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19 Mar.2015

Consultation response on the revision of the EU Emission Trading System (EU ETS) Directive

Background: On 24 October 2014, the European Council agreed on the 2030 framework for climate and energy, including a binding domestic target for reducing greenhouse gas (GHG) emissions of at least 40% in 2030 as compared to 1990. To meet this target, the European Council agreed that the emissions in the EU Emission Trading System should be reduced, compared to 2005, by 43%. A reformed EU ETS remains the main instrument to achieve the emission reduction target. The cap will decline based on an annual linear reduction factor of 2.2% (instead of the current 1.74%) from 2021 onwards, to achieve the necessary emission reductions in the EU ETS. The European Council furthermore gave strategic guidance on several issues regarding the implementation of the emission reduction target, namely free allocation to industry, the establishment of a modernisation and an innovation fund, optional free allocation of allowances to modernise electricity generation in some Member States.

The strategic guidance given by European leaders on these elements will be translated into a legislative proposal to revise the EU ETS for the period post-2020. This constitutes an important part of the work on the achievement of a resilient Energy Union with a forward looking climate change policy, which has been identified as a key policy area in President Juncker's political guidelines for the new Commission.

The purpose of this stakeholder consultation was to gather stakeholders' views on these elements.

CEPI's Key messages :

- The ETS in general, and the benchmarks in particular, should reward installations and sectors reducing GHG emissions, without penalising early movers, new investment made, and low-carbon economic growth. Fiscal and legislative stability and predictability are needed to enable investments in low-carbon technologies.
- The pulp and paper industry cannot pass through carbon costs to its customers: the global market of export goods sets prices, not the production costs of the European industry. This can be easily verified by the lack of correlation between carbon prices and final product prices.
- For “direct carbon costs”, free allocation is a necessary condition but not sufficient to avoid carbon leakage: support mechanisms should be set up to help the EU industry improve its energy efficiency and reduce its GHG emissions.
- Concerning “indirect carbon costs”, it would be better for a mandatory and harmonised EU-wide compensation scheme to address the impact of rising electricity costs due to ETS in all Member States. Financing of compensation schemes should include also, but not be limited to, auctioning revenues from ETS.
- Support for innovation in industry should not come at the expenses of carbon leakage protection: funding for innovation will have to come on top of free allowances for industry. It should be directed to directly finance large-scale demo and pilot projects, as well projects close to commercialisation stage (TRL 6-8). These are high risk, high capital investments where the private sector would not be able to deliver without the backing of public financing.
- The role that European industry plays in the circular economy and in the bioeconomy is of strategic importance for Europe’s access to raw materials and reducing Europe’s carbon footprint. This should be acknowledged when reviewing the EU ETS, by addressing the ETS impact on prices and availability of raw material, such as wood.

Read the full reponse.

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28 Nov.2014

CEPI welcomes Commission intentions for meaningful recycling in Europe and identifies enabling measures for meeting ambitious targets

UPDATE: The Commission has recently announced the withdrawal of the waste targets review and will publish a new proposal in the course of 2015.

Comments by CEPI on the European Commission proposal for a DIRECTIVE OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL amending Directives 2008/98/EC on waste, 94/62/EC on packaging and packaging waste, 1999/31/EC on the landfill of waste, 2000/53/EC on end-of-life vehicles, 2006/66/EC on batteries and accumulators and waste batteries and accumulators, and 2012/19/EU on waste electrical and electronic equipment /* COM/2014/0397 final - 2014/0201 (COD)


• Recycling Targets must be ambitious but realistic to increase collection in an environment where some Member States have already reached high recycling rates. Member States should set their target for paper packaging recycling at a minimum of 80% by 2020.
• Packaging Recycling targets in Europe should not discriminate between the different consumer packaging materials
• The proposed methodology to calculate recycling rates can favour high quality recycling but it should refer to material specific standards or similar quality assurances. For paper, the input method should continue to apply under strict input quality criteria, including for exports
• Incineration restrictions and separate paper collection obligations are needed as complementary measures to ensure recyclable paper diverted from landfills gets actually recycled.
• Final recycling must be clearly defined to ensure targets are meaningful and can be compared between Member States.

