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 CEPIDownload here
Methodology for the development of a systematic approach to derive suitable BAT-AELs ranges
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:
Framework for Carbon Footprints for paper and board products
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.
Best Available Technique (BAT) Conclusions for the Production of Pulp, Paper and Board
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.
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.
ECHA launches the Classification and Labelling Platform
The new C&L Inventory feature is a web-based discussion forum where C&L notifiers and REACH registrants of the same substance can come together and agree on the classification and labelling of their substance.
The publication of the C&L Platform is one of the ECHA initiatives to support companies to proactively work on the quality of their notifications and better fulfil their legal obligations to come to agreed entries on the C&L Inventory when appropriate. It provides an easy and safe way for companies to get in contact with notifiers or registrants of the same substance. The aim is to facilitate compliance with the CLP Regulation and improve the overall quality of the public C&L Inventory data. It will also be beneficial for SMEs as they will be able to follow the classifications set by larger companies.
The C&L Platform is simple and user-friendly. It can be accessed through the C&L Inventory web page on the ECHA website and discussion features are available for each substance that has different notifications in its Inventory summary page. Each discussion room is accessible only to those registrants and notifiers who have submitted a notification for that particular substance. Once agreement is reached on a common classification and labelling, companies have to notify the Agency accordingly and update their notifications in REACH-IT. These changes are subsequently reflected in the public C&L Inventory on the ECHA website.
The Agency is organising a public webinar in March on the use of the platform. More information will soon be published on the ECHA homepage.
CEPI is partner of the 2012-2013 campaign 'Working together for risk prevention'
The Healthy Workplaces Campaign 2012–13 ‘Working together for risk prevention’ encourages managers, workers and other stakeholders to join forces to improve safety and health.
The Campaign is co-ordinated by the European Agency for Safety and Health at Work (EU-OSHA), and partners in the EU’s 27 Member States and beyond.
The 2012–13 Healthy Workplaces Campaign is decentralised and is designed to help national authorities, companies, organisations, managers, workers and their representatives and other stakeholders to work together to enhance health and safety in the workplace.
The campaign focuses on:
- risk prevention
- managing risks
- encouraging top managers to actively engage in risk reduction
Central to the campaign are a range of materials that will further these goals. These include reports, practical guides, flyers, posters and DVDs.
CEPI has just published a report along with EMCF entitled 'No Paper without Skilled, Healthy and Safe People'. View the report here.