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Puutuoteteollisuus ry

FFWI

Puutuoteteollisuus ry on suomalaisen puutuoteteollisuuden ja siihen liittyvää toimintaa Suomessa harjoittavien yritysten edunvalvoja ja yhteinen ääni.

Lobbying Activity

Response to Union framework for the calculation of life-cycle Global Warming Potential for new buildings

27 Oct 2025

Puutuoteteollisuus ry (Finnish Woodworking Industries Federation) welcomes the proposed Delegated Regulation establishing an EU-wide framework for calculating and disclosing the whole-life Global Warming Potential (GWP) of new buildings. We strongly support the objective of harmonised comparability across Member States, a 50-year reference period, a clear minimum scope of building elements, and stage-by-stage disclosure (A to D) on Energy Performance Certificates (EPCs). To ensure fairness for bio-based construction and feasible implementation for small and medium-sized enterprises, several targeted improvements are needed. All EN 15804-compliant Environmental Product Declarations (EPDs) and CPR-compliant Digital Declarations of Performance and Conformity (DoPC) should be accepted in all Member States without additional approval to avoid market fragmentation. Building-level GWP must be calculated through a mandatory roll-up of verified product-level indicators, including stages A4 to A5, B, C and D. EPCs should disclose GWP-fossil, GWP-biogenic, GWP-LULUC and GWP-total, accompanied by a Roll-up Annex containing the bill of quantities, data sources and aggregation steps to ensure transparency and verifiability. EU-level reference datasets should be published and regularly updated to represent current manufacturing technologies. These default data should be conservative but realistic and allow the use of EN 15804 sectoral averages when product-specific data are unavailable. Biogenic carbon storage should be explicitly recognised at the building level in both GWP-biogenic and GWP-total, consistent with product-level indicators under the CPR. A harmonised dynamic life-cycle assessment method should be permitted, reported alongside the static 100-year GWP value during a transition period. Symmetrical treatment is required for biogenic storage and substitution credits in timber and for carbonation in concrete to avoid double counting. Modules D1 and D2 should remain mandatory, supported by clear Commission guidance on allocation and avoided-burden methods. For operational impacts (stage B6), each Member State should publish a single national greenhouse gas factor set covering the full 50-year period, while the Commission defines boundary conditions to maintain comparability. For on-site renewable energy systems such as building-integrated PV or storage, allocation option B2 should be adopted so that envelope-integrated renewables common in timber construction are treated fairly. The EPC and Roll-up Annex should include a Tier-3 breakdown of results for foundations and groundworks, above-ground load-bearing structure, envelope, core mechanical and electrical systems, and on-site energy systems. To preserve comparability of GWP results per square metre, the definition of useful floor area should follow International Property Measurement Standards (IPMS), and the chosen standard should be stated on the EPC. Service-life rules should follow ISO 15686 with fractional replacements in stage B4. Member States should publish national reference service lives for timber components such as façades, windows, CLT and glulam, while allowing project-specific evidence where supported by data. Circularity should be strengthened through an annex referencing ISO 20887, with practical checklists for design-for-disassembly and verified datasets for reclaimed timber products linked to stages D1 and B5. To enable SMEs, the Commission should provide templates, open datasets and funding to support EPD and DoPC development. Datasets should remain open, machine-readable and compatible with BIM and LCA tools to minimise administrative burden. By enforcing mutual recognition of product data, establishing a clear roll-up calculation rule, recognising biogenic carbon storage, allowing dynamic life-cycle reporting, ensuring a Tier-3 breakdown for transparency and aligning service-life rules, the Regulation can deliver a fair and credible framework that rewards
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Response to European strategy for housing construction

