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Stora Enso Oyj

Stora Enso

Stora Enso is a leading provider of renewable products in packaging, biomaterials, and wooden construction.

Lobbying Activity

Stora Enso urges bio-based focus for Advanced Materials Act

13 Jan 2026
Topic — This consultation addresses measures to enhance European competitiveness and strategic autonomy in advanced materials.
Message — The company recommends using public procurement to drive demand for bio-based materials and earmarking dedicated funding for alternatives to critical raw materials. They also call for harmonized permitting and legislative alignment to reduce administrative complexity.1234
Why — This would lower financial risks and speed up the commercialization of their wood-based products.56
Impact — Traditional fossil-intensive material producers would lose market dominance as bio-based alternatives gain preference.78
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Response to Land use, land use change and forestry – establishing trajectories towards 2030

12 Dec 2025

Stora Enso welcomes the opportunity to provide input regarding the establishment of LULUCF trajectories for 20262029. We strongly support the EUs climate ambitions and, as a major actor in the European forest sector, are committed to the Science Based Target initiatives (SBTi) 1.5°C pathway. As such, Stora Enso is targeting a 50% absolute reduction in Scope 13 COe emissions by 2030 and reaching net-zero by 2040. Actions supporting our achievement of these targets include sustainable forest management, improved resource and energy efficiency, and products that store carbon while substituting fossil-based materials. Our main recommendations are to: 1. Set LULUCF trajectories based on realistic potential and current forest dynamics, not only past performance; and 2. Integrate risk and sustainability considerations by introducing flexibility mechanisms. More background and detail is included in the attached PDF.
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Meeting with Elsi Katainen (Member of the European Parliament) and Finnish Forest Industries Federation (Metsäteollisuus ry) and UPM-Kymmene Oyj

25 Nov 2025 · Current issues in forestry policy and EU

Meeting with Luis Planas Herrera (Cabinet of Commissioner Jessika Roswall)

5 Nov 2025 · EU Deforestation Regulation

Meeting with Ruth Reichstein (Cabinet of President Ursula von der Leyen)

3 Nov 2025 · attached

Meeting with Ruth Reichstein (Cabinet of President Ursula von der Leyen)

3 Nov 2025 · The EU Deforestation Regulation, Circular Economy Act, Industrial Accelerator Act, BioeconomY

Stora Enso urges EU fund for bio-based innovation scale-up

3 Oct 2025
Topic — EU framework to strengthen innovation ecosystem and support innovative company growth.
Message — The company requests a dedicated public fund for first-of-a-kind bio-based products, harmonised EU recyclability rules, and simplified cross-border licensing. They argue current fragmentation and long development timelines prevent breakthrough technologies from scaling commercially.123
Why — This would accelerate deployment of technologies like Emission-Free Pulping and attract private investment for their 10-15 year development cycles.45
Impact — Fossil-based materials producers would face increased competition from accelerated bio-based alternatives.6
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Meeting with Jessika Roswall (Commissioner) and

3 Oct 2025 · The bioeconomy and forest data

Meeting with Matthieu Moulonguet (Cabinet of Commissioner Wopke Hoekstra)

4 Sept 2025 · LULUCF and carbon removals and carbon farming certification framework

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

3 Sept 2025 · Discussion about circularity and trade matters.

Stora Enso Urges Flexible Voluntary EU Nature Credits

9 Jul 2025
Topic — The Commission is developing a voluntary framework for nature credits to restore biodiversity.
Message — The framework must support both biodiversity and bioeconomy goals without imposing restrictive management methods. Stora Enso requests a flexible, outcome-focused methodology that accommodates local specificities. They strongly argue that credits should reward positive actions rather than being used for offsetting damage.12
Why — This framework provides new funding while protecting the supply of renewable wood materials.3
Impact — Polluting industries would be prevented from using nature credits to compensate for environmental degradation.4
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Stora Enso Demands EU Back Wood Solutions Over Fossil Materials

4 Jul 2025
Topic — The EU is consulting on accelerating industrial decarbonization and competitiveness.
Message — The company wants carbon labels to reflect the carbon stored in wood products through improved life-cycle assessments. They also propose mandatory targets for renewable materials in public building projects.123
Why — These changes would improve the market competitiveness of wood products against cheaper fossil-based alternatives.4
Impact — Energy producers and heavy industries like steel would face reduced subsidies and tougher competition.56
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Stora Enso advocates including waste incineration in EU carbon market

4 Jul 2025
Topic — A review of the EU carbon market rules for various industrial sectors.
Message — Stora Enso calls for the "full and mandatory inclusion of municipal waste incineration" to ensure a "level playing field." They argue negative emissions should be handled via the "Effort Sharing Regulation" to avoid "mitigation deterrence." Finally, they request "free allocation proportionate to the exports" for pulp and paper.123
Why — This strategy protects their market share and reduces the cost of exports.45
Impact — Waste incineration facilities would face new financial burdens from mandatory carbon pricing.6
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Stora Enso Urges EU to Prioritise Bio-Based Products and Funding

23 Jun 2025
Topic — The EU is developing a strategy for a circular and competitive bioeconomy.
Message — Stora Enso requests dedicated public funding and prioritisation of bio-based materials. They urge the EU to leverage existing rules instead of adding new burdens.123
Why — These measures would secure investments and increase demand for renewable wood products.4
Impact — Bioenergy producers would lose financial support for burning wood to generate electricity.5
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Meeting with Wopke Hoekstra (Commissioner) and

12 Jun 2025 · Roundtable meeting on forestry value chain and bioeconomy aspects

Meeting with Raffaele Fitto (Executive Vice-President) and Swedish Forest Industries Federation and

22 May 2025 · Round table discussion concerning bio economy and its implications on regional policy

Meeting with Aurel Ciobanu-Dordea (Director Environment) and FoodDrinkEurope and

22 May 2025 · Discuss with interested stakeholders the practical aspects and challenges of ensuring compliance with Art.5(5) of the PPWR (concerning PFAS limits in food-contact packaging)

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 Luis Planas Herrera (Cabinet of Commissioner Jessika Roswall), Paulina Dejmek Hack (Cabinet of Commissioner Jessika Roswall)

