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Media Centre - Position Papers
CEPI comments on the draft EU guidelines on environment and energy aid
It is unwise to raise costs for the industry to promote competition in the internal market, by doing so Europe will lose competitiveness in the global market.
CEPI therefore calls the European Commission to urgently modify the proposed draft guidelines on environment and energy aid for 2014-2020, in order to:
• allow 100% aid intensity for cogeneration;
• do not cap exemption from electricity price increases due to support for renewables;
• do not change definition for energy intensive industry.
The Guidelines on environment and energy aid for 2014-2020 will be an essential tool for reaching the ambitious 2020 energy and climate goals in a cost-effective manner. It is therefore important to promote low-carbon investments while preventing distortion of competition.
The European Commission should scrutinise the impact of proposed measures on the overall EU industrial competitiveness. Preventing intra-EU distortion of competition is important. But in a global competitive market, EU industry is faced with costs unmatched by other economies.
CEPI asks the European Commission to urgently correct three main issues.
First, allow 100% aid intensity for cogeneration.
The European Commission cannot adopt interpretative guidelines derogating from EU law. Art. 15 of the Council Directive 2003/96/EC (the so-called “Energy Taxation Directive”) specifically allows Member States “total or partial exemptions or reductions in the level of taxation” for energy used and electricity produced from combined heat and power generation (so-called “cogeneration” or “CHP”). However, the draft guidelines propose restricting investment and operating aid for cogeneration installations (from para. 17 onwards).
Such a restrictive interpretation is not only contrary to EU law, but also to the overarching 2020 energy-climate policies, where promotion of cogeneration is a key element of energy efficiency policies. It is arbitrary, inappropriate and acts as a disincentive for cogeneration, and the promotion of energy efficiency.
Second, do not cap exemption from electricity price increases due to support for renewables.
The draft state aid guidelines propose capping aid for industry at 85% for increased costs to support renewable energy sources (RES). This proposal in unacceptable for two main reasons:
1. From an environmental perspective, there is no link between the additional cost associated to RES promotion and the behavioural change expected by the beneficiary (industry) to achieve this environmental objective. Although RES contribute also – but not exclusively – to the environmental objective, the redistribution of costs within society is a social policy, where competency lies with the Member States;
2. The cost of promoting RES varies across Member States, even for the same technology. The cost depends on geographical conditions and on the way it fits into other cost components in the electricity bill, such as: national energy mix, network charges, other taxes and levies. Tackling just one component of the overall electricity price will not address intra-EU competition. On the contrary, an additional cost promoting RES set at EU level has the potential of further increasing market distortion.
Third, do not change definition for energy intensive industry.
The Energy Taxation Directive clearly defines “energy-intensive business” a business entity “where either the purchases of energy products and electricity amount to at least 3,0 % of the production value or the national energy tax payable amounts to at least 0,5 % of the added value” (Art. 17).
However, the draft state aid guidelines introduce a different definition of energy intensive industry, setting higher thresholds (10% trade intensity and 5% tax costs/gross value added). The new thresholds are based on carbon leakage criteria set in the EU Emission Trading System (ETS).
Such an interpretation is arbitrary and conceptually not correct. The carbon leakage criteria are meant to protect EU industry from unmatched costs from third countries. It looks at global competition. The state aid guidelines look at intra-EU competition. The basis for assessing distortion of competition cannot be the same.
The definition of energy intensive industry in the state aid guidelines needs to match the definition in the Energy Taxation Directive to avoid legal uncertainties distorting the internal market.
For more information, please contact Nicola Rega at (email@example.com)
Increase the availability of paper for recycling in the EU
• As part of the Waste Target review, the paper industry proposes an EU-wide ban on landfilling/incineration of recyclable paper by 2020.
• Current EU paper recycling performance could increase by 10 million tonnes of paper and board if diverted from landfilling and incineration. Theoretically this incremental volume could result in a paper recycling rate of about 80% (71.7% was achieved in 2012).
• The policy context in the EU supports the notion of diverting recyclable materials from landfilling and incineration to recycling. However, without a legal requirement,local authorities do not always make recycling a priority for these streams. The paper industry is committed to supporting them in doing so.
In 2012, about 78.5 million tonnes of paper were consumed in Europe (EU-27). Of this volume, 56 million tonnes were recycled. An estimated volume of 10 million tonnes of paper and board, potentially useful for recycling, is currently going into incineration or landfill. The industry sees this as a valuable source of material that could be put back into the production cycle – increasing the current EU recycling rate significantly – but needs legal support to enable this because waste management decisions are mostly made by local authorities. The paper industry is committed to supporting local authorities in improving the collection of paper for recycling.
Increasing the availability of paper for recycling will have a positive effect on job and value creation in the EU, both in the waste management sector as well as in the processing industries. An extra 10 million tonnes would result in a paper recycling rate of about 80% (71.7% in 2012).
A ban in landfill will bring about a coherent implementation of EU policy
European Commission communications emphasise that a resource-efficient Europe needs to turn its own waste into a resource so as to decrease its dependence on imports of raw materials, reduce the impacts on the environment and generate economic opportunities.
The Waste Framework Directive includes a waste hierarchy which clearly prioritises recycling over energy recovery and disposal. One of the key conclusions of the European Commission’s report on the Thematic Strategy on the Prevention and Recycling of Waste1 is that ‘’Significant margin for progress still exists beyond the current EU minimum collection and recycling targets’’. ‘’[An] optimal combination of economic and legal instruments should be promoted notably through landfill bans and by applying the producer responsibility concept to additional waste streams on the basis of a common European approach’’.
The Road Map for a Resource Efficient Europe foresees: ‘’By 2020, waste [will be] managed as a resource’’. ‘’Energy recovery is limited to non-recyclable materials, landfilling is virtually eliminated and high quality recycling is ensured’’. Europe needs to step up its efforts so as to achieve this milestone for all recyclable materials by 2020.
CEPI believes that recyclable paper presents a material source for which the above milestone can be realistically met by 2020 at the latest. A specific ban on landfilling/incineration of recyclable paper could mark the first concrete step towards the elimination of incineration/landfilling of all recyclable materials by 2020 or at a later date where appropriate.
