (Member of the European Parliament)

17 Apr 2024 · EP Elections

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

15 Apr 2024

Please have a look on the attached feedback on the draft 18th amendment of Regulation 10/2011 on plastic materials and articles intended to come into contact with food.
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Meeting with Taru Haapaniemi (Cabinet of Commissioner Janusz Wojciechowski)

27 Mar 2024 · Deforestatioon regulation

Meeting with Eero Heinäluoma (Member of the European Parliament)

25 Mar 2024 · Ajankohtaisaiheet

Meeting with René Repasi (Member of the European Parliament)

18 Mar 2024 · Meeting and general exchange of views

Meeting with Nils Torvalds (Member of the European Parliament)

14 Mar 2024 · PPWR

Meeting with Elsi Katainen (Member of the European Parliament)

13 Mar 2024 · General EU transport policy

Finnish Forest Industries Federation urges flexibility in BPA packaging rules

8 Mar 2024
Topic — The Commission is consulting on restricting bisphenol A in food contact materials.
Message — The industry requests monitoring focus solely on materials for moist and fatty foods. They advocate for flexible monitoring methods and excluding unintentional contamination from mandatory follow-up. They also seek clearer definitions for testing methods and detection limits for compliance.1234
Why — These adjustments would lower compliance costs and prevent redundant testing for paper manufacturers.56
Impact — Consumers might face higher prices if companies pass on expensive monitoring costs.7
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Meeting with Henna Virkkunen (Member of the European Parliament)

14 Feb 2024 · EU legislation on forests and forest use

Meeting with Eero Heinäluoma (Member of the European Parliament)

13 Feb 2024 · Ajankohtaisaiheet

Meeting with Henna Virkkunen (Member of the European Parliament) and UPM-Kymmene Oyj

30 Jan 2024 · Exchange of views

Response to Evaluation and revision of the Weights and Dimensions Directive

10 Jan 2024

The Finnish Forest Industries Federation thanks for the opportunity to comment on the legislative proposal of the Weights and Dimensions Directive. Based on over 30 years of experience, we see higher weights and dimensions as the solution for more freight to be moved with less emissions in Europe. With northernmost factories in the EU, Finnish forest companies have tackled this problem to operate in remote and sparsely populated territories with no existing rail connections and unprofitable to build. 30 years of development work has resulted in longer and heavier trucks made to serve certain geographical conditions and industrial needs. The results achieved speak for themselves: Energy-efficiency of wood trucks has increased by almost 20% since year 2013 when the national weight limit of 76 tonnes came into force (previously 60 tonnes). In the forestry sector alone, the amount of cargo loads on national roads has reduced by 25% since 2013. As we seei it, the energy-efficiency gains are the low-hanging fruit for reducing the carbon footprint of road transport in Europe. The Weights and Dimensions Directive should incentivise all CO2 savings also via low-emission vehicles and energy-efficiency gains. Alternative fuels and zero-emission technologies for heavy-duty vehicles are yet developing and more needs to be done for their uptake, where the lack of technological maturity increases the cost of available solutions. We agree that free movement of goods and fair conditions of competition in the single market need to be ensured by removing unnecessary regulatory barriers, but not introducing new barriers where things are fine. The northern parts of Finland and Sweden have evolved into a vast joint wood acquisition territory, with free movement of goods and well-working cross-border practices. Over 16 000 wood trucks cross the border annually in areas where general traffic count is low and thus rail connections are unprofitable to build. The amount of wood cargo over the border is about to double due to new investments in northern Finland. The legal framework must continue to give certainty for investments in cases where neighbouring countries have allowed higher weights and dimensions. In duly justified cases we must be able to supplement the legal framework to ensure continuation of well-working practices. The reasoning behind the current practices needs to be understood not to create unnecessary regulatory barriers. solutions are needed as "one size fits all" does not work in different parts of Europe due to geographical conditions and business/industry needs. This is important, as Finland needs its only remaining land border to work well. Russia's war in Ukraine has seized all wood imports from Russia and de facto eliminated Finlands longest land border. Finnish companies rely on working cross-border practices to the western neighbours as the only Finnish land border left is between Lapland and the northern parts of Sweden and Norway. With a population density of 2 people per square kilometre Lapland on its own is bigger than the Benelux countries altogether.
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Meeting with Elsi Katainen (Member of the European Parliament) and Technology Industries of Finland (Teknologiateollisuus ry) and Chemical Industry Federation of Finland (Kemianteollisuus ry)

13 Dec 2023 · Current political agenda

Meeting with Nils Torvalds (Member of the European Parliament) and Technology Industries of Finland (Teknologiateollisuus ry) and Chemical Industry Federation of Finland (Kemianteollisuus ry)

12 Dec 2023 · Finnish export industries

Meeting with Henna Virkkunen (Member of the European Parliament)

12 Dec 2023 · EU research policy

Finnish Forest Industries urge digital automation for reporting

28 Nov 2023
Topic — The EU initiative seeks to reduce corporate reporting requirements by twenty-five percent.
Message — The industry requests digital data transfer interfaces to avoid manual submission of data. They also call for clearer instructions and more accurately defined baselines for sustainability reporting.12
Why — Automation would prevent companies from wasting several person-years on repetitive administrative tasks.34
Impact — Competitors risk losing sensitive business secrets through mandated data sharing within supply chains.5
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Meeting with Nils Torvalds (Member of the European Parliament)

27 Nov 2023 · Actual EU-policy matters

Meeting with Miapetra Kumpula-Natri (Member of the European Parliament)

15 Nov 2023 · PPWR

Meeting with Markus Ferber (Member of the European Parliament, Shadow rapporteur) and Bundesverband Güterkraftverkehr Logistik und Entsorgung (BGL) e.V.

15 Nov 2023 · WDD

Meeting with Elsi Katainen (Member of the European Parliament, Shadow rapporteur) and Finnish Transport and Logistics SKAL

10 Nov 2023 · Weights and dimensions directive

Meeting with Miapetra Kumpula-Natri (Member of the European Parliament)

8 Nov 2023 · Carbon removal technologies and the bioeconomy

Meeting with Elsi Katainen (Member of the European Parliament)

8 Nov 2023 · General forest topics

Meeting with Elsi Katainen (Member of the European Parliament, Shadow rapporteur for opinion)

31 Oct 2023 · Packaging and packaging waste

Meeting with Eero Heinäluoma (Member of the European Parliament)

25 Oct 2023 · Topical issues

Meeting with Anna Deparnay-Grunenberg (Member of the European Parliament)

24 Oct 2023 · Waldpolitik

Meeting with Mauri Pekkarinen (Member of the European Parliament)

18 Oct 2023 · Discussion on the new Commission's programme and carbon removal

Meeting with Henna Virkkunen (Member of the European Parliament)

17 Oct 2023 · Bio Economy and Carbon Removal Certification

Meeting with Maria Noichl (Member of the European Parliament, Rapporteur for opinion)

13 Oct 2023 · Soil health and forests

Meeting with Nils Torvalds (Member of the European Parliament)

10 Oct 2023 · Bioeconomy strategy

Meeting with Martin Hojsík (Member of the European Parliament, Rapporteur) and European Environmental Bureau and

28 Sept 2023 · Soil Health Law

Meeting with Ljudmila Novak (Member of the European Parliament, Shadow rapporteur)

27 Sept 2023 · Meeting on Directive on Soil Monitoring and Resilience

Meeting with Mauri Pekkarinen (Member of the European Parliament)

26 Sept 2023 · Discussion on European forest industry

Meeting with Eero Heinäluoma (Member of the European Parliament)

11 Jul 2023 · Nature restoration law (envi)

Meeting with Henna Virkkunen (Member of the European Parliament)

11 Jul 2023 · EU Nature restoration

Meeting with Miapetra Kumpula-Natri (Member of the European Parliament) and Helsinki EU Office

11 Jul 2023 · Meeting on nature restoration law

Finnish Forest Industry Urges Stronger Support for PEF Methodology

3 Jul 2023
Topic — The EU is consulting on rules to substantiate environmental claims using footprint methods.
Message — The industry calls for stronger recommendations to use the Product Environmental Footprint methodology. They insist that industry actors must be involved in drafting specific product rules. Verification must not be too complicated or costly for companies.123
Why — Stronger PEF integration allows them to leverage existing work and lower compliance costs.4
Impact — Independent verifiers lose if accreditation standards are lowered to accommodate industry preferences.5
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Meeting with Nils Torvalds (Member of the European Parliament)

14 Jun 2023 · Nature restoration law

Meeting with Lukas Visek (Cabinet of Executive Vice-President Frans Timmermans)

7 Jun 2023 · Soil health

Meeting with Emma Wiesner (Member of the European Parliament)

31 May 2023 · Rundabordssamtal om EUs skogspolitik

Meeting with Christine Schneider (Member of the European Parliament)

25 May 2023 · PPWR

Meeting with Suvi Leinonen (Cabinet of Commissioner Jutta Urpilainen)

24 May 2023 · Forests

Meeting with Mauri Pekkarinen (Member of the European Parliament)

23 May 2023 · Meeting on carbon removal and Electricity Market Design

Meeting with Eero Heinäluoma (Member of the European Parliament)

23 May 2023 · Nature restoration law (ENVI)

Meeting with Eero Heinäluoma (Member of the European Parliament)

22 May 2023 · General topical issues

Meeting with Henna Virkkunen (Member of the European Parliament)

22 May 2023 · EU Carbon Removal regulation

Finnish Forest Industries Urge Exemption for Heavy Truck Categories

17 May 2023
Topic — An EU review of CO2 emission standards for new heavy-duty road vehicles.
Message — The federation requests that the directive exclude specific heavy vehicle categories from new standards. They advocate for technology-neutral rules that recognize efficiency gains from heavier loads.12
Why — This helps the industry avoid high costs associated with adopting immature zero-emission technologies.3
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Meeting with Eero Heinäluoma (Member of the European Parliament)

4 May 2023 · Nature restoration law (ENVI)

Meeting with Nils Torvalds (Member of the European Parliament)

3 May 2023 · ecodesign for sustainable products regulation

Finnish Forest Industries Federation urges realistic bio-based recycling targets

2 May 2023
Topic — Establishing technical screening criteria for economic activities contributing to a circular economy.
Message — The organization requests the Act recognize primary wood as a way to lower climate impact. They argue recycling targets for bio-based products are unrealistic and discourage builders from wood.12
Why — Maintaining market access for primary timber products avoids economic losses and stifled investment.34
Impact — Developers lose the incentive to use wood, harming efforts to meet EU climate targets.5
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Finnish Forest Industries Urges Complementary Reuse and Recycling Rules

20 Apr 2023
Topic — The European Commission is reviewing requirements to reduce packaging waste and increase recycling.
Message — They argue that recyclable and reusable options should be complementary solutions for sustainability. They request exempting paper-based packaging from reuse targets if recycling goals are met.12
Why — This protects the industry's massive investments in fiber-based recycling technologies and infrastructure.3
Impact — Climate advocates lose if the shift to reuse inadvertently increases fossil-based plastic consumption.4
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Meeting with Delara Burkhardt (Member of the European Parliament, Shadow rapporteur) and EuroCommerce and

28 Mar 2023 · Packaging Waste

Meeting with Petri Sarvamaa (Member of the European Parliament)

