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16 Nov.2017 ,

Letter to European Commission Vice President Timmermans on Plastics Strategy


The undersigned organisations are writing to express deep concern over the European plastics strategy currently under development. Based on drafts released by the media, we believe the strategy seriously risks: 1) being developed in silos of plastics without a systemic view, 2) failing to respect the principle of technological/material neutrality and having serious unintentional and unassessed consequences for competing materials and technologies that may in some cases perform better in terms of environmental impacts and circularity and 3) missing the opportunity to drive a low-carbon circular economy. Representing sectors that both compete and work with plastics, we would call upon you to take corrective measures, including the concrete requests for actions listed below before the Commission moves to adopt the strategy.

1) The strategy is being developed in silos of plastics without a systemic view
Plastic materials compete on the market with many other materials with similar or better functionalities and similar or lower negative impact. We strongly believe that the silo approach adopted by the Commission – ignoring interactions, market mechanisms, competition, implications on the whole packaging value chain – will have serious unassessed and unintended consequences and does not ensure fair and equal treatment of all materials. In our view, the draft plastics strategy fails to consider and assess the value chain systems both within the petrochemical industry and even more so in the wider economy. Our observations include:
• the evident market failures of plastic prices; instead the strategy seems to suggest introducing more financial support mechanisms despite the fact that oil and gas subsidies in the EU are significant and have been growing in the OECD at a much higher rate than the growth of GDP ;
• the potential to substitute plastics by better alternatives for some applications;
• the potential to replace fossil feedstock by alternative feedstocks (to name but one, sustainable lignin );
• the sourcing element as circularity is not only about recycling but about the sustainable production of input material; sustainable sourcing is a growing concern and already a legal requirement for other technologies;
• the market impacts for other solutions, materials and products;
• other key policies such as climate change, mobility or bio-economy.

The undersigned deeply regret that - despite several attempts to be heard - they have not been allowed to contribute to the discussion on the strategy.

We would call for the Commission to incorporate the following elements in the plastics strategy:
I. Interaction of the many connected policies, including low-carbon bioeconomy.
II. Implications for competing technologies and materials to ensure fair competition and a level playing field.
III. A holistic view reflecting the reality where plastics are not addressed in isolation and a dynamic understanding of the sectors involved and impacted by the strategy.
IV. Assessment of the systems of value chains within the petrochemical industry, with a view to subsidies for fossil-based plastics and in the wider economy.
V. Assessment of the petrochemical industry as a resource.
VI. Improved assessment of alternative feedstocks, including existing by-products from other sectors and their accessibility, and symmetry in assessing traditional fossil feedstocks’ environmental impacts.
VII. Our industry should be included in the platforms which will be established to discuss and implement this strategy as it will have a direct impact on us.

2) The strategy risks failing to respect the principle of technological neutrality
The measures proposed in the draft plastics strategy and the associated financial and other support would fail to respect the principle of technological neutrality and non-discriminatory policy. And this, notwithstanding that circular economy targets would remain lower for plastics than for other materials.

We find it unfair to have a strategy that rewards the laggards whilst other materials who have done the work and paid for it themselves in the past decades risk being penalised. It would be a strange outcome if the final strategy were to favour a material that remains problematic over less problematic ones.

We would call for the Commission to incorporate the following elements in the plastics strategy:
VIII. Full respect of the principle of technological neutrality in a fair and equal approach.
IX. Reserving an equal amount of public funding for other solutions, materials and technologies as will be the case for plastics.
X. Acknowledgment and promotion of sustainable substitution by competing solutions, materials and technologies; more sustainable packaging materials should be preferred when there is a choice.
XI. Assessment of, and setting policy requirements for, plastics with metrics and boundaries comparable to competing technologies; targets set for plastic materials have to be set on a par with targets for other materials.
XII. Consideration of the full life cycle of plastics, including upstream sourcing of feedstocks (both alternative and traditional).

3) The strategy misses an opportunity in a low-carbon and circular economy
The strategy misses an opportunity to combine a drive for resource efficiency and a move away from non-renewable resource use. As highlighted by President Juncker and the Industrial Policy Strategy released by his Commission, the aim is to build a low-carbon circular economy.

The potential offered by the bio-based economy should be considered alongside the potential to streamline the plastics value chain and make it more efficient. The US public procurement strategy for bio-based materials and products has had a significant positive impact in terms of growth and jobs : similarly the public procurement in Europe should first consider sustainable substitutes to plastics.

We would call for the Commission to incorporate the following elements in the plastics strategy:
XIII. To ensure that public procurement rules or economic incentives are fair, proportionate and not unduly supporting a material, such as recycled plastics, instead of choosing other solutions, materials and technologies, in particular renewable or already highly recycled, over fossil-based plastics.
XIV. Indeed, we would call for the Commission to incentivise industry to encourage companies to choose more sustainable, renewable materials in the first place when selecting their packaging materials. This might be through taxation on the use of plastic or providing positive incentives to use more sustainable materials.

We share a common aim: producing a sustainable circular European economy. The buy-in of the wider economy and society in general for the plastics strategy prepared by the European Commission would require a much more holistic and systemic approach and respect of the principle of technological neutrality by giving a fair and equal treatment to all sectors. At the same time, the plastics strategy should be seized as an opportunity to bring the plastics industry on a par with other industry sectors regarding responsible performance, not least to protect the marine environment and other water bodies.