For more information, please contact Mr. Jori Ringman-Beck at (firstname.lastname@example.org), mobile n°: +32 478 255 070.
1 European Commission, 2011. Report from the Commission on the Thematic Strategy on the Prevention and Recycling of Waste. COM(2011) 13 final, p 9
EU-US Transatlantic Trade and Investment Partnership: regulatory cooperation will provide the biggest benefit to the pulp & paper industry
The American Forest & Paper Association (AF&PA) and the Confederation of European Paper Industries (CEPI) and their members are strong proponents of free but fair trade. They support the objectives of the Transatlantic Trade and Investment Partnership (TTIP) negotiations aimed at eliminating barriers to trade, including regulatory barriers. The further reduction or elimination of trade barriers will strengthen the economies of the U.S. and the EU and enhance their global competitiveness.
The combined EU and U.S. pulp and paper industry accounts for more than 40% of the worldwide production and some companies have operations on both sides of the Atlantic. U.S.-EU trade in pulp and paper is very robust and both areas are among each other largest foreign markets. In 2012, U.S.-EU trade of pulp and paper & paperboard totalled $6.4 billion / €5.0 billion1.
The U.S. and the EU eliminated tariffs on all pulp and paper (Chapter 47 and Chapter 48 of the Harmonized System, respectively) as part of their implementation of the 1994 Uruguay Round Agreement of multilateral trade negotiations. Enhanced regulatory cooperation, particularly in the area of timber legality, renewable energy and biomass, environment, health & safety, and recovered paper definitions is a new step that will provide a real benefit to the pulp and paper industry.
Closer regulatory cooperation between the U.S. and the EU has the potential to generate significant cost savings and efficiencies. As suggested by the Final Report of the U.S.-EU High Level Working Group on Jobs and Growth, the elimination, reduction and prevention of unnecessary regulatory barriers are expected to provide the biggest benefit of the TTIP. While the U.S. and the EU regulatory systems differ, they share regulatory objectives because citizens on both sides of the Atlantic demand high level of protection.
TTIP should create a basis for genuine international leadership as well as providing new momentum to improve environmental, health and safety standards around the world.
“The U.S. and European pulp and paper industries are interested in achieving a more open and efficient regulatory environment, such as greater access and transparency of each other’s regulatory processes and mutual recognition that avoids duplicative compliance efforts,” said AF&PA President and CEO Donna Harman.
In this regard, there are a number of areas where a sectoral approach on greater regulatory cooperation could reduce costs and administrative burdens in both the U.S. and the EU. As CEPI Director General Teresa Presas stated: “The pulp and paper sector, as represented by AF&PA and CEPI, is well positioned to reach more detailed regulatory cooperation within the overall TTIP negotiations, both on existing regulations as well as regulation on new and emerging products”.
The paper industry in the EU and the U.S. will work to reach agreement on specific proposals through a constructive sectoral dialogue. In addition, CEPI and the AF&PA believes that, beyond the agreement, the TTIP should remain a dynamic, ‘living’ agreement with sufficient flexibility to incorporate new areas and issues over time.
For more information, please contact:
- CEPI: Bernard Lombard, Trade & Competitiveness Director, at email@example.com
- AF&PA: Jacob Handelsman, Senior Director, International Trade, at firstname.lastname@example.org
CEPI aisbl - The Confederation of European Paper Industries
The Confederation of European Paper Industries (CEPI) is a Brussels-based non-profit making organisation regrouping the European pulp and paper industry and championing this industry’s achievements and the benefits of its products.
Its collective expertise provides a unique source of information both for and on the industry; coordinating essential exchanges of experience and knowledge among its members, and with the industry stakeholders. Through its 18 member countries (17 European Union members plus Norway) CEPI represents some 550 pulp, paper and board producing companies across Europe, ranging from small and medium sized companies to multi-nationals, and 1000 paper mills. Together they represent 24% of world production.
American Forest & Paper Association (AF&PA)
The American Forest & Paper Association (AF&PA) serves to advance a sustainable U.S. pulp, paper, packaging, and wood products manufacturing industry through fact-based public policy and marketplace advocacy. AF&PA member companies make products essential for everyday life from renewable and recyclable resources and are committed to continuous improvement through the industry’s sustainability initiative - Better Practices, Better Planet 2020. The forest products industry accounts for approximately 4.5 percent of the total U.S. manufacturing GDP, manufactures approximately $200 billion in products annually, and employs nearly 900,000 men and women. The industry meets a payroll of approximately $50 billion annually and is among the top 10 manufacturing sector employers in 47 states.
Visit AF&PA online at afandpa.org or follow us on Twitter @ForestandPaper.
1 Pulp: $1.95 billion / €1.52 billion and paper & paperboard $4.44 billion / €3.5 billion.
Weight & dimensions’ limits: let’s make the best use of Europe’s roads!
The Directive 96/53/EC on Weights & Dimensions1, which is currently under review, regulates the weights and dimensions of heavy-duty vehicles operating as international and national transport within the EU. Under certain circumstances, and in line with the principle of subsidiarity, the Directive also permits Member States to provide derogations.
Road: the predominant mode of transport for freight today and tomorrow
Trucks dominate inland EU freight transport2 with a 72% share of the tonne-kilometres and account for about 94% of the CO2 emissions. There are currently 6.5 million heavy goods vehicles in circulation in the EU, transporting more than 80% of goods in volume (tonnes) and more than 90% of goods in value.
Road transport is, in general, the most flexible and efficient mode of transport when considering short distances and, for sure, the last miles. This is the only mode of transport that can ensure door-to-door delivery of goods to customers. While all transport modes are needed, the 2011 White Paper on Transport recognises that road transport will continue to be the predominant mode in the future. Road should therefore be considered in a nondiscriminatory way.
The European paper industry makes use of the three basic modes - rail, road and water, but like many industry sectors, road is the main mode of transport for European distribution and it is expected to remain the case in the future. A vast majority of the yearly 250 million tonnes of the paper industry raw materials and finished products is indeed transported by road in Europe. Around 55% of road transport concern long distance trips, 30% regional distance and the remainder local distance. Logistics costs average 10% of turnover.
