MM Kotkamills Oy
MM Kotkamills in brief MM Group is Europe’s leading producer of cartonboard and folding cartons focusing on sustainable and innovative fibre-based packaging solutions. Including the latest acquisitions, MM generates sales of approximately EUR 3.2 billion and employs approx. 12,500 people. MM Kotkamills joined the MM Group on Aug. 2nd 2021. The integrated company in Finland manufactures innovative products created from wood, a renewable natural resource. Its range of sustainable products includes food-safe consumer boards, the high-quality saturating kraft paper Absorbex®, and ecological wood products. The fully recyclable AEGLE® and ISLA® boards, produced since 2016, were complemented in 2018 with water-based dispersion barriers, replacing plastics used in packaging and food service applications. All our products are environmentally friendly, recyclable and safe to use.
ID: 196160532627-78
Lobbying Activity
Response to Revision of the Renewable Energy Directive (EU) 2018/2001
17 Nov 2021
Response to COM(2021) 557 final
MM Kotkamills welcomes the opportunity to respond to Commission’s proposal on the revision of the directive COM(2021) 557 (later RED III). The revision is part of the European Green Deal and Fit for 55 package. Fit for 55 aims to decrease emissions in different sectors while increasing carbon sinks. As a part of the package, the revision of RED III aims to increase the share of energy produced from renewable sources from 32% to 38-40% by 2030, as in the Renewable Energy Directive (RED II).
MM Kotkamills is part of MM Group, Europe’s leading producer of cartonboard and folding cartons focusing on sustainable and innovative fibre-based packaging solutions. The integrated company in Finland manufactures innovative products created from wood, a renewable natural resource.
Sawdust, the main source of MM Kotkamills’ raw material comes from the side stream of saw industry. We use 700,000 solid cubic meters of sawdust per annum to produce unbleached pulp for producing Absorbex®. As paper-based laminates have a long service life, the carbon of sawdust is bound for decades.
Statement
MM Kotkamills is pleased to see that the aim of the Commission remains high on climate ambition. The overall approach of the package is extremely high and on general level, we welcome the intent to co-prepare and coordinate the entire package. However, the overall complexity of the regulative package opens the problem with double regulation. The second problem comes with the ripple effect of the complex regulation. Changing one regulation without considering on the very detailed level could cause even unwanted harm to the overall aim of the package.
Cascading use and bioenergy
RED III will further increase the requirement and need for bioenergy and therefore for the demand of biomass. Both the overall increasing target for renewable energy and its sub-targets for transport sector’s biofuels will further increase the demand. RED III will also remove the double counting of energy content for transport sector’s advanced biofuels. Sawdust is listed as a possible feedstock for advanced biofuels in Annex IX a list. Feedstocks from Annex IX a will face further demand from aviation and maritime sectors with new biofuel requirements.
In RED II recitals, the previous legislation mandated the Member States to pay due regard to waste hierarchy. Also, RED II required that national support mechanisms should not cause distortions to raw material markets. RED III re-enforces the principle of waste hierarchy through the introduction of cascading use (Article 3(3)) and takes a stronger stance against raw material market distortions. The phase-out of biomass use for electricity production by 2026 is also introduced.
MM Kotkamills is extremely pleased to see the introduction of cascading use. We would like to highlight the extremely important issue of making a clear distinction on what is deemed cascading use and what is not. Sawdust is generally regarded as residue or waste and therefore listed as a possible feedstock for advanced biofuels. For MM Kotkamills, sawdust is far more than a residue. It is the main raw material we use in the pulp manufacturing process. We would like to highlight that the increase of bioenergy and even more so the increasing demand for advanced biofuels will cause great raw material market distortions. The current and ongoing energy price crisis and Commission’s toolkit on loosening the state aid guidelines are also jeopardising the functioning of the raw material market.
To summarise, MM Kotkamills:
1. SUPPORTS the targets of RED III both on climate and renewable energy
2. WELCOMES the increasing role of cascading use
3. HIGHLIGHTS the need to clearly define cascading use
4. HIGHLIGHTS the need to fully assess the impact to raw material markets
5. CALLS for Commission to consider the availability of sustainable raw materials and residues when raising ambition on all sectors simultaneously
Read full responseResponse to EU Forest Strategy
4 Dec 2020
Kotkamills welcomes the roadmap for the new EU forest strategy and thanks for the opportunity to share its view for the further development of the initiative.