26 Mar 2025 · Circularity, bio economy

Response to EU Start-up and Scale-up Strategy

16 Mar 2025

Stora Enso is a renewable materials company that employs more than 15 000 people in the EU. We deliver renewable and circular products that store carbon and provide low-emission alternatives to non-renewable materials and are one of the worlds largest private forest owners. We also have our own in-house innovation activities and have invested in start-ups such as TreeToTextile and CarbonScape that are part way through their scale-up journeys. Please find below a brief response to the questions raised in the Call for Evidence. Do you agree that startups and/or scaleups face the hurdles identified in this document ? We do not see any major issues relating to research and technology infrastructure or IP, knowledge, and services. However, we do consider access to finance a key hurdle, and believe this is most likely a consequence of the other listed barriers (regulatory/fragmentation issues, market access and access to talent). Are there any additional hurdles faced by startups and/or scaleups? No additions to the list. What actions do you think the EU should take to address these hurdles? Access to finance: Developing new materials and growing to any substantial size of business takes a long time (10-15 years) and requires heavy capital investments from start-up to scale-up, which does not typically suit VC exit timelines of 3-10 years. While access to finance is not impossible in the EU, it would be significantly easier if the Capital Markets Union were fully realised. Completing the Capital Markets Union to create a genuine single capital market in the EU would increase the options for scale-ups and reduce the risk that they feel the need to look to other markets. It is often stated that the US outperforms the EU on scale-ups, particularly in finance. Although US states may have varying rules on labour and taxes, possibly even more so than within the EU, access to finance remains unrestricted across state borders. Make it easier to establish and operate a business across the EU. For example, a licence to operate in one Member State (MS) should be a licence to operate in any MS. The Commission could consider a Societas Europea 2.0 model, which would allow a start-up in one MS, as long as it fulfils all legal requirements in that MS, to operate in any or all other MS. We note that the Letta report 1 proposes a European Code of Business Law that could provide a 28th regime to aid Europeanisation. The same section in the Letta report also points to the need for simplification of administrative procedures. Harmonisation is paramount. For example, we are developing an innovative new material, Papira, which is a foam made of wood fiber and technically completely recyclable in the paper stream. Papira is plastic-free and can replace plastic foams and fillings when protecting products in transport. Pending adoption of harmonised Design for Recycling criteria and material identification labelling, it has to be tested locally in each MS, and could be rejected if a recycler were to deem it non-recyclable. This may be a challenge for a large business, but it would be a more insurmountable hurdle for a start-up/scale-up. Harmonisation governing the placing on the market of products should provide the enabling conditions for new, innovative products and solutions to be viable. We note the European Commissions Omnibus proposals on simplification and support a particular focus on SMEs. Facilitate start-ups/scale-ups to build consortia: Public procurement is a good way to enter a new market. However, tendering requires resources and stability, which is often hard for early-stage companies, as also flagged in the Letta report. The Commission should consider creating simplified new and/or enhancing existing tools to support the building of consortia, similar to those used for EU research programmes. Any measures or guidance that can increase the opportunities for scale-ups and SMEs to participate would be welcome.
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Meeting with Katri Kulmuni (Member of the European Parliament)

7 Mar 2025 · Ajankohtiaset ja tulevat metsäasiat

Meeting with Emma Wiesner (Member of the European Parliament)

6 Mar 2025 · Di Energiintensiv industri 2025

Meeting with Aura Salla (Member of the European Parliament) and UPM-Kymmene Oyj

5 Feb 2025 · forest industry, EU, bioeconomy

Meeting with Katri Kulmuni (Member of the European Parliament) and Finnish Forest Industries Federation (Metsäteollisuus ry)

4 Feb 2025 · Ajankohtaiset metsäasiat

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

21 Nov 2024 · EU Waldmonitoringrahmen

Meeting with Katri Kulmuni (Member of the European Parliament)

5 Nov 2024 · Forest monitoring

Meeting with Elsi Katainen (Member of the European Parliament)

16 Oct 2024 · Metsäpolitiikka

Meeting with Beatrice Timgren (Member of the European Parliament)

16 Oct 2024 · EU Forrest Policy

Stora Enso urges EU to recognize broader forest product storage

11 Jul 2024
Topic — Evaluation of the LULUCF Regulation to improve future climate policy for land use.
Message — Stora Enso argues forests should not offset emissions from other sectors. They request including more wood-based products and biogenic carbon capture in accounting.12
Why — These changes would help the company market its wood-based innovations and avoid harvesting restrictions.3
Impact — The agricultural sector would lose the ability to use forest sinks to mask emissions.4
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Meeting with Taru Haapaniemi (Cabinet of Commissioner Janusz Wojciechowski)

23 May 2024 · Forest-based Bioeconomy Dialogue

Meeting with Maroš Šefčovič (Executive Vice-President) and European farmers and

14 Mar 2024 · High level dialogue on forest-based bioeconomy

Stora Enso urges EU to reward wooden wind towers

1 Mar 2024
Topic — European Commission initiative regarding design elements for renewable energy auction criteria.
Message — The company wants auction criteria to prioritize life cycle carbon analysis for projects. They advocate for using wooden materials to lower the carbon footprint of turbines.12
Why — These criteria would favor Stora Enso's position as a supplier of renewable wood.3
Impact — Traditional steel suppliers face increased competition from bio-based alternatives in the wind sector.4
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Meeting with Petri Sarvamaa (Member of the European Parliament)

12 Feb 2024 · Current Topics in Agriculture

Meeting with Nils Torvalds (Member of the European Parliament)

7 Feb 2024 · PPWR

Stora Enso Urges Ground-Based Verification for EU Forest Monitoring

5 Feb 2024
Topic — The EU is establishing a framework for regular, open-access monitoring of forest conditions.
Message — Stora Enso wants satellite data cross-checked with ground observations to ensure accuracy. They recommend aligning terminology with existing inventories and adding forest regeneration indicators.12
Why — Accurate data prevents sustainable timber harvests from being wrongly interpreted as forest damage.3
Impact — Forest owners risk unfair scrutiny if uncalibrated satellite readings provide inaccurate information.4
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Response to Revision of the plant and forest reproductive material legislation

6 Dec 2023

Stora Enso welcomes the proposal for a Regulation on the production and marketing of forest reproductive material (FRM), and its intention to harmonise rules on how FRM is approved, certified, and labelled. However, we do see room for improvement in some parts of the proposed text and would like to make the following recommendations for legislators consideration: 1. The proposed definition of 'forest reproductive material' in Article 3 is incomplete, as it omits two important categories of FRM - parts of plants and planting stock - currently classified as FRM by the Council Directive 1999/105/EC. This oversight, if left uncorrected, would exclude those two categories of FRM from the scope of the new regulation. The definition should therefore be re-aligned with the definition set forth in the Council Directive 1999/105/EC. 2. The proposed legal requirement in Article 10 to predict future climatic and ecological conditions places an unrealistic burden on professional operators, especially considering that they often lack precise information about the specific location where their FRM will ultimately be used. Instead of being asked to predict the future, professional operators should be requested to refer the users to relevant available information concerning the FRMs overall suitability for climatic and ecological conditions through websites containing existing knowledge and data, as developed by researchers and national authorities. 3. Article 16 mandates competent national authorities to inspect and issue an official label for every individual lot of FRM, putting an undue administrative and logistical burden on Member States. Allowing Member States to authorise, under supervision, professional operators to issue and print the official label would ensure a more balanced approach, in line with the current rules under the Council Directive 1999/105/EC. Additionally, we recommend that the official label contains a QR code, through which professional operators can provide users with easy access to instructions on how to take care of, store, and plant the FRM. 4. The use of bio-molecular techniques should be permitted as a complementary method in the procedure for the approval of basic material, in line with latest scientific evidence. Relying solely on observation or prolonged experimentation for the approval of basic material can prove excessively resource-intensive and time-consuming. Modern predictive methods, such as genomic selection, allow for reliable, precise, and efficient evaluation of basic material and can therefore expedite the evaluation process. Stora Enso is a renewable materials company that employs around 15 000 people in the EU. We are also one of the biggest forest owners in the world and we provide comprehensive sustainable forest management services to private forest owners. We use, produce, and sell forest reproductive material to ensure forest regeneration.
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Meeting with Helena Braun (Cabinet of Vice-President Maroš Šefčovič)

27 Nov 2023 · Implementation of the EU Forest Strategy for 2030

Meeting with Nils Torvalds (Member of the European Parliament)

27 Nov 2023 · Deforestation Regultion

Meeting with Irène Tolleret (Member of the European Parliament)

20 Nov 2023 · Gestion des forets

Meeting with Ruth Reichstein (Cabinet of President Ursula von der Leyen)

16 Nov 2023 · Climate and environmental policy/NEB

Meeting with Andreas Glück (Member of the European Parliament)

