PRESS RELEASE: CEN workshop Milan set to advance standardisation needs for European paper and board value chain
CEPI, the industry association representing the pulp and paper industry at European level will coorganise a kick off meeting for a CEN workshop on identifying standardisation needs for inter-EU trade on 27 June 2018 in Milan, Italy. A three-month long process will follow where it is expected a “CEN workshop agreement” will be reached in early October.
Despite the EU gradually broadening and deepening its Single Market, new or changing technical regulations in different EU Member States have created indirect technical barriers to trade. This workshop will seek to best address solutions for combatting these barriers to frictionless trade in the EU, whilst ensuring a uniform, high level of consumer protection throughout the EU Member States.
“The fibre-based packaging chain has completely reviewed and revised its Industry Guideline for paper and board in contact with food. Through this process we have identified gaps and opportunities in European standardisation” says Jori Ringman, Deputy Director General of CEPI. “This workshop will lay the groundwork for further harmonisation within the industry and is complimentary to the long-term voluntary work to set the standards for food safety in the sector.”
The workshop will be organised under the auspices of the European Committee for Standardisation (CEN) framework and will therefore be supported by its member in Italy - UNI (Ente Nazionale Italiano di Unificazione). The kick-off meeting itself will take place at the Federazione Carta e Grafica, the association representing the whole paper and board packaging chain in Italy.
In conjunction with its efforts on standardisation and in line with its commitment to ensure the highest quality industry standards CEPI and its value chain partners will also shortly publish the revised version of the Industry Guideline for the Compliance of Paper & Board Materials and Articles for Food Contact. The revised version is expected to be published in late September.
Letter to European Commission environment department on the postponement of the Intermediate Paper Pilot PEFCR
Letter addressed to Kestutis Sadauskas, Director and Hugo Maria Schally, Head of Unit at DG Environment from Sylvain Lhôte, Director General of the Confederation of European Paper Industries (CEPI)
I am writing to inform you that CEPI will postpone the submission of the PEFCR until further activities have been finalised to achieve the operational and workable category rule the pilotshould deliver. I believe this decision deserves some explanations and I feel useful to outline our reasons for postponing the submission and the steps CEPI will take to conclude the pilot.CEPI has always shared the need to establish a customer and consumer friendly manner of communicating about the environmental performance for paper products. Indeed we recognise the initial aim of the PEF was to have a harmonised method for simplifying environmental footprints for products and organisations. It is important to include the views ofall stakeholders such as those of material and product producers as well as customers to secure a manageable workload that ensures the effectiveness of future PEFs.
For nearly seven years, CEPI has been actively assisting DG Environment in piloting product environmental footprints.
In 2011, DG Environment requested CEPI’s assistance in putting together from scratch a PEFCR project. CEPI was able to prepare at very short notice the first-ever PEFCR for paper by promptly mobilising a large number of industry experts and by implementing innovative working methods such as crowdsourcing. The project concluded that the PEFCR was too academic to be applied in daily business and would require simplification. Two years later, CEPI was invited to join the 2013 – 2016 Environmental Footprint (EF) pilot phase with the understanding that, building on the previous pilot, the new pilot would be rather limited in time and would deliver a simpler and workable tool.
Unfortunately this has not been the case. The project’s objectives turned out to be much more ambitious than initially signalled and required significantly more expert time, money and resources than was communicated to pilots. Managed by the JRC, the Intermediate Paper Pilot was due to be completed by 2016 but has been repeatedly extended. It is now expected to carry on until the first quarter of 2018 and may be further delayed. This has caused a massive burden for the organisations involved as companies could not plan over time the allocation of experts’ resources to the project. Throughout the process, our industry experts have continuously demonstrated their agility to adapt and commitment in contributing to the project.
Additional burden has been caused by what seems to be a lack of understanding by the JRC of materiality and business needs, including confidentiality. Likewise, the JRC seems to lack the ability to take into account results from the studies (especially testing the Communication Vehicles) which goes against the stated objectives of the project.