Kotkamills believes achieving the objectives of the roadmap requires an ambitious and overarching new forest strategy, while maintaining the competence of forest policies within the Member States.
Kotkamills agrees with the objectives set out in the roadmap and highlights the importance to acknowledge the multiple functions of European forests. The society depends on forests in multiple ways, which are all combined in the framework of sustainable management of forests. We believe the new forest strategy should thoroughly emphasize the framework of ecologically, socially and economically compatible use of forests.
Kotkamills would like to point the Commissions’ attention to the accelerating trend of energy use of forest-based biomass. We highlight that burning of forest-based biomass and fuels developed from it, should not be supported or subsidised on the expense of products that effectively sequestrate carbon. As a good example, sawdust is used for producing saturating base kraft papers and high pressure laminates (https://kotkamills.com/products/absorbex/). The new forest strategy should sufficiently acknowledge the issue and aim to guarantee that forest-based biomass is directed primarily to creating products of low environmental impact and to replace carbon intensive materials.
Recommendations:
1. Emphasize the framework of sustainable management of forests. Establish the new forest strategy on ecological, economic and social aspects of forest use.
2. Create an ambitious and overarching new forest strategy which is based on subsidiarity.
3. To guarantee that forest-based biomass is directed primarily to high-value carbon-binding products and guarantee that energy use of forest-based biomass truly remains a last resort.
Read full responseResponse to Review of the requirements for packaging and feasibility of measures to prevent packaging waste
6 Aug 2020
We thank for the opportunity to give our feedback on the Roadmap on Review of the requirements for packaging and other measures to prevent
packaging waste.
Kotkamills is a Finnish forest indsutry company. We also manufacture packaging boards for flexible boxboards as well as for food packaging.
We are pleased that the Commission aims to improve the functionality of the internal market by providing clearer guidelines and definitions for packaging. This would create a much more level playing field and would provide consumers with coherent information of the products.
We would like to highlight the following.
• Create clear, standard-based and technology-neutral definitions for biodegradability and compostability of packages. We are pleased to see this is recognised by the recent Eunomia report on the effectiveness of the requirements of the PPWD as a main area that needs strengthening, and that they push for the consideration of compostable packaging in certain applications;
• Create clear and predictable standards for what is considered recyclable and taking into account recycled fibres and their benefits;
• Clear definitions between words plastic and polymer.
More detailed response is attached.
Read full responseMeeting with Helena Braun (Cabinet of Executive Vice-President Frans Timmermans)
19 Jun 2020 · European Green Deal and circular economy
Response to Farm to Fork Strategy
20 Mar 2020
Kotkamills position on the roadmap of Farm to Fork Strategy
Kotkamills fully supports the ambition of the European Commission’s Green Deal and Circular Economy Action Plan. It is our belief that the Farm to Fork Strategy will mark yet another milestone in greening our ecosystem and assuring safe food and feed chains for future generations.
Safe and sustainable use of packaging materials is also a key instrument in building a strong Farm to Fork Strategy; a principle which is at the heart of our business. Kotkamills is made of three separate but united business lines working together as a forerunner for the circular economy. Kotkamills Wood produces high quality timber products and delivers valuable raw materials as a byproduct for other businesses. Absorbex Oy is a world leading producer of saturating base kraft utilising saw dust and recycled fibre as a raw material. Our Consumer Boards businesses serve the consumer packaging industry with plastic free AEGLE and ISLA products which are designed for easy recycling.
To provide excellent protection for food, the properties of AEGLE and ISLA boards can be enhanced for high grease and liquid resistance, with water-based, aqueous, dispersion barriers. The boards are helping create environmentally-sound food packaging and disposable cups, which are not only a conscious choice for hygienic serving, but also reduce the impact of plastic waste in Europe, for they are fully recyclable.