9 Nov 2023 · Packaging and Packaging Waste Regulation

Meeting with Jorge Pinto Antunes (Cabinet of Commissioner Janusz Wojciechowski)

26 Oct 2023 · Regards to the European Commission’s forthcoming proposal on the Forest Monitoring Law

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

25 Oct 2023 · Soil health and Forests

Stora Enso urges flexible monitoring for EU forest soils

18 Oct 2023
Topic — This consultation establishes a new EU framework for monitoring and restoring soil health.
Message — Stora Enso asks for site-specific soil management based on scientific evidence and local assessments. They request flexible measurement cycles and existing national tools to minimize administrative costs. The company urges involving landowners and managers in the development of soil legislation.123
Why — Using existing national tools and flexible cycles would reduce the company's compliance costs.4
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Meeting with Nils Torvalds (Member of the European Parliament)

18 Oct 2023 · NGT & SML

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

28 Sept 2023 · Soil Health Law

Meeting with Heléne Fritzon (Member of the European Parliament) and The European Organisation for Packaging and the Environment

13 Sept 2023 · Möte med Stora Enso och Europen (APA level)

Meeting with César Luena (Member of the European Parliament) and The European Organisation for Packaging and the Environment

12 Sept 2023 · PPWR

Stora Enso Urges Separate Rules for Biogenic Carbon Removals

31 Aug 2023
Topic — This consultation evaluates the role of carbon management technologies in decarbonizing the EU economy by 2050.
Message — The company demands that the regulatory framework ensure biogenic carbon is clearly differentiated from fossil carbon. They argue biogenic emissions should be accounted for in the LULUCF regulation rather than the EU ETS. Additionally, they state that industrial removals should not inadvertently incentivize more fossil power or bioenergy production.123
Why — The company would be able to monetize carbon stored in its wood products through a regulated removals market.4
Impact — Bioenergy-only operators would lose out as the company advocates for prioritizing material production over energy use.5
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Meeting with Miapetra Kumpula-Natri (Member of the European Parliament)

23 May 2023 · Meeting on Critical Raw Materials Act

Meeting with Tiemo Wölken (Member of the European Parliament, Shadow rapporteur)

16 May 2023 · Carbon Storage in long-living products (Staff level)

Meeting with Mohammed Chahim (Member of the European Parliament, Shadow rapporteur)

9 May 2023 · CRMA

Meeting with Cornelia Ernst (Member of the European Parliament, Shadow rapporteur)

5 May 2023 · CRMA - substitution of graphit

Stora Enso Urges Realistic Wood Recycling Targets in EU Taxonomy

3 May 2023
Topic — The Commission is defining sustainable investment criteria for circular economy and biodiversity objectives.
Message — The company requests lowering recycled content thresholds for wood buildings and clarifying material definitions. They also urge the Commission to recognize existing environmental restoration efforts.123
Why — Lowering thresholds would enable Stora Enso’s primary wood products to be classified as sustainable.45
Impact — Environmental advocates may see these lower thresholds as weakening high circular economy goals.6
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Stora Enso urges renewable materials shift in EU packaging rules

20 Apr 2023
Topic — EU regulation on packaging waste reduction, recycling requirements, and reuse obligations.
Message — The company requests that the regulation promote circular renewable materials over fossil-based alternatives, establish 90% mandatory separate waste collection targets, and maintain exemptions for cardboard transport packaging from reuse obligations. They argue current provisions may inadvertently shift markets toward less sustainable plastic or energy-intensive materials.123
Why — This would protect their fiber-based packaging business from displacement by plastic alternatives.45
Impact — Reusable plastic packaging manufacturers lose market share in transport and grouped packaging segments.6
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Meeting with César Luena (Member of the European Parliament)

30 Mar 2023 · MEP Luena's Team on Packaging and Packaging Waste Regulation

Stora Enso Urges Separate EU Certification for Biogenic Carbon

20 Mar 2023
Topic — EU regulatory framework for certifying and monitoring sustainable carbon removal solutions.
Message — Differentiate between fossil and biogenic removals to prevent carbon storage from masking high emissions. Include biogenic removals in the land-use framework and ensure additionality rules are workable.1234
Why — This validates their wood products as carbon sinks and incentivizes their industrial carbon capture investments.567
Impact — Fossil fuel companies lose the ability to obscure emissions by combining them with biogenic accounting.8
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Meeting with Mauri Pekkarinen (Member of the European Parliament)

14 Mar 2023 · Meeting on PPWR

Meeting with Salvatore De Meo (Member of the European Parliament, Rapporteur) and The European Organisation for Packaging and the Environment and European Fruit Juice Association

14 Mar 2023 · PPWR

Meeting with Valdis Dombrovskis (Executive Vice-President) and BUSINESSEUROPE and

16 Feb 2023 · Critical Raw Materials package

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

3 Feb 2023 · Bioeconomy, urban wastewater, packaging&packaging waste

Meeting with Petri Sarvamaa (Member of the European Parliament) and Finnish Forest Industries Federation (Metsäteollisuus ry)

24 Jan 2023 · Topical issues in EU politics

Meeting with Nils Torvalds (Member of the European Parliament, Shadow rapporteur for opinion) and Finnish Forest Industries Federation (Metsäteollisuus ry) and

12 Jan 2023 · Packaging and packagingwaste

Response to European Critical Raw Materials Act

22 Nov 2022

Stora Enso is a renewable materials company that employs more than 18 000 people in the EU. We deliver renewable and circular products that store carbon and provide low-carbon alternatives to non-renewable materials. We are one of the largest private forest owners in the world and are working to replace fossil-based materials with sustainable, renewable alternatives based on wood. We fully agree that to achieve the green transition, the EU must significantly increase and diversify its critical raw materials supply, strengthen circularity, and support research and innovation. To achieve these objectives, it is worth noting that such materials are not only available through extractive industries, as new, renewable alternatives are emerging. In this context, Stora Enso believes that the Critical Raw Materials Act must strengthen and support European renewable raw materials and solutions that can replace fossil materials imported from outside Europe. This would help to boost Europes strategic autonomy and resilience, in line with the Green Deals objectives. We note that the Call for Evidence refers to a parallel objective focusing on the substitution of critical raw materials. This is welcome, but we would recommend going further by adding a fifth pillar to the regulatory dimension outlined in the Call for Evidence. Stora Enso recommends that the European Commission therefore also focus on: 1. projects and solutions where renewable material can replace fossil material to help speed up the European green transition; and 2. scaling up solutions where European raw materials can replace materials sourced outside Europe to shore up European self-sufficiency and resilience. The definition of critical raw materials is tied to their high economic importance and the high risks linked to their supply. The new EU policy framework for critical raw materials should, therefore, consider the significance of emerging alternatives to critical raw materials with sufficient supply and production capacity in the EU. Please see further detail in the attached PDF.
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Meeting with Elena Montani (Cabinet of Commissioner Virginijus Sinkevičius), Rozalina Petrova (Cabinet of Commissioner Virginijus Sinkevičius)

10 Nov 2022 · Implementation of EU Forest Strategy for 2030, proposal for Nature Restoration Law and revision of EU packaging rules

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

10 Nov 2022 · Implementation of EU Forest Strategy for 2030, proposal for Nature Restoration Law and revision of EU packaging rules

Meeting with Mauri Pekkarinen (Member of the European Parliament) and Finnish Forest Industries Federation (Metsäteollisuus ry)

9 Nov 2022 · Current EU Forestry Affairs

Meeting with Pär Holmgren (Member of the European Parliament)

