Finnish Forest Industries Federation

Finnish Forest Industry Federation Industry (FFIF) hope that the FF55 package including RED will provide regulatory stability which promotes the industry’s investments in climate friendly products and production as well as in sustainable forestry.

Finnish Forest Industry Federation Industry (FFIF) hope that the FF55 package including RED will provide regulatory stability which promotes the industry’s investments in climate friendly products and production as well as in sustainable forestry.

Finnish Forest Industries’ viewpoints on public consultation on EU renewable energy rules Wood-based products and sustainable forest management will play an important role when achieving 2030 climate targets and climate neutrality for 2050. Our industry is up to the challenge.

Finnish Forest Industries Federation (FFIF) supports the European Commissions objective in Packaging and Packaging Waste Regulation proposal to reduce packaging waste and increase the reuse, recyclability, and recycling of packaging materials.

There are limited amount of critical raw materials. The mining of such non-renewable materials have several sustainability issues. It is clear that such materials are needed. However, Europe should find and develop renewable alternatives to scarce critical raw materials. For example, by-products of pulp production (e.g. lignin) can provide promising materials to materials used in batteries.

Finnish Forest Industries Federation (FFIF) reply to Commission call for evidence for an Impact Assessment: Environmental impact of waste management – revision of EU waste Framework. FFIF supports the policy maker’s intention to optimise waste management systems to ensure high-quality recycling, including higher recycling rates and good quality secondary raw materials.

Finnish Forest Industries Federation (FFIF) welcomes the possibility to provide feedback on the proposal for establishing a certification framework for carbon removals. Why our industry is in the sweet spot of carbon removals? 1. Technological sinks: Our industry manufacturers various wood-based products, but we also produce bioenergy from low quality wood (so called side streams).

Finnish forest industries would like emphasize following aspects: • Nature-based carbon removals should primarily help member States to reach their LULUCF targets. More clarity is needed on the interaction between the LULUCF regulatory framework and the proposed certification of carbon removals and on the impact on raw materials availability • Carbon removals from forests play a key role in achieving the EU climate…

It is important to continue developing methods to calculate the life-cycle environmental impacts of products The Green Claims Directive directs companies to use widely recognized scientific evidence to assess the life-cycle environmental impacts of products.

In principle, the Finnish forest industry supports the initiative’s good ambition of sustainable products. An effective transition to a bio-based circular economy requiring sustainable products to become the norm. The ESPR is a broad and ambitious framework law that all products produced by the Finnish forest industry.

Filed in Finnish · English published by the European Commission

1 (2) Eeva Korolainen 18 November 2021 Finnish Forest Industries Federation Register ID number: 39671713910-36 Eeva Korolainen, Trade Policy Manager [email removed] Finnish Forest Industries’ response to the consultation on the Carbon Border Adjustment Mechanism (CBAM) Finnish Forest Industries Federation (FFIF) wishes for the FF55 package, including the CBAM, to provide regulatory stability that would promote…

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

Forest industry plays a significant role in mitigating climate change and reaching European Green Deal objectives. The industry offers climate friendly products for European and global markets, also substituting more fossil intensive alternatives. Reaching i.a. climate objectives requires the safeguarding of EU industries' competitiveness and legislative predictability and stability.

Europe needs competitiveness. Elevating European bioeconomy as a driver of competitiveness requires broad understanding. While biotechnology is an important part of the bioeconomy, it is too narrow when considering industrial production and global business opportunities. Thus, the Finnish Forest Industries Federation emphasizes that the Biotech Act must adopt a comprehensive approach.

The Finnish Forest Industries Association represents Finnish forest-based industries. As an important sector of the bioeconomy, we offer solutions that can replace fossil-intensive products, store and utilise captured biocarbon, and meet the needs of consumers, industry and society. Finnish forest-based industries are already well advanced in the transition away from fossil fuels.

Filed in Finnish · English published by the European Commission

Finnish Forest Industries Federation Register ID number: 39671713910-36 Ahti Fagerblom, Manager, Climate and Energy Policy [email removed] Finnish Forest Industries’ response to the consultation on the Energy Efficiency Directive (EED) Finnish Forest Industry Federation Industry (FFIF) silver that the FF55 package including EED will provide regulatory stability which promotes the industry’s investments in climate…

Filed in Finnish · English published by the European Commission

Finnish Forest Industries’ viewpoints on public consultation on EU energy efficiency directive (EED) Wood-based products and sustainable forest management will play an important role when achieving 2030 climate targets and climate neutrality for 2050. Our industry is up to the challenge.

