Svenska Cellulosa Aktiebolaget SCA
SCA
Kärnan i SCAs verksamhet är skogen, 2,6 miljoner hektar i norra Sverige.
ID: 592965728221-49
Lobbying Activity
Response to Climate change mitigation and adaptation taxonomy
18 Dec 2020
EU Sustainable Finance Taxonomy
Consultation reply on proposed delegated act
Svenska Cellulosa Aktiebolaget SCA is Europe’s largest forest owner with 2.6 million hectares of forest land in northern Sweden and 50 000 hectares of forest land in Estonia and Latvia. Based on the sustainable management of this forest resource, SCA has built an industrial ecosystem with the aim of creating the maximum value in and from the forest. This value chain comprises sawmilling and the production and refining of wood products, production of paper for packaging, of pulp for primarily hygiene application and renewable energy in various forms.
SCA has calculated the climate effect of the company’s operations. The net sequestration of the company’s forests, growth minus harvesting and natural losses, amounted to 5.4 million tonnes of carbon dioxide in 2019. The emissions of fossil carbon dioxide in the company’s value chain, including transportation and indirect emissions from the production of input materials, amounted to 0.9 million tonnes. The substitution effect, the positive climate effect from substituting one product with a higher carbon footprint with one with a lower – wood instead of concrete, paper packaging instead of plastic packaging, biofuel instead of fossil fuel – amounted to 6.0 million tonnes of carbon dioxide. The net climate effect of SCA’s operations in 2019 was positive and amounted to 10.5 million tonnes of carbon dioxide corresponding to the emissions of all passenger cars in Sweden.
An important policy tool
SCA is of the opinion that, properly designed, the Taxonomy is an important policy tool. The proposed delegated act and its technical screening criteria in Annex 1 and 2 provide, however, an impediment to the Taxonomy achieving its aims and risks slowing down the societal transition.
By its broad scope and high complexity, the act goes way beyond the ordinary scope of a delegated act. Thereby, the act will be a strong formative element in the future European industry policy. The degree of complexity makes it very hard for an operator to interpret the proposed criteria, which in turn will make implementation difficult and risks resulting in legal uncertainty.
As currently drafted, the act would exclude existing sustainable forest management from the Taxonomy with regard to climate change mitigation.
SCA asks for the act to be revised in a transparent and inclusive way. The following concerns need to be addressed:
SCA’s main concerns
• A delegated act is not a proper way to form a new European industrial policy
• The forest based value chain should be recognized as an important system for bringing about climate change mitigation, while providing for other societal needs
• Sustainable forest management should qualify for meeting the criteria, thereby providing a basis for a number of downstream climate change mitigation measures, provided that the carbon stock for a relevant entity (company, region, country) is maintained or increasing
• The reference to “improved forest management” should be replaced by “existing forest management” with the condition on the bullet point above
• Any reference to additionality should be removed, as it disqualifies activities, such as sustainable forest management, that is already sustainable and provides a key resource for developing products and measures that adds to the work of mitigating climate change
• Any reference to “close-to-nature management” should be removed as the concept is not defined and there is no scientific base for the term
• Forest based bio-energy is not a transitional activity but a sustainable and renewable energy resource
Read full response8 Feb 2019
Referring to new information provided by DTPA manufacturers (dossier submitters), SCA urges the European Commission and the Member States to postpone the final decision on the harmonized classification of DTPA until RAC has had a chance to review this new information and until there is additional clarity on the key concepts of the CLP involved in the classification of DTPA and chelating agents in general.
For more details see attached file
Read full response