9 Nov 2022 · Stora Enso roundtable on how best to minimise trade-offs and maximise synergies in the EU bioeconomy

Meeting with Nils Torvalds (Member of the European Parliament)

2 Nov 2022 · Forestry, packaging industry

Meeting with Jorge Pinto Antunes (Cabinet of Commissioner Janusz Wojciechowski)

7 Oct 2022 · How we can best ensure ways forward that will mitigate climate change through responsible and sustainable business operations and product innovations. To discuss the upcoming proposals for the revision of the Packaging and Packaging Waste Directive

Stora Enso urges flexible national plans for nature restoration

19 Aug 2022
Topic — New EU legislation setting legally binding targets to restore degraded ecosystems across Member States.
Message — The company requests that restoration plans remain tailor-made to Member States to reflect diverse ecosystems. They argue economic activities, including wood supply, must continue within restored areas. They also propose extending the three-year monitoring cycle for slow-growing Nordic forests.123
Why — Flexible rules would protect the company's wood supply and prevent operational restrictions on commercial forests.4
Impact — Conservationists lose if commercial logging is permitted to continue within areas targeted for ecological restoration.5
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Response to Review of the Construction Products Regulation

8 Jul 2022

Please, find attached Stora Enso's full feedback to the 'Construction products – review of EU rules'. Stora Enso is a renewable materials company that employs more than 18 000 people in the EU. We deliver renewable and circular products that store carbon and provide low-carbon emission alternatives to non-renewable materials. We are one of the largest private forest owners in the world and manage our forests sustainably, ensuring that we always grow more trees than we harvest while also safeguarding biodiversity. Our key Policy asks are the following: 1. Recognise the climate benefits of locking and storing carbon into construction products. 2. Prioritise renewable materials alongside recyclable materials and recycled content. 3. Enable the development and use of innovative and sustainable products. 4. Ensure that any traffic-light labeling system does not minimize the important role of environmental product declarations (EPD).
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Meeting with Frans Timmermans (Executive Vice-President) and Neste Oyj and

9 Jun 2022 · climate leadership from businesses

Stora Enso Urges Harmonised EU-Wide Forest Monitoring and Data

6 May 2022
Topic — The EU is developing a framework for forest observation and planning.
Message — Stora Enso advocates for user-friendly interfaces that connect forest observation data into one system. They recommend combining satellite imagery with ground-based measures and laser scanning for better accuracy. The framework should monitor forest regeneration and biodiversity indicators tailored to local regions.123
Why — Harmonised data would lower the administrative effort required to manage their global forest holdings.45
Impact — Small private forest owners may struggle to meet reporting requirements due to limited resources.6
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Meeting with Jytte Guteland (Member of the European Parliament)

20 Apr 2022 · Deforestation

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 Nils Torvalds (Member of the European Parliament, Rapporteur) and EuroNatur - Stiftung Europäisches Naturerbe

31 Mar 2022 · RED III

Meeting with Frans Timmermans (Executive Vice-President)

31 Mar 2022 · Site visit to a project using wood-based materials in batteries

Meeting with Petri Sarvamaa (Member of the European Parliament)

30 Mar 2022 · Forestry & Deforestation

Response to Soil Health Law – protecting, sustainably managing and restoring EU soils

16 Mar 2022

Stora Enso welcomes the opportunity to provide feedback on the impact assessment of the upcoming EU directive on soil health. We welcome that the European Commission will carefully investigate the possible provisions of the soil health law, the alternative policy options, and associated impacts to tackle soil degradation in the EU against a ‘business as usual baseline. As particular attention will be given to subsidiarity, proportionality, flexibility, operational feasibility, legislative simplicity, and the administrative costs of implementation, we would like to provide the Commission with science-based information about the role of soils in the northern boreal forest, compared to soils in other ecosystems. Also, we would like to address the challenges with soil-based models for products’ environmental footprint. Healthy and fertile soils in forests are the foundation for all our operations and contribute to the crucially important objectives of the EU Green Deal. It would be essential that the upcoming policy initiative would build on the existing policy initiatives, as well as on soil variability and different environmental and climate conditions. Forests vary across the EU due to differences in geography, soil conditions, climate, and the history of land use for each landscape. One-size-fits-all soil management practices would lead to negative side effects, as what is beneficial in one place, can be detrimental in others. Policies prescribing how to manage soils and which practices to use or not, instead of stating the desired result, will therefore yield unintended and negative consequences. A well-functioning and meaningful forest health policy initiative is essential for mitigating climate change. We would recommend that the upcoming policy initiative: • Recognizes that land-use intensity occurs in a gradient from intensive agriculture to extensive forestry. The granularity along this gradient is very high due to local variations in soils’ qualities and locally adapted practices. Hence, it is not possible to generalise how to manage soils in a one-size fits all manner. • Considers how national and regional land-use practices affect soils locally. • Addresses the recognized issues in each region. • Considers that a regionalised approach to nitrogen fertilization exists. While nitrogen addition to managed ecosystems in Central Europe may cause eutrophication and nitrogen leaching from soils, due to the long history of atmospheric nitrogen deposition over the mid-European continent, nitrogen fertilization in northern forest alleviates progressive nitrogen limitation due to the rising CO2 concentrations in the atmosphere and will not at all lead to eutrophication and nitrogen leaching. • Incentivise forest peatland restoration in a local context, i.e. the final decision on when and where to restore drained and forested peatlands, must remain within member states. Our above-mentioned recommendations are drawn from our science-based analysis, presented in the attachment. Our document answers the questions below: • Why do the northern forest soils store big amounts of carbon? • How do the boreal forests differ from the forests in the south? • What does science tell us about carbon losses from soils caused by harvesting? • What is the role of nitrogen in carbon accumulation in boreal forests? • How does climate change impact the nitrogen supply of soils? • What is the impact of harvesting on carbon stock in soils? • What is the impact of forest management on soils? • How do management and restoration of peatlands improve forest landscapes? • What are the challenges when addressing soils in boreal forests in the current frameworks for products’ environmental footprint? Should you have any questions, please do not hesitate to contact us at: meri.siljama@storaenso.com
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Response to Waste Framework review to reduce waste and the environmental impact of waste management

22 Feb 2022

Stora Enso is a renewable materials company and one of the largest private forest owners in the world, employing 18 000 people in the EU. We deliver renewable and recyclable products that store carbon and provide low-carbon alternatives to fossil-based materials. Stora Enso believes that we should aim for more than a circular economy: we should aim for a circular bioeconomy, where waste and fossil-based products are reduced to a minimum, and renewable materials are used efficiently. We support the European Commission’s ambition to reinforce the waste hierarchy in the Waste Framework Directive (WFD) focusing on waste prevention, reuse, and recycling. We appreciate that the Commission wants to combine waste reduction measures with waste prevention measures, including improved separate collection requirements to further improve the quality of recycling. We also welcome the focus on residual waste, i.e., waste that is not currently recycled. We would raise the following points for consideration in relation to the policy options and evidence for the WFD revision: 1) Avoid a one-size-fits-all approach: different waste streams require different waste management practices 2) Effective separate waste collection and labelling in the EU is key to improving waste management 3) Support for prefabricated and other approaches that prevent construction waste 4) Streamline waste prevention across a wider variety of policy tools Please see the attached PDF for more detail.
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Meeting with Nils Torvalds (Member of the European Parliament)