Recycling Targets: Minimum targets for Paper Packaging Recycling Rates should be set at 80% by 2020 in all Member States

European Paper Industry is a world champion in recycling, but reaching new targets will be increasingly challenging as several Member States have already reached recycling rates close to the theoretical potential of paper recycling. The average European Paper Recycling rate was 71,7% in 2013 and the sector has set a target of 70% recycling rate by 2015. The recycling rate has increased significantly from levels around 40% in 1990 and 62% in 2005, but has started levelling up since the last five years. As we reach the absolute potentials of paper recycling in some Member States, setting ambitious targets in all Member States is crucial to further stipulate recycling in less than average performing countries. Too ambitious average targets alone will however not be sufficient to reach the objectives set out in the circular economy communication. Further improvement of the paper and board packaging recycling rate will largely depend on progress in less than average performing countries. CEPI therefore proposes that all Member States set their target for paper packaging recycling at a minimum of 80% by 2020. Concrete targets for 2025 and 2030 should be set once the performance based on the proposed methodology and progress towards 2020 targets is assessed, e.g. through the newly proposed early warning system.
Recycling targets in Europe should not discriminate between consumer packaging materials and one material should not compensate for others in a Member State’s calculation of all packaging waste prepared for re-use and recycled. Recyclability and the recycling performance have increasingly become key aspects in the competition between consumer packaging materials.

Calculation Methodology : for paper, the input method should continue to apply under strict input quality criteria
CEPI welcomes the Commission’s intention to set the focus on high quality recycling. The recycling process can only deliver efficiently produced high quality recycled products if the input to this final recycling process fulfills strict quality requirements, too. The Commission proposal rightly distinguishes between final recycling processes with « clean » input material, for which the input method would continue to be applied, and final recycling processes with lesser quality material, for which the output method would have to be applied. CEPI understands the proposed discarded materials as non-target material that is not part of the original product and can be separated in dry sorting.
In the production of recycled paper, the input material for the recycling process is covered by a European Standard (EN 643). This standard sets limits on the share of non-paper components generally not exceeding 1,5%. CEPI is therefore of the opinion that for paper, the input method should continue to apply. However, the Commission proposal leaves too much room for interpretation and should refer to European Standards or similar quality assurances.
Paper for Recycling exported outside the European Union should count towards the recycling rate provided it meets the EN 643 standard and is effectively recycled outside Europe at broadly equivalent environmental conditions as in the EU. This should be demonstrated by a certification scheme as it is being considered by the European Commission and which would include in its scope the reprocessing site in the destination country and ensure traceability through adequate documentation.
Furthermore, it is of great importance that the denominator for the calculation of the recycling rates is identical in all Member States to allow for comparison.

Complementary measures to reach recycling targets
To reach high recycling targets based on the proposed new methodology, complementary measures next to the introduction of a landfill ban are however essential:

Incineration restrictions
CEPI welcomes the introduction of a landfill ban for recyclable waste. However, CEPI thinks that formulating a landfill ban for recyclable material and high recycling targets is not sufficient to reach the objectives. CEPI therefore thinks it is needed to formulate incineration restrictions for recyclable material from the municipal waste stream. This is to avoid waste is only shifted one step up in the waste hierarchy. In the past, several Member States have set the focus on diversion from landfill. This has partly led to low quality collection systems, which would not be able to deliver the input quality to recycling processes according to the new methodology as suggested bythe Commission proposal.

Obligation to collect paper separately from other recyclables and residual waste
To ensure reaching the required quality input for paper recycling processes, paper should be collected separately from other recyclables such as plastics, metal and glass, and from residual waste. The Waste Directive of 2008 has formulated a separate collection target in 2008, however Member States have interpreted this requirement in different ways. CEPI therefore urges the Commission to reinforce the requirement on separate collection for paper. Separate collection is crucial to achieve the landfill restrictions proposed by the commission.

Current recycling definition is too vague
The current definition of recycling is too vague, as it includes next to “reprocessing” also “any other recovery operations”. This leads to a wide range of interpretations, including on the recycling rate, between countries and materials. The only way to ensure material that has been discarded is effectively back in the circular economy is to make sure it is not recognized recycled unless it is reprocessed in a production process into new products, materials or substances that have comparable properties to the corresponding virgin raw materials. The proposed methodology for high quality recycling cannot be reached without a precise recycling definition. Article 3 (17) of directive 2008/98/EC should be amended as follows :

• ‘recycling’ means any recovery operation by which waste materials are reprocessed into products, materials or substances whether for the original or other purposes. It includes the reprocessing of organic material but does not include energy recovery and the reprocessing into materials that are to be used as fuels or for backfilling operations; ‘final recycling’ means reprocessing in a production process of waste or materials reclaimed from waste into products, materials or substances with similar properties as the equivalent virgin raw material based product, material or substance. It excludes pre-processing.