We remain at your disposal to discuss the matter further and will be in contact with your respective teams of Commissioners in order to support the development of the strategy.

Kind regards,

CITPA, International Confederation of Paper & Board Converters
CEPI, Confederation of European Paper Industries
ACE, The Alliance for Beverage Cartons and the Environment
CEPI CONTAINERBOARD, European Producers of corrugated case materials
CEPI EUROKRAFT, European Producers of Sack Kraft Paper and Kraft Paper
ECMA, European Carton Makers Association
EMBALPACK, European Association of Makers of Packaging Papers
EMFA, European Moulded Fibre Association
EUROSAC, European Federation of Multiwall Paper Sack Manufacturers
FEFCO, European Federation of Corrugated Board Manufacturers
PRO CARTON, European Association of Carton and Cartonboard Manufacturers

 

CC: Commission Vice-President Katainen, Commissioners Moedas, Vella, Bienkowska
Secretary General of the Commission
Director Generals of DG Grow, DG RTD, DG ENV

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13 Nov.2017 ,

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
category rule.
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

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13 Nov.2017 ,

European paper industry takes over environmental footprint method from EU

The Confederation of European Paper Industries (CEPI) informed the European Commission on 13 November of its intention to take over the PEFCR (Product Environmental Footprint Category Rules) prepared under a larger EU pilot on environmental footprints.


The PEFCR project promised to deliver a clear, simplified and workable method for environmental footprinting that our value chain could effectively use and rely upon. After more than four year’s work, the European Commission body in charge of the project is far from this objective. CEPI will now take the necessary measures to conclude the project and design a tool that is meaningful for business and workable for SMEs,” says Sylvain Lhôte, Director General at CEPI.


Initiated in 2013, the Intermediate Paper Pilot was meant to deliver a methodology for environmental footprinting of intermediate paper in a clear and workable format for all users. It was considered, at that time, that the workability of future PEF rules was imperative for the paper value chain, particularly SMEs. Led by the European Commission’s Joint Research Centre, however, the project has since been turned into an overly academic tool and the process continuously delayed.


The industry recognises the value of establishing a reference tool for communicating the environmental performance of paper products to customers and consumers. The industry has therefore decided to take back the lead from the European Commission and revise the PEFCR. In order to do so, CEPI has outlined a number of key steps in a letter sent to the Commission’s environment department here. The process would lead to developing free software for calculating the environmental footprint of intermediate paper, which could be extended by the printing and paper converting associations to a tool for final paper products. CEPI believes these steps are achievable over the 2018 – 2019 period.

Note to editor:

CEPI is the pan-European association representing the forest fibre and paper industry. Through its 18 national associations CEPI gathers 495 companies operating more than 900 pulp and paper mills across Europe producing paper, pulp, cardboard, tissue and other bio-based products. CEPI represents 22% of world production, €81 billion of annual turnover to the European economy and directly employs over 175,000 people.


For more information, please contact Jori Ringman, Deputy Director General at j.ringman@cepi.org or by phone at (+32) 478 25 50 70

For press related enquiries, please contact Ben Kennard, Press Manager at b.kennard@cepi.org or by phone at (+32) 487 39 21 82
 

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09 Nov.2017 ,

ETS reform restores regulatory certainty but gaps remain

Following today’s inter-institutional political agreement on the Emissions Trading System (ETS) the Confederation of European Paper Industries (CEPI) is broadly encouraged by improvements in the regulation for the 2021-2030 period.

The conclusion of the ETS negotiations now restores the regulatory predictability needed for advancing industrial transformation. Investments in low-carbon technologies are core to what we stand for as an industry. A more stable regime and tools such as the ETS Innovation Fund will be crucial in accelerating the industry's transition towards a low-carbon circular bioeconomy” says Sylvain Lhôte, Director General of CEPI.

The final compromise text improves significantly the scheme with a more robust stability in carbon leakage provisions and firmer predictability in reviewing the benchmark values. The Innovation Fund will also act as a crucial mechanism in advancing the breakthrough technologies that will spur the industry’s low-carbon transition.

Nonetheless, several aspects of the text are lacking and these would need to be resolved. For instance, the Market Stability Reserve (MSR) was significantly amended without any prior assessment of its impact on “industrial competitiveness and the risk of carbon leakage”, even though this was an explicit requirement when amending the MSR decision. Likewise, no solution was found to effectively ensure compensation for indirect costs for exposed energy intensive installations. Finally, while the risk of a shortfall in free credits has been mitigated it has not been structurally eradicated thereby causing unnecessary regulatory risks. The impact of all of the above-mentioned aspects will become more evident by 2021, when all implementing legislation will be finalised. It is therefore imperative to swiftly finalise the full regulatory landscape by adopting all the implementing acts well ahead of 2021.

Note to editor:

Ensuring that the ETS also functions as a pro-investment tool is a core component of the European paper industries ‘2050 Investment Roadmap’. Check out our ‘Alignment matrix’ here to see how the ETS can provide a platform for catalysing and enabling industry transformation in Europe.

For more information, please contact Nicola Rega, Climate Change and Energy Director at n.rega@cepi.org or by phone at (+32) 485 40 34 12

For press related enquiries, please contact Ben Kennard, Press Manager at b.kennard@cepi.org or by phone at (+32) 487 39 21 82

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