18 Sept 2025

The European Commission has correctly identified that solving Europe's housing affordability crisis requires tackling the construction sector's chronic low productivity. As the Finnish Woodworking Industries, we argue that the solution is not incremental change but a decisive strategic shift towards industrialised offsite construction using sustainable, bio-based materials like timber. This is the single most effective lever to simultaneously deliver affordable, high-quality housing at speed while turning our built environment into a powerful tool for climate action. While improving the energy efficiency of our existing building stock through renovation is critical, it will not solve the fundamental housing supply gap. A balanced approach is needed. To increase the number of available homes, a significant wave of new construction is indispensable. The decision to renovate or rebuild must be guided by pragmatic, data-driven lifecycle assessments. It is crucial to note that timber is a uniquely versatile solution for both paths: not only for highly efficient new builds, but also for innovative, lightweight renovations and vertical extensions (added floors), which can add thousands of new apartments to existing urban buildings. However, the potential of this modern, productive construction ecosystem is currently locked by systemic, outdated barriers. Our industry is ready to invest and scale up, but we face a regulatory environment that was not designed for industrialisation or a true Single Market for prefabricated products. The primary obstacles are clear: 1.Unpredictable and Outdated Local Permitting: The core problem for industrial manufacturing is not just the length of permit processes, but their unpredictability, which makes production planning impossible. This is compounded by outdated local zoning and prescriptive building codes that penalize modern, high-performance timber systems. 2.A Fragmented Single Market: The lack of a common EU-wide 'Type Approval' for prefabricated building systems forces innovative SMEs into costly, redundant national testing and certification, destroying economies of scale and hindering cross-border trade. 3.Misaligned Market Incentives: Public procurement and market frameworks too often fail to reward superior lifecycle performance, creating a market that undervalues sustainability, carbon storage, and long-term efficiency. To solve this, we propose a strategy built on proven, high-impact interventions, not theoretical ideals. We call on the Commission to champion three key actions: First, establish a true Single Market with an EU-wide 'Type Approval' system. This single action would slash administrative burdens and unlock cross-border competition and innovation. Second, drive market demand with smart, performance-based regulation. The EU should promote the adoption of proven models like Denmark's mandatory lifecycle GWP limits for new buildings, which have successfully stimulated the market for low-carbon solutions. Third, modernise local frameworks by promoting best practices. The EU can lead the way by championing binding, predictable deadlines for building permits and the shift towards performance-based codes, creating the stable investment climate our industry needs. This roadmap is not just a vision; it is a practical reality. On September 14, 2025, Canada launched its "Build Canada Homes" initiative, a national strategy built on a catalogue of pre-approved designs, fast-track permitting, and a focus on modular timber construction. This powerful international precedent demonstrates that our proposals are effective and deliverable. Europe must match this level of ambition. Our detailed position paper, attached below, provides further evidence for these points. We are a key partner in this transition, and we stand ready to work with the Commission to build a more affordable, sustainable, and productive Europe.
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Response to European Affordable Housing Plan

14 May 2025

The Federation of Finnish Woodworking Industries welcomes the European Affordable Housing Plan (AHP). The housing crisis demands effective solutions. Timber construction, leveraging wood as a renewable, low-carbon, and carbon-storing material, is uniquely positioned to deliver affordable, sustainable, and high-quality housing rapidly. Its suitability for prefabrication boosts productivity, cuts construction times, and minimizes site disruption, directly addressing AHP goals. We urge the Commission to consider the following areas: 1. Streamlining Regulatory Frameworks & Permitting: Current fragmented regulations and unpredictable permitting processes create significant barriers for timber solutions and cross-border trade. Harmonize Core Standards: Prioritize EU-level harmonization of essential building regulations. Crucially, ensure consistent interpretation and application of Eurocode 5, including aligned National Annexes, to reduce market fragmentation that stifles competition and inflates costs for manufacturers navigating differing national requirements. Accelerate Harmonized European Standards (hENs) & EU-Wide Type Approvals: Resource and expedite the development of hENs under the CPR for key timber products. This is vital for fair market access and avoids costly repeated national tests/approvals (even for ETA-approved products). Establish a clear, efficient EU-wide "type approval" system for prefabricated timber elements/modules to drastically cut duplicative testing, speed market entry, and lower costs for innovative housing. Modernize Permitting & Zoning: Mandate and support Member States in adopting digital, efficient, and predictable permitting processes including binding deadlines. Unpredictable permit durations cripple industrial prefabrication capacity planning. Reform local zoning rules that disproportionately penalize timber (e.g., outdated height limits, fire separation rules based on legacy materials) and actively incentivize low-carbon solutions like timber. 2. Mobilizing Investment & Supporting Low-Carbon Innovation: Financial hurdles and procurement practices often fail to recognize timber's advantages. Align Financial Instruments & Timelines: EU funding and national programs must support investment in timber prefabrication capacity. This is closely linked to industrial prefabrication schedules, and ultimately to factory downtime and unsustainable financial risks for manufacturers. Promote Green Finance & Risk-Sharing: Develop financial tools that acknowledge timber's environmental benefits and mitigate perceived risks for innovative or large-scale projects, especially addressing higher initial risk premiums. Revise Public Procurement: Advocate for robust public procurement criteria valuing lifecycle carbon (including embodied carbon and carbon storage), construction speed, modularity, and reduced on-site emissions. This unlocks timbers potential for faster AHP delivery. Standardize CO2 Calculation: Support harmonized CO2 calculation methodologies for buildings for fair assessment of timber's climate benefits. 3. Enhancing Skills & Cross-Border Operations: Skills gaps and logistical barriers limit widespread adoption. Expand Timber-Specific Training: Support EU and national initiatives for architects, engineers, contractors, and permit officials on modern timber design, advanced fire engineering, digital tools, and on-site best practices. Address outdated assumptions about timber performance. Harmonize Transport Regulations: Facilitate cross-border trade for prefabricated timber modules by harmonizing oversized load regulations at EU/national levels. Differing rules (e.g., permissible transport widths) are direct trade barriers. Conclusion: Timber industry is ready to contribute to the AHP. Addressing these barriers will unlock timber construction's capacity to deliver affordable, sustainable, high-quality housing, meeting urgent societal needs while advancing climate and bioeconomy goals.
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Response to Environmental claims based on environmental footprint methods

