Association of the Austrian Wood Industries

We would like to express the following views on the legislative act: 1) A separate registration in each country involves an enormous amount of work: understanding the specific requirements of each country, registering 27 times, and then constantly uploading data 27 times and paying 27 invoices. On top of that, managing 27 accounts, updating 27 accounts when a member of staff changes, carrying out 27 audits, etc.

In order for the transformation envisaged by the European Green Deal to succeed and the set renewable energy targets to be achieved, appropriate low-CO2 alternatives to energy supply are necessary. That is why more electricity from renewable sources, climate-friendly gases and fuels as well as renewable heat in adequate quantities are required.

The Association of the Austrian Wood Industries welcomes the Commission's initiative to revise and simplify the delegated acts on the EU taxonomy. The delegated acts are quite difficult to apply and involve a high administrative burden for companies, especially SMEs. Please see comments in the enclosed file

We welcome the proposal for a revision of the Energy Performance of Buildings Directive (EPBD) as a contribution to achieving the EU's 2030 energy and climate targets and the 2050 climate neutrality target. Decarbonizing the building sector is an important step towards achieving the EU's climate and energy targets. Consequently, it is also important to consider all aspects.

Statement of the Association of the Austrian Wood Industries on the Proposal for a Regulation establishing a Union certification framework for carbon removals General information: The Association of the Austrian Wood Industries welcomes in principle the Union framework for the certification of CO2 removals, in which quality criteria and rules for verification and certification as well as for the operation of…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The overall target is climate neutrality by 2050. However, it is essential that the measures support decarbonization and climate neutrality and do not mean excessive negative developments for the European economic area as a single effort.

The industry constantly takes new initiatives to improve energy efficiency. Due to the high energy costs, it is a matter of course to continuously question the energy efficiency of the systems and technologies. But it is becoming more and more challenging to take new measures.

We welcome the publication of the proposal for the revision of the CPR and would like to take the opportunity to provide feedback. A well-functioning internal market for construction products based - as the main route - on harmonised standards as a tool for technical language and harmonised assessment methods is urgently needed.

Statement of the Association of the Austrian Wood Industries on the Proposal for a Regulation of the European Parliament and of the Council on nature restoration - 2022/0195 (COD) General: In principle, the Association of the Austrian Wood Industries welcomes the measures of the European Commission to reduce the effects of climate change and biodiversity loss.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The European Commissions initiative on affordable housing offers a good opportunity to promote sustainable development in the housing sector by providing low-carbon, biobased and energy-efficient housing solutions. The decarbonisation of housing in the European Union aims to make the building sector climate-neutral by 2050.

The Association of the Austrian Wood Industries would like to express its gratitude for the opportunity to contribute to the simplification of legislation aimed at facilitating housing construction as a means of tackling the housing affordability crisis. Please see our views in the attachment.

At the outset, it is stated that the first problem is that carbon depletion in the land sector has declined in recent years: due to increasing harvest rates in connection with wood demand and forest aging, persistent emissions from organic soils, natural disasters and a lack of political and financial incentives.

We welcome the initiative for a new EU Framework for Forest Monitoring and Strategic Plans. Indeed, a European forest monitoring system can help to strategically plan and swiftly react to ever-growing pressure from climate change on Europe's forests.

European forests are essential to achieve the target of -310 Mt CO2 in the LULUCF sector. In the form of wood, they are a renewable source of raw materials available across Europe, on which a strong value chain depends. However, this report shows that the health and sinking effects of forests are declining due to climate change and ageing, and that the sink effect has so far been greatly overestimated.

Filed in German · English published by the European Commission

We are pleased to have the opportunity to offer some views on the evaluation of the Economic Partnership Agreement (EPA) with Japan after five years of implementation. The objectives of teh agreement are to liberalise and facilitate trade and investment and promote a closer economic relationship between the EU and Japan.