8 Feb 2022 · Deforestation regulation

Response to Measures to reduce microplastic pollution

17 Dec 2021

Stora Enso is a renewable materials company that employs 18 000 people in the EU. We deliver renewable and recyclable products that store carbon and provide low-carbon alternatives to fossil-based materials. The fact that our material comes from sustainably managed forests and grows back is at the heart of our sustainability strategy, which has set a target of 100% regenerative solutions by 2050. We are one of the largest private forest owners in the world and always grow more than we harvest, while also safeguarding biodiversity. Stora Enso fully supports the aims of the European Green Deal and Circular Economy Action Plan (CEAP), including efforts to tackle the challenge of microplastics in the environment. The Call for Evidence focuses on three potential sources of microplastics, including synthetic textiles. We advocate for a shift towards a circular textile industry, using bio-based textile fibers with a low environmental footprint, and emerging technology that ensures reduced use of energy, chemicals, and water during the production process compared to conventional fibers. As well as improving the overall climate impact, such a shift would also reduce the potential for unintentional release of microplastics. Since 2018, Stora Enso has been a shareholder of the joint venture “TreeToTextile AB” alongside H&M Group, Inter IKEA Group, and innovator Lars Stigsson. Our aim is to significantly reduce the environmental footprint of the textile industry and to make sustainable textile fibers available to all. Cellulosic and regenerated cellulosic fibers are not synthetic textiles. As such, a clear definition relating to synthetic fibers is needed to avoid uncertainty, and to promote more environmentally friendly textile alternatives. Any future legislation needs to clearly define what is in scope. Given that this initiative relates to the unintentional release of microplastics, we recommend a similar approach to the Single-Use Plastics Directive (SUPD), which considers that unmodified natural polymers are not defined as plastic. The Commission’s consultants, BioInnovation Service, have previously referred to a study by Zhang et al. on “Emission and reduction measures of microplastics from textile origin” (2021). The report concludes that “particles shed from synthetic textiles made of e.g., PES, PA, PLA and cellulose acetate can be considered MPs, while particles shed from cellulosic and regenerated cellulosic textiles cannot.” Stora Enso supports this definition. In any case, whatever definition is used, it should allow for innovation, as new fibers are constantly being developed that can help to meet the drive for a greener and more circular economy. We support the principle of Better Regulation and encourage consistency with existing legislation, such as the SUPD as mentioned above, and when developing relevant future initiatives. Please see the attached PDF, which contains further references and hyperlinks to the studies we have cited. We would be happy to answer any questions / provide further detail on any of the points raised.
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Response to Land use, land use change and forestry – review of EU rules

5 Nov 2021

Stora Enso supports the EU’s climate ambitions enshrined in the European Climate Law and the corresponding 55% emissions reductions target. Forests and the European forest industry play a key role in mitigating climate change. Our contribution can be divided into three main areas: CO2 sequestration in growing forests, carbon storage in wood-based products, and substitution of fossil-based raw materials with forest-based products. The Commission’s proposal for a revised LULUCF delivers on some of these aspects, while it falls short on others. It is essential that increased carbon removals in the forestry sector are not used as an excuse for continued high levels of emissions in other sectors. European forests should not carry the burden of high emitting sectors. The current proposal lacks sufficient safeguards against this. Stora Enso is specifically concerned about the proposed integration of emissions from the agriculture sector into the LULUCF sector from 2030 onwards. There is an imminent risk that the increased contribution of the LULUCF sector to the EU’s long-term climate neutrality target will be cancelled out or hampered by a lack of emissions reductions in the agriculture sector. Stora Enso welcomes the Commission’s proposal to add the category “carbon storage products” in addition to the “harvested wood products”. This widens the scope of products that can, rightfully, be considered to store carbon. With today’s terminology, LULUCF does not fully consider the carbon stored in all types of products. Stora Enso thus looks forward to the adoption of delegated acts widening the scope for products. We urge the Commission to not omit any suitable carbon storage products. We therefore propose that the legislative text specifies that the new carbon storage products category include all products from “pulping including by-products and residues”. This will ensure the transparency of real climate impacts of products and allow for new, innovative products to be included. Examples of such products include that it is now possible to replace graphite in anodes for lithium-ion batteries with lignin, which is a pulping residue. Biogenic emissions and renewable products are expected to continue to in the EU beyond 2050. We therefore propose that BECCS is included in LULUCF (whilst fossil carbon capture storage (CCS) should remain the EU ETS). Including BECCS in the LULUCF is logical, as biogenic emissions come from renewables and land covered in scope of the LULUCF. Using the same accounting system and regulation for all biogenic storage products, emissions and possible carbon removals from this sector will avoid double-counting in other regulations and systems. We believe the EU needs stronger policies for BECCS. Academics and modelers agree that, without deploying technology-based carbon removals, it is unlikely that we will be able to reach the goals of the Paris Agreement. We recommend focusing on promoting BECCS, thus creating a new category alongside harvested wood products and carbon storage products. The net carbon removal target of 310 million tonnes of CO2 equivalent by 2030 does not come with an impact assessment. As the methodology behind this target is unknown, it is difficult to know if the target is science-based. It is, however, clear that the land sector carbon sink is prone to natural fluctuation outside human control, as well as uncertainties in exact measurements of carbon flows. It is therefore important that member states continuously aim to improve methodologies for measuring carbon flows and that these improvements are reflected in the assessment of target fulfillment. It is not uncommon that member states update their carbon removals assessment with new figures that differ significantly from previous reporting. As an exact target will be arbitrary, we propose that a target range is specified. For further information, please find enclosed our position paper on the topic.
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Response to Policy framework on biobased, biodegradable and compostable plastics

27 Oct 2021

Stora Enso is a renewable materials company that employs 18 000 people in the EU. We deliver renewable and recyclable products that store carbon and provide low-carbon alternatives to fossil-based materials. The fact that our materials grow back is at the heart of our sustainability strategy, which has set a target of 100% regenerative solutions by 2050. We are one of the largest private forest owners in the world and manage our forests sustainably, ensuring that we always grow more than we harvest, while also safeguarding biodiversity. Stora Enso fully supports the aims of the European Green Deal and the Circular Economy Action Plan (CEAP), both central policy tools to help achieve the EU’s climate ambitions. It is therefore natural that we also support efforts to improve knowledge about, and regulation of, bio-based (BBP), biodegradable and compostable plastics (BDCP). These materials, such as PLA, can be used in certain fiber-based products where a small amount of plastic is needed, and where biodegradable or compostable properties are also desirable. We believe such materials can contribute to the transition away from fossil-based plastics and towards improved circularity. It is nevertheless important to carefully consider for what purpose they are designed and to ensure the right materials are used for the right end use. Our main points of feedback / recommendations for the European Commission are as below, and more detail is available in our full response (attached). • Ensure the policy framework reflects different conditions across the EU, such as climate, geography, and availability of biowaste collection and processing. • Build on existing carbon dating technology for measuring BBP, in order to state bio-based content percentage. • Ensure a clear distinction between biodegradation and composting, with criteria focused on the whole life cycle. • Update EN 13432 so that it is as clear and unambiguous as possible. • Pursue harmonised labelling, which clearly includes the conditions under which materials will biodegrade or compost, whilst also developing and harmonising biowaste collection facilities across the EU. • Raise awareness of consumers across the Union on the importance of collection. No product attribute makes disposal in nature a viable end-of-life. • Consider how upstream products could be considered as “enablers” of downstream biodegradability or compostability. • Ensure that the Impact Assessment for this initiative takes account of its potential impact on other bio-based, biodegradable, and compostable materials.
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Response to Restoring sustainable carbon cycles