Future challenges need to be addressed to secure long-term competitiveness and sustainability
The main challenges to be faced by road transport relate to increasing costs, the shortage of drivers across Europe, the growing level of road congestion and the rising level of greenhouse gas emissions (GHG emissions).
Road transport costs have grown over the years because of rising fuel price, road charging and truck drivers working regulations and increasing wages. This impacts the price of raw materials and goods and consequently the overall competitiveness of the industry.
Further cost increases are expected in the coming years due to further internalisation of external costs - to meet stricter emission targets, rising road charging and stricter minimum safety standards. Although road cannot carry everything, the ability of rail and other modes of
transport to help overcome these challenges remains very limited. There is often no affordable and efficient alternative to roads unfortunately.
Significant efficiency gains are possible and can deliver competitiveness and sustainability for shippers and the EU economy
As said in the EU Commission’s White Paper, urgent action is needed to make road transport more resource-efficient and to further integrate the various transport modes to achieve a true Single European Transport Area. Road should have its efficiency pushed to the optimum to deliver its full potential in a sustainable way, i.e. by reducing its GHG emissions and without neglecting road’s safety and security. All opportunities to reduce GHG emissions must therefore be considered.
Smart innovations to improve aerodynamics and reduce fossil fuel consumption and derogations to allow their implementation, as proposed by the EU Commission, are a step in the right direction. However, increasing incrementally the weight and dimensions’ limits and payload of trucks in legislation is one of the most cost-efficient and sustainable solutions.
Trucks weight and dimensions’ limits are one of the main bottlenecks that need to be addressed. 44 tonnes should be considered as a minimum weight limit in all EU Member States.
For international transport, Directive 96/53/EC sets limits to vehicles engaged in international transport to 40 tonnes and 18.75 meter of length, with the exception of intermodal transport where a maximum of 44 tonnes is permitted in a range of 150 km. However, individual Member States can allow higher weight limits on their roads.
The paper industry sector, like chemicals, steel, building, wood and petroleum is affected by weight restrictions because it transports mainly heavy goods. However, dimension restrictions hit also some segments of the paper industry that require high volumes.
Some countries like Germany and Spain apply a 40 tonnes limit for road transport and 44 tonnes limit for intermodal transport. But some others have allowed 44 tonnes for all transports - Belgium, France, Italy, and Luxemburg on 5 axles or United Kingdom on 6 axles. Even higher weight limits prevail with 48-50 tonnes in Czech Republic, the Netherlands, Norway, 60 tonnes on 7 axles in Denmark and 5 axles in Sweden, and even 76 tonnes in Finland on 9 axles. Several years of experience with heavier vehicles on relevant roads in those countries has not revealed any particular safety issues or infrastructure problems.
Allowing longer trucks and trucks able to carry heavier payloads is crucial in the context of the Directive’s revision. Increasing the authorised maximum weight and promoting the European Modular System (EMS) have to be considered since it would result in a decrease of the number of trucks on the road and road freight journeys, while addressing drivers shortages. It would reduce congestion on European roads and transport costs, give a boost to European industry’s competitiveness; and, as important, reduce fuel consumption and emissions.
CEPI supports the EU Commission’s proposal to extend the provision authorising the circulation of 44-tonne combinations of vehicles with 5 or 6 axles transporting 40-foot containers for intermodal transport to those carrying 45-foot containers.
EMS: let subsidiarity and innovation prevail!
The use of EMS should be promoted for relevant infrastructure. It can significantly help accommodate the growth of needed road transport volume by delivering additional loading capacity, higher resource efficiency and fewer trips without increasing risks of accidents, more wear and tear on roads and without major investment in infrastructure. All this has been proven in trials in, amongst other countries, Denmark, Norway and the Netherlands, and where the full operation of such modular combinations is already permitted, such as in Sweden and Finland.
CEPI, like many other European and national trade organisations supports the EMS3. The EMS is a concept that allows combinations of existing loading units (vehicles and load modules) into longer and sometime heavier vehicle combinations to be used on some parts of the road network, but obviously not in city centres or any other sensitive areas. Indeed, based on standard modules, it gives high flexibility to operators to adapt the vehicles to different situations, offers the possibility to use long combinations when possible and shorter combinations when necessary, and favours co-modality. As it is based on existing equipment, it is easy to implement and very easy to rearrange to shorter combinations and adapt to local conditions.
EMS already operates in several Member States under certain circumstances and conditions and offers industry a much needed efficiency and a greener alternative to many other current logistics solutions. EMS favours the development of intermodal transport and co-modality and supports the development of other transport modes like rail since it is built on using standard ISO 20 and 40 feet containers common also to rail and maritime freight transport. Allowing longer trucks on the roads would not shift substantial volumes of loads from rail to road as goods transported by road tend to be higher value goods, whilst rail is more suited to lower value goods. Road and rail are indeed complementary modes with limited areas of competition.
Cross-border trips with higher capacity trucks and EMS should be allowed and only subject to agreement between the concerned Member States
The Directive’s revision should enable higher weight limits for cross-border trips. Single compartment articulated vehicles with an upper limit of 44 tonnes for road transport (on five axles) and 50 tonnes (on 6 axles) for intermodal operations across Europe should be allowed for instance. Cross-border trips with even higher capacity trucks between two or more neighbouring countries that have the same limits should also be allowed.
By maintaining a weight difference between road transport and intermodal transport for single-compartment vehicles, there is no risk of a reverse modal shift from intermodal to road transport.
Industry is indeed often impacted by the lowest authorised vehicle weight limit on the route, which leads some time to absurd situations. Belgium has a maximum authorised weight of 44 tonnes for five-axle road haulage combinations like France4, but because of the EU Directive, at the border, the weight of the vehicle must be reduced to 40 tonnes. Once it has crossed over into the other country, the weight limit applicable is again 44 tonnes.