Next to these measures, CEPI has the following comments on the Commission proposal:
Extended Producer Responsibility : CEPI believes that the proposed provisions of Annex VII paragraph 6.1 and 6.4 place disproportionate financial burden on producers and cover aspects beyond the producers’ control. Putting the burden of « financial contributions to cover the entire cost of waste management… » would act as a disincentive for other actors with roles and responsibilities in the waste collection and sorting chain to focus on cost efficiency. Consequently the competitiveness of European economy would be harmed. CEPI believes that extended producer responsibility should not allow overlapping and duplicating payments: fees should only apply in absence of action when responsibility is delegated to compliance schemes, and fees should be charged on the basis of true cost after the deduction of all fees and revenues related to the waste generated. CEPI also believes Annex VII concerning minimum requirements for EPR should not be amended through the adoption of delegated acts since they are an essential part of the legislation.
Renewability : CEPI is concerned that the Commission published a proposal on the circular economy without mentioning renewability. CEPI believes that the contribution of renewable materials and products to the circular economy should be acknowledged, e.g. by adding renewability to the packaging eco-design options for Member States consideration. CEPI believes that such a non-binding list of ecodesign options is preferred over national packaging design requirements as proposed by the Commission as the latter would undermine the single market by producing barriers to trade.
Definition of Municipal Waste : The definition of municipal waste should not include material from the retail sector. The collection of waste from the retail sector is already well organised. Including the retail sector would divert the focus from the challenge of improving the waste collection from households and small shops.

For more information, please contact Ulrich Leberle at, mobile +32 479 905 921


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21 Mar.2014

Customer Requests: CEPI recommends use of harmonised disclaimers for voluntary declarations in the European pulp and paper industry

Companies are experiencing, in their daily customer contacts, requests for various declarations, frequently related to non-relevant topics and often totally misplaced. Answering such requests can cause misunderstandings with customers.

In order to help companies give responsible and harmonised answers to their customers CEPI recommends a set of standard disclaimers (see annex), to be routinely used depending on the type of request and on the individual discretion of each company. These disclaimers are recommended to be used routinely when signing declarations in reply to those requests, by inserting them in the declaration document. Using the same disclaimers across the pulp and paper industry will reduce the pressure of making unsubstantiated declarations and reduce reputation risks as well as the risk of possible financial claims for individual companies and the sector as a whole.

i. These disclaimers are not intended to be used when such declarations of compliance are mandatory (required by law). These shall be prepared and issued mandatorily, following the forms and ways of releasing them as the legislation requires.

ii. These disclaimers are intended to be used for voluntary declarations regarding statements attesting to the compliance with specific legislation or with qualitative and technical adaptations to non-binding technical standards. For such requests for voluntary declarations, three standard disclaimers are recommended by CEPI:

a. Issuing a declaration on the absence of certain substances
b. Refusing a declaration of compliance with non-relevant legislation
c. Issuing a declaration of compliance with non-relevant legislation

For more information, please contact Jori Ringman, at, telephone n°: +32 47825 50 70


Additional information

CEPI aisbl - The Confederation of European Paper Industries
The Confederation of European Paper Industries (CEPI) is a Brussels-based non-profit organisation regrouping the European pulp and paper industry and championing industry’s achievements and the benefits of its products. Through its 18 member countries (17 European Union members plus Norway) CEPI represents some 520 pulp, paper and board producing companies across Europe, ranging from small and medium sized companies to multi-nationals, and 950 paper mills. Together they represent 24% of world production.


Annex : Disclaimers

1. Requests that may be relevant to our sector, but which are made in a form that is neither in line with legislation nor with scientific common sense. The most frequent case to be considered is a request to declare the “absence” of certain chemicals, whilst the applicable legislation sets a specific limit or no limits are set at all. The voluntary release of such declarations should be accompanied by the following disclaimer:

With reference to the present declaration, ‘absence’ means that the final product may contain substances that were in the incoming raw materials as traces or impurities and were not intentionally added during the pulp and papermaking process.

2. Requests related to declarations that are totally irrelevant to our sector1.
In case the company decides not to release any declarations, the following disclaimer should be used:

The declaration that has been requested cannot be released, as it concerns2 [(for example) the restrictions on the content of the chemicals listed in the Directive 2002/95/EC, the so called ‘RoHS directive’, on the use of hazardous substances in electrical and electronic equipment.]
This legislation is not applicable to pulp and paper products.

3. In case the company nevertheless decides to voluntarily release a declaration where the request is related to legislation or standards that are not relevant to pulp and paper, the voluntary release of such declarations should be accompanied by the following disclaimer:

Where the present declaration refers to legislation or a standard in which this product is not included in the scope, ‘compliance’ means a declaration of intent by the manufacturer, whereas there are no legal means to formally comply due to the limitations set by the scope of the referred legislation or standard. ‘Absence’ means the final product may contain substances that were in incoming raw materials as traces or impurities and were not intentionally added during the pulp and papermaking process.