7 Oct 2021

Stora Enso is a renewable materials company that employs over 18 000 people in the EU. We deliver products that store carbon and provide low-carbon alternatives to non-renewable products. We are one of the biggest private forest owners in the world and source much of our wood from other, smaller-scale private forest owners. We sustainably manage all the forests we own by ensuring that we never harvest more than we grow, while safeguarding biodiversity. Of the forests we own or manage, 98% are certified according to FSC and/or PEFC certification schemes. The forest industry plays a key role in the green transition and tackling climate change. Stora Enso supports the EU’s Biodiversity Strategy, as well as the Commission’s targets of reaching a 55% emissions reduction by 2030, and net zero by 2050. As a significant forest owner and purchaser, we have a great responsibility to contribute to these ambitions. We want to be a constructive partner to the Commission in the pursuit of the Green Deal’s vision. We welcome this timely initiative and, with our extensive expertise in the area, would like to put forward some recommendations for consideration when developing plans for Restoring sustainable carbon cycles. In summary, we recommend that the European Commission should: 1. Use EU funding to accelerate deployment of Bioenergy with carbon capture and storage (BECCS). Simply linking incentives for this to the EU’s ETS will not raise prices quickly enough to have meaningful impact in the timeframe needed. 2. Incentivise Europe’s Forest owners and managers to sustainably increase forest growth, in order to ensure vitality of forests and their key role in sustainable carbon cycles. 3. Ensure safeguards are put in place, so that increased carbon removals in the forestry sector are not used to compensate for continued high levels of fossil-based emissions in other sectors. 4. Increase and speed up the substitution of fossil-based products with renewable ones. When doing so, it should be acknowledged that a range of renewable products are needed to substitute fossil-based ones, whilst ensuring that all material is used efficiently and that the right type of material is used for the right type of product. 5. Focus incentives on ensuring the forest industry continues to innovate and deliver materials that will accelerate and add value to the green transition. To achieve net zero by 2050, a multi-faceted approach will be needed, including through carbon removals and storage. Forest owners and the forest industries can play an important role, by helping to achieve the balance between carbon sequestration, sustainable use of the forests’ resources to substitute for fossil-based products, and carbon storage in products We see a strong need to successfully expedite BECCS’ deployment. In addition, forests' climate effects are based on healthy and well-growing trees and the fact that harvested wood is allocated to products with the best possible substitution effects. By promoting forest growth, and incentivising innovation, there is an opportunity to achieve increased carbon removal, whilst ensuring that the forest industry can innovate and deliver the materials that will bring more benefits in the green transition. This could include, for example, continuous efforts to find new and higher value uses for forest-based products. Yet, it should also be acknowledged that, in the forest industrial process, the whole tree should be used, and that different materials will be used for different products. All these products are needed to substitute fossil-based ones in the green transition. Finally, policy coherence should be ensured to avoid any risks of double accounting of emissions and removals, and to prevent inconsistences between different frameworks and commonly used tools. More detail is in our position paper (attached). We remain at the Commission's disposal to provide further input and expertise as this initiative is taken forward.
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Response to Revision of EU legislation on registration, evaluation, authorisation and restriction of chemicals

1 Jun 2021

Stora Enso is a renewable materials company that employs over 18 000 people in the EU. With our renewable, recyclable raw material, wood, we operate at the heart of the circular bioeconomy. We deliver products that store carbon and provide low-carbon alternatives to non-renewable products. Stora Enso’s obligations under REACH are both as a manufacturer of articles and substances and as a downstream user. Stora Enso fully supports the ambition of the EU’s Chemicals Strategy for Sustainability to better protect citizens and the environment, while boosting innovation in safe and sustainable chemicals. Regarding the REACH Inception Impact Assessment, Stora Enso would appreciate the consideration of the following points: 1. Revision of the registration requirements We welcome the Commission’s efforts to fill current knowledge gaps and improve hazard assessment. However, clarifications are needed as to how environmental footprint data will be included. We do not support the incorporation of mandatory overall environmental footprint reporting within REACH. There is, as yet, no agreed standard for footprint calculations that would encompass all chemicals concerned under REACH in an unambiguous and equally accessible way to producers. In this respect, any information requirements on environmental footprint under REACH should avoid duplication of other EU initiatives under development, such as under the sustainable product policy initiative. We also want to stress that new data requirements should be clear and well justified. The generation of analytical data, testing and dossier constitution are costly processes and must add value. In addition, the revision of registration requirements should be regarded as an opportunity to support and accelerate acceptance of alternative non-animal testing methods. 2. Simplifying communication in the supply chains We agree that communication in the supply chains through safety data sheets (SDS) and exposure scenarios (ES) is inefficient, as stated by the Commission in the Roadmap. Legislators should bridge the gap between legislation and reality. We have identified three major hurdles: the lack of adequate knowledge throughout the supply chain, the lack of standardised information and the excessive administrative burden on downstream users. Currently, chemical suppliers do not always know what an exposure scenario is (depending on their position in the supply chain), and if they do, they are not willing to discuss the content. Moreover, there are too many different formats of ES, information is complex and difficult to interpret, and there are no requirements on mixtures. This creates a large administrative burden for downstream users. We urge the Commission to make ES more usable. We recommend standardising information (including on mixtures) and considering the needs of those receiving them at the end of the supply chain. Harmonised electronic formats for SDS and ES are welcomed. Recommendations In conclusion, reporting requirements should be clear, well justified and avoid duplication of other EU policies and legislation. We also recommend standardised information with the end of the supply chain in mind.
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Meeting with Helena Braun (Cabinet of Executive Vice-President Frans Timmermans) and European Youth Forum and

21 May 2021 · Presentation on radical decarbonisation

Meeting with Camilla Bursi (Cabinet of Commissioner Virginijus Sinkevičius) and European Youth Forum and

21 May 2021 · Presentation on radical decarbonisation

Meeting with Katherine Power (Cabinet of Commissioner Mairead Mcguinness)