Low weight limits lead to additional costs and hinder smooth transport of goods throughout the EU and constitute an obstacle to the well-functioning and the completion of the Single Market. Permitting international transport with higher load deliveries across the EU and discouraging any cross-border barriers that limit its benefits would result in savings for all economic operators and would have a positive impact on energy consumption and the environment.
A recent EU Parliament study5 concludes that cross-border use with EMS vehicles would help at-source greening road transport, steering combined transport and further supporting an efficient EU transport network involving all modes of transport, including road.
The creation of specific corridors for bigger trucks between Member States should be also encouraged.
Industry and shippers’ voice should be heard when considering the review of the Directive 96/53/EC
Competitiveness and sustainability should be the key objectives when considering the review of the Directive 96/53/EC. It should aim at higher efficiency of the road transport to the benefit of the industry and the whole society by keeping our economy moving and enhancing the functioning of the internal market.
The paper industry as well as other industry sectors would benefit from increased weight and dimensions’ limits throughout the EU, with the necessary restriction on axles pressure.
CEPI believes that the authorised maximum weight should be increased as a general rule and, based on extensive trials, the use of EMS promoted. Cross-border trips between Member States where the same weight and dimensions’ limits prevail should be allowed.
Innovation, smart solutions and rationalisation in the transport and logistics field can have a great impact on competitiveness and sustainability and should therefore be promoted, to contribute to the EU 2020 strategy about sustainable growth and jobs and the success of an ambitious industrial policy.
1 COUNCIL DIRECTIVE 96/53/EC, of 25 July 1996, lays down for certain road vehicles circulating within the EU the maximum authorized dimensions of national and international traffic and the maximum authorised weights of international traffic.
2 According to EU Commission statistical pocketbook 2013 (2011 data), the share of intra-EU freight transport is 45.3% for trucks 36.8% for seagoing ships, 11.0% for rail and 3.7% for inland waterways. Road accounts for 71.8% of the EU27 of inland freight transport in billion tonne-km, rail 17.4%, inland waterways 5.8% and pipelines 4.9%.
3 These organisations are members of the EMS Forum: http://www.modularsystem.eu/
4 Since 1 January 2013, France has increased the statutory limit to 44 tonnes for transport within the French territory. Before 1 January 2013 the limit - with a few exceptions - was 40 tonnes.
5 “THE IMPACT OF MEGATRUCKS” - EU Parliament Transport & Tourism Committee, July 2013.
Industry needs a predictable and realistically achievable set of measures; we therefore urge EU policy makers to set the ambition levels of the future air policy framework so that they remain consistent with the investments needed in the context of the upcoming 2030 energy and climate framework:
- The 2020 ceilings should be aligned with the Gothenburg Protocol objectives in order to preserve the short-term competitiveness of EU industries
- Setting 2025 interim targets should not lead to imposing measures that go beyond what is expected from the application of the current legislative framework
- The 2030 TSAP objectives should not be set beyond the 50 % gap closure scenario, in order to remain cost-effectively achievable
Promoting a competitive European industry should also be ensured, as underlined in the Commission Communication on Industrial Policy “A Stronger European Industry for Growth and Economic Recovery” builds on the "Integrated Industrial Policy for the Globalisation Era" adopted by the Commission in 2010 as part of the Europe 2020 Strategy with its main message that: “Industry must be placed centre stage if Europe is to remain a global economic leader”
By the end of this year, through the adoption of the forthcoming EU air policy package, the EU Commission will adopt a revised Thematic Strategy on Air Pollution (TSAP) including new national emission ceilings for 2020 and further emission reduction measures for up to 2030.
The upcoming regulatory package may therefore impact our industrial sectors through the revision of the TSAP objectives, the revision of the National Emissions Ceilings directive (NEC) and through the setting of new source regulations (e.g. medium size combustion units).
Setting overly ambitious TSAP objectives could lead to setting very tight requirements in industrial regulations, pushing plants towards best of BAT (Best Available Techniques for control of emissions/pollution) or even beyond the use of BAT should ceilings not otherwise be met, thereby raising costs for EU consumers and impacting on the competitiveness of EU industry and jobs.
Analysis of the TSAP report #10 presented at last SEG meeting (3rd April 2013)
The so called ‘2025 central policy scenario’ (derived from a 75 % “gap closure” between the emissions reductions required by current legislation and those under a maximum technically feasible reduction scenario - MTFR) was established by IIASA (International Institute for Applied Systems Analysis) and modelled using the GAINS Integrated Assessment Model, in the absence of, inter alia:
- a sensitivity analysis (consideration of how much outcomes are dependent on certain variables which are currently unknown) around alternative energy scenarios (models based on a different energy make-up, in terms of varying levels of coal, renewables, etc); deeply affecting both attainability and compliance costs);
- consideration of a relationship between binding ceilings and practical attainability if some sectors do not deliver their reductions (e.g. transport and NOx, agriculture and ammonia);
- the inclusion of real sensitivity analysis based on alternative and more recent studies aimed at monetising impacts
- an assessment of the advantages of setting ceilings in 2030 as an alternative to 2025
Time should be given to consider all the above in order to arrive at a robust ambition-setting process.
This robustness is vital to ensure that ambition levels (expressed as revised national emission ceilings) based on one single energy scenario do not result in significant escalation in compliance costs or non-achievability in a different actual future energy world. While we fully support a rigorous comparison of costs and benefits of legislative proposals we do not believe that current understanding of costs and benefits is adequate to justify the ‘economics textbook’ approach used by IIASA in setting ambition levels. The 75% gap closure (the distance between emission reductions required by current legislation and those if every technically feasible reduction was undertaken) of the ‘2025 central policy scenario’ is consequently neither technically justified nor prudent as the basis for a revised TSAP.
The authors of the IIASA report (section 6.2 on page 50) have examined the achievability of the emissions ceilings of the central policy scenario under a previous different energy scenario (the one called PRIMES 2010, two years before the current energy scenario PRIMES 2012 and concluded a significant number of them could not be achieved under those conditions! They drew the conclusion that “It remains a political judgment of risk management to what extent less likely developments should be considered in the setting of national emission ceilings”.
