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Södra Skogsägarna ekonomisk förening

Södra

Södra Skogsägarna ekonomisk förening är en ekonomisk förening som ägs av ca 53 000 skogsägare.

Lobbying Activity

Meeting with Frans Timmermans (Executive Vice-President) and Swedish Forest Industries Federation and

31 Mar 2022 · Forest policy and the EU Green Deal roundtable discussion

Meeting with Helena Braun (Cabinet of Executive Vice-President Frans Timmermans) and Swedish Forest Industries Federation

16 Apr 2021 · European Green Deal and the preparation of the EU Forest Strategy

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

8 Feb 2019

Södra Skogsägarna ek. för. Södra Cell statement regarding DTPA classification under the CLP Regulation We support the information provided by the consortium of DTPA suppliers, Dow et al. stating that there is most likely a lack of human relevance of the effects seen in rats at the estimated exposure. We would also like to point out the following practical impacts of the classification. The classification is completely void of public health benefits (none of the potential adverse effects of DTPA could materialise in reality), and could nonetheless potentially harm the environment and hamper the good current compliance with EU law. In the Nordic countries, manganese concentration in the soil is higher than in many other countries, and therefore also in the trees. Chelating agents (DTPA and EDTA) are needed in the processes to bind and remove manganese ions and other metals originating natural from the wood (naturally occurring in the soil). The purpose for us at Södra Cell to remove manganese ions is to bleach with hydrogen peroxide (as required by BAT 19 by the Commission Implementing Decision 2014/687/EU and other EU environmental law). For paper and board producers manganese ions also have to be removed to control smell and taste properties in paperboard for food packaging (as required in the Regulation (EU) No 1935/2004 article 3). DTPA and EDTA are essential in order to avoid chlorine bleaching. Since we in the European pulp industry pioneered alternatives to chlorine bleaching, the AOX emissions have dropped drastically (- 94.7% in 2017 since 1991). Paradoxically, if classified as 1B, it would no longer be permitted to use DTPA in EU Ecolabel products (and would, in most cases, be disapproved by the customers), forcing us to continue the environmentally best practice without recognition by the EU Ecolabel and facing risks in the market. Similarly, if no longer able to comply with Regulation 1935/2004 for food contact materials, the alternative packaging solution would most likely have higher environmental impacts, as is the case for many materials covered now by the Single Use Plastics Directive. DTPA (and EDTA) have been used for three decades in the pulp and paper industry for the above applications; the safe handling and protection of the environment in emissions is known and well demonstrated. Alternative chelating agents would be difficult to identify and would need to have exactly the same function of binding metal ions hence, logically, would risk being later classified in the same disproportionate way despite no demonstrated human toxicity impacts. It is therefore crucial that all known scientific facts have been considered and evaluated before any decisions of classification are made. The proposed classification would be disproportionate and would not benefit society. To consider the unintended serious environmental harm following the discontinued use of chelating agents would be counterproductive. It will affect an industry producing biobased and recyclable material contributing to the global circular economy. We therefore urge for postponing the proposed new classification of DTPA in the CLP Regulation until uncertainties are investigated and the scientific documentation has been thoroughly assessed.
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