Swedish Forest Industries Federation

Swedish Forest Industries’ position on REDIII in the “Fit for 55”-proposal Please find the full feedback in the attached position paper. Summary Support a higher renewable share in the EU energy mix, but allow for rules on forest biomass to be properly evaluated before new ones are discussed The Swedish Forest Industries support the Green Deal and the important goal of a climate neutral society by 2050.

SFIF welcomes the European Commission´s objective to set revamped harmonised rules on packaging and packaging waste with the aim of putting an end to wasteful packaging and boosting its reuse and recycling. In the framework of the European Green Deal and the Circular Economy Action Plan, it is crucial to ensure that products placed on the European market contribute to reach the climate neutrality by 2050 objective.

Swedish Forest Industries welcome the new Circular Economy Action Plan, as we believe it will be beneficial in achieving the overall targets for the European Green Deal. Reduce waste and create better conditions to improve reuse and recycling of goods are necessary to achieve the transition to (more) circularity of resources.

The Swedish Forest Industries Federation represents the Swedish forest industry. Our members refine wood resources to bio-based products. These includes among others pulp, paper, board, packaging material, sawn timber, refined wood products and advanced biofuels. The Swedish forest industry fully support the objective of achieving a climate neutral EU by 2050.

The Swedish Forest Industries Federation welcomes a certification of carbon removals to further incentivice forest based climate solutions, and proposes recommendations for how to improve the framework to make it more implementable and focused on the core objective of removing carbon.

Our forests are key in addressing the global challenges of climate change and biodiversity loss. Forests boasts the majority of terrestrial biodiversity, and they are one of the most important solutions to addressing the effects of climate change as they provide important carbons sinks absorbing and storing large quantities of CO2 and supply renewable and recyclable raw materials to substitute fossil resources.

The Swedish Forest Industries Federation (SFIF) welcome the opportunity to contribute further to the 2026 review of the EU Emissions Trading System (ETS). The Swedish pulp and paper industry fully supports the EU objective to reach climate neutrality by 2050.

Swedish Forest Industries Federation (SFIF) welcomes the European Commission´s objective to set a baseline for requirements for substantiation of environmental claims to mitigate greenwashing. The proposal constitutes an important and needed piece of legislation which complements other legis-lation related to consumer protection.

The Swedish Forest Industries Federation represents the Swedish forest industry. Our members refine wood resources to bio-based products. This includes among others pulp, paper, board, packaging material, sawn timber, refined wood products and advanced biofuels. Some members have large forest holdings. The Swedish forest industry is highly trade intensive.

Swedish Forest Industries Federation (SFIF) welcomes the European Commission’s ecodesign requirements for sustainable products as well as the establishment of overarching sustainability requirements. In the framework of the European Green Deal and the Circular Economy Action Plan, it is crucial to ensure that products placed on the European market contribute to reach the climate neutrality by 2050 objective.

Swedish Forest Industries Federation (SFIF) welcomes the Commission’s action plan on circular economy and the Sustainable Product Initiative acknowledging the importance of ensuring the placement of more sustainable products on the Internal market to support Europe’s transition towards a more circular economy and achieve the goals set under the European Green Deal.

The Swedish Forest Industries Federation represents sawmills and pulp and paper mills supply a substantial share of the biomass and bio-based products in the EU, including side streams for energy use. The sector relies on the possibility to practice active sustainable management adapted to the local context to produce raw material.

The Swedish Forest Industries Federation represents companies that use forests to provide the raw materials for their products and services. This includes producers of pulp, paper, cardboard, packaging and biofuel. Similarly, sawmills producing all sorts of boards, planks, roof trusses and other prefabricated construction elements are also included.

The Swedish Forest Industries Federation (SFIF) represents companies that are large producers and users of renewable energy. Internal use of biomass residues is an important part of the industries substitution of fossil fuel. Sustainable primary and secondary biomass, as well as transport fuels, renewable electricity and heat, constitute a significant share of RES in Sweden and the EU.