24 Mar 2023 · Topical issues in EU forestry politics

Meeting with Ville Niinistö (Member of the European Parliament)

23 Mar 2023 · CRCF (staff level)

Finnish forest industry demands recognition for wood-based carbon storage

21 Mar 2023
Topic — The EU is establishing a framework to certify and monitor carbon removals.
Message — The group wants recognition for carbon stored in wood and fossil material substitution. They request a clear definition of renewable carbon to distinguish biogenic and fossil sources. Certification should include product storage and incentivize industrial carbon capture technologies.123
Why — This would secure industrial access to timber and create markets for bio-based products.45
Impact — Environmentalists lose as the plan seeks to prevent carbon from being locked in forests.6
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Meeting with César Luena (Member of the European Parliament, Rapporteur)

9 Mar 2023 · MEP Luena's Team on Nature Restoration

Meeting with Mauri Pekkarinen (Member of the European Parliament) and Confederation of European Paper Industries

8 Mar 2023 · Breakfast meeting on ESPR

Meeting with Mauri Pekkarinen (Member of the European Parliament)

7 Mar 2023 · Discussion on current issues on forestry

Meeting with Petri Sarvamaa (Member of the European Parliament) and Technology Industries of Finland (Teknologiateollisuus ry) and Chemical Industry Federation of Finland (Kemianteollisuus ry)

7 Mar 2023 · IED and Zero Pollution

Meeting with Eero Heinäluoma (Member of the European Parliament)

6 Mar 2023 · Current forest issues

Meeting with César Luena (Member of the European Parliament, Rapporteur)

1 Mar 2023 · MEP Luena's Team on Nature Restoration

Meeting with Katherine Power (Cabinet of Commissioner Mairead Mcguinness) and Confederation of European Paper Industries

8 Feb 2023 · Taxonomy and Forestry

Meeting with Nils Torvalds (Member of the European Parliament)

25 Jan 2023 · Taxonomy

Meeting with Elsi Katainen (Member of the European Parliament)

25 Jan 2023 · EU Taxonomy

Meeting with Petri Sarvamaa (Member of the European Parliament) and Stora Enso Oyj

24 Jan 2023 · Topical issues in EU politics

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

12 Jan 2023 · Packaging and packagingwaste

Meeting with Eero Heinäluoma (Member of the European Parliament)

11 Jan 2023 · Nature restoration law

Meeting with Mauri Pekkarinen (Member of the European Parliament)

11 Jan 2023 · Discussion on the EU Nature Restoration Act

Meeting with Petri Sarvamaa (Member of the European Parliament) and Maa- ja metsätaloustuottajain Keskusliitto – Central Union of Agricultural Producers and Forest Owners

10 Jan 2023 · Nature restoration law

Meeting with Elsi Katainen (Member of the European Parliament, Shadow rapporteur)

19 Dec 2022 · Nature restoration

Meeting with Katherine Power (Cabinet of Commissioner Mairead Mcguinness) and UPM-Kymmene Oyj and Steptoe LLP

9 Dec 2022 · Imports of Birch plywood of Russian origin to the EU market

Meeting with Sofja Ribkina (Cabinet of Executive Vice-President Valdis Dombrovskis) and Steptoe LLP

9 Dec 2022 · Imports of Birch plywood of Russian origin to the EU market

Response to European Critical Raw Materials Act

25 Nov 2022

There are limited amount of critical raw materials. The mining of such non-renewable materials have several sustainability issues. It is clear that such materials are needed. However, Europe should find and develop renewable alternatives to scarce critical raw materials. For example, by-products of pulp production (e.g. lignin) can provide promising materials to materials used in batteries. Further innovations from wood-processing industries could provide more alternatives relying on domestic and renewable raw materials. This would decrease dependency on imports from third countries. Furthermore, this would decrease the need of current non-renewable critical raw materials.
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Meeting with Henna Virkkunen (Member of the European Parliament)

9 Nov 2022 · EU Forest Policy

Meeting with Miapetra Kumpula-Natri (Member of the European Parliament)

9 Nov 2022 · Meeting on contemporary matters

Meeting with Nils Torvalds (Member of the European Parliament)

9 Nov 2022 · Forestry

Meeting with Mauri Pekkarinen (Member of the European Parliament) and Stora Enso Oyj

9 Nov 2022 · Current EU Forestry Affairs

Meeting with Elsi Katainen (Member of the European Parliament)

9 Nov 2022 · Ajankohtaiset EU-metsäasiat

Meeting with Nils Torvalds (Member of the European Parliament)

27 Oct 2022 · Carbon removal

Meeting with Ville Niinistö (Member of the European Parliament)

26 Oct 2022 · Forestry

Meeting with Mauri Pekkarinen (Member of the European Parliament)

25 Oct 2022 · Meeting on bioenergy and carbon removal

Meeting with Miapetra Kumpula-Natri (Member of the European Parliament)

13 Oct 2022 · Meeting on Energy Crisis

Meeting with Miapetra Kumpula-Natri (Member of the European Parliament)

28 Sept 2022 · Meeting on the Nature Restoration Law

Meeting with Henna Virkkunen (Member of the European Parliament)

28 Sept 2022 · EU Energy Policy

Meeting with Elsi Katainen (Member of the European Parliament)

5 Sept 2022 · Ajankohtaiset EU-metsäasiat

Finnish Forest industry warns against costly EU nature restoration targets

22 Aug 2022
Topic — The EU proposes legally binding targets to restore biodiversity across the continent.
Message — Member states must control restoration targets to ensure cost-effectiveness and protect industry competitiveness. They advocate for voluntary measures instead of binding requirements outside the Natura 2000 network. Definitions must be clarified to protect national forest management competence.12
Why — This would lower implementation costs and maintain raw material availability for industry.3
Impact — Environmental objectives are compromised if restoration is restricted to voluntary measures and networks.45
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Meeting with Alviina Alametsä (Member of the European Parliament) and Technology Industries of Finland (Teknologiateollisuus ry)

13 Jul 2022 · Stakeholder Reception

Finnish Forest Industries urge protection of sensitive industrial data

27 Jun 2022
Topic — EU initiative revising rules for reporting and publishing industrial pollutant data.
Message — FIFF opposes installation-level reporting and the publication of additional business details like production volumes. They argue that reporting obligations should not be expanded through delegated acts.12
Why — This helps companies protect business secrets and minimizes unnecessary administrative burdens.34
Impact — Public groups lose granular data access that supports informed environmental decision-making.5
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Finnish forest industry demands local flexibility in emissions directive

23 Jun 2022
Topic — This consultation reviews rules to ensure industrial installations align with Green Deal environmental targets.
Message — FIFF insists on retaining plant-specific flexibility instead of mandating the strictest emission limits. They also oppose new environmental management systems and vague transformation plans that create bureaucratic overlaps.12
Why — Maintaining current flexibility avoids technically unfeasible requirements and protects the industry's global competitiveness.345
Impact — Transparency advocates lose public access to environmental data due to business confidentiality concerns.6
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Response to Sustainable Products Initiative

22 Jun 2022

In principle, the Finnish forest industry supports the initiative's good goal of sustainable products. An effective transition to a bio-based circular economy requires sustainable products to become the norm. The ESPR is a broad and ambitious framework law that covers all products produced by the Finnish forest industry. However, the key question is how to apply sustainability requirements more closely at product group level in further preparation. The FFIF would like to point out few aspects that should be considered in the future preparation of the legislation. Please refer to the attachment for more details. 1. Include renewability of raw materials as an additional ecodesign requirement. The ESPR introduces a long list of ecodesign requirements, such as durability, repairability and ease of maintenance, recycling and its ease and quality, as well as the use of recycled materials. From the perspective of the Finnish forest industry, one important requirement is missing, namely the renewability of raw materials. It is important to incentivise products made from renewable resources. This would facilitate shifting from today’s linear, fossil-based economy to a circular and bio-based one. Europe should finally tap into the full potential of forests, forest-based products, and sustainable forest management practices to reduce its dependence on fossil materials. 2. Ecodesign requirements need to be developed based on relevant Union legislation or other instruments and overlapping regulation must be avoided. Requirements for specific products or product groups need to be specific, coherent, and cost-efficient. Furthermore, development of requirements needs to take into consideration relevant technical characteristics for that specific product or group of products. The existing product-specific legislation should continue to be applied in cases where it exists, such as for packaging through Packaging and Packaging Waste Directive (PPWD) to avoid duplicating or overlapping regulation. 3. Requirement of recycled content should not be considered for fibre-based products. We acknowledge that mandatory recycled content can be a useful policy instrument to support and build markets for recycled materials in case where recycling is not functioning well. However, if applied on already existing and well-functioning recycling markets, mandatory recycled content risks being counterproductive and can even jeopardize market functionality. In case of Finland, where the overall recovery rate of paper and board was as high as 94% in 2020, the mandatory recycled content requirements would mean that millions of tonnes of recycled paper and board would need to be imported yearly, increasing emissions and costs. Whereas less good quality material would be available for recycling in other parts of Europe. 4. Ensure the direct involvement of industry representatives in the development of the product-specific delegated acts. The involvement of the industry in the drafting of the product specific requirements would ensure these can deliver concrete environmental benefits and are at the same feasible for the industry in an economically and technically viable way. 5. Support the development of self-regulation measures to facilitate the implementation of Ecodesign requirements. Given the wide range of products that will need to be addressed and the technical expertise needed to develop appropriate sustainability requirements, we welcome the possibility given to the industry to put forward proposals for self-regulating measures for the upcoming product groups. Our industry is continuously developing guidelines at a European level, together with other organizations along our value chain. Moreover, by allowing and applying self-regulation assessment will incentivise for more products to be able to fulfill compliance of Ecodesign requirements.
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Meeting with Henna Virkkunen (Member of the European Parliament)

22 Jun 2022 · Renewable Energy Directive

Meeting with Suvi Leinonen (Cabinet of Commissioner Jutta Urpilainen)

21 Jun 2022 · European green deal and forests

Meeting with Mauri Pekkarinen (Member of the European Parliament)

21 Jun 2022 · Discussion on RED III and forest issues

Meeting with Frans Timmermans (Executive Vice-President) and Greenpeace European Unit and

9 Jun 2022 · forest visit

Meeting with Miapetra Kumpula-Natri (Member of the European Parliament)

3 Jun 2022 · co2 emission target directive for the agriculture and forestry sector

Meeting with Henna Virkkunen (Member of the European Parliament)

25 May 2022 · LULUCF

Meeting with Nils Torvalds (Member of the European Parliament)

9 May 2022 · Taxonomy, Fit for 55

Meeting with Mauri Pekkarinen (Member of the European Parliament)

6 May 2022 · Discussion on EU taxonomy

Finnish Forest Industries Federation demands respect for national forest management

5 May 2022
Topic — A proposal for an EU-wide forest monitoring system and long-term strategic plans.
Message — The federation recommends improving existing international reporting systems instead of creating new laws. They argue that Member States must maintain the power to decide forest management priorities. Furthermore, they demand that specific forest location data remain secret to ensure data reliability.123
Why — Respecting local management allows the industry to avoid costly EU-wide forestry regulations and restrictions.4
Impact — Environmental monitors and the public lose access to transparent data on specific forest conditions.5
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Finnish forest industry urges recognition for carbon-storing wood products

