In the opinion of CEPI, the report by the European Commission does not go far enough. Ultimately, what the European pulp and paper industry calls for is a level playing field among the various sectors where the same raw material used for paper making or for energy should comply with the same sustainability criteria. Forest products, such as paper, already have to comply with sustainability criteria, notably through Green Public Procurement policies.
Compared with individual approaches by Member States, a harmonised European scheme is the most effective way;
- to avoid perverse incentives to use wood in a manner that is less demanding from sustainability performance and efficiencies (both energy and raw material efficiencies) perspective;
- to ensure the efficient functioning of the internal market for biomass by avoiding that biomass is transported to areas where the support mechanisms are the highest and sustainability criteria are the weakest;
- to avoid the import of unsustainably produced biomass from outside the EU considering it is likely that several Member States will rely on imports, including from non-EU countries, to achieve their renewable energy targets.
- to ensure that taxpayers' money, through its use for subsidies in the bio-energy sector, does not contribute to unsustainable practices in the forest.
In conclusion, CEPI urges the European Commission to quickly consider a legislative proposal for harmonized and binding sustainability criteria at European level.
"The European Commission reportedly states that all policy measures should aim at creating a sustainable economy. The report published today clearly demonstrates the need for a coherent EU approach among its policy areas.", commented Teresa Presas, CEPI Managing Director. "The forthcoming EU 2020 strategy should address these inconsistencies.", she continued.
The European pulp and paper industry is a significant user of wood, a natural and renewable raw material. Over years, CEPI‘s members have continuously committed to use raw materials - especially wood fibre - that comes from legal and sustainable sources. Such a commitment is increasingly third party verified according to the standards and principles of credible independent certification systems1.
In 2008, on top of the industry's strong commitment to only source legal wood2, 59 % of the wood used by the European pulp and paper industry was certified by one or more of the credible independent forest certification schemes, operating in Europe and this share is growing. The European Paper Industry is also the biggest single user and producer of bio-energy in Europe, since its biomass based energy consumption corresponds to more than a quarter of the total solid biomass based energy used in Europe.
In the context of Europe's climate change policy and of the ambitious targets set in the field of renewable energy sources, CEPI welcomes and supports the need to link the achievement of the 20% share of renewable energy target to sustainability requirements applicable to both liquid biofuels for transport and solid biomass for the generation of heat and power. Furthermore, biomass also can only be considered "renewable" if its use and its production do not have negative economic, social and environmental impacts.
Concerning the feedstocks used to reach those targets, it has to be stressed that sustainability criteria cannot undistinctly and equally apply to all kind of feedstocks. Sustainability criteria that are relevant for certain types of forests and sources of feedstocks and certain management practices might be irrelevant and create an unnecessary burden on the European producers and users of solid biomass, be it as raw material or as a resource for energy generation.