Finnish Forest Industries Federation Register ID number: 39671713910-36 [name removed], Senior Adviser, Energy [email removed] Finnish Forest Industries’ response to the consultation on the Emissions trading system (ETS) Finnish Forest Industry Federation Industry (FFIF) hope that the FF55 package including ETS will provide regulatory stability which promotes the industry’s investments in climate friendly products…

The following aspects should be taken into account in the upcoming update of EU ETS: To assure the level playing field between EU and the rest of the world and to avoid carbon leakage, it is utmost important that the new environmental regulation is implemented simultaneously in all marine areas of the world (IMO timetable). No EU-wide ETS for maritime transport should be created.

The Finnish Forest Industries Federation supports the EUs climate neutrality and competitiveness goals and highlights the importance of scaling biomanufacturing to strengthen resilience and reduce strategic dependencies.

The Finnish Forest Industries Federation welcomes the public consultation initiated by the European Commission. The Finnish Forest Industries Federation, representing the pulp and paper industry in Finland, has followed with concern the process for harmonised classification and labelling of DTPA and titanium dioxide (TiO2).

Finnish Forest Industries Federation Register ID number: 39671713910-36 Ahti Fagerblom, Manager, Climate and Energy Policy [email removed] Finnish Forest Industries’ response to the consultation on the Energy Taxation Directive (ETD) Finnish Forest Industry Federation Industry (FFIF) hope that the FF55 package including ETD will provide regulatory stability which promotes the industry’s investments in climate…

Overlapping, cumulative effects of the Energy Taxation Directive (ETD) and the Emission Trading System (ETS) must be avoided to ensure European industries' global competitiveness. The effective steering mechanism of the ETS already comprehensively accounts for CO2 externalities by inflicting costs on energy-intensive industries in proportion to their GHG emissions.

Memo Maija Rantamäki 1 (2) 19 August 2022 Finnish Forest Industries Federation’s response to the commission's consultation on the Nature Restoration Law Forest industry products and sustainable forest management play an important role in achieving the European Green Deal goals.

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

The Finnish Forest Industries Federation (FIFF) supports the objectives of European Green Deal and ensures that the Finnish forest industry sector is willing to continuous environmental improvement and green transition. FIFF emphasises that the Industrial Emissions Directive (IED) has been an effective tool for reducing industrial emissions.

Feedback 1 (2) 20 April 2020 Finnish forest industry feedback - Public consultation on the Inception Impact Assessment for the Industrial Emissions Directive The Industrial Emissions Directive (IED) and sector-specific BAT conclusions have resulted in a considerable reduction of industrial emissions. Emissions have been reduced greatly even before the directive was adopted.

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

The Finnish Forest Industries Federation thanks for the opportunity to comment on the legislative proposal of the Weights and Dimensions Directive. Based on over 30 years of experience, we see higher weights and dimensions as the solution for more freight to be moved with less emissions in Europe.

Finnish Forest Industries Federation thanks for the opportunity to participate in this call for evidence. Representing one of the biggest industry branches in Finland, forest industries have been actively involved in developing weights and dimensions of road transport for over 25 years.

The Commission wants to elevate the status of sustainability reporting which is understandable because together with financial information it gives a comprehensive picture of a company. The proposal for a sustainability reporting directive includes various new aspects and would broaden the scope of sustainability reporting. However, it is good that non-listed SMEs would be left outside of the scope.

The Finnish forest industry is committed to sustainability and with our renewed sustainability commitments spanning to the year 2025 we aim to demonstrate leadership and continuous improvement in sustainability. Thus, the industry has supported the top-level environmental objectives enshrined in the EU's framework to facilitate sustainable investment.

Through interaction with people ecosystem services become commodities and benefits that promote human well-being. Forests produce many different ecosystem services. Biodiversity maintenance, wood and wood fibres are important provisioning services. Other key ecosystem services the forest produces include eg. carbon sequestration, regulation of water quality and cycles, food production, and recreational use.