It is also important to recognize the limitations of GAINS resulting from the significant 'simplification' of the varying activities within a given industry sector. This results in the application of 'aggregated emission factors' and 'aggregated costs'. As a consequence the high incremental cost versus incremental emission reduction (cost effectiveness) is obscured, a cost that that would in practice have to be met by Industry, especially at the high ambition levels.
Bearing in mind what IIASA considers as “less likely development” is the recovery from this dramatic economic crisis the EU is struggling to achieve, we urge EU decision makers to follow the way of wisdom in setting credible and affordable ambition levels.
Key principles supported by industry
Industry supports the general approach of seeking cost-effective solutions to address air pollution across the fullest range of contributing sources. The Industrial Emissions Directive (IED) is the central framework covering the overwhelming majority of industrial sites in Europe and will be fully implemented through developing BAT conclusions for all sectors. The IED will keep driving the continued improvement of environmental performance through the regular updates of the BREFs (BAT REFerence documents) and adoption of revised BAT conclusions.
Emissions from industry have been reduced substantially over the last two decades. Hence the potential for further cost-effective reduction from industry is thereby lower, and this should be fully recognised when considering further policy measures in the context of the upcoming revised TSAP.
1. The TSAP objectives should be maintained at an achievable level, consistent with the application of the best available techniques and their associated emissions performance, and not set beyond the A2 scenario (50 % gap closure) for 2030. The A5, A4 and A3 scenarios (75 % gap closure) would force a significant number of Member States to deliver emission reductions close or even beyond the MTFR scenario and thus pushing most of their industrial installations to performing close to or beyond the emission levels that are associated to the Best Available Techniques, and investing in commercially unaffordable abatement techniques if those are considered technically applicable.
2. The 2020 National Emission Ceilings shall be set so that EU member states would not be forced achieving stricter objectives as compared to the internationally-approved Gothenburg Protocol ceilings. This is the only approach ensuring a level playing field between EU and non EU countries and preserving the short-term competitiveness of the EU industries facing international competition.
3. Beyond 2020, mandatory targets shall only be set for 2030 to avoid any regret investments and align air quality policy consistently with the upcoming 2030 energy and climate change package. Should interim targets be defined in 2025, these must be solely based on the so-called current legislation reference (CLE) scenario (in this scenario now new policies are put in place but current legislation is implemented), which already includes investment in measures such as applying the IED BAT-based operating conditions in all industrial installations. These investments (many of which are yet to made) under the CLE scenario will already allow achieving additional reduction beyond the reductions required by the Gothenburg Protocol (e.g. NOx reductions of 60%, compared to 42% under Gothenburg and SO2 reductions of 70%, compared to 59% under Gothenburg). Industry therefore considers any 2025-based indicative interim targets should not lead to setting measures that go beyond what is expected from the application of the current legislative framework.
CEPI comments on the discussion document ‘Paper Vapour – the climate impact of paper consumption’ from the European Environmental Paper Network
The European Environmental Paper Network (EEPN) presented preliminary findings of their Paper Vapour report. The report aims to show that paper has a large climate impact and it questions the carbon neutrality of wood fibre. The Confederation of European Paper Industry (CEPI) analysed the report. CEPI advises a major reworking of the draft report before publishing final findings. There are several reasons for this:
I. The data do not match the sources referenced
The report concludes that pulp and paper industry emissions are 7 kg of vapour per kg produced leading to total emissions that are larger than those of waste and landfilling, chemicals, oil and gas, fuel and power, steel and aluminium and iron combined.
It uses data from the World Resource Institute (WRI). However, the report does not show the original WRI data for all sectors. In table 2 a new figures was inserted for the percentage of the pulp and paper sector. In the original WRI publication the emissions from pulp, paper and print are set to be 1.1% (http://www.wri.org/chart/world-greenhouse-gas-emissions-2005). Instead a number seven times higher than the original was included based on separate calculations. The report lists this fact only on page 11, which is misleading. Either WRI figures should be used entirely to be able to compare them correctly or all sector figures need to be re-calculated on an equal basis. At the moment the figures in table 2 do not add up to 100% any longer; they exceed that figure.
2. The underlying data are unlikely at best
The emissions of industry sectors are well documented by the International Energy Agency (IEA). The IEA publications on industrial efficiency and CO2 emissions show that 70% of industrial emissions are emitted by three sectors: iron and steel, non-metallic minerals (cement) and chemicals and petrochemicals. The direct emissions from the pulp, paper and print industry together add up to 189 Mtonnes in 2005 at global level, 2.8% the of industrial emissions (IEA Energy Technology Perspectives). These data are based on national country statistics. EU steel sector emissions in EU ETS published by the European Environment Agency (EEA) are around 140 Mtonnes in non-crisis years, four times that of the 35 Mt from the European pulp and paper industry according to EEA statistics.
The IEA data divided by the global production figures used in the report (328 Mt pulp and paper produced), lead to a direct emission of 189/328 = 0.58 t/t as a global average, compared to the 0.34 t/t for Europe. These are direct emissions only. When adding indirect emissions from electricity in line with European data (0.34 vs. 0.10, CEPI sustainability report based on EU ETS and energy consumption statistics), the number used for direct production emissions in the report is 100% higher than reality.
Vice versa, the weighted average of 1.51 t/t used in the EEPN report would lead to 546 Mt global emissions for the paper industry, compared to the realistic 189 Mt from the IEA statistics.
3. The combination of data leads to mistakes
In table 1, data from a multitude of sources are combined resulting in an altered total figure. Similarly, the combination of different data leads to mistakes. An example is ‘Debarking and Chipping’. US data from a single study are used in the report in this instance. The emissions (0.45 t/t) are higher than the overall EU average production emissions. Moreover, debarking and chipping for pulp production is included in pulp production statistics, because they are part of our production process.
Wood chipping in the US, meant for exports of bio-energy, is delivering wood to the power sector, not to the pulp and paper industry. Additionally, a Carbon mass balance credit is added without any further explanation. Again a number is used higher than the real and verified emissions from paper production today. The source is the author of the report himself. CEPI believes a clearer explanation is needed to understand how these figures have been calculated.