29 Apr 2022
Topic — The Commission is proposing a regulatory framework for certifying sustainable carbon removals.
Message — They request that the full mitigation potential of forest products be rewarded. Recognition of carbon storage products and their substitution effect is considered vital. The capture of biogenic carbon should remain an optional choice.12
Why — This would boost demand for wood and incentivize investments in sustainable forest management.3
Impact — Fossil fuel and non-renewable sectors lose market share as wood products substitute their materials.4
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Meeting with Petri Sarvamaa (Member of the European Parliament)

27 Apr 2022 · Forestry & Biodiversity

Meeting with Sirpa Pietikäinen (Member of the European Parliament) and Technology Industries of Finland (Teknologiateollisuus ry) and Chemical Industry Federation of Finland (Kemianteollisuus ry)

11 Apr 2022 · Topical discussion around energy and digital politics and Ukraine, Finnish trade politics

Meeting with Mauri Pekkarinen (Member of the European Parliament, Rapporteur for opinion)

29 Mar 2022 · Discussion on forests

Meeting with Nils Torvalds (Member of the European Parliament, Rapporteur) and Neste Oyj

28 Mar 2022 · RED III

Meeting with Petri Sarvamaa (Member of the European Parliament)

25 Mar 2022 · Agriculture & Forestry

Meeting with Petri Sarvamaa (Member of the European Parliament)

16 Mar 2022 · Forestry

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

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

Meeting with Andrea Vettori (Cabinet of Commissioner Virginijus Sinkevičius)

11 Mar 2022 · EU Nature Restoration Law

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

11 Mar 2022 · EU Nature Restoration Law

Response to Evaluation and revision of the Weights and Dimensions Directive

18 Feb 2022

Finnish Forest Industries Federation thanks for the opportunity to participate in this call for evidence. Representing one of the biggest industry branches in Finland, forest industries have been actively involved in developing weights and dimensions of road transport for over 25 years. Achieved results have proved that with optimisation of weights and dimensions road transportation can become substantially greener and cost-effective, leading to safer and more sustainable supply and value chains. Tackling the challenges of the single market, bearing in mind national needs Free movement of goods and fair conditions of competition in the single market need to be ensured by removing unnecessary regulatory and market barriers but bearing in mind different conditions within the EU. The background of the current patchwork of rules needs to be understood, as one size fits all does not work in different parts of Europe due to geographical conditions and business/industry needs. Attention needs to be paid to the already existing practices especially in cases when their environmental benefits can be proved. Crossing the border When simplifying the rules between different member states, the already existing practices needs to be taken carefully into account. Where neighbouring states allow higher weights and dimensions, the border crossing practice should continue to give certainty for the investments. Furthermore, with the means of digitalisation, the agreements and formalities between member states should be eased up. The harmonised EU legal framework should be a supplement to national rules, and not replacing them. Weights and dimensions important for decarbonisation The use of vehicles of variable weights and dimensions is one piece of the puzzle of decarbonising transport alongside with other parts of the logistic chains, namely rail and inland waterways transport. Making road transport more sustainable requires that more freight is moved with less emissions. The Finnish experience has proved heavier and longer vehicles to be an effective tool for greener and safer road transport. National limits have increased energy-efficiency gains and lowered fuel use in the forestry sector by up to 20% since year 2013. Alone in the forestry this has reduced cargo loads by more than 25% on the national roads. Alternative fuels and zero-emission technologies for heavy-duty vehicles are yet developing and more needs to be done for their uptake, where the lack of technological maturity increases the cost of available solutions. Higher weights and dimensions should incentivise all CO2 savings also via low-emission vehicles and energy-efficiency gains. The use of heavier and longer combinations should not be tied exclusively to alternative fuels or intermodal transport chains. Eco-combis have been developed to serve certain geographical conditions and business/industry needs and have a proven track of their contribution to sustainable development. It should also be noted that greening of road transport is currently pursued by several legislative proposals in the EU. Thorough evaluation is needed, how to strike a balance in order not to create less incentives to continue developing sustainable logistic chains. Road safety cannot be compromised Measures considered to increase economic efficiency and environmental performance of heavy-duty vehicles should consider fully the road safety objectives of EU transport policy. Considering the long experience that we have had in the norther part of Europe using higher masses and dimensions, there is not any significant decrease in terms of road safety. In practice, heavier and longer dimensions have reduced the number of vehicles in traffic. Modern vehicle technologies, such as stabilising driving mechanisms, ensure that heavier and longer vehicles are at least as safe as smaller ones.
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Response to Waste Framework review to reduce waste and the environmental impact of waste management

18 Feb 2022

Finnish Forest Industries Federation (FFIF) reply to Commission call for evidence for an Impact Assessment: Environmental impact of waste management – revision of EU waste Framework. FFIF supports the policy maker’s intention to optimise waste management systems to ensure high-quality recycling, including higher recycling rates and good quality secondary raw materials. For FFIF it is important to increase the already high recycling rates, improve fibre-based material collection, and ensure the high-quality of secondary raw materials, namely Paper for Recycling (PfR). PfR is a valuable secondary raw material and key in ensuring our transition to a Circular Economy. The sector has been very successful in maximising its utilisation, with 73.9 % recycling rate in Europe in 2020 and 49.6 Mt of PfR used to make new paper and board products constituting 56.3% of the total amount of paper and cardboard produced. In Finland the PfR recycling rate in 2020 was as high as 94 %, whereas the recovery of household wastepaper in Finland was 91 %. In its call for evidence for an Impact Assessment, the Commission has identified problematic areas and stressed main policy objectives. FFIF wishes to address and comment on some of those policy options: Waste hierarchy: re-use and recycling should be complementary measures We support the Commission objective to safeguard the waste hierarchy, and implement measures supporting waste prevention. Turning waste into resources for circular economy is a key in waste prevention; this can be achieved both with recycling and re-use which are equally important in this process. Thus, the Commission should refrain from imposing horizontal targets and adopt a case-by-case approach taking into consideration the current recycling and environmental performance of each material stream. Support measures for separate collection We support the Commission’s intention to improve the separate collection of waste by clarifying and/or restricting the scope of derogations provided for in Article 10(3) of the Waste Framework Directive. For the paper and board industry, the biggest barrier in further increasing recycling rates and recyclability potential in Europe is the lack of harmonised application of separate collection at source of paper and board. Separate collection of paper and board materials ensures that fibres are not lost and return in the recycling loop. It also enhances the quality of fibres by avoiding soiling of material from the source to the sorting line. Separate collection of waste oils The overall sustainability of the whole system should be taken into account, when setting obligations for separate collection of waste oils. Miscellaneous oily waste fractions, that cannot be regenerated, should be strictly kept outside of separate collection requirements. EPR fees based on net-cost principle FFIF supports the idea of using EPR fee modulation to facilitate and accelerate the transition towards a low carbon circular economy. Nevertheless, it is equally important that EPR fees are based on the net-cost principle. Paper recycling is high-quality recycling We support the optimization of recycling processes to achieve higher recycling rates and secondary raw materials of higher quality. Nevertheless, we deem important that the Commission takes into consideration the already high-quality recycling capability of certain waste streams when drafting a definition of high-quality recycling, in order to avoid unnecessary barriers in already well-functioning recycling processes, both in terms of environmental performance and high-quality secondary raw materials output.
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Meeting with Mauri Pekkarinen (Member of the European Parliament)

9 Feb 2022 · Discusssion on Fir for 55 and forests

Meeting with Nils Torvalds (Member of the European Parliament)

21 Jan 2022 · Fit for 55

Meeting with Mauri Pekkarinen (Member of the European Parliament)

21 Jan 2022 · Discussion on forests

Finnish Forest Industries support biomass sustainability criteria delay

3 Jan 2022
Topic — This consultation concerns the timing of sustainability rules for biomass emissions.
Message — They urge the postponement of sustainability and greenhouse gas emission criteria. The group opposes national taxation schemes meant to address delayed EU rules.12
Why — The postponement prevents companies from being penalised while lacking necessary regulatory guidance.3
Impact — Member States struggle to promote cascading biomass use without national taxation.4
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Finnish forest industry urges stability and protection for exports

18 Nov 2021
Topic — The EU is proposing a carbon price on imports to prevent carbon leakage.
Message — The federation requests regulatory stability and more analysis regarding the mechanism's effect on global competition. They argue that the EU must address risks to exports and avoid policies that increase electricity costs.123
Why — Excluding electricity from the scope would prevent a significant rise in production costs.45
Impact — European exporters face losing market share to foreign competitors if trade frictions increase.67
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Meeting with Silvia Modig (Member of the European Parliament)

17 Nov 2021 · Fit for 55 -package

Response to FuelEU Maritime

8 Nov 2021

Finnish Forest Industry Federation Industry (FFIF) hope that the FF55 package including FuelEU Maritime will provide regulatory stability which promotes the industry’s investments in climate friendly products and production as well as in sustainable forestry. Background: Climate solutions provided by our sector Wood-based products and sustainable forest management play an important role in the European Green Deal, especially in achieving 2030 climate targets and climate neutrality by 2050. Finland aims to be climate neutral already by 2035. Our industry is up to the challenge and provides sustainable and climate-friendly solutions to achieve these goals. The Commission demonstrated the climate benefits of our sector already in the 2050 vision A Clean Planet for All, where the importance of a circular bio-economy as a building block and our various climate mitigating and recyclable products were highlighted. The Commission communicated that products from renewable resources are much needed. Our industry delivers these products such as construction materials, pulp, packaging materials, textiles, composites, tissue papers, baking and cooking papers, bioplastics, paper and bioenergy. Our climate roadmap "Green and vibrant economy" (2020) shows that wood-based products manufactured in Finland reduce carbon dioxide emissions globally by about 16 million tonne per annum. This substitution effect is achieved by replacing fossil-intensive products with wood-based products. Our mills can phase-out the use of fossil energy in about 15 years. At the same time our forest resources keep increasing. Main points on FuelEU Maritime • Longer transition periods needed for reducing greenhouse gas intensity Justification: Pre-fixed tight targets and short transition times do not consider the challenges in availability and costs of alternative fuels in maritime. Regulation should not cause distortions to freight transport. • Relative competitiveness of freight-intensive industry to be maintained Justification: Freight transport is facing several different steering mechanisms (ESR, energy taxation, ETS in road and maritime transport, FuelEU Maritime). It's not clear what will be the final impact and total costs to freight-intensive industries in Europe. Nevertheless, EU should avoid extra costs to industries that provide climate-friendly products to global markets.
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Finnish Forest Industries Urges Unrestricted Free Emission Allowances

8 Nov 2021
Topic — This consultation reviews the EU Emissions Trading System to meet higher 2030 climate targets.
Message — The federation insists free emission allowances should not depend on energy efficiency investments. They oppose excluding facilities that primarily use biomass from the trading system.12
Why — Maintaining unrestricted free allowances protects the export competitiveness of the Finnish forestry sector.34
Impact — Climate policy efficacy might suffer if industry efficiency targets are not legally mandated.5
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Finnish Forest Industry Federation urges stability in biomass regulations

