Finnish Forest Industries Federation

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.

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

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 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 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 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.

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)

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.

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.