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position papers
31 Mar.2020

Enhancing the EU forest policy framework through a stronger EU forest strategy post 2020

Cepi position on the new EU Forest Strategy post-2020                                                           

European forests and the forest-based sector provide multiple solutions that contribute to Europe’s part in keeping global warming below 1.5 degrees by strengthening its role in the circular bioeconomy. The Confederation of European Paper Industries (Cepi) and members welcome the inclusion of new EU Forest Strategy as a part of the European Commission contribution to climate change mitigation and the COP26 in Glasgow and applauds the deserved spotlight the new strategy gets in the European Green Deal.

European forests are only indirectly regulated by the EU in the context of forest-related policies developed under conferred competences, or by means of coordination of national forestry policies at EU level via targeted action plans, such as the EU Forest Strategy 2014-2020. Keeping in mind the complex competence division on forests and forestry, and likelihood that the EU initiatives impacting forests and the forest-based sector are projected to increase in near future, Cepi and its members suggest some key principles and instruments to be included in the new strategy to strengthen the policy coherence between the new EU Forest Strategy and 2050 Climate Strategy[1] as well as the updated Bioeconomy Strategy[2]. Furthermore, these tools would play a role in making the future strategy more meaningful and ambitious than its predecessor.

During the last decades the European forest resources have increased in terms of forest coverage and growing stock. Viable industries with continuing long-term investments in sustainable forest management ensure healthy and resilience of forest ecosystems. Sustainability is at the core of the forest-based industries. European multifunctional forests and sustainable management ensure the provision of the ecosystem services e.g. raw material supply, clean air, water, biodiversity and improve the health and resilience of forests that face a growing number threats (e.g. drought, forest fires, pests, floods, erosion) caused by the climate change. Therefore, new EU Forest Strategy should take into account the entire forest-based value chain and provide the sector with appropriate tools to enhance its ability to meet the growing demands of the societies. To achieve this it would be essential to strengthen the cooperation of the actors involved and use the expertise stemming from the Standing Forestry Committee, DG GROW expert group on forest-based industries and the Civil Dialogue Group on Forestry and Cork.

The new EU Strategy should build on the holistic concept of Sustainable Forest Management[3] developed under the FOREST EUROPE process. Currently the definition, principles and criteria have been embedded into national legislation and guidelines as well as voluntary systems such as forest certification in place. However, different EU sectoral policies identified the need for a sustainability framework and tempted to define criteria for it, partially in an inconsistent way.

Therefore, the new Forest Strategy should give a mandate to the Standing Forestry Committee to establish the European risk-based approach and sustainability criteria for forest management adopted in the recast of the Renewable Energy Directive as a non-end-use specific sustainability system for forest biomass.  The EU Forest Strategy should guide relevant EU policies in applying the system as appropriate. This two-step approach to minimise the risk of using unsustainable forest biomass respects the complex competence division of Member States and the EU as it comes to forests and forestry.

Consequently, in the near future, the new EU Forest Strategy could encourage the European Commission to conduct fitness checks of the legislations already agreed to ensure that contradicting policies hindering the development of the sector would be reviewed and possibly revised.   In the long-term, fostered cooperation on forestry could be enhanced via the establishment of e.g. pilot projects or preparatory actions to further develop existing networks such as the Standing Forestry Committee and Civil Dialogue Group on Forestry and Cork. These pilots or actions would improve knowledge on the possible impacts of strategic decisions affecting forests and the forest-based sector.

Currently in the EU, approximately 65%[4] of the forest growth is harvested, meaning that there is a constant accumulation of biomass that could be sustainably used to enhance the development of the circular bioeconomy across Europe. Keeping and attracting the investments in Europe is of utmost importance as it comes to building green growth in Europe. Fostering the knowledge-base on the availability of forest resources with socio-economic indicators and science-based data on biodiversity should be further developed as a part of the new EU Forest Strategy. This work should build on the achievements of the last strategy in which the Forest Information System for Europe (FISE) was established.     

In order to implement the European Green Deal successfully, the new Forest Strategy should focus on the acknowledgement and the uptake of all climate benefits of the forests and the forest-based sector. Too narrow focus on the sink function of forests undermines the other climate benefits, namely the increased substitution of fossil-based materials and energy as well as further development of carbon storage in forests and products. The recently published EU Forest-based industries vision 2050 describes sustainable pathways to a climate friendly future. New innovative materials and products have a potential to contribute replacing traditional plastics in packaging and in other sectors. Cepi would like to highlight that besides paper and board, e.g. wood-based textiles, bio-chemicals and other everyday commodities can be done by the pulp and paper industry, in a sustainable, circular manner.    