7 Jul 2023

Proposal for Green Claims Directive On behalf of the producers of wood-based products we would like to give following feedback: At this stage the proposal looks complicated and regulations intertwined on with another. At the moment the Construction Products Regulation is under revision and the ESPR is taking shape. Furthermore some of our products are used in the packaging sector and fall under PPWR. One single producer (e.g. a sawmill) can produce tens or hundreds of different products targeted at different end uses. Therefore we would ask the Commission to take a coherent view in developing these regulations so that the administrative burden for a producer won't be too heavy and difficult to handle. The majority of companies in our sector are SME's.
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Response to Ecodesign for Sustainable Products - Product priorities

11 May 2023

Inclusion of Furniture in the ESPR is welcome as it will create generic rules that harmonize the communication on the market and ensures the level playing field. However, the scope is extensive as furniture has numerous functions and raw materials, and the scale in manufacturing varies from private entrepreneurs to stock listed companies. Taking into account the wide array of products under the proposed scope this regulation work would be heavy and time consuming. One should either prioritize certain furniture by scope or to group them by some other classification method. Compared to many other products the circular economy of furniture is rather well established already now. Furniture is already now reused, repaired and recycled. Different kind of furniture are finding new owners through flea markets and recycling centers and some design items even get added value if they are old and come from a certain era of production. Many producers already now provide spare parts and repair services. Even households are able to make some small repairs and improvements by easily available tools. The trend is that more and more of furniture come to the EU market from outside Europe, especially from the Asian countries where the manufacturing costs are lower. This already has led to situation that the value of such furniture can be low, and their life cycle can be much shorter than before. Regulation enhancing repair and maintenance properties for furniture is therefore welcome and supports the longer life cycle and quality of these products. One should also align the work with other pieces of legislation currently under development by the EU. There are several policies like the taxonomy, nature restauration law, biodiversity strategy, deforestation-free products regulation etc that are intertwined with the aims of ESPR. There should not be conflicting demands between the mentioned legislation and ESPR. Similar attention should be put to materials with global environmental concern and demand for control systems of origin like cotton, wool, feathers, rattan, certain metals etc. One should also take into account the embodied energy in materials like glass and steel or the fossil based raw materials like most plastics. The regulation should be fair to producers from all sizes. Requirements should be based on available regulation and additional verification should not be needed. One should also take into account the local preconditions. Regions with long distances dont have the same infrastructure for recycling as densely populated areas. There are areas where at the moment is no recycling capacity available. Besides there are components in furniture that by definition cant have recycled content, like massive wood. Even the reuse of massive wood can be limited if they contain paints, varnishes or other treatments not acceptable any more. One also should assess the impact to the environment for recycling and reuse that need long distance transport, high energy input or other added treatment compared to virgin material. Repair of furniture should not lead to violation of the IPR.
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Response to Initiative on EU taxonomy - environmental objective

3 May 2023

Taxonomy Environmental Delegated Act In our comments to the Taxonomy Environmental Delegated Act, the Federation of the Finnish Woodworking Industries (FFWI) focuses on technical screening criteria aimed at reaching the environmental objective Substantial contribution to the transition to a circular economy in relation to the economic activities construction of new buildings and renovation of existing buildings. We would ask this Act to recognise and reflect the sectorial particularities as well the regional preconditions. FFWI supports the view that the calculation and the disclosure of life cycle GWP for new buildings and renovation of existing buildings should play a crucial role in all EU policies, including the Taxonomy. But we need to take into consideration our national reality in Finland: a scarcely populated but large country. Long transport distances and processing of small amounts of recyclable/reusable wood-based materials cause such an environmental load that the use of secondary materials may not be more beneficial when compared to the use of primary materials. On the other hand national legislation for limiting the carbon footprint of building will be introduced soon. The draft Act poses that, when it comes to the construction of new buildings and respectively renovation of existing buildings, when using bio-based products there should be a 20 % and 10 % share of recycled or re-used products. At the moment there is no criteria and resource to verify the suitability of reused products to be used in construction. And there is only one factory that produces particle board in the whole country and it cant process the volumes needed to be recycled. It is not economically feasible to invest in new capacity. The Construction Products Regulation sets high standards for the safety of construction works as well as health of the people. The given target levels of reuse/recycling cannot be reached at a foreseeable future. This would limit wood-based products out of the scope of the Act which is in a conflict both national targets for using bio-based materials as well many EU initiatives (EPBD, The New European Bauhaus, certification of carbon removals etc.). Finland has a big production of wood-based products but a small home market. 70 % of our sawn and planed timber is exported. Wood to be reused/recycled will be available in the countries where it will be used. Most of the sawn wood used domestically will be used in construction where it stays tens or hundreds of years storing carbon. The system for collecting, sorting and verifying the suitability of demolition wood is not available yet in Finland. Transition to circular economy takes time and resources to establish the necessary capacities. According to the numerous studies the use of renewable wood leads to lower carbon footprint of a building. The Act should aim at the low GWP of the building and that can be achieved by using wood. Therefore the Act should acknowledge responsible-sourced bio-based renewable materials like wood as a means to lower the climate impact of buildings as a parallel means to recycled content or re-used components.
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