The Finnish Forest Industries Federation (FFIF) considers it important to raise awareness and build capacity within the EU on the development of climate resilience and risk management. FFIF aligns with the European Climate Risk Assessment report published by the EEA in 2024, which states that the most impactful climate action is to reduce emissions, without relying so heavily on forest-based mitigation.

The reporting requirements for businesses have significantly increased, especially in the realms of environment, sustainability, climate, energy, and finance policies. For instance, sector-specific European sustainability reporting standards stemming from the Corporate Sustainability Reporting Directive and mentioned in the Commission's work programme for 2024, reporting related to climate and environmental taxonomy…

The proposed 40% gap between typical and default values forest biomass fuels supply chains is not justified since the motivation behind it seems like to discourage the use forest biomass. This is not appropriate for a technical annex. A decision to change values mentioned in this way does not seem particularly fact based or supported by scientific reports.

Finnish Forest Industries’ response to the consultation on the LULUCF regulation Finnish Forest Industry Federation Industry (FFIF) silver that the FF55 package including LULUCF will provide regulatory stability which promotes the industry’s investments in climate friendly products and production as well as in sustainable forestry.

Filed in Finnish · English published by the European Commission

Wood-based products and sustainable forest management will play an important role when achieving climate neutrality for 2050 as proposed by the Commission in Green Deal. Our industry is up to the challenge. We are contributing to mitigating climate change by decreasing fossil emissions and by bringing novel and traditional products from renewable resources into markets while simultaneously the European forest…

Memo Maija Rantamäki 1 (2) 5 May 2022 Answer by the Finnish Forest Industries Federation to the call for evidence on New EU Framework for Forest Monitoring and Strategic Plans The Finnish Forest Industries Federation (FFIF) welcomes the EU Commission's efforts to improve the quality and comparability of EU-level forest data.

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

Finnish Forest Industry Federation Industry (FFIF) hope that the FF55 package including FuelEU Maritime will provide regulatory stability which promotes the industry’s investments in climate friendly products and production as well as in sustainable forestry.

Forest industries are one of the biggest freighters in Finland transporting annually over 80 million tons of raw-wood and products within Finland. Wood is collected from forests and terminals all around Finland and transported by rail, road and inland waterways to the factories.

To achieve climate neutrality in 2050 the EU needs to promote carbon removals. The policy framework should recognise the benefits of the biogenic carbon cycle and the climate benefits of wood-based product value chains (sink, sustainable carbon source, carbon stock, substitution). Forest industry is an important part of the solution in all key carbon removal measures aiming for negative emissions: 1.

While the FPR has been successful in setting a harmonised framework, its current structure risks slowing innovation and circularity. Currently, the FPR has too strict requirements for CMCs and too narrow list of allowed CMCs, which limits the use of new materials (particularly waste) and the development of new types of products.

Finnish Forest Industries Federation supports the prohibition of the destruction of unsold consumer goods. However, there are still unclear points regarding what the implementing acts on the disclosure of information on discarded unsold consumer goods will include. The implementing acts should consider only the products made available on the market, as defined in the ESPR FAQs.

Finnish Forest industries Federation welcomes the European Commission efforts in seeking proportionate and targeted actions to reduce the impacts of products that are imported to the EU and that are associated with deforestation.

The Finnish Forest Industries Federation (FIFF) supports transparency and availability of environmental information. According to an impact assessment the existing European Pollutant Release and Transfer Register (E-PRTR) has proven to be a pivotal knowledge base on emissions from EU industrial activities. It gives the public access to high-quality data, thereby supporting environmental decision-making.

The Finnish Forest Industries Federation welcomes the upcoming fitness check to evaluate the key legal instruments of the FLEGT Action Plan, namely the FLEGT Regulation and EU TR. The Finnish forest industry actively promotes procurement of legal timber and subsequently usage of legal timber in the whole value chain.

The Finnish forest industries support ambitious EU climate policy and contribute to climate solutions through bio-based products that replace fossil-intensive alternatives and store bio-based carbon. Based on domestic renewable raw materials, wood, the sector strengthens Europes self-sufficiency, resilience, economy, and employment.