Cepi believes that by including the above mentioned instruments in the new strategy and/or its action plan, the strategy would not only guide forest-related actions in all EU forest-related proposals but also bring added value compared to the current strategy and its multiannual implementation plan (Forest Map). 











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13 Dec.2019

Joint statement: A Taxonomy Delivering Sustainable Growth in Europe

We, the signatories, represent sectors of major importance for European economic development and wealth. We provide highly skilled jobs to Europeans and invest in innovative solutions, renewable and efficient technologies that make the transition to a competitive, low carbon and circular economy in Europe possible. Doing so, we help fight climate change and lead the way towards a more sustainable world.
We welcome efforts to mobilise the financial sector in accelerating the move towards a prosperous and sustainable Europe in 2050. To achieve this, a stable, fair and favourable investment framework in Europe will be key. In that regard, the European Commission’s Sustainable Investment Regulation proposal (so-called ‘Taxonomy Regulation’) is an important and necessary step and the draft report recently tabled by the Technical Expert Group (TEG) (mandated by the Commission) sets out a first basis to define what sustainable investments are. Yet the TEG report is insufficient and needs serious improvements to provide the clarity, objectivity and predictability needed in order to accelerate investments in sustainable solutions, guarantee affordable financing, safeguard energy supply security at acceptable cost, but also boost innovation and competitiveness in Europe. To this end, the Sustainable Investment Regulation and derived Taxonomy should apply the following key principles:
● The future Taxonomy should help implement the adopted EU legislation, including the EU energy, climate and circular economy legislation as well as other sectoral legislations. Given that the Taxonomy will likely start applying as of 2023, businesses, governments and financial market participants should not be faced with different targets, standards or thresholds that could disrupt markets, distort competition and result in excessive costs linked to burdensome implementation. Coherence should also be ensured with the existing investment classifications, for example the Principles for Responsible Investment Reporting Framework and/or the European Investment Bank’s Energy Lending Policy. Flexibility should however be left to investors and businesses that wish to go beyond the Taxonomy as part of their investment strategies.
● The future Taxonomy’s criteria and thresholds should be impact assessed prior to their application, to avoid unintended consequences for the sectors in which they will apply. The draft
TEG report presents important inconsistencies as well as technical and methodological flaws that could prevent investors from making fully informed decisions on their investments. Therefore, the future Taxonomy should be above all internally consistent and conducive to a level playing field that allow businesses and investors to invest in sustainable solutions that meet their varying needs. Metrics and thresholds are essential elements in EU legislation and should thus not be defined in delegated acts that do not allow their proper prior impact assessment and scrutiny by EU Member States and stakeholders.
● The future Taxonomy’s criteria and thresholds should also be developed and assessed by EU Member States and stakeholders. This should be done before they start applying, in line with the Commission’s Better Regulation agenda. In this regard, we have noted the lack of industrial representation in the TEG, the short consultation time on the TEG report as well as the lack of communication and coordination between the various working groups dealing with different aspects of the TEG report. The Sustainable Finance Platform will be instrumental to involve all relevant parties, beyond financial market participants, and develop a Taxonomy that delivers for investors, the economy and the environment.
● The future Taxonomy should be technology neutral and lead to investment in innovation, infrastructure and solutions that help achieve the EU goals cost-effectively. The TEG report privileges some technologies and solutions over others. For example, not all activities are subject to a Life Cycle Emissions analysis. Some sectors face stricter requirements than the 2030 EU energy and climate goals despite their sustainability benefits (e.g. cogeneration or bioenergy), when other activities need to apply today’s EU legislation (e.g. space heating and domestic hot water systems). Some solutions are also not properly considered (e.g. the value of heat and gas networks, including for storing renewable energy). A holistic approach looking at all solutions that contribute to meeting the EU energy, environmental, climate and circular economy goals is required to ensure a neutral approach and a level-playing field.
● The future Taxonomy should adopt a transitional, evidence-based and pragmatic approach, which reflects today’s technological development, available renewable and highly efficient low-carbon solutions significantly contributing to the transition, as well as current energy mixes and existing infrastructure. EU countries will have different starting points entailing varying investment needs. Europe’s transition to a cleaner society will not take one single form nor will it happen all in one day. Above all, no one should be left behind. Investments considered ‘sustainable’ today should also not become ‘unsustainable’ overnight because they are not listed or do not fit the Taxonomy definition. This is key to ensure regulatory certainty and economic stability.
● The future Taxonomy should better tackle environmental sustainability but also the social and economic pillars of sustainability. Focusing mainly on carbon emissions reduction, the TEG report needs to tackle better concepts such as circular economy, resource efficiency and energy efficiency for their significant environmental and health benefits (e.g. lower ecological and resource depletion, better air quality) as well as economic benefits (e.g. independent, secure and reliable supply of raw materials and energy, reduced dependence on imports, improved competitiveness). Not doing so risks compromising the very notion of (all-around) sustainability, which is essential to make fully informed and successful investment decisions for the future. On the contrary, integrating those dimensions into the Taxonomy would render it more comprehensive and better aligned with other major EU policy priorities, including fostering reindustrialisation and employment in Europe, and help make the move to a sustainable society an economic success for Europe.
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26 Nov.2019