4. The key number is not explained
A crucial discussion is missing from the report, linking forest accounting with the number 6.83 t/t in the first section. This number doubles the emission calculation made in the report, without explanations on how it is derived. The source seems to be the grey picture on page 5, which is not referenced properly. It seems to relate to a virgin paper production cycle. It is also unclear to what the percentages in the picture refer to. Yet this picture seems to be the basis for the entire allocation of biomass emissions, without any further explanation. The conclusions of the report are very difficult to assess, as the calculations included are contrary to current standards in life cycle accounting, monitoring or reporting rules in legal frameworks and the UNFCCC accounting rules
Carbon neutrality is an issue in emission accounting, based on the UNFCCC accounting rules, including LULUCF. The emissions of carbon emitted when burning wood for energy are calculated in the national forestry (LULUCF) accounts, enabling a zero factor to be used for biomass.
The report quotes in many cases from an article in the Science magazine and the discussions in the USA. The so called accounting error in forest carbon accounting as referred to in the Science articel is an issue for non-Kyoto countries. However, it is clear that in Europe, having signed the Kyoto protocol and following the agreements reached in Durban, proper forest accounting is taking place. It is based on the LULUCF legislation and a zero emission factor from the EU Monitoring, reporting and verification guidelines. Around 80% of all wood used in the European industry is coming from EU forests and the pulp from known and established planted forests.
But the core of the matter remains, if the wood used is sourced from sustainably managed sources one cannot double count carbon stock, flow approaches and forest and biomass emissions, as seems to be the case in this study. In Europe forest carbon stock has been growing for years, and proper forest accounting is taking place.
5. The report compares apples and pears
The report makes comparisons between the pulp and paper sector and other sectors in society, to emphasise the size of emissions calculated. The comparisons are flawed for a number of reasons. Some were mentioned before, additionally, the constructed pulp and paper LCA style number in the report is compared to non LCA data of other sectors. The basis for the calculations are completely different. In addition, the word “direct” emissions is used incorrectly in several cases throughout the report, not in line with scope 1 and scope 2 emissions normally used in reporting on industrial emissions.
6. Old and US data are used for a European study
The paper was commissioned by the European paper network and is intended for the European discussion, but only two of the sources are European and no European data has been used. CEPI strongly feels the data should also be European and reflect the real situation in the European production and consumption of paper and board. The current discussion paper does not. To address imports of paper into Europe for consumption, a weighted average can be calculated. But the fact remains that the vast majority of paper used in Europe is produced in Europe from European raw materials.
7. Sources are unclear
Last but not least, the study should avoid quoting background studies made by the same author, without further references. This leaves figures untraceable. Nine out of the 11 data used are either (co)sourced to Jim Ford, Climate for Ideas or EPN. There are many more public studies and materials available that could have been used, providing additional data and references.
In a nutshell, verification of the conclusions made in the report based on the calculations, data and sources presented is not possible. The 7 kg of paper vapour is not backed by the material presented. CEPI recommends a complete overhaul of the report to be credible.
For more information, please contact Marco Mensink at email@example.com
EU-US Transatlantic Trade and Investment Partnership: additional bilateral market openings and regulatory convergence to deliver competitiveness and a level playing field
The talks between the EU and US for a Transatlantic Trade and Investment Partnership (TTIP) began in Washington on 8 July. These negotiations aim to achieve ambitious outcomes in three broad areas: a) market access, b) regulatory issues and non-tariff barriers, and c) rules, principles and new modes of cooperation to address shared global trade challenges and opportunities.
The EU is the world leader in paper exports and the US is its main trading partner. Around 4.5 million tonnes of pulp and paper are traded between the two areas every year. Importantly, this trade has been free of import tariffs since 20041. The European and the US paper industry together accounts for more than 40% of the global production.
CEPI supports launching negotiations with the US, aiming at the full liberalisation of bilateral trade in goods and services. In addition, we believe the EU-US TTIP gives an opportunity to explore further trade liberalisation in raw materials and energy. CEPI views the TTIP’s biggest potential benefits as being the elimination, reduction and prevention of unnecessary “behind the border” obstacles to trade and investment. This is of primary importance, especially for the companies operating on both sides of the Atlantic.
We hold the TTIP should envisage convergence in a wide range of areas, including not only wood legality and renewable energy legislation but also standards for paper for recycling. This convergence should deliver reductions in both compliance costs and administrative burdens.
In parallel, the TTIP should create a basis for genuine international leadership as well as providing new momentum to developing and implementing international regulations and standards. Overall, CEPI believes it represents a strong potential driver of mutual job
creation, economic growth and competitiveness.
Non-discriminatory access to US gas is a ‘sine-qua-non’ condition
The TTIP negotiations have to ensure no discrimination or restriction regarding access to energy within the transatlantic market, particularly natural gas in the US.
Natural gas provides 40% of the European pulp and paper industry’s energy needs, next to the over 50% bioenergy in our fuel mix. Many of the most efficient power plants run on natural gas. Significantly, while gas prices in Europe have doubled since 2003 and are expected to keep rising, shale gas has brought US gas prices to extraordinary low levels.
CEPI holds the TTIP should lead to a common strategy to reduce energy and raw material export restrictions at the global level. It should set rules to provide an open, stable, predictable, sustainable, transparent and non-discriminatory framework for traders and investors worldwide.
Tariffs on the pulp and paper industry’s raw materials and chemicals have to be eliminated on both sides on the agreement’s entry into force
CEPI calls for tariff elimination to occur on the agreement’s entry into force, with transition periods, if any, being kept as short as possible for sensitive products. In addition to wood and paper for recycling, the pulp and paper industry is a major user of non-fibrous raw materials and chemicals. Imports of chemicals into the EU are still affected by tariffs2 and starch imports also subject to substantial tariffs3 to enter EU markets.
Cooperation on rules and standards mean higher efficiency, lower compliance costs and a reduced administrative burden
The European and US paper industries, as founding members of the ICFPA4, have both actively promoted sustainable forest management and fought illegal logging at the global level while also increasing recycling.