EF pilot phase had indeed three stated main objectives: 1. test the process for developing product- and sector-specific rules; 2. test different approaches to verification; 3. test communication vehicles for communicating life cycle environmental performance to business partners, consumers and other stakeholders. Instead of advancing an operational and pragmatic modelling rule in simulacra that would help produce a simplified and robust reflection of reality, the project has been pushed in an overly complex and detailed direction. When testing the communication vehicles, it was independently and unanimously found across different downstream sectors, various sizes of business and geographic locations, that all customers rejected the footprint results due to the complexity and redundancy (beyond what can be considered material) of data.
As it now stands, performing a footprint calculation with the PEFCR remains a challenge and requires either the deep expertise of in-house LCA teams or the use of external consultants at a significant cost. This will make the tool far too costly and unusable for our industry value chain mostly composed of SMEs. The maxim, set by Commissioner Vella at the EF mid-term conference, “what is not good for SMEs is not good for anyone” has obviously been lost by the JRC when it comes to the process, the complexity and the cost of the task. Worryingly, the functioning of the Intermediate Paper PEFCR is also still today unknown. In addition to their human resources, companies involved in the pilot have invested €15,000.00 (x production site x product) to produce supporting studies in 2016. A “final” PEFCR then went through a formal consultation. But somewhat inconsistently, the final PEFCR wasn’t at that time final and was then significantly amended by JRC referring to the guidance that was only made available after the “final” PEFCR was presented. The JRC is still in process of amending the PEFCR.
Industry experts and companies involved in the project have lost confidence that a meaningful and workable tool can be delivered under the current approach and process. We do regret this situation but still believe it can be resolved.
Firstly, a majority of the companies involved in the Intermediate Paper Pilot have made a commitment to review and revise the current PEFCR into an operational and pragmatic category rule.
Secondly, CEPI is willing to set aside a budget to develop this into free intermediate paper software and stands ready to extend it for final paper products. We indeed appreciate the offer by DG Environment (email 11/07/2017) to share the software code being developed for t-shirts, beer, leather and olive oil pilots. We strongly believe this could radically reduce the cost of PEF calculations in the paper value chain and make it readily available to SMEs. Both activities would fit neatly within the transition phase the Commission has announced for April 2018.
Both activities would fit neatly within the transition phase the Commission has announced for April 2018.
CEPI will therefore postpone the submission of the PEFCR until the following activities have been finalised, by the end of 2018:
1. CEPI would take over the coordination and management of the project.
2. Review and revise internally the current PEFCR to an operational and pragmatic
3. The Technical Secretariat would be restarted to formally revise the PEFCR.
ln addition, CEPI would expect DG Environment to share the software code being developed for t-shirts, beer, leather and olive oil pilots in order that CEPI can develop it into free intermediate paper software, ready to extend to a tool for final paper products.
The PEFCR and calculation tool would be actively disseminated and made available for free by CEPI to radically reduce the cost of PEF calculations in the paper value chain. We trust this approach will meet the interest of the paper value chain, its consumers and stakeholders as well as DG Environment.
I believe we can all agree that we share a common aim in producing a successful European tool that will be actually used by all businesses. I remain available to further discuss the matter at your convenience.
Sylvain Lhôte, Director General at CEPI
The above signatories have signed a proposal for the development of a systematic approach for deriving suitable BAT1-AEL2s ranges, submitted to DG Environment of the European Commission.
The legal obligation for permitting authorities to set the emission limit value for a given pollutant at a level that ensures that, under normal operating conditions, emissions do not exceed the BAT-AEL, has far-reaching consequences. BAT-AELs have to be implemented as ELV3s and industrial installations have to comply with those. A systematic approach to derive the BAT-AEL as a result of the BREF review process and the data collection performed in that context is therefore a must. A robust and transparent approach will secure consistency for stakeholders throughout the BREF review process, as well as for regulators and operators at permitting level. Based on both the Guidance published in the Official Journal of the EU in March 2012 and on our combined industrial experience, we have outlined in this paper an approach which should help deriving both ends of the BAT-AEL range systematically. This is crucial if one wants to preserve the integrity of IED implementation through appropriately-designed and truly applicable BAT conclusions, technically achievable and economically viable BAT-AELs.