8 Nov 2021
Topic — Revision of the Renewable Energy Directive to achieve higher 2030 climate targets.
Message — The federation calls for implementing current sustainability criteria before introducing new ones. They oppose mandatory rules on cascading wood use and higher burdens for small producers.123
Why — Maintaining current rules ensures investment stability and avoids extra costs for smaller facilities.4
Impact — Environmental advocates lose stricter protections for forest biodiversity and soil health standards.5
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Finnish forest industry demands stable biomass rules in energy revision

8 Nov 2021
Topic — The EU is revising the Renewable Energy Directive to meet 2030 climate goals.
Message — The federation requests that the EU maintains current sustainability rules instead of adding new ones. They oppose legislative restrictions on how wood is used and reject lowering thresholds for small energy producers.123
Why — They would avoid new compliance costs and safeguard their existing biomass energy investments.45
Impact — Environmental advocates lose stricter protections for forest biodiversity and soil health across Europe.67
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Response to Revision of the Energy Tax Directive

8 Nov 2021

Finnish Forest Industries Federation Register ID number: 39671713910-36 Ahti Fagerblom, Manager, Climate and Energy Policy ahti.fagerblom@forestindustries.fi Finnish Forest Industries’ response to the consultation on the Energy Taxation Directive (ETD) Finnish Forest Industry Federation Industry (FFIF) hope that the FF55 package including ETD will provide regulatory stability which promotes the industry’s investments in climate friendly products and production as well as in sustainable forestry. Background: Climate solutions provided by our sector Wood-based products and sustainable forest management play an important role in the European Green Deal, especially in achieving 2030 climate targets and climate neutrality by 2050. Finland aims to be climate neutral already by 2035. Our industry is up to the challenge and provides sustainable and climate-friendly solutions to achieve these goals. The Commission demonstrated the climate benefits of our sector already in the 2050 vision A Clean Planet for All, where the importance of a circular bio-economy as a building block and our various climate mitigating and recyclable products were highlighted. The Commission communicated that products from renewable resources are much needed. Our industry delivers these products such as construction materials, pulp, packaging materials, textiles, composites, tissue papers, baking and cooking papers, bioplastics, paper and bioenergy. Our climate roadmap "Green and vibrant economy" (2020) shows that wood-based products manufactured in Finland reduce carbon dioxide emissions globally by about 16 million tonne per annum. This substitution effect is achieved by replacing fossil-intensive products with wood-based products. Our mills can phase-out the use of fossil energy in about 15 years. At the same time our forest resources keep increasing. Main points on ETD • Energy taxation should not be extended to bioenergy nor maritime fuels Justification: Leaving fossil resources into the ground should be a priority in climate polity. Taxation on renewables would give totally wrong signal and undermine the main idea in Renewable Energy Directive, promoting renewables that is. Maritime is facing a rush hour of new regulation bringing massive costs and effects on industry’s competitiveness. Taxation on maritime fuels is not justified when emissions are already cut by ETS and FuelEU Maritime initiatives. • Tax levels should not be harmonized in a way that is detrimental to industry's global competitiveness (especially electricity tax and diesel tax) Justification: Energy intensive industry needs affordable electricity to speed up electrification and to succeed in global competition. Industry does not compete with regular consumers such as citizens and thus different tax levels do not distort competition. EU should avoid any extra costs, such as high diesel taxation, to freight-intensive industry competing on global markets. One has to keep in mind that industries also provide climate-friendly products and globally substitute fossil use.
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Response to Updating Member State emissions reduction targets (Effort Sharing Regulation) in line with the 2030 climate target plan

8 Nov 2021

Finnish Forest Industries Federation Register ID number: 39671713910-36 Ahti Fagerblom, Manager, Climate and Energy Policy ahti.fagerblom@forestindustries.fi Finnish Forest Industries’ response to the consultation on the Effort Sharing Regulation (ESR) Finnish Forest Industry Federation Industry (FFIF) hope that the FF55 package including ESR will provide regulatory stability which promotes the industry’s investments in climate friendly products and production as well as in sustainable forestry. Background: Climate solutions provided by our sector Wood-based products and sustainable forest management play an important role in the European Green Deal, especially in achieving 2030 climate targets and climate neutrality by 2050. Finland aims to be climate neutral already by 2035. Our industry is up to the challenge and provides sustainable and climate-friendly solutions to achieve these goals. The Commission demonstrated the climate benefits of our sector already in the 2050 vision A Clean Planet for All, where the importance of a circular bio-economy as a building block and our various climate mitigating and recyclable products were highlighted. The Commission communicated that products from renewable resources are much needed. Our industry delivers these products such as construction materials, pulp, packaging materials, textiles, composites, tissue papers, baking and cooking papers, bioplastics, paper and bioenergy. Our climate roadmap "Green and vibrant economy" (2020) shows that wood-based products manufactured in Finland reduce carbon dioxide emissions globally by about 16 million tonne per annum. This substitution effect is achieved by replacing fossil-intensive products with wood-based products. Our mills can phase-out the use of fossil energy in about 15 years. At the same time our forest resources keep increasing. Main points on ESR • So called additional reserve should remain voluntary Justification: Leaving fossil resources into the ground should be a priority to prevent CO2 emissions and to stop cumulating carbon in the atmosphere. Emphasizing sinks too much would leave the door open for continuation of fossil emissions also in the future. This must not happen. • Extra costs for industries’ transports should be avoided to maintain competitiveness in global markets Justification: Cargo transports will possibly be under influence of several different steering mechanisms (ESR, energy taxation, ETS in road and maritime transport, FuelEU Maritime). It's not clear what will be the final impact and total costs to freight-intensive industries. Nevertheless, EU should avoid any extra costs to industries that provide climate-friendly products to global markets.
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Response to Review of Directive 2012/27/EU on energy efficiency

8 Nov 2021

Finnish Forest Industries Federation Register ID number: 39671713910-36 Ahti Fagerblom, Manager, Climate and Energy Policy ahti.fagerblom@forestindustries.fi Finnish Forest Industries’ response to the consultation on the Energy Efficiency Directive (EED) Finnish Forest Industry Federation Industry (FFIF) hope that the FF55 package including EED will provide regulatory stability which promotes the industry’s investments in climate friendly products and production as well as in sustainable forestry. Background: Climate solutions provided by our sector Wood-based products and sustainable forest management play an important role in the European Green Deal, especially in achieving 2030 climate targets and climate neutrality by 2050. Finland aims to be climate neutral already by 2035. Our industry is up to the challenge and provides sustainable and climate-friendly solutions to achieve these goals. The Commission demonstrated the climate benefits of our sector already in the 2050 vision A Clean Planet for All, where the importance of a circular bio-economy as a building block and our various climate mitigating and recyclable products were highlighted. The Commission communicated that products from renewable resources are much needed. Our industry delivers these products such as construction materials, pulp, packaging materials, textiles, composites, tissue papers, baking and cooking papers, bioplastics, paper and bioenergy. Our climate roadmap "Green and vibrant economy" (2020) shows that wood-based products manufactured in Finland reduce carbon dioxide emissions globally by about 16 million tonne per annum. This substitution effect is achieved by replacing fossil-intensive products with wood-based products. Our mills can phase-out the use of fossil energy in about 15 years. At the same time our forest resources keep increasing. Main points on EED • The use of non-fossil energy should not be limited by capping the energy use or unrealistic energy savings targets Justification: Leaving fossil resources into the ground should be a priority instead of limiting energy use (so called energy efficiency first principle). Energy system integration requires lots of non-fossil energy (electrification, P2X, hydrogen solutions in general, CCU/BECCS/CCS etc.). • Mills should not be forced into energy efficiency investments Justification: At the mills there are typically many kinds of investment needs (for example on new production lines, renewable energy, raw material handling and infrastructure in general). It is not justified to force mills to prioritize one kind of investment above others. The best knowledge about investment needs and their cost-efficiency is at the mills.
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Response to Land use, land use change and forestry – review of EU rules

4 Nov 2021

Finnish Forest Industries’ response to the consultation on the LULUCF regulation Finnish Forest Industry Federation Industry (FFIF) hope that the FF55 package including LULUCF will provide regulatory stability which promotes the industry’s investments in climate friendly products and production as well as in sustainable forestry. Background: Climate solutions provided by our sector Wood-based products and sustainable forest management play an important role in the European Green Deal, especially in achieving 2030 climate targets and climate neutrality by 2050. Finland aims to be climate neutral already by 2035. Our industry is up to the challenge and provides sustainable and climate-friendly solutions to achieve these goals. The Commission demonstrated the climate benefits of our sector already in the 2050 vision A Clean Planet for All, where the importance of a circular bio-economy as a building block and our various climate mitigating and recyclable products were highlighted. The Commission communicated that products from renewable resources are much needed. Our industry delivers these products such as construction materials, pulp, packaging materials, textiles, composites, tissue papers, baking and cooking papers, bioplastics, paper and bioenergy. Our climate roadmap "Green and vibrant economy" (2020) shows that wood-based products manufactured in Finland reduce carbon dioxide emissions globally by about 16 million tonne per annum. This substitution effect is achieved by replacing fossil-intensive products with wood-based products. Our mills can phase-out the use of fossil energy in about 15 years. At the same time our forest resources keep increasing. Main points on LULUCF • A long-term climate policy is needed to ensure a competitive and predictable operating environment for climate-friendly industry Justification: The main goal of the EU's climate policy should be reducing fossil emissions, not compensating them by land use sector. It is important that the fossil emissions of other EU Member States or other sectors are not compensated with the sinks of forested countries. In order to ensure effective measures, long-term and predictable climate policy is needed. The new proposed overall EU target for carbon removals by natural sinks, -310 Mt CO2 by 2030, is extremely challenging and should not be increased. The total annual net sink reported by the Member States was circa -268 Mt CO2 in 2016-2018, which means that the land use sector sinks should be increased by 15 % in less than ten years. The Commission proposes formation of so called AFOLU-sector (Agriculture, Foresty and Land Use) after 2030 and its climate neutrality until 2035. The Finnish forest industry sees EU-level climate neutrality of the AFOLU-sector very challenging. It is well known that the reduction of emissions from agricultural sector has been difficult and will continue to be so. This situation must not result in the situation where European forested countries are forced to compensate emissions of the countries with high AFOLU sector emissions. The AFOLU climate neutrality target should been set on a Member State level. • Carbon benefits of all wood products need to be considered Justification: Wood-based products have remarkable climate benefits. They can store carbon and replace non-renewable products with high fossil emissions. Regrettably, EU policies, including the LULUCF, do not sufficiently highlight this possibility of replacing products made from non-renewable raw materials with renewable wood-based products (substitution). This viewpoint is crucial when balancing policies between wood use and natural sinks. The Commission aims to build a framework of carbon removals and to establish a system that provides incentives to protect carbon stocks and increase removals. The development of voluntary carbon markets for forests should be carefully addressed with view of the current accounting rules for the LULUCF sector emphasizing Member
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Response to Restoring sustainable carbon cycles