Swedish Forest Industry Federation, SFIF, welcomes a discussion of nature restoration, but more focus would be on nature conservation management activities. More effective conservation management in protected areas, will enable an effective and sustainable forest management in other areas, for circular bioeconomy purposes.

The Swedish Forest Industries (SFIF) welcomes ambitious climate targets and emphasizes the importance of implementing them in a realistic way with the help of transparent and accurate impact assessments from the EU Commission and Member States. The SFIF urges the EU Commission to accelerate the phase-out of fossil-based materials and energy with EU climate policy while safeguarding EU competitiveness.

• We agree to the conclusion that there are significant EU added value and we believe that the Seville process is an important tool in this regard and should continue. A review of the Seville process instead of an opening of the Directive could accommodate most of the issues identified by the IED evaluation eg climate, energy and circular economy.

The Swedish Forest Industries Federation (SFIF) represents the Swedish forest industry. Our members refine wood resources to bio-based products. This includes among others pulp, paper, board, packaging material, sawn timber, refined wood products and advanced biofuels. We fully support the need of harmonised food safety regulation and the need to revise the EU rules on food contact materials.

The Swedish Forest Industries Federation (Skogsindustrierna), thanks for the opportunity to participate in this call for evidence. We look forward to the Commission's public consultation on the coming revision on European Directive 96/53/EC later this year. The Swedish Forest Industries Federation is one of the largest industry branches in Sweden.

Recommendations from Swedish Forest Industries: 1. Involvement of forest sector actors: The Commissions inclusion of stakeholders, e.g. through a dedicated expert group, is crucial for a scientifically sound and practically viable nature credit framework.

Please see full position paper on the LULUCF propsal from the Swedish Forest Industries attached. Forests are one of the most important solutions to addressing the effects of climate change as they provide important carbons sinks absorbing and storing large quantities of CO2 and supplying raw materials to substitute fossil resources.

The Swedish Forest Industries (SFIF) supports a strengthened 2030 climate target and climate neutrality by 2050. It is, however, important that a holistic and inclusive approach is applied when defining the contribution from forests, forestry and forest-based products.

The Swedish Forest Industries Federation (SFIF) welcomes the opportunity to provide input on this call for evidence. SFIF fully supports the view that better data and information enables better decision making. It is of crucial importance that the impact assessment clarifies a number of issues. SFIF wishes to highlight the following: 1. Clarify purpose and added value and make use of existing reporting schemes.

LULUCF policies should be based on balanced and realistic assessments of the forests natural dynamics and consider other sustainability dimensions Maintaining natural carbon sinks in the long term is a crucial part of reaching climate goals, also beyond 2050. This should, however, not be compromised by focusing on short term targets or unreasonable burdens on specific Member States.

The general principles of the Aarhus Convention are important, but the very broad interpretation of the Convention by the Implementation Committee and various environmental organisations is not in line with the original intentions of the Convention.

Filed in Swedish · English published by the European Commission

Swedish Forest Industries Federation (SFIF) welcomes the opportunity to give feed-back on this initiative. There are many drivers of global deforestation, but the expansion of agriculture is the most important one. This expansion can be divided in two parts. One is global demand for agriculture commodities such as palm oil, soya and beef.

Communication on stepping up EU Action against Deforestation and Forest Degradation Roadmap feedback by the Swedish Forest Industries Federation (SFIF) A1. Problem the initiative aims to tackle SFIF agrees that the drivers are multiple and complex as described in the roadmap. Many initiatives have been taken in the past (TFAP.

Sweden Skogsindustrier Association is a trade association whose members are of Swedish paper and masaföretag and sawmills. Members engaged in forestry activities and skogsindustriell on own land or on behalf of other owners.

Filed in Swedish · English published by the European Commission

Product Environmental Footprint (PEF) The pulp and paper sector has been deeply involved in the development of category rules for Intermediate Paper Products. The methodology is very time and resource consuming. Furthermore, some parts of the methodology as defined in the guide, have shown not to be robust, mature and scientifically grounded. It is valid for the eco/human toxicity and land use impact categories.