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Paper industry points out major topics for second round negotiations
The Confederation of European Paper Industries (CEPI) supports the negotiations of an EU-US Transatlantic Trade and Investment Partnership (TTIP), aiming at the full liberalisation of bilateral trade in goods and services. Its largest potential benefits lie in raw materials and energy trade liberalisation, cooperation on rules and standards as well as future regulation frameworks, according to CEPI. The paper industry in the EU and the US will deliver relevant provisions for the agreement through a constructive sectoral dialogue.
Underlining the importance of this partnership CEPI Director General Teresa Presas stated: “We believe a well-negotiated partnership represents a strong potential driver for mutual job creation, economic growth and competitiveness in our industry. The EU and the US are significant players in the global pulp and paper market. They trade 4.5 million tonnes of pulp and paper every year and account for more than 40% of the worldwide production.”
The EU-US TTIP needs to explore trade liberalisation in the area of raw materials and energy. Here, the TTIP negotiations have to ensure free access to energy within the transatlantic market, particularly natural gas from the US. Gas prices in Europe have doubled since 2003, while shale gas has brought US gas prices to extraordinary low levels. Additionally, imports of chemicals into the EU are still affected by tariffs and starch imports are subject to substantial charges before entering EU markets.
Subsequently, cooperation on rules and standards could fetch higher efficiencies, lower compliance costs for industry as well as reduced administrative burden. The US and EU, for example, have both taken major steps when it comes to wood legality. The US implemented the Lacey Act several years ago and the EU recently adopted the Timber Regulation. The two schemes need to converge in scope and requirements and aim at a simplified declaration systems to become more effective in addressing illegal logging.
Additionally, CEPI considers it essential to promote cooperation at an early stage and set a framework for future consultations and impact assessments. Impact assessments on trade and investments flows should be prepared every time regulatory initiatives start. And analyses of existing regulations that come up for review are essential for increasing compatibility and coherence in regulation. Finally, cooperation on new and emerging issues such as nano-materials would help prevent future trade irritants.
More details in the CEPI position paper on the EU-US Transatlantic Trade and Investment Partnership: http://www.cepi.org/node/16581
For more information, please contact Daniela Haiduc at firstname.lastname@example.org, mobile: +32(0)473562936
Note to the Editor
EU-US Transatlantic Trade and Investment Partnership site: http://ec.europa.eu/trade/policy/in-focus/ttip
European Commission press release 11 November: http://europa.eu/rapid/press-release_IP-13-1069_en.htm
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
Europe must enable industry to compete more effectively within the Single Market and global context to create jobs and generate sustainable growth. This requires a realignment of EU policies in support of industrial competitiveness.
Increasing industry’s share of production to 20% by 2020 would create at least 400.000 new jobs a year, reversing the losses of recent years. Alongside those new jobs in the industrial sector, many more jobs would be created in the supporting service sector.
The strategy paper builds on the first set of horizontal policy recommendations published by BUSINESSEUROPE in “Manufacturing a prosperous Europe” (date February 2013). It puts forward a series of concrete policy proposals in nine policy fields of strategic importance where progress is needed for a pro-industrial growth environment.
BUSINESSEUROPE’s 5 key recommendations to support industrial competitiveness:
- Open global markets
An ambitious and competitiveness-driven internal and external trade policy agenda is a priority for growth. Fighting protectionism and opening foreign markets should be the leitmotiv of an ambitious EU free trade agenda.
- Get the balance right in energy and climate policy
The EU needs to reassess its approach to energy. The high cost lessons from the current EU policy need to be fully addressed while taking game changers as the shale gas revolution in the US and the very limited progress in global climate talks into account. This requires an energy policy that addresses security of supply and climate/environmental concerns in a cost-competitive manner and that promotes significantly improved coordination of member state energy mix strategies.
- Finance future industrial growth
Improving access to corporate finance is vital for industrial companies and economic growth. These actions need to be underpinned by steps towards the implementation of the banking union. European financial market reforms need to balance safeguarding financial stability and financing needs of companies without generating undue negative impacts on lending. Furthermore, the market-led development of alternatives to traditional bank finance must be supported.
- Secure the supply of raw materials at competitive prices
European industry is heavily dependent on the import of critical raw materials and energy. It is essential to reduce export restrictions on raw materials applied by some resource holding countries and to ensure that EU environmental and other legislation does not inadvertedly undermine the import of primary or secondary raw materials into Europe.
- Translate skills into employment
The availability of a skilled workforce, in particular people with Science, Technology, Engineering and Mathematics (STEM) skills, is an essential to improve industrial competitiveness and innovation. Europe must increase the number of students and graduates in STEM subjects. In addition, the principles of work-based learning as apprenticeships and dual learning elements must be included as well as strengthened in Member States’ existing systems.
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 email@example.com, 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