5 Oct 2021

Finnish forest industry sees that phasing out fossil emissions should remain as primary target ibn EU climate policy. Natural sinks or technological sinks should not be used as excuse for prolonging fossil economy. A voluntary carbon market, if poorly implemented, could lead to a situation where e.g. fossil based industries are encouraged to carry on without significant changes. Technological carbon removals such as Carbon Capture and Utilisation (CCU) or Bioenergy with Carbon Capture and storage (BECCS) could lead to negative emissions in coming decades. This requires technological breakthrough that make carbon removals and utilization profitable to industries. The promotion of BECCS could lead to the creation of a voluntary carbon market that is coherent with current and comprehensive climate policy. Those are additional sinks which are easier to delimit outside of double accounting, a situation where two parties (eg. country and a company) claim the same carbon removal. Pulp and paper mills are potential application sites for both CCU and BECCS. It could be possible to achieve negative emissions but there is a need to incentivize the deployment of this technology. It needs to become available and economically viable for industry to achieve zero or negative emissions. Active forest management brings climate benefits by enhancing both the forest sink and amount and the quality of wood, which makes it fit for construction and other products substituting those with high CO2 emissions. Recycling these products is an essential part of circular economy which prolongs the lifespan of the carbon in products. Wood construction may have potential in developing voluntary carbon market. Landowners will also benefit if the demand for climate-friendly timber construction increases. Forest damages can cause significant reductions in annual sinks and, at worst, reduce forest carbon stocks. Therefore, forests are not well-suited source to the needs of the voluntary carbon market. The stability/permanence of carbon stocks is very uncertain as climate change continues. They are stable in the models, but not in real life. Active sustainable forest management is crucial for disturbance risk prevention. Investments in sustainable forest management and utilization of wood are the best guarantee of ensuring the resilience in multifunctional European forests. Forests and the forest industry carry great importance for Member States in view of employment, the economy and the environment. The forest industry employs approximately 2.6 million people in the EU and enables the EU to transition from the use of non-renewable natural resources to a bio-based circular economy. The gross value added of the forest-based industries is over EUR 129 billion or 7.1 % of the total manufacturing industry in the EU. Forest-industry companies are also major corporate tax payers, contributing to both public finance, and via their employees to state and municipal taxes. Successful forest industries create wellbeing also for landowners and foresters through demand of wood. The wellbeing of landowners has been dependent on the success of the industry for more than 100 years and may continue and increase in the future if the industry's operating conditions are not weakened.
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Response to European Bioeconomy Policy: Stocktaking and future developments

31 Aug 2021

The Finnish Forest Industries Federation welcomes the proposal of the EU Commission to consider an update of the Bioeconomy Strategy and its action plan and stresses the following aspects in the development of an effective, updated strategy: 1. The Bioeconomy Strategy needs to be fundamentally linked to other EU policy initiatives that drive Green Deal objectives. The bioeconomy will de facto play an essential role in Europe's green transition. And yet, EU's Industrial Strategy, for instance, fails to support the Commission's own 2050 vision A Clean Planet for All, ignoring the bioeconomy's necessary contributions. In its current incarnation, EU's industrial strategy makes no reference to the Bioeconomy Strategy nor does it mention the bioeconomy in any form. The discrepancy is obvious and leaves bioeconomy-based industries that are supposed to deliver solutions for a green transition in a policy void. Hence, there is a strong need for greater EU policy coherence to ensure a strategic and incentivized trajectory for the development of the European bioeconomy. An explicit goal of an updated Bioeconomy Strategy must be its integration with other pertinent EU policy initiatives such as the Industrial Strategy and the upcoming work programmes of Horizon Europe. In particular, the bioeconomy should ideally be recognized as a critical ecosystem of its own in addition to the 14 identified in EU's updated Industrial Strategy; the European Raw Materials Alliance should explicitly take into account renewable materials provided by the bioeconomy; and bioeconomy-based solutions should explicitly be addressed in the planned "transition pathways" driving the European industries' green transition. 2. The implementation of the Bioeconomy Strategy must exceed the boundaries of the research policy domain. Currently, the existing Bioeconomy Strategy lives a secluded life in a proverbial silo governed by research and innovation policy. Accordingly, the majority of initiatives related to the development of the bioeconomy are funnelled through research related policy instruments. While research, development and innovation will continue to be formidable engines of renewal for the bioeconomy, its current stage calls for a more holistic approach that takes the entire value chain, including the industry's larger operating environment, into account. The industry is tasked with picking up the ideas developed in research, turning them into actionable solutions, and bringing them onto markets under the pressure of global competition. The promotion of renewable, bio-based materials and products as substitutes for existing fossil-based solutions and CO2 storage should be at the core of the new Bioeconomy Strategy. A research-driven policy approach alone is inadequate to deal with this market-oriented stage in the bioeconomy value chain and needs explicit support from other policy domains. This calls for co-ordinated, inter-service development and implementation of the Bioeconomy Strategy from the start. 3. Investments in industrial R&D as well as technology demonstrations and pilots are needed to increase material and energy efficiency, develop novel applications, and scale production technologies for an effective diffusion of bioeconomy solutions across industry boundaries. The industrial bioeconomy needs to be put explicitly on the agenda of current and future research and innovation as well as industrial policy instruments - such as Horizon Europe, the Innovation Fund and IPCEI - that accelerate the development and adoption of new bio-based materials and products. 4. The development of a viable bioeconomy is not possible without the continuous flow of raw materials. Active and timely forest management is an essential part of the forest-based bioeconomy's value chain, providing raw materials to industry as well as employment and well-being to rural areas. At the same time it helps to ensure resistance of forests against pests and diseases.
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Response to Revision of Non-Financial Reporting Directive

29 Jun 2021

The Commission wants to elevate the status of sustainability reporting which is understandable because together with financial information it gives a comprehensive picture of a company. The proposal for a sustainability reporting directive includes various new aspects and would broaden the scope of sustainability reporting. However, it is good that non-listed SMEs would be left outside of the scope. As always, definitions related to the scope of the directive should be unambiguous. The directive would empower the Commission to adopt delegated acts which would set new reporting standards. This cannot be supported because e.g. the content of the standards should be better defined in the directive. Nevertheless, complementary guidance could be given by EFRAG. Overall, it is important that the standards will leave room for companies to report on material topics. While the regulatory framework relevant to the industry is evolving rapidly it is crucial to ensure that EU regulations and different definitions are coherent. This should be the guiding principle also in developing sustainability reporting. It is notable that the Commission's timeline is again fast paced creating more challenges from company perspective. At the same time, the taxonomy regulation is increasing the administrative burden of companies. And the taxonomy criteria adopted by the Commission are not in line with the current regulatory framework. Thus, the ambiguous criteria are unworkable. Because sustainability reporting should be consistent with the taxonomy shortcomings of the taxonomy should be taken into account in the legislative process. Currently, it is hard to make an over-arching assessment on the possible impacts of the directive proposal. Importantly, new standards should be based on existing definitions and frameworks. This would be a meaningful way to improve comparability in a situation where the new directive is increasing costs without clearly pointing out benefits of the new regulations. Principally, there is no need for new binding reporting requirements. Regarding sustainability information needs of different stakeholders vary substantially. Additionally, the strategies of companies may differ also within sectors. That is why the companies should be able to focus flexibly on reporting material topics. Mandatory auditing included in the proposal is further increasing costs for companies. Hence, it is reasonable that limited assurance is accepted. As it is a substantial new requirement it should, however, be voluntary and defined clearly. Generally, sustainability reporting is not as established as financial reporting which should be taken into account in the legislative process. For example, a balance should be found concerning the digitalisation requirement and costs resulting from it. We are yet to see the true befits from digital reporting. In short, new regulations should be proportionate and the legislative processes open.
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Response to Commission Delegated Regulation on taxonomy-alignment of undertakings reporting non-financial information

28 May 2021

The Finnish forest industry supports the essence of the EU taxonomy – mobilising sustainable investment. As the first delegated act on the taxonomy approved by the EU Commission covers forest management it is important to note that the growth of our forest resources can be improved while increasing the use of wood. In addition, Finnish forest industry products account for over 16 million tonnes of CO₂ emissions abated globally per year. Furthermore, emissions of forest industry mills are already extremely low and – according to our own climate road map – these mills could be completely fossil fuel free as early as 2035. However, the first set of criteria put forward by the Commission is as such increasing the administrative burden on the whole production chain, but the advantages of the new requirements cannot be credibly demonstrated. In the taxonomy, the Commission would like to look at the climate impact of forests on forest holdings of at least 13 hectares over a 30-year period, which is at odds with all current EU regulations. The model used and the forest holding size limit will mean a significant increase in bureaucracy, while any climate benefits will be highly uncertain. Climate impact monitoring and reporting work well at the country level in accordance with current legislation. Because, the Commission has not taken into account the climate benefits of current sustainable and active forestry the criteria should be revised and brought in line with the current regulatory framework. Thus, in developing taxonomy reporting it should be taken into account that the current taxonomy is very much a work in progress and covering only a part of the economic activities a company might be involved in. Thus, many aspects of the draft reporting delegated act are hard to evaluate. The taxonomy requires non-financial undertakings to use three key performance indicators (KPI), the proportion of their turnover, their capital expenditure and their operating expenditure related to environmentally sustainable activities. Already this is placing further administrative burden on companies. Adding complexity to disclosures would also increase the uncertainty and confusion among investors that the taxonomy process has created so far. Still, the Commission considers that companies should provide for a breakdown of the KPIs based on the economic activity pursued, including transitional and enabling activities, and the environmental objective reached. Referring to a need to ensure greater transparency, the Commission wants also that specific accompanying information should be reported for the share of economic activities that are described in the Commission’s delegated acts, but that do not yet meet the relevant technical screening criteria and the share of economic activities that are not covered by the Taxonomy-related delegated acts. Furthermore, the draft requires companies to provide for extensive accompanying qualitative information about the calculation and the key elements for change of the three KPIs during the reporting period. This detailed approach raises questions about practicability given the diversity of company structures and the unfinished nature of the taxonomy. Also, the fast-pased timeline for adoption does not leave enough time for companies to prepare for new extensive requirements.
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Response to Guidance on REDII forest biomass sustainability criteria

28 Apr 2021

The Finnish Forest Industries emphasizes following viewpoints: Wood-based products and sustainable forest management play an important role in the European Green Deal, especially in achieving 2030 climate targets and climate neutrality by 2050. The Commission demonstrated the climate benefits of our sector already in the 2050 vision A Clean Planet for All, where the Commission communicated that products from renewable resources are much needed. Our industry delivers these products such as construction materials, pulp, packaging materials, textiles, composites, tissue papers, baking and cooking papers, bioplastics, paper and bioenergy. Proposed REDII implementing act under consultation does not bring climate benefits nor stable operating environment for businesses. Operational guidance should not go beyond REDII mandate. Instead of guidance, the draft creates substantive forest legislation that should be under Member State competence. Forestry has its own set of legislation on national level taking into account national circumstances. Forestry should not be regulated by EU’s energy legislation. Publicizing the Navigant study would be especially useful for understanding the factual basis of the current proposal. The sustainability criteria should be implemented as agreed in the REDII since for wood processing industry the last 15 years have been time of instability due to unclarity about the sustainability rules. Now with the recently agreed and soon implemented REDII rules, both forest owners and the industry should be given an opportunity to make investments without a risk that rules will suddenly change. Delaying investments is bad news for the climate as it hinders the renewing of the industry.
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Meeting with Jorge Pinto Antunes (Cabinet of Commissioner Janusz Wojciechowski)

26 Apr 2021 · Contribution of Finnish forest sector to climate neutrality.

Meeting with Taneli Lahti (Cabinet of Commissioner Jutta Urpilainen)