16 Mar 2021 · Draft delegated act, Taxonomy

Response to Revision of EU rules on food contact materials

28 Jan 2021

Stora Enso strongly support further harmonisation of the food contact materials (FCM) legislation as outlined in the accompanying attachment. Introducing a unified approach across the EU is required to ensure the EU’s internal market and prevent further development of another layer of national legislation. A well-designed EU FCM Regulation based on a harmonised approach taking into consideration sustainability and health aspects is better fit to ensure a well-functioning internal market than a patchwork of national legislations. As such, Stora Enso support the option to build on the existing FCMs framework instead of proposing a new one. It is important to highlight that the lack of EU specific measure for fiber-based FCMs does not mean, that they are currently unsafe. All of Stora Enso’s fiber-based packaging materials that come into contact with food comply with the Regulation (EU) No 1935/2004 and Regulation (EU) No 20223/2006. As such, Stora Enso issues a Declaration of Compliance (DoC) for these FCMs. The safety of the paper & board FCMs is vital for Stora Enso. Due to the lack of EU specific measure for paper and board, Stora Enso and the paper and board value chain have contributed to develop the Food Contact Guidelines for the Compliance of Paper & Board Materials and Articles in the past years. We welcome and support that the Commission’s Inception Impact Assessment, which states: “Rules would legally define the level of safety that needs to be achieved as well as set clear rules on how to achieve this”. Yet, it is also important that these EU rules also define the level of safety for the starting substances as well as intermediate materials. Stora Enso supports safety evaluation of chemical substances used in the production of FCM. The Commission proposal to apply a “one substance one assessment” approach should be carefully defined to ensure that by offering a simplified solution the safety of the FCM is not compromised and consumer safety is ensured. The specific use of a substance in FCM requires a dedicated risk assessment. We understand the European Food Safety Authority’s risk assessments would take time and the current positive list approach is not possible for all non-harmonised FCMs. As such, it would be preferable for current national and other acknowledged lists of authorized substances such as BfR Recommendation XXXVI were endorsed by the Commission. This would allow for a smooth adaption period for the industry. It is vital that every operator in the food value chain takes its responsibility of evaluating the risks for their specific step in the chain, and inform the next operator in the value chain on topics or limitations that may have influence on the safety of FCMs at later production stages. Stora Enso would welcome EU guidance to incetivise and promote the transparency needed for this. Exchange of information along the supply chain is a prerequisite for food safety. At the same time, these guidelines need to bear in mind that the intellectual property of the companies involved needs to be protected as it can be compromised, if sensitive information is demanded to be disclosed. Our natural wood based FCMs are mixtures of organic/synthetic and natural materials. We would welcome if the planned categorization of FCMs would not further complicate compliance evaluations of multi-materials, multi-material multilayers and composite materials. Future FCM legislation should also acknowledge the use of recycled materials in order to encourage and support the circular economy. Stora Enso fully supports increasing recycling or sustainability. It is equally important that food safety is not compromised. In conclusion, Stora Enso supports Option 1 as it provides an efficient and consistent approach in regulating the FCM while maintaining a high level of safety. When implementing such an option enough time should, however, be given by regulators so that the industry can adapt to the new FCM regulatory changes
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Stora Enso urges EU to recognize forestry's climate benefits

17 Dec 2020
Topic — This consultation establishes a classification for economic activities that contribute to EU climate objectives.
Message — The Taxonomy must recognise the benefits of substituting fossil-based products with forest-based products. They urge replacing improved forest management with sustainable forest management criteria. The additionality criteria should be removed to ensure a level playing field.123
Why — Aligning with existing rules would reduce administrative burdens and protect their existing sustainable investments.45
Impact — Responsible companies lose because the criteria favor competitors who have historically lagged in sustainability.67
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Response to EU Forest Strategy

1 Dec 2020

Stora Enso fully supports the EU Commission’s climate ambitions; we need to reduce our emissions by at least 55% by 2030. The forest industry plays a key role in this green transition and tackling climate change. Stora Enso is one of the biggest private forest owners in the world. In the Nordics, we also cooperate with other private forest owners, providing them with comprehensive forest management services. We are determined to be the leader in sustainable forest management and the renewable materials company providing solutions in transition to circular bioeconomy. We contribute to tackling climate change by managing our forests sustainably, ensuring we never harvest more trees than we grow while safeguarding biodiversity. We also deliver products that store carbon and providing low carbon alternatives to fossil-based or other non-renewable products to maximize carbon sequestration. We believe that the key to combatting global warming involves the use of renewable materials, resource and energy efficient production processes, and sustainable forest management practices. The substitution effect must be put at the centre of the EU’s future Forest Strategy. As a company, most of our positive climate effects comes from substituting and thereby avoiding emissions from non-renewable materials. In collaboration with the Swedish University of Agricultural Sciences, we have calculated our climate impact along our entire value chain. The estimated climate effect at corporate level was a net removal of 11.5 million Mt CO2-eq per year (i.e. a climate benefit) when considering value chain emissions, sequestered and stored biogenic carbon from forest land and temporarily stored biogenic carbon in our wood products and avoided emissions from substitution. Biogenic carbon refers to carbon that is sequestered from the atmosphere during biomass growth and may be released back to the atmosphere later due to combustion of the biomass or decomposition. As such, the uptake of biogenic carbon counteracted around 40% of the value chain emissions, while the largest climate benefit (removal of 17.9 million Mg CO2-eq) was due to substitution of more greenhouse gas-intensive products. We know from experience that using forest products - and the substitution effect from doing so - is a part of the long-term solution to mitigate climate change. To put this in perspective, our corporate net removals of 11.5 million CO2-eq equates to the CO2 emissions of some 5 million midsize cars driving 20 000 km annually. Objectives on forest protection, biodiversity, wood production and other ecosystem services are not in contradiction, instead they can be combined. EU needs well considered balance between set aside areas and productive use of forest land not to reduce forest-based products ability to replace fossil-based and emission intensive alternatives which are key to meeting the carbon neutrality goal. If designed right, forestry policy will contribute to a positive biodiversity development, whilst also ensuring that the raw material can be used to substitute fossils fuel products leading to best overall outcome. The EU Forest strategy should consider the opportunities that lies in further developing the forest industry. Stora Enso employs over 18 000 people in the European Union, and most of these people are based outside of urban areas. As such, the sector already today contributes to the Green Deal objectives of a just transition; leaving no-one behind. Stora Enso recommends that the EU Forest Strategy: 1. focuses on the substitution effect 2. acknowledge that forest protection, biodiversity, wood production and other ecosystem services are not in contradiction with sustainable forest management; and 3. harness the opportunities within the forest industry to create rural and green jobs. Please also find attached fuller comments and background paper.
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Response to Protecting biodiversity: nature restoration targets

1 Dec 2020

Stora Enso is one of the biggest private forest owners in the world. In the Nordics, we also cooperate with other private forest owners, providing them with comprehensive forest management services. We contribute to tackling climate change by managing our forests sustainably, ensuring we never harvest more than we grow while safeguarding biodiversity. We also deliver products that store carbon and provide low carbon alternatives to non-renewable products to maximize carbon sequestration. As such, we want highlight the following regarding the nature restoration targets roadmap. It is premature to set legally binding nature restoration targets, when the roadmap rightly points out that there is: “no requirement to comprehensively map, monitor, assess and achieve good condition of ecosystems”. As the objective is to restore degraded ecosystems, we believe other policy initiatives should be reviewed to incentivise this, before arbitrarily setting legally binding targets. We must first gain a better understanding in the area and underlying casuses of the problem. A better understanding of biodiversity is needed so that policies are evidence based and achieve the results wanted: a healthier and better growing forest with a diverse flora and fauna. Sustainable forest management and active conservation efforts in set-aside areas should be the main tool to meet objectives and such management should be adaptive. There are large differences in monitoring systems and data availability between Member States, which reinforces the use of member state specific indicators of biodiversity. Goals for preservation of biodiversity of species should be focused on populations rather than individuals and can be combined with active sustainable management of forests. Moreover, when setting goals to improve biodiversity it is important to acknowledge that time is an important factor, and that actions taken today can take several decades to pay off in terms of increased preservation status for individual species, habitats or ecosystems. We actively supports and fund research on biodiversity indicators. As this work develops, we would happily share results. Objectives on biodiversity, wood production, forest protection from fires and calamities, as well as other ecosystem services such as water and recreational benefits can be balanced. EU needs well considered balance between set-aside areas and productive use of forest land not to reduce forest-based products ability to replace fossil-based and emission intensive alternatives which are key to meeting the carbon neutrality goal. Yet, it must be acknowledged that set-aside areas will need active management to enhance biodiversity as well as carbon sinks. A good start would therefore be to ensure that all set-asides are well managed to meet the purpose of having them, before creating new ones. If designed right, forestry policy will enhance biodiversity development, whilst also ensuring that the renewable raw material can be used to substitute fossils fuel products leading to best overall outcome. Good experiences from forestry practices in the Nordics should be utilised when developing policies in the EU. Forest conditions as well as forest eco-systems varies; and thus, definitions and methodologies rightly vary considerably between Member States. A one-size-fits-all approach cannot be applied. The forestry practices in the Nordics, having the basis in the legislation, have proven that forestry, deforestation and negative biodiversity development can be decoupled. For instance, the biomass in Swedish and Finnish forests has become one of the largest contributors to net-GDP growth in these countries. Another example is that positive development in key biodiversity indicators are seen in the Swedish forests. Since 1990 there has been a 100 % increase of hard dead wood and 70% increase of old forest. Finally, we have attached our position paper on the EU Biodiversity Strategy for further information.
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Response to Land use, land use change and forestry – review of EU rules