The US and EU have taken major steps regarding wood legality, with the former having implemented the Lacey Act for several years and the latter having recently adopted the Timber Regulation. CEPI firmly believes that the convergence of the two schemes in terms of scope and requirements should be aimed at and the declaration systems simplified as much as possible. However, an end to the illegal wood trade can only be achieved through a push at a global level.
Equally, convergence would also deliver mutual benefit in recycling. We believe paper for recycling grades definitions5 requires harmonisation on both sides of the Atlantic.
We call for increased cooperation between EU and US standardisation bodies to reduce redundant and burdensome testing, harmonisation of certification requirements and further development of international standards.
Convergence on climate change and energy policies is needed to avoid highly distorting measures and deliver higher results at the global level
The European paper industry has made strong and clear commitments to sustainable development and mitigating climate change, transparently reporting on its progress.
However, regulatory convergence is required to deliver on climate change mitigation and environmental protection objectives. Consequently, CEPI believes EU and US policies aiming at reducing greenhouse gas emissions and promoting bioenergy and biofuels should converge to raise efficiency and reduce distortion.
We view the TTIP as being a platform to address the most distortive forms of subsidies and scenarios where government interference is distorting markets. For example, US fuel tax credits have highly distorted competition with Europe in recent years, without any significant environmental benefits.
Carbon neutrality of biomass and sustainability criteria should be jointly promoted for the sustainable sourcing and conversion of solid biomass, irrespective of the final wood use. This convergence process should bind both parties at all administrative levels (EU Member States and the US state governments) to ensure a maximum efficiency and effectiveness.
Future regulation developments: the need for increased consultation and cooperation
CEPI considers it essential to promote cooperation between regulators from both sides at an early stage. A framework for future cooperation has to be set up, where procedures for consultation and impact assessment are considered. Ex-ante impact assessments on trade and investments flows should be carried out when preparing regulatory initiatives, with only compatible regulations being adopted. This should be done through an effective, evidencebased bilateral consultation mechanism, with its outputs shared transparently.
Furthermore, the TTIP should include provisions on ex-post analysis of existing regulations that come up for review. We consider it essential to avoid missing opportunities to both increase compatibility and coherence as well as remove unnecessary regulatory complexity.
Cooperation on new and emerging issues such as nano-materials would help prevent future trade irritants. We believe mutual consultation at an early stage should become common practice, triggered whenever US agencies or the European Commission start developing new criteria or legislation.
Beyond the agreement, the TTIP should remain a dynamic, ‘living’ agreement with sufficient flexibility to incorporate new areas and issues over time.
CEPI will contribute to a successful TTIP by delivering relevant sectoral provisions to be included in the agreement through a constructive dialogue with its US counterpart.
1 As a result of the WTO Uruguay Round sectoral agreement of 1994.
2 HS Chapters 28, 29, 32, 35 and 38 with average ad valorem import tariffs of 5-6%.
3 HS Chapters 11 and 35 with import tariffs up to 224 euros / tonne.
4 International Council of Forest and Paper Associations - http://www.icfpa.org/
5 European standard EN 643.²
Conclusions from the position:
The ESC believes the Directive should be revised having in mind changes that can allow industry to respond to these pressures and in a way that can foster growth and competitiveness in the European transport sector. The ESC’s position includes a series of changes to the Directive, all intended to improve efficiency and environmental standards of the road transport of goods while pursuing the goal of a true Single European Transport Area. The alternatives supported by the ESC would achieve a decrease in the number of road freight journeys and the number of trucks on the road. At the same time they would result in a reduction in the number of drivers needed as well as less congestion on Europe’s roads. Also, and considering the economic crisis faced by Europe, these options would signify a decrease in transport costs while improving European industry’s competitiveness. These suggestions would also mean the reduction of fuel consumption and emissions, following the environmental improvements recognised by the Commission. In conclusion the ESC urges the Commission to engage in a comprehensive dialogue with all stakeholders to find the best ways to implement the necessary changes to the Directive.
To read the full position in pdf format, please click on Download here.
CEPI is a member of the European Shippers’ Council.
Sulphur limits in marine fuel: temporary exemptions and costefficient accompanying measures are the solutions
A new directive(1) bringing the European Union's regulation on marine fuel sulphur content in line with international requirements set out under the international maritime convention on pollution prevention known as MARPOL entered into force on 17 December 2012. The objective of this directive is to address the problem of air pollution from maritime transport by lowering sulphur emissions.
The European paper industry is extremely concerned by the impact of these measures on competitiveness and jobs in the 13 EU Member States bordering the SECA(2), while no substantial environmental and health benefit is to be expected because of the resulting “modal back shift” – from maritime transport to road transport. To the contrary, subsequent higher GHG emissions are expected(3) in contradiction with the EU White Paper on Transport.
In a previous position paper(4), the European paper industry expressed its support to the International Maritime Organisation (IMO) efforts to address the problem of air pollution from maritime transport at global level by lowering sulphur emissions. Some European paper companies have even been in the forefront to reduce voluntarily sulphur emissions since the 1990s.
Because of the lack of low sulphur fuel and technical devices that could lead to actual reduction of sulphur emissions more cost-efficiently by 2015, the implementation of these measures is expected to have a cost of around 300 million euros for the pulp & paper industry located in the North of Europe related to an estimated increase in shipping costs of 20-45% further to a 50-80% price increase in marine fuels. The threat on RoRo and RoPax vessels is very serious as they represent between 30% and 60% of the volumes transported from/to Finland and Sweden. The cost is expected to reach 4 billion euros for the whole economy of these countries per year from 2015, mainly due to the substantial increase of the onshore diesel price(5). Thousands of direct jobs will be put at risk, as well as numerous indirect jobs. These rules will, as trade barriers do, disturb substantially supply chain management and trade flows and further distort competition within the EU and with foreign countries.