7 Apr 2021 · State of Play of the Sustainable Finance Taxonomy

Response to Thermal oxidation materials and derivates in EU fertilising products

14 Feb 2021

The Finnish Forest Industry Federation (FFIF) would like to thank for the opportunity to comment the above-mentioned Commission Delegated Regulation amending Annexes II to Regulation (EU) 2019/1009 of the European Parliament and of the Council. The FFIF has a positive view towards increasing ash fertilization as a catalyst for example for forest growth. Hence, the FFIF sees that there is good potential to promote the circular economy through the amendment of the Annexes of the Regulation (EU) 2019/1009 by adding the thermal oxidation materials and derivates as a component material category (CMC13) in EU fertilizing products. However, in order the regulation to be useful and promote circular economy, the FFIF sees that few amendments are needed in the Annex 2. In other acts currently in place in Finland, such as the landfilling act, the TOC limit for regular landfills is 5%. This gives a good indication of what is considered safe and meaningful threshold for TOC in the current legislation. Other pitfall in the current proposal is that it excludes industrial sludges from the Annex 2. Hence, in order to promote the circular economy, material efficiency and the circulation of nutrients, the following amendments should be done in the current Annex 2: •Paragraph 1(a) of the Annex 2 excludes industrial sludges. This exclusion should be removed or shaped so that the ashes from treated industry sludges are suitable components when other criteria is fulfilled. •Regarding 1(b), last part of the sentence "if not chemically modified", should be deleted in order to be clearer and in line with the LCP Directive definition. •In Paragraph 4(b), we propose 5% limit value instead of 3% for TOC. •In general, the origin or the material that produces ash should not be the main defining factor, but rather the different criteria set in the proposed regulation. Hence, we don't see the need to exclude the sewage sludge either in 1(a).
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Response to Climate change mitigation and adaptation taxonomy

18 Dec 2020

The Finnish forest industry supports the essence of the EU taxonomy – mobilising sustainable investment. As the current proposal on the taxonomy covers forestry it is important to highlight that the growth of our forest resources can be improved while increasing the use of wood. This is not acknowledged in the current proposal on the taxonomy. Finnish forest industry products account for over 16 million tonnes of CO₂ emissions abated globally per year. Emissions of forest industry mills are already extremely low and – according to our own climate road map – these mills could be completely fossil fuel free as early as 2035. In order to embed forestry into the taxonomy in a balanced manner, forestry activities that are in line with the renewable energy directive (REDII) should be taxonomy compliant throughout the forestry criteria. REDII sustainability criteria are based on two-step risk assessment. The risk assessment starts at the level of a country's legislation. If national legislation does not meet the requirements of the sustainability criteria, sustainability must be considered in the wood sourcing area. The draft delegated act suggests two other forestry categories, named as “improved forest management” and “conservation forestry” to be included in the taxonomy. According to the Commission these “economic” activities can make a substantial contribution to the climate change mitigation and adaptation. The initial purpose of the taxonomy regulation was to address sectors with the biggest potential to contribute to the environmental objectives of the law. The forest industry strongly questions a substantial contribution of these two forestry activities in a fair and sustainable manner. Conservation forestry is a marginal economic activity. Suggested criteria for conservation forestry and improved forest management, including verification systems via compulsory forest management plans or equivalent with required climate benefit analysis, would heavily increase administrative burden in particular for private forest owners (In Finland, 80 % of the wood procured domestically by the forest industry comes from private forests). In practice, this means increased red tape for 60 % of the EU’s forest area. At the same time, additionality and “do no significant harm” criteria would exclude existing sustainable and environment-friendly forest management from sustainable financing. With the criteria proposed in the draft delegated act by the Commission, also the afforestation/reforestation project will be almost impossible to implement. Since the Helsinki resolution of 1993, there has been a common understanding between the Member States of the EU and beyond in Europe about the principles of sustainable forest management. These principles are embedded in Member States national forest legislations and voluntary marked-based certification systems (in Finland 93 % of commercial forests) which the sector is widely using. As of 2021, various EU policies influence the forest sector. In particular, the recast of the Renewable Energy Directive (REDII) sets sustainability criteria for forest biomass used in large-scale CHP installations. Set against a no-management baseline, sustainably managed forests under EU MSs’ legislations provide raw material for climate friendly products and increase forests’ carbon storage capacity in the long-term and therefore fulfilling the main aim of this taxonomy legislation. The current draft is not respecting the competence division on forest policy and can lead to detrimental false misperceptions as it comes to future sustainability provisions in other EU policies. In addition, the overall aim of the EU taxonomy for sustainable finance and the contribution of forests are put at risk if the proposed requirements are adopted. In addition, the taxonomy should not undermine sustainability of carbon-emission free energy production from hydropower and nuclear power.
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Response to EU Forest Strategy

3 Dec 2020

Finnish Forest Industries welcomes the Roadmap and calls for a timely adoption of the new EU Forest Strategy. Together with other forest sector stakeholders, the industry is at the core of the strategy and its implementation. Competence in forest policy lies with the EU Member States, as highlighted in the views of the Council and the Parliament on the EU Forest Strategy. Member States must continue to decide policies on forestry and forests, including on their conservation, protection and restoration measures. Also forest and forestry -related definitions should be done by the Member States. This includes e.g. primary and old-growth forests, afforestation, reforestation, degraded areas and closer to nature forestry. To ensure coordinated, systematic decision-making, the forest-specific measures of the Green Deal should be shaped in the Standing Forestry Committee with a strong EU Forest Strategy mandate. As part of a bio-based circular economy, the forest industry enables the achievement of the European Green Deal targets. The climate neutrality target requires an ambitious shift towards wood-based circular economy with a continuous flow of renewable, wooden raw material from sustainably managed forests. Wood-based products replace fossil intensive and non-renewable products. The EU Forest Strategy should boost the role of renewable raw materials as a solution. As the Roadmap suggests, a comprehensive strategy is needed to ensure that forests-related policies are consistent. They also need to be stable for companies to invest, develop new solutions and renew themselves. Forestry and forest industry create green growth by providing jobs and well-being around Europe and especially in its peripheries. In heavily forested countries, forest sector plays a significant role in the national economy. It has been estimated (Pöyry 2017) that the global markets of wood-based products may increase by 200 billion euros by 2030. From the economic, social and ecological point of view, it is very important for the European forest sector to get the most out of this. Sustainable forest management offers sustainable solutions that benefit the climate. Value-creation from selling timber motivates the landowner to carry out active forestry, which in turn assures sinks and timber today as well as for future generations. As long as forests stay vital and keep growing, they store carbon and provide materials for substituting non-renewable materials. Europe should, as a clear priority, eliminate the use of fossil resources. Emphasizing the need for sinks leaves the door open for continuation of fossil emissions beyond 2050. Passive forestry focusing on storing fossil CO2 in forests is a short term and a risky strategy. Ageing forests are not stable carbon storages, nor stable sinks, because they are vulnerable to damages (storms, pests, forest fires, erosion, drought, floods etc.), which over time can turn to carbon emitting sources. Furthermore, a forest sink as such does not create jobs, nor green growth. Sustainable and active forest management is an effective way to maintain and enhance biodiversity, to prevent forest damage and to promote the vitality of forests and their adaptation to changing conditions. Sustainably managed commercial forests, their protected valuable habitats and forest conservation areas form biodiversity networks. Biodiversity-friendly afforestation is part of a long-term climate solution: it also offers wooden raw material for the production of environmentally friendly products and increases carbon sinks. In Finland, peatlands represent one third of the territory and 25 % of wood potential. Strict protection and restoration measures in significant areas of peatlands would have major negative consequences to the forest owners as well as for the rural areas' and the Finnish national economy. The long-term sustainable management and use of forests on peatlands is constantly being developed as part of the SFM concept.
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Finnish Forest Industries Federation urges stability and leakage protection

26 Nov 2020
Topic — The EU is reviewing its carbon trading system to meet higher climate goals.
Message — The federation urges preserving regulatory stability and avoiding retroactive rules for long-term investments. It calls for strong carbon leakage protection by ensuring enough free credits for industry production. The group opposes extending the current emissions trading to road transport and buildings.123
Why — This would protect the industry's profitability and allow for optimal long-term investment planning.4
Impact — Consumers would face higher costs if the trading system expands to new sectors.5
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Response to Land use, land use change and forestry – review of EU rules

26 Nov 2020

Wood-based products and sustainable forest management will play an important role when achieving climate neutrality for 2050 as proposed by the Commission in Green Deal. Our industry is up to the challenge. We are contributing to mitigating climate change by decreasing fossil emissions and by bringing novel and traditional products from renewable resources into markets while simultaneously the European forest resources keep increasing. The Commission demonstrated the climate benefits of our sector already in the 2050 vision A Clean Planet for All, where the importance of a circular bioeconomy as a building block and our various climate mitigating and recyclable products were highlighted. The Commission communicated that products from renewable resources, such as construction materials, packaging materials, textiles, composites, bioplastics, paper and bioenergy are much needed. It is crucial to highlight the following issues in the forthcoming review of LULUCF-regulation: Europe should, as a clear priority, eliminate the use of fossil resources. Leaving fossil resources into the ground should be a priority to prevent CO2 emissions and to stop cumulating carbon in the atmosphere. Emphasizing the need for sinks leaves the door open for continuation of fossil emissions also in the future, beyond 2050. This must not happen. Instead, fossil resources should be left in the ground and sustainable solutions should be unleashed. It is necessary to ensure sustainable supply of raw materials from actively and sustainably managed forests. Needs for investments, competitiveness and environmental effectiveness should be applied from a circular bioeconomy viewpoint. Investments and competitiveness in our sector are and will be built on reliable and continuous wood supply. This and environmental effectiveness, moreover, are dependent on healthy and well-growing forests. They can be maintained only by active forestry which optimizes the carbon uptake while producing timber, paper, board, etc. thereby maximizing the overall climate mitigation effect. This is since active forestry is effective and sustainable from an environmental, social and economic point of view. Guidelines on closer-to-nature-forestry can be developed in Standing Forestry Committee, mandated by the future EU Forest Strategy. It is the value-creation from selling timber that motivates the landowner to carry out active forestry, which in turn assures sinks and timber today as well as for future generations. As long as forests keep growing, they store carbon and provide materials for substituting fossil materials. Passive forestry focusing on storing fossil CO2 in forests, on the other hand, is a short term and a risky strategy, as it would lead to ageing forests more vulnerable to damages. Forests are not stable carbon storages, nor stable sinks, because they are vulnerable to several damages (storms, pests, forest fires, erosion, drought, floods etc.), which over time can change them from being sinks to becoming carbon emitting sources. Active forestry creates healthy forests that provide sinks also in the long-term (2050, 2100). Furthermore, a forest sink as such does not create jobs, nor green growth. The EU needs to acknowledge the climate benefits of renewable products. The EU has a long history of promoting renewable energy but is still lacking in promoting renewable products, thereby missing out on a potentially large climate mitigation benefit. There is no need for separate support mechanisms for forest sector as long as the internal market functions well and EU policies (e.g. LULUCF, REDII, Forest Strategy, Industrial Strategy, Horizon, Circular Economy) recognize and take into account the climate benefits of wood-based products. There are complex interactions between sectors. The wood-based products with substitution effects impact well beyond our own industrial boundaries (housing, packaging, hygiene products, furniture, clothing, transport, etc.).
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Response to Updating Member State emissions reduction targets (Effort Sharing Regulation) in line with the 2030 climate target plan