In line with the sustainability principles of the EU Green Deal, we want to see the Farm to Fork Strategy address the entire value chain from sustainable production of food to resale and waste management. This includes the promotion of the use of safe and sustainable food packaging. Use of easily recyclable materials and safe and sustainable chemicals should be addressed under this strategy as well as in the revision of the Food Contact Materials Directive. With this in mind, Kotkamills would like to address the following:
Food packaging
Use of plastics in food packaging has in the past offered good hygiene and prolonged the shelf-life of multiple food products. But plastics litter threatens our health and our ecosystems: it is neither sustainable nor climate friendly. Fortunately, alternatives to traditional plastics already exist for lots of food products. Kotkamills packaging materials offer the same hygienic conditions to fast and frozen foods as plastic does. Our products can be used in disposable straws and cutlery as well.
What sets Kotkamills’ solutions apart from the traditional plastic packaging industry is the recyclability. Our barrier boards can be recycled using a variety of already existing waste streams, such as wastepaper or corrugated paper. Products are also biodegradable. It is therefore vital that the role of these easily recyclable products is recognised in the forthcoming revision of the Food Contact Materials Directive.
Safe and sustainable chemicals in food packaging
Recycled content in food contact materials need some virgin material in order to uphold high levels of food safety. Some alternatives to traditional plastics that offer similar grease and vapour resistance qualities, include certain potentially chemical compounds that might be harmful for health, such as fluorochemicals. Flurochemicals are harmful and should be restricted, thus ensuring only safe and sustainable chemicals are used in food contact materials, like those materials found in our products.
Clear labelling and standards
In order to promote sustainable packaging materials and provide consumers with more information about the sustainability of packaging products, the EU should create clear, standard-based and technology-neutral definitions for biodegradability and compostability of packaging. The EU should also create clear and predictable standards for what is considered recyclable, taking into account recycled fibres and their benefits.
Read full responseResponse to A new Circular Economy Action Plan
20 Jan 2020
Kotkamills reply to the consultation
Road map for new circular economy action plan
Kotkamills, a Finnish forest industry company producing recyclable consumer boards for food packaging including cups and fast food applications, warmly welcomes this Commission initiative. In our view, the road map includes ambitious and achievable targets regarding circular economy, building on the success Europe has already made on boosting circularity in the Union. It is essential that the sourcing of raw materials is carried out in the most sustainable way possible, but it is also vital to ensure that products placed on the market can be recycled or reused. Fibre-based products that can be easily recycled offer a sustainable solution. They are readily available, safe to use and better for the environment than plastics.
This fibre-based packaging can also be recycled with existing infrastructure and waste streams, such as bleached paper, corrugated paper, paper board or mixed waste. We therefore call on the circular action plan to promote the production of plastic-free products which are easier to recycle than plastics by using the already existing recycling streams. Promotion could be through the use of incentives for bio-based resources or more bans on single-use plastic packaging.
In order to ensure a fair and just transition to climate neutrality and full circularity, we also call for the following:
• Improve the implementation of existing waste legislation and use of infrastructure. Allowing bio-based packaging to be recycled with normal paper streams would reduce waste and encourage the use of alternative, sustainable packaging.
• The circular economy action plan should tackle the unnecessary use of harmful or potentially harmful chemicals.
• Make the market for secondary raw materials more financially attractive to reduce the use of virgin materials. Predictable legislative framework helps in speeding up the transition to climate neutral circular economy and helps to create an attractive market for recycled materials.
Kotkamills is a responsible partner that delivers renewable products and performance to its customers' processes via product innovations created from wood, a renewable raw material. Our product range includes fully recyclable consumer board products AEGLE® and ISLA®, and one of the key brands of the company is Absorbex®, an innovative laminating paper product for the laminate, plywood and construction industries. Moreover, Kotkamills offers ecological, technically sound and visually attractive wood products for demanding joinery and construction.
Read full responseMeeting with Sebastien Paquot (Cabinet of Vice-President Karmenu Vella)
4 Feb 2019 · Plastic Strategy
Meeting with Sebastien Paquot (Cabinet of Vice-President Karmenu Vella) and Kreab Worldwide
21 Nov 2018 · Single Use Plastics and alternatives to plastic
Meeting with Risto Artjoki (Cabinet of Vice-President Jyrki Katainen) and Kreab Worldwide
20 Nov 2018 · Plastics strategy