The problem is the too tight time schedule and the lack of alternative solutions. Exhaust-gas cleaning system – the scrubbers - technology has improved, but so far there is only a limited number of test installations in operation and no manufacturing company can guarantee its functioning with the harsh conditions at sea. Because of technical and cost reasons, only a limited number of vessels could consider this technology as a possible solution. In the long term, LNG is among the most promising solutions from an environmental and economic aspect. That’s the reason why CEPI supports the launching by the EU Commission of a Clean Fuel Strategy(6) but as technology implementation and infrastructure are proceeding relatively slowly, it won’t be an option before 2020 at the earliest and only new vessels will be in a position to benefit from it by that time.
Several European countries expressed their concerns regarding the potential impact on their economy and were of the opinion that ways to mitigate the impact of these measures should be explored, including temporary exemptions in IMO as it is the only realistic option at present.
The EU Commission, which is conducting an impact assessment study - to be available end 2013, should help identify pragmatic solutions to mitigate the impact on the European industry’s competitiveness. To this aim, the EU Commission’s ‘Toolbox’ should be further developed to allow cost-efficient solutions, while a boost should be given to low sulphur fuel supply and abatement technologies. Member States and EU Commission should indeed support investments in these areas but also in LNG infrastructure on the long term. In the meantime, no fine should be imposed on companies by Member States.
The set-up of a platform(7), aiming at getting expertise and recommendations of stakeholders – including industry representatives and shippers, on the implementation of the Sulphur directive is crucial and the European paper industry can give a valuable contribution.
The EU Commission has adopted in October 2012 an ambitious Communication on Industrial Policy aimed at boosting the competitiveness and output of its manufacturing sector and have its share increased to 20 percent of GDP by 2020, up from 16 percent today.
In a context of severe economic recession, CEPI urges Member States and EU Commission to help identify pragmatic solutions and not penalise industrial sectors that depend heavily on maritime transport.
For more information, please contact Bernard Lombard, CEPI Competitiveness & Trade Director, at firstname.lastname@example.org, Tel: +32 2 627 49 00
1 Directive 2012/33/EU of the European Parliament and of the Council of 21 November 2012 amending Council Directive 1999/32/EC as regards the sulphur content of marine fuels.
2 The Sulphur Emission Control Area includes the Baltic Sea, North Sea and English Channel, i.e. Finland, Sweden, Norway, the Baltic States, Poland, Germany, Denmark, the Netherlands, Belgium, and to some extent United Kingdom and France.
3 Institute of Shipping Economics and Logistics’ study “Die weitere Reduzierung des Schwefelgehalts in Schiffsbrennstoffen auf 0,1% in Nord- und Ostsee im Jahr 2015: Folgen für die Schifffahrt in diesem Fahrtgebiet“, September 2010.
4 “Marine fuel: Lowering sea transport emissions requires pragmatism and flexibility”, CEPI Nov. 2010.
5 Consequences of the EU Sulphur Directive, SWECO, October 2012.
6 Proposal for a Directive on the deployment of alternative fuels infrastructure, COM(2013) 18/2.
7 The European Commission proposed the set-up of the European Sustainable Shipping Forum.
Commission's proposal for a general data protection regulation-Position of the paper and print value chain
Our associations are part of the paper and print value chain - including paper manufacturing, paper converting, printing, postal services and direct marketing – and are committed to safeguarding the protection of personal data.
We acknowledge that recent globalisation trends and technology developments create the need for a review of the existing legal framework, i.e. Directive 95/46/EC on Data Protection, to ensure the privacy of personal data of European citizens. In this context, we welcome the Commission’s proposal for a general data protection Regulation as published on 25 January 2012.
The European strategy for growth and competitiveness emphasises the need for the development of the single European market with free movement of goods, services, labour and capital. With data being an integral part of this process, the ability to use and move data within the European Union must be considered as an essential requirement of a revised legislation. A balance needs to be found between consumer protection requirements and businesses’ development needs.
The review of the existing framework is primarily aimed at tackling the growing development of online technology. However, in doing so, the risk is to destabilise the more ‘traditional’ side of the communication industry, which is not being questioned for its ability to protect personal data.
As members of the paper and print value chain, we herewith wish to address some aspects of the proposed Regulation affecting postal direct mail.
“Legitimate interest” and “right to object”
We welcome the Commission’s proposal acknowledging the “legitimate interests” of the controller to process data (article 6) and retaining the “right to object” for data subjects at any time of the processing of personal data (article 19). And we strongly support the application of the latter to postal direct mail purposes (article 19.2) as it ensures the safeguarding of the efficient legal framework, which has been in place for nearly two decades and which has been complemented with self-regulatory initiatives from the business community.
In order to safeguard the efficient legal framework applicable to the postal direct mail, it is crucial that the “legitimate interest” of the controller to process data is being maintained and the “right to object” is not being replaced by a “prior consent” approach.
Measures based on profiling
Article 20 of the proposed Regulation relates to the activities of profiling. We are surprised to see that companies’ legitimate interest for doing profiling is not recognised in the draft legislation.
Profiling allows for the identification of categories of individuals (not for the identification of individuals), thereby ensuring that companies target the right audience with relevant information. Without profiling, the postal direct mail business will effectively become a doorto- door mail drop service. This is not in the interest of consumers, nor of companies, who would have to support unnecessary costs.
While profiling has indeed become more complex with the advent of OBA, (online behavioural advertising), the Commission must not ignore traditional profiling activities that remain valid today. Banning all profiling activities would seriously hamper businesses’ capacity to advertise, via postal direct mail, products and services to the relevant customer, thus limiting offers on the market and preventing customers from having a choice and getting the best out of the internal market.
Consequently we are of the opinion that the companies’ legitimate interest for doing profiling should be recognised as proposed in the Recommendation CM/Rec(2010)13 of the Committee of Ministers to member states on the protection of individuals with regard to automatic processing of personal data in the context of profiling.
CEPI – Confederation of European Paper Industries – www.cepi.org
FEDMA – Federation of European Direct and Interactive Marketing – www.fedma.org
FEPE – European Envelope Manufacturers Association – www.fepe.org
INTERGRAF – European Federation of Print and Digital Communication – www.intergraf.eu
Paper Chain Forum – www.paperchainforum.org
POSTEUROP – European Postal Operators – www.posteurop.org