26 Nov 2020

Finnish Forest Industries Federation Contact: ahti.fagerblom@forestindustries.fi Finnish Forest Industries’ viewpoints on public consultation on EU Effort Sharing (ESR) Wood-based products and sustainable forest management will play an important role when achieving climate neutrality for 2050 as proposed by the Commission in Green Deal. Our industry is up to the challenge. We are contributing to mitigating climate change by decreasing fossil emissions and by bringing novel and traditional products from renewable resources into markets while simultaneously the European forest resources keep increasing. The Commission demonstrated the climate benefits of our sector already in the 2050 vision A Clean Planet for All, where the importance of a circular bioeconomy as a building block and our various climate mitigating and recyclable products were highlighted. The Commission communicated that products from renewable resources, such as construction materials, packaging materials, textiles, composites, bioplastics, paper and bioenergy are much needed. It is crucial to highlight the following issues in the forthcoming review of ESR regulation: Europe should, as a clear priority, eliminate the use of fossil resources. Leaving fossil resources into the ground should be a priority to prevent CO2 emissions and to stop cumulating carbon in the atmosphere. Emphasizing the need for sinks leaves the door open for continuation of fossil emissions also in the future, beyond 2050. This must not happen. Instead, fossil resources should be left in the ground and sustainable solutions should be unleashed. Cost-competitiveness has always been and will be a crucial issue for industries operating globally. When reviewing ESR it is important to ensure the availability of energy and raw material in reasonable price, and also well-functioning and cost-effective logistics. The carbon leakage must be avoided whether modifying ESR leads to expanding ETS or not, whether it leads to changing LULUCF or not. Expanding ETS to transport and/or buildings should not increase industry's costs. This risk is real if transport and building sector have a much higher carbon abatement cost than sectors currently under the ETS. A combined ETS with industry sectors would offer the possibility for the road transport and buildings sectors to buy certificates instead of reducing emissions. When reviewing ESR EU should secure that forerunners are not restrained and that no one is left behind, but allow no free riders either. Every EU Member State should aim for climate neutrality by 2050 latest. In the last decades, some Member States have been able to achieve remarkable climate mitigation results by decreasing fossil emissions and/or increasing natural carbon stocks. We need to see Europe where every Member State is on the right track.
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Response to Review of Directive 2012/27/EU on energy efficiency

21 Sept 2020

Finnish Forest Industries’ viewpoints on public consultation on EU energy efficiency directive (EED) Wood-based products and sustainable forest management will play an important role when achieving 2030 climate targets and climate neutrality for 2050. Our industry is up to the challenge. We are contributing to mitigating climate change by decreasing fossil emissions and by bringing novel and traditional products from renewable resources into markets while simultaneously forest resources keep increasing both in Europe and Finland. Our industry is characterized by long investment cycles and that 2030 is very close in terms of investment horizon. It is therefore of primary importance to secure stability in the regulatory framework. This allows for optimal planning of investment decisions. Member States are still in the process of transposing the recently agreed review of the Energy Efficiency Directive (Directive 2018/2002) into national legislation. Operators are still in the process of adjusting to the agreed regulatory framework. Re-opening these provisions will create regulatory instability for several years, having a negative impact on investments. We therefore consider inappropriate and premature introducing changes in the just agreed regulatory framework. New legislative provisions introduced by the recently agreed Energy Efficiency directive should not be subject to revision. In general, energy efficiency directive should aim to increase energy efficiency and not set an artificial energy consumption cap. Greenhouse gas emissions are already capped within EU-area. There is no need to cap energy consumption too. Climate friendly solutions (e.g. electrification of industry, flexibility mechanisms, energy storages, CCS/CCU) seems to increase the energy demand in the future dramatically. If the EED will be revised, the energy consumption cap must be removed.
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Finnish Forest Industries Opposes Premature Renewable Rule Changes

18 Sept 2020
Topic — The European Commission is revising renewable energy rules to meet climate targets.
Message — The federation considers it premature to change the recently agreed framework. They argue re-opening rules creates instability that harms long-term investments.12
Why — A stable framework allows the industry to plan and secure investments.34
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Response to EU rules on industrial emissions - revision

20 Apr 2020

Please find attached the feedback of the Finnish Forest Industries Federation (FFIF).
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Response to 2030 Climate Target Plan

15 Apr 2020

Attached file
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Response to Carbon Border Adjustment Mechanism

1 Apr 2020

Forest industry plays a significant role in mitigating climate change and reaching European Green Deal objectives. The industry offers climate friendly products for European and global markets, also substituting more fossil intensive alternatives. Reaching i.a. climate objectives requires the safeguarding of EU industries' competitiveness and legislative predictability and stability. Finnish Forest Industries Federation (FFIF) supports the goal of reducing carbon emissions globally and preventing carbon leakage. In our view, the EU should primarily improve and reinforce its existing carbon leakage system that addresses the issue at EU level. Initially, we are concerned about a possible Carbon Border Adjustment Measure (CBAM) and its negative impacts. Our position is based on an analysis, the results of which highlight: • the (technical) difficulty of realizing the measure; • the negative effects it would have on international cooperation and trade; • the negative effects it would have on EU business' competitivity (e.g. increased cost of imported inputs, having also an effect on export competitivity); • the expected inefficiency of the measure as to emission reductions; and • the risk of removal of the current carbon leakage measures. Realizing CBAM WTO-consistently would be a challenge. CBAM is a new issue that is not directly governed by WTO agreements and it has not been addressed in dispute settlement. Even with most careful preparation the measure would likely be challenged by trading partners. In a worse case scenario, partners would simply, without a dispute process, deem the measure an illegal trade barrier. If a CBAM were realized, there could be discussion on the need and the possible removal of current carbon leakage measures. The question would arise whether CBAM and the current measures could co-exist and whether this would result in discriminatory treatment and be WTO-inconsistent. Having partners view EU measures or activity illegal or as protectionism would lead to retaliation or similar unilateral action on their part. Thus the measure and choices made could further deteriorate international cooperation, increase compliance cost and reduce competitivity, and increase the risk of trade wars. For now it is not known whether a CBAM will be proposed and if so, what type of measure it would be. With the information available currently, we understand that the possible measure would first apply to a limited number of sectors and that its scope could later be broadened. At the very least, forest industry should not be among the first sectors to which the measure would apply. Even so, there is no assurance whatsoever that our exports would not be hit hard by our partners reactions. We find it indispensable that each sector is carefully consulted and their views taken into account both if a measure is being prepared and more urgently if a sector is considered for inclusion in the scope of the measure's application. European forest industry exports more than it imports. The opportunities to export and spread European solutions should not be impaired.
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Response to Revision of the Energy Tax Directive

1 Apr 2020

Overlapping, cumulative effects of the Energy Taxation Directive (ETD) and the Emission Trading System (ETS) must be avoided to ensure European industries' global competitiveness. The effective steering mechanism of the ETS already comprehensively accounts for CO2 externalities by inflicting costs on energy-intensive industries in proportion to their GHG emissions. Thus, any possible revisions to the ETD must be carefully considered against their combined effect with other steering mechanisms to stay clear of overlapping taxation detrimental to industrial competitiveness that, in turn, drives the industry's investments into climate-neutral technology. On the same note, it is important to keep current lower taxation level exemptions in place for energy-intensive industries . Electrification of energy-intensive industries is a major contributor towards achieving the Green Deal's emission reduction goals. It is thus important that effective incentives to drive the process, requiring major investments in new industrial process and energy technology, remain in place and are further reinforced. One key incentive is access to competitively priced electricity. The electricity tax, in turn, is a central steering mechanism affecting the cost related to electricity use. For the long-term commitment of the European industry to investing into electrification, it is crucial that the EU commits to stable projections of a competitive level for the electricity tax in the long-term. Maintaining the currently competitive minimum level of the electricity tax is a critical success factor for the industry to invest into renewables-based electrification. Vis-á-vis third countries, this is also an important factor in maintaining a level playing field with regards to total energy costs, one of the major objectives of the EU's new industrial strategy . Achieving the Green Deal's emission reduction goals without introducing renewable and biomass-based alternatives to fossil-derived energy applications is unrealistic. Biomass-based raw materials sourced from sustainably managed, renewable sources are carbon-neutral and constitute one of the key pillars supporting a climate-neutral economy. The EU has laudably acknowledged this by allowing biomass- and other renewable energy solutions a tax-free status. This policy has been a key driver of investments into renewables-based innovation and fossil-free industrial infrastructure in the past decade. It is therefore of utmost importance that the EU maintain its current approach and allow tax-free production of renewable and bio-based heat and electricity. The Finnish forest industries strongly support the EU's current practice and advise the EU to maintain its commitment to this policy in the intended revision of the ETD. To most energy-intensive industries the use of energy constitutes a sizeable chunk of expenditures on their profit and loss accounts. This, in and by itself, provides for the best of incentives to invest into innovative, energy-efficient processes. These not only drive down energy-related costs in the industry's race for business competitiveness but also contribute to the shift to a energy-efficient economy. Throw in the promises of renewables-based industrial electrification and you have an effective formula for reaching for the Green Deal's climate goals. That said, the innovation-driven transition requires immense private investments. It is thus ill-advised to draft policies that aim to steer investments by levying additional cost burden on companies facing global competition. They undermine the industry's capability to invest into renewal by saddling it with extra costs and decreasing the amount of resources available for investments. Policies based on positive incentives - such as exemptions, tax-free treatment and lower tax rates for practices that help achieve the EU's climate goals - are much less prone to effects that are detrimental to the industry's investment capabilities.
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Finnish forest industry urges existing tools over new deforestation rules

3 Mar 2020
Topic — Consultation on minimizing deforestation risks from products sold in the European Union.
Message — The federation urges the Commission to prioritize better implementation of existing tools instead of proposing new regulation. They specifically request expanding the Timber Regulation's scope to include printed products and wooden chairs.12
Why — This approach avoids creating unnecessary administrative burdens for European raw material producers.3
Impact — Importers of printed materials would face new compliance costs from expanded regulations.4
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Finnish Forest Industries urges expansion of timber regulation scope

28 Feb 2020
Topic — This fitness check evaluates EU rules designed to combat global illegal logging.
Message — The federation calls for expanding regulation to cover printed products and furniture. They also request better recognition for forest certification schemes as tools to verify origin.12
Why — Expanding the rules would give Finnish companies a competitive advantage over imports.34
Impact — International traders using countries with weak laws to funnel illegal wood lose.5
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Response to Revision of Non-Financial Reporting Directive