A long-term strategy for Europe’s industrial future: from words to action

The Industry4Europe coalition has today issued its new Joint Paper A long-term strategy for Europe’s industrial future: from words to action. Through cross-sectoral recommendations, the Industry4Europe coalition contributes to the future EU industrial strategy announced by European Commission President-Elect Ursula von der Leyen.

The Joint Paper presents concrete industrial policy proposals in seven priority fields; business-friendly policy environment, sustainability at business core, upgraded skills and training, enhanced research and innovation, investment and improved access to finance, reinforcement of the European Single Market and strengthened trade and international market access.

The 149 industry organisations behind Industry4Europe stand united in their repeated calls for an ambitious and long-term EU industrial strategy that must help Europe remain a hub for a leading, smart, innovative and sustainable industry, that provides quality jobs and benefits all Europeans and future generations.


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05 Sep.2019

TEG report’s draft technical screening criteria for forestry creates legal uncertainty and ignores the long-term characteristics of forests

In the context of the European Commission’s ongoing work on developing a classification system for sustainable investments1, the undersigned organisations would like to express their views on the inclusion of forestry into climate change mitigation activities drawn up by the Commission’s Technical Expert Group (TEG) on Sustainable Finance 2. Due to competence distribution in the EU and the subsidiarity principle applicable in the complex area of forests and forest management, the undersigned organisations highly recommend using the forest biomass sustainability approach of the recast of the Renewable Energy Directive (REDII)3, which relies on Member State legislation instead of developing an additional new system of screening criteria for forests and forestry.
Europe’s diverse forest resources, including growing stock and area, have been increasing significantly during the last decades mainly due to investments in sustainable forest management. Concurrently, forests have become increasingly influenced by dynamic changes due to large-scale calamities, pests and diseases. The undersigned organisations welcome the fact that the sustainable finance initiative recognizes the significant contributions provided by the forest sector to the overall objective of a carbon neutral Europe. To strengthen these contributions, investments are indeed needed in order to achieve not only the climate change mitigation and adaptation objectives, but also to maintain other forest functions and to respond to other growing expectations from society addressed to European forests.
The undersigned organisations welcome the fact that the proposed sustainable finance regulation builds on the definition of sustainable forest management (SFM), referred to in the 2013 EU Forest Strategy4, which European countries and the European Commission endorsed within the framework of the Ministerial Conference on the Protection of Forests in Europe5. Given the fact that the proposed taxonomy regulation also aims to define a set of criteria, and that SFM contributes in many ways to several UN Sustainable Development Goals as well as to the Paris Agreement goals, it is crucial to ensure that a holistic approach to SFM is applied while keeping in mind that forest policy is a competence of Member States.
Sustainable and active forest management plays an important role in meeting EU climate, environmental and energy policy objectives, e.g. tackling climate change, preserving biodiversity, improving energy security and contributing to the development of the circular bioeconomy in Europe. It provides three main climate benefits: CO2 sequestration in resilient, growing forests; carbon storage in wood and wood products; and a renewable and climate-friendly raw material that substitutes for fossil-based materials and fuels.
To further ensure these roles and even strengthen them in the future, it is of utmost importance that the future taxonomy regulation does not undermine the objectives of the 2030 Climate and Energy Framework nor the EU 2050 Climate Strategy6 through the adoption of an inconsistent system of criteria for forest management. Even though the proposed initiative aims at steering private funding to more sustainable investments, it is likely that the policy will also have an impact on public investments.
As regards the GHG balance, the forestry sector’s positive contribution to the Union’s climate and energy goals must be considered in the context of the entire life cycle phases of any given forest and the multifunctionality of forest management. In this context, the recently adopted LULUCF Regulation aims to ensure a balance between emissions and removals from the land use, land use change and forestry (LULUCF) sector by 2030 at country level. Unfortunately, the set of climate mitigation activities envisaged in the TEG report disregards the holistic concepts of sustainable forestry and multifunctional forests as well as their related carbon cycles by not specifying in the criteria that the requirements should apply at country level and fit with the long-term cycles of forests.