* * *
1A typical example is the declaration on the compliance with the restrictions on the chemicals listed in Directive 2002/95/EC (RoHS Directive) regarding the use of hazardous substances in electrical and electronic equipment. Naturally, such declarations are mandatory in special cases where the product is used for electronic applications.
2Insert the reference and scope of the legislation or standard relevant to the request.


The disclaimer has been translated into Spanish by our member Aspapel. Read it here

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17 Mar.2014

The paper sector social dialogue calls for boosting the re-industrialisation of the EU

The Confederation of European Paper Industries (CEPI) representing the employers in the paper industry and industriAll European Trade Union, representing 7.1 million workers across supply chains in manufacturing, mining and energy sectors are the Social Partners in the European Social Dialogue Committee for the paper sector.

In the current context of economic crisis, characterized by the decline of the manufacturing sectors, CEPI and industriAll Europe take note with great concern of the overall loss of competitiveness of the European manufacturing industries, which leads to capacity closures and job losses.
CEPI and industriAll Europe welcome the European industrial policy and its ambition to increase the contribution of the industries to 20% of the GDP by 2020. However, CEPI and industriAll believe it needs to go further in redressing the competitiveness of the manufacturing sectors.
The goal of a European industrial policy should be holistic and be directed towards safeguarding and even developing industrial activities and creating stable high quality employment while increasing efficiency and sustainability in the process, taking into account the more general objective of sustainable development.

However, high energy and raw material prices are undermining industrial growth in Europe, while our industry faces fierce competition from regions of the world where energy costs are much lower than in Europe.

Therefore, CEPI and industriAll Europe urge the European Institutions to establish the enabling and predictable conditions needed to fulfill the ambition to increase industry’s share of GDP by 20%. They ask the EU Institutions:

• To allow the industry time for adaptation, and to reduce the regulatory risks for companies, in light of the some 130 ambitious environmental targets the EU intends to achieve between 2010 and 2050.

• To carefully balance new targets in the field of climate change with considerations of increasing the competiveness of its industry and ensuring the security of energy supply with view on the absence of similar commitments from the EU main trade partners. It would be incoherent and suicidal to impose constraints on our industry while importing products that do not meet the same constraints. For the paper sector, the renewable energy policies subsidizing the use of biomass wood for burning are putting at risk the sustainable and cost-effective availability of raw materials.

• To improve the coordination of forthcoming policies and legislations – including the social ones - and shift the policy work to better and coherent regulation. As an example, the publication of a non legally-binding guidance note to clarify the implementation of the EU Timber Regulation leads in reality to a substantial modification the Regulation itself. Hence it may create legal uncertainty and additional burden for the European operators.

• To promote fair and balanced terms, including in energy, environmental and social terms, when negotiating trade agreements, which otherwise could negatively impact the competitiveness of the domestic industries.

• To further promote the Commission’s initiatives aiming at assessing the environmental regulatory layers (e.g. Cumulative Cost Assessment) and thus to create stable and enabling conditions for the European manufacturing sector keeping in mind its vision to enhance growth, safe and healthy jobs and competitiveness.

• To secure sufficient support, notably from the EU budget, for research and innovation as well as in training and qualifications of the workforce that can benefit the manufacturing industries of Europe.

At a time where the paper sector social partners are concerned about the difficulties to attract young people to work in the manufacturing industries – in particular as young people mostly see capacity closures in the EU and relocations -, only a strong and ambitious industrial policy with concrete measures benefitting all the industrial branches can reverse the trend and create the conditions for investments within the European Union.

The EU paper sector social dialogue brings together the paper workers and employers from the EU member States, represented by IndustriAll European Trade Union and CEPI.

Major challenges to the sector include falling demand for certain products and the shift towards CO2-neutral production. The move to more efficient use of raw materials and the contribution to a low-carbon economy within a forest-fibre industry combining pulp, paper and wood-based products will lead to a demand for new skills and qualifications and a need to (re-)train the workforce. The Committee is currently focusing on:

• health and safety
• skills and qualifications
• demographic change
• resources and raw material policies.

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14 Feb.2014

Europe should support, not hamper EU industrial competitiveness

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 (

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14 Feb.2014

Landfill and incineration restriction for recyclable paper

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 (, 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


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29 Nov.2013

EU-US TTIP negotiations CEPI-AF&PA joint statement

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
- AF&PA: Jacob Handelsman, Senior Director, International Trade, at

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 or follow us on Twitter @ForestandPaper.


1 Pulp: $1.95 billion / €1.52 billion and paper & paperboard $4.44 billion / €3.5 billion.

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13 Nov.2013

Road freight transport

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:
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.


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24 Oct.2013

Response to Commissioner Potočnik’s comments on the EU Air Policy Review

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.

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18 Oct.2013

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% ( 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

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