25 Feb 2020

The Finnish forest industry is committed to sustainability and with our renewed sustainability commitments spanning to the year 2025 we aim to demonstrate leadership and continuous improvement in sustainability. Thus, the industry has supported the top-level environmental objectives enshrined in the EU's framework to facilitate sustainable investment. As Finnish companies provide globally solutions to these objectives mobilizing sustainable investments is our shared goal. In bolstering the foundation for sustainable investments, the Commission underlines rightly the importance of non-financial information. To this end it is highly likely that the market – driven by investors' needs for better non-financial information – will unify ESG reporting requirements and consequently there is no need to strengthen the provisions of the NFRD at this stage. Additionally, it should be taken into account that users of non-financial information include a vast array of stakeholders – and obviously not only investors. We want to serve our stakeholders in the most meaningful way and therefore in establishing new standards voluntary approaches should be used primarily. Furthermore, the guidelines on reporting climate-related information published in June 2019 showed that guidelines geared around one theme can be problematic too as the approach might lead to a variety of different guidance. So companies’ ability to select and report material topics should be protected. The guidelines are also excessively detailed and less usable compared to common reporting frameworks. Examples include the guidance asking to describe how the performance of the company with regard to climate influences its financial performance, where possible with reference to financial KPIs and whether and how the company’s remuneration policy takes account of climate related performance, including performance against targets set. While these would be hard to quantify in the future clear guidelines on how to calculate non-financial KPIs would bring comparability between companies. The Commission could also give an explicit statement of support for voluntary work to drive further comparability within a sector. Finally, setting new guidelines and requirements for companies should be done bearing in mind different sizes and resources of companies. The level of detail may well be overwhelming and disproportionate for smaller companies. In addition, if third party evaluation would be required a register of authorised service providers might help both companies and investors to make better assessments of companies' environmental and climate performance.
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Meeting with Catherine Geslain-Laneelle (Cabinet of Commissioner Janusz Wojciechowski)

19 Feb 2020 · Green Deal, EU Biodiversity Strategy, Finnish forestry

Meeting with Arto Virtanen (Cabinet of Commissioner Jutta Urpilainen)

3 Feb 2020 · Green Deal, the EU Biodiversity Strategy and the EU Forest Strategy.

Response to A new Circular Economy Action Plan

20 Jan 2020

Finnish Forest Industries Federation welcomes the upcoming adoption of a new Circular Economy Action Plan that aims at accelerating the transition towards a circular economy. Circularity begins with the renewability of virgin materials and all raw materials are legally and sustainably sourced. Therefore, it would be crucial that interlinks would be sought between the circular and the bioeconomy in order to enhance policy coherence and effectiveness of these two policies. Forest industries is an enabler of the circular economy. Finnish forest industries would like to highlight: • The forest industry’s renewable raw material, wood, can be turned into many different kinds of climate-friendly products which replace those which are made out of unrenewable raw materials. Forest industry bioeconomy growth areas include construction and interior decoration, packaging and tissue, as well as bio-based energy. New bioeconomy products come in the form of bioenergy, biofuels, and biochemicals as well as biocomposites, which combine wood and fibres with other materials. Interesting opportunities are opening up for wood as a replacement for fossil raw materials such as plastic or aluminium in packaging. Wood contains many different ingredients that can be used in, for example, the cosmetics or pharmaceutical industries. The textiles industry is developing textile fibres from wood and these can replace, for instance, cotton or polyester. • Paper and board are a well-functioning example as it comes to circularity and closing the loops. In 2018, paper has reached a recycling rate of 71,9% and even 84,6% in paper-based packaging on EU-level. • Setting requirements on mandatory recycled content might be useful in specific sectors to balance market failures there, but it could lead to counterproductive effects as it comes to paper and board. Paper and board manufacturing needs the continuous flow of virgin fibers. What is important, the raw material of virgin fibers, wood, comes from sustainably managed forests. Without virgin fiber, there won’t be any recycled fiber. • Regarding waste prevention and re-use new requirements should only be set following a thorough assessment of the environmental impacts, including hazardousness in a risk-based approach. Further action on re-use should be limited to products that are not designed for recycling.
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Response to EU 2030 Biodiversity Strategy

15 Jan 2020

Protecting and restoring biodiversity is a highly important part of the sustainable use of raw materials. Biodiversity is among the many ecosystem services provided by forests. Management practices applied in forests today show that ecological functions of forests can be maintained along with all other functions. This is why it is essential to connect biodiversity-related policy to the three pillars of sustainability and ensure a holistic approach with respect to sustainable forest management. Finnish Forest industries views on the EU biodiversity policy: 1. The evaluation of the current Biodiversity Strategy should be known before setting goals for a 2030 biodiversity strategy 2. Biodiversity strategy should contribute in balance to the other forest-related initiatives such as forest strategy. It is essential to ensure good coordination and enhance synergies among the forest-related EU policies. The recent development seems to follow a silo approach rather than addressing forest biodiversity as part of holistic sustainable forest management. 3. The targets in the Biodiversity Strategy have to stay within realistic limits. To be measurable, timely, and feasible well-targeted actions have to be based on best available scientific knowledge. When insufficient, this knowledge base has to be improved. Unattainable target for example for forest protection would hinder practical implementation. High protection targets wouldn’t take into account the disparity of protecting areas between different member countries and would hamper the sustainable use of renewable raw materials in certain areas. 4. Characteristics of the Member States have to be recognized and respected An EU one-size fits all approach will not address the diversity of forest ecosystems and their relevant challenges in an appropriate manner - flexibility in implementation is essential. EU Members States should define priorities and selection criteria for conservation and restoration of ecosystems. Existing sustainable forest management practices are already well covered by Member State legislation and other additional tools (E.g. voluntary certification and voluntary conservation measures as METSO Forest Biodiversity Programme in Finland.)
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Meeting with Arto Virtanen (Cabinet of Commissioner Jutta Urpilainen)

14 Jan 2020 · the Green Deal, the EU Biodiversity Strategy and the EU Forest Strategy

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

3 Sept 2019 · Bioeconomy

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

8 Feb 2019

The Finnish Forest Industries Federation welcomes the public consultation initiated by the European Commission. The Finnish Forest Industries Federation, representing the pulp and paper industry in Finland, has followed with concern the process for harmonised classification and labelling of DTPA and titanium dioxide (TiO2). FFIF proposes that DTPA and titanium dioxide are left out of the final proposal for the REACH committee meeting on February 14th. DTPA The Finnish Forest Industries Federation supports the comments made by the Lead registrants that DTPA does not deserve the proposed Cat. 1B classification for developmental toxicity and urges the European Commission and the Member States to postpone the final decision on this until RAC has had a chance to review the new information provided by the dossier submitters and until there is additional clarity on the key concepts of the CLP involved in the classification of DTPA and chelates in general. In the pulp and paper industry chelating agents are needed in the processes to bind and remove manganese ions and other metals originating from the wood (naturally occurring in the soil) in the following two main applications, both of which occur in closed systems under strictly controlled industrial operations. 1. Control of smell and taste properties in paperboard for food packaging (as required by Regulation 1935/2004). The formation of aldehydes is prevented. The aldehyde formation is catalyzed by manganese and cause smell and off taste. 2. Bleaching with hydrogen peroxide and ozone (as required by BAT 19 by the Commission Implementing Decision 2014/687/EU and other EU environmental law). The manganese ions and metal ions cause a catalytic oxidation of hydrogen peroxide and ozone. If classified 1B, the main consequences of the reclassification of DTPA are the risk of losing customer approval, unintended environmental harm and hampering the manufacturing process of paper and board. If no longer able to comply with Regulation 1935/2004 for food contact materials, the alternative packaging solution most likely would have higher environmental impacts as has been discussed in the Single Use Plastics Directive. DTPA (and/or other chelating agents) are essential for bleaching based on alternative techniques to avoid chlorine-based bleaching and have enabled drastic reduction of AOX emissions. DTPA and other chelating agents have already been used for several decades in the pulp and paper industry for the above applications. Therefore, the safe handling of these agents and protection of the environment is well known and demonstrated. TiO2 More time is needed for the considerations. As stated in the RAC opinion, the TiO2 classification (carcinogenic if inhaled, Carc. 2) is not based on substance-specific toxic properties but on its dust form1. A similar hazard profile is also characteristic for other poorly soluble low toxicity particles (PSLTs). There are many such materials, e.g. road dust has a corresponding hazard profile. The EU has previously in the UN GHS Sub-Committee opposed a classification criteria for combustible dusts on the basis that dust form is not an intrinsic property of a chemical. A more thorough consideration should take place to understand the legal and practical consequences before fundamentally changing the CLP classification principles like now proposed. A classification of TiO2 would have major impact on the European paper industry, since TiO2 is a widely used pigment, that gives the products exceptional characteristics. For decades, occupational safety has been based on the principle of avoiding dust materials. If the use of dust materials cannot be avoided, exposure to them is prevented. CLP classification based on dust form of a material would not increase the safety of use of such a substance at any stage of the supply chain.
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Finnish Forest Industries Urge Higher ETS Compensation Levels

17 Jan 2019
Topic — The consultation reviews rules for compensating industries for carbon-related electricity price increases.
Message — The federation calls for flexible reporting thresholds and higher maximum compensation levels. They also oppose making aid conditional on new energy efficiency investment requirements.123
Why — Increased aid would help offset rising carbon prices and maintain industrial competitiveness.4
Impact — Environmental groups lose a mechanism to ensure industries invest in energy efficiency.5
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Meeting with Jyrki Katainen (Vice-President) and Technology Industries of Finland (Teknologiateollisuus ry) and Chemical Industry Federation of Finland (Kemianteollisuus ry)

11 Dec 2018 · Finnish EU-presidency and EU innovation policies

Finnish forest industry demands robust carbon leakage cost assessments

13 Nov 2017
Topic — This consultation defines industry sectors at risk of carbon leakage for 2021-2030.
Message — The federation requests that electricity assessments reflect how fossil fuel plants set market prices. They also propose treating non-EU countries as a single block for trade calculations.12
Why — These measures provide stability and prevent companies from facing competitive disadvantages globally.34
Impact — Trading partners with climate policies lose out if they are not considered comparable.5
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Meeting with Kaius Kristian Hedberg (Cabinet of Commissioner Elżbieta Bieńkowska)

6 Sept 2017 · EU policies on energy & climate

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

28 Sept 2016 · Bioeconomy

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

7 Sept 2016 · Issues related to trade with Russia

Meeting with Shane Sutherland (Cabinet of Commissioner Phil Hogan)

6 Sept 2016 · Renewable Energy

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

6 Sept 2016 · energy and climate policy, circular economy package

Meeting with Kaius Kristian Hedberg (Cabinet of Commissioner Elżbieta Bieńkowska), Rolf Carsten Bermig (Cabinet of Commissioner Elżbieta Bieńkowska) and Finnish Energy - Energiateollisuus ry

29 Apr 2016 · Large Combustion Plant

Meeting with Shane Sutherland (Cabinet of Commissioner Phil Hogan)

19 Jan 2016 · Forestry

Meeting with Shane Sutherland (Cabinet of Commissioner Phil Hogan)

9 Dec 2015 · Forestry

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

18 Nov 2015 · Energy Union, Land use sectors, renewable energy, biomass sustainability, ETS, Transport, Energy Security

Meeting with Yvon Slingenberg (Cabinet of Vice-President Miguel Arias Cañete)

17 Nov 2015 · RES, biomass sustainability and LULUCF

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

23 Jun 2015 · Circular Economy

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

20 Apr 2015 · Circular Economy

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

20 Apr 2015 · Circular Economy

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

23 Feb 2015 · Introductory meeting

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

20 Jan 2015 · Sustainable forest industries