26 Nov 2020

Stora Enso fully supports the Commission’s climate ambitions; we need to reduce our emissions by at least 55% by 2030. The forest industry plays a key role in this green transition and tackling climate change. We are the renewable materials company, providing solutions in transition to circular bioeconomy. Stora Enso contribute to tackling climate change by managing our forests sustainably, ensuring we never harvest more trees than we grow while safeguarding biodiversity. We also deliver products that store carbon and provide low carbon alternatives to non-renewable products to maximize carbon sequestration. Stora Enso welcomes the statement in the LULUCF Roadmap that: “The substitution of fossil-based materials with bio-based ones (e.g. use of wood in construction) should also be better incentivised”. We believe this is a key tool in mitigating climate change. Stora Enso would welcome further analysis of all options outlined in the Commissions LULUCF Roadmap and will therefore not indicate a preferred option. It is imperative that any revision of LULUCF ensures that sustainable forest management can be further stimulated within the existing policy framework, thereby positively affecting sequestration, storage and substitution. We are, however, concerned about any option that would combine the LULUCF sector and other land-related sectors, such as agriculture. As agriculture already today is a net emitter and is projected to continue to be so, a merger of sectors will, by definition, result in an increased emissions load. This would have to be balanced by higher forest removals, which could lead to demand for reducing harvesting rates in existing forests. This would risk developing negative effects on mitigation potentials, green growth and jobs in Europe as the full utilisation of the substitution effect our renewable material have in substitution fossil-based products. This could also leakage effects due to increased imports from outside of the EU. Stora Enso would like to encourage the Commission to ensure that the substitution effect of forest-based products is put at the centre of any revision. As a company, most of our positive climate effects come from substituting and thereby avoiding emissions from non-renewable materials. In collaboration with the Swedish University of Agricultural Sciences, we have calculated our climate impact along our entire value chain. The estimated climate effect at corporate level was a net removal of 11.5 million Mt CO2-eq per year (i.e. a climate benefit) when considering value chain emissions, sequestered and stored biogenic carbon from forest land and temporarily stored biogenic carbon in our wood products and avoided emissions from substitution. Biogenic carbon refers to carbon that is sequestered from the atmosphere during biomass growth and may be released back to the atmosphere later due to combustion of the biomass or decomposition. As such, the uptake of biogenic carbon counteracted around 40% of the value chain emissions, while the largest climate benefit (removal of 17.9 million Mg CO2-eq) was due to substitution of more greenhouse gas-intensive products. This report is attached as supporting evidence to our response. To put this in a perspective, our corporate net removals of 11.5 million CO2-eq equates to the CO2 emissions of some 5 million midsize cars driving 20 000 km annually. Stora Enso also wants to caution the Commission against using the LULUCF sector to make up for other sector’s emissions. Forest should not only be used as carbon sinks or storage; but equal weight should be given to maximising carbon sequestration. Finally, an important element of the existing Regulation is the use of historical intensity to define future utilisation of forests. The Roadmap does, however, not define that this element is up for review. Stora Enso believes it should be, and that the Regulation should be adjusted to be more “forward leaning” in calculations of harvesting levels.
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Meeting with Frans Timmermans (Executive Vice-President)

21 Sept 2020 · Climate ambition, green recovery and carbon pricing

Response to A new Circular Economy Action Plan

20 Jan 2020

Stora Enso – a leading provider of renewable materials – would like to highlight the following topics of certain importance for of a New EU Circular Economy action plan: We fully support the aim of the circular economy action plan to contribute towards a transition towards a climate neutral economy. Sustainable forestry and renewable materials have a strong potential to positively contribute to climate mitigation and a circular economy simultaneously. As a means the speed-up the transition both sustainable management of forests and substitution of fossil-based materials should be acknowledged in the circular economy action plan. Renewable materials are important to several value chain as part the solution for circularity and the climate challenge. This include prioritised areas for EU: i.e construction, plastics and textiles. Wood fibres are already today used in these value chains, such as wood construction material in the construction sector, renewable and recyclable packaging solutions as alternative to fossil-based plastics alternatives and wood based textiles that can replace fossil and other non-sustainable alternatives. To realise the full potential of forest based renewable materials it is essential to secure both sustainably sourced forestry-based resources and high-quality secondary raw materials. The paper industry is a role model of the circular economy with 71,9% recycling rate in 2018 and wood fibre can be recycled up to 20 times. It is key that the coming EU action on circular economy take into account the differences regarding recyclability pre-precondition between non-renewable materials and renewable materials. Renewable materials need a continuously adding of high quality sustainably sourced fresh fibres for a circular system to function over time. Given the benefits of sustainably sourced renewable resources, it is important with a level playing field between sustainable managed renewable resources and recycled materials. If not, there is risk of missing out of the opportunity to speed up the transition towards a climate neutral and circular Europe. Europe already has a leadership with regards to sustainable sourcing of forestry-based resources. This a competitive advantage to further build on. Good experiences from forestry practices on national level in Europe should be utilized. We are convinced increased efficiency in production (i.e maximized positive climate impact from sustainable forestry), biodiversity and circularity can be addressed simultaneously in a successful way – this should be acknowledged in the action plan. Stora Enso have further elaborated on what "A sustainable product policy" should embrace in the attached document.
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Meeting with Jyrki Katainen (Vice-President)

9 Jul 2019 · Circular bioeconomy

Meeting with Sebastien Paquot (Cabinet of Vice-President Karmenu Vella)

12 Jun 2019 · SDGs, Sustainable Products and Production

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

8 Feb 2019

Stora Enso refers to the new information provided by the dossier submitters (BASF, Dow and Nouryon) and urges the European Commission and the Member States to postpone the final decision on the harmonised classification until RAC has had a chance to review it and until there is additional clarity on the key concepts of the CLP involved in the classification of DTPA and chelating agents 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. Avoid an unacceptable change in the composition of the food and control organoleptic properties of paperboard for food packaging (as required by Regulation (EU) No 1935/2004). 2. Purifying fibres by treating 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 and in that way destroy the capacity of the mentioned non-chlorine agents. Environmental goals and the fundamental principal of REACH aim to replace substances with a classification as Repr. 1B by less harmful substances. 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. • Other non-renewable materials (for example plastics) will be replacing paperboard, if DTPA can not be used. • DTPA is used in the pulping process, in which wood is turned to fibres. The new classification Repr. 1B of DTPA would jeopardize the use of DTPA in pulping process and would thus mean bigger usage of natural resources – wood. As stated above we call to postpone the proposed classification of DTPA in the CLP Regulation until the new information supplied by dossier submitters is assessed by RAC.
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Meeting with Antonio Lowndes Marques De Araujo Vicente (Cabinet of Commissioner Carlos Moedas), Michael Hager (Cabinet of Vice-President Günther Oettinger), Risto Artjoki (Cabinet of Vice-President Jyrki Katainen)

9 Nov 2018 · Bioeconomy