1. Best Available Techniques
2. Associated Emission Levels
3 Emission Limit Values
Read the full document:
In 2007, CEPI was one of the first to propose a common framework enabling companies to undertake carbon footprints for paper and board products, as there was no standardised approach for their development at that time. Since then, three major internationally-recognised product-related carbon footprint protocols and frameworks have been published, namely:
− The “Greenhouse gases - Carbon footprint of products - Requirements and guidelines for quantification and communication” technical specification from the International Organization for Standardization (ISO/TS 14067:2013);
− The Product Life Cycle Accounting and Reporting Standard (Product Standard) from the World Resource Institute (WRI) and World Business Council for Sustainable Development (WBCSD) GHG Protocol published in 2011;
− The European Commission Product Environmental Footprint (PEF) Category Rules (PEFCR) for Intermediate Paper Products (Final Draft PEFCR for stakeholder consultation, May 2016);1
A revision of this common framework has now been undertaken to update the methods in order to be more aligned with the methods proposed in these guidance documents.
Buyers are more and more asking for the “carbon footprint” associated with the supply chain for the manufacture, distribution and disposal of products provided to them. Customers are asking for “carbon footprints” for different reasons:
− to meet public concerns
− to increase their own available information
− to improve their image and reputation
− to position against competition
− to compare different products
− to reduce the climate effect of their own activities.
The common framework aims to bring forward the attributes of our products and show the way to obtain the most useful information possible.
Discussion on the BAT conclusions for the pulp and paper sector
The new BAT conclusions for the production of pulp, paper and board was published in all EU languages in the Official Journal of the European Union on 30 September 2014 containing the legally binding requirements for all pulp, paper and board producers located in Europe. With the adoption of the Industrial Emissions Directive (IED) in 2010 for the permitting and control of emissions of installations, BAT conclusions become legally binding for all industrial and energy operators.
The publication of the BAT conclusions for pulp, paper and board production manifests the start of a four year period of intensive work. By 1 October 2018, all European pulp, paper and mills must consider the new BAT conclusions and adhere to them in their permit to operate. The permit conditions, including emission limit values, must be based on the new BAT conclusions. All mills must have revisited their environmental permit, discussed the suggested (non-prescriptive) best available techniques (BAT) and the (prescriptive) BAT conclusions with the permitting authority, and where feasible, have implemented necessary measures in the mill.
Coordinated by the European Commission’s European IPPC Bureau in Seville, the revision of the original best available techniques reference document for pulp and paper manufacturing (BREF-PP, published 2001) started already in 2006. The revised BREF-PP, published in May 2015, is a background document to the new BAT conclusions for the paper sector. It details over 900 pages pulp and paper production processes, lists BATs to consider, associated emission levels, etc. BREFs are only available in English; they have no legal status but are reference for those involved in setting permit conditions for installations.
The Confederation of European Paper Industries (CEPI) has issued an implementation guide with the objective to give mill operators and environmental managers an understanding of principles and views of importance while considering the need to revise the permit. This implementation guide discusses the BAT conclusions for the sector. It also includes a question and answer section. The guide is developed by and for industry with the purpose to help pulp and paper mills during discussions with authorities on the implementation of the new BAT conclusions.
As circumstances and interpretations differ among all EU member states, CEPI’s ambition is to support and guide operators of the sector. Doing this, we take a view that is achievable for operators within the legal framework. In the end, decisions are taken by the national or local competent authorities and, where necessary, reviewed by the judiciary. The guide is not intended for the competent authorities but to help you to refer to official documents published by the EU (in your language) and in national legislation. In order to further support industry mills operators and managers before the implementation deadline, CEPI has set up a helpdesk for frequently asked questions.
If you have any further questions, please send an email to firstname.lastname@example.org.