The undersigned organisations also reiterate that the best practical way to include forests and forest management into the upcoming sustainable finance framework would be to use the risk-based approach for forest biomass as applied in the Renewable Energy Directive (recast) which properly covers sustainability concerns in forestry and which was adopted by all respective EU institutions and Member States. This would avoid confusion, legal uncertainty and subsequent restrictions to investments in the forestry sector. Unfortunately, the sustainable forest management requirements proposed by the TEG suggests another sustainability set for forestry.
If, in the longer run, a more comprehensive and robust system is needed, the EU Forest Strategy already provides an appropriate framework to accomplish this. Even though forest policy is a competence of the Member States, other EU policy fields indirectly address forests and their use given the fact that forests have the potential to provide multiple solutions to global challenges. Due to an increasingly scattered and fragmented EU policy framework, the implementation plan7 of the EU Forest Strategy called for an identification of a comprehensive set of sustainability criteria and indicators regardless of end use. The corresponding SFM criteria and indicators should be applicable for the purpose of different EU policies where relevant and when there is a need to refer to SFM and its means of evidence in a way linkable to subsequent life-cycle phases. Any specific additional sectorial policy driven criteria to determine sustainability aspects in the forest sector is not desirable.
Therefore, in the future work on the taxonomy, we strongly recommend that the TEG and the Sustainable Finance Platform rely more on expertise from the forest sector – especially concerning the critical role of forestry in the carbon cycle and climate change mitigation – and on established and commonly agreed instruments. This would minimise the risk of shortcomings and misconceptions in the proposed structure and content of the taxonomy system related to forests and forestry.
SFM requirements should always use provisions of Member State legislation based on the Forest Europe process as a baseline. Market-based solutions, such as forest certification and the forestry criteria of the Climate Bonds Initiative could be carefully used considering their voluntary nature and that they are only one of many means of proof. Therefore, in EU legislation, it should be clearly acknowledged and made possible to prove sustainable practices based on well-developed forest governance systems including monitoring and enforcement systems in place at national level. Furthermore, any requirement of forest management plans for forest holdings should strictly follow the respective legislation of Member States, especially regarding provisions for their content, disclosure of information, auditing and reporting intervals. In addition, the provisions on forest management plans should be consistent and in line with the Rural Development Policy 2014-20208 that acknowledges the small-scaled nature of private forest ownership in the EU.
The aforementioned recommendations will allow the European Union to send out a clear message to investors on how to promote the development and sustainable use of forest resources and the entire forest-based value chain with a view to positively contribute towards achieving the Paris Agreement climate objectives.
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14 Jan.2019

A joint call for an updated and stronger EU Forest Strategy

Acknowledging the report from the European Commission on progress in the implementation of the Forest Strategy the undersigned organizations, representing forest owners, managers, contractors and the forest-based industry, call on the European Commission, Parliament and Council to update the EU Forest Strategy with an aim to strengthen its role as a key reference for sustainable forest management. An update of the EU Forest Strategy is essential to ensure that the development of forest-related EU policies in the coming decades is better coordinated and more coherent.

Since the EU Forest Strategy was adopted in 2013, the EU policy framework and the EU policies affecting forests have strongly evolved. It is now more broadly recognized that forests and the forest sector play a crucial role in addressing major challenges in line with the United Nation’s Sustainable Development Goals and the climate change mitigation goals of the Paris Agreement.

In this context, special care must be taken to recognize the role of Sustainable Forest Management (SFM) to ensure forest ecosystem’s health and vitality and the delivery of multiple advantages to society and the bioeconomy.

However, forests and the forest-based sector are now increasingly expected to deliver on horizontal and sectoral EU policies addressing forests. These include:
- The 2050 Climate Change Mitigation Strategy that aims to maximize the potential of carbon storage in forests while providing raw materials for renewable products used to substitute for non-renewable materials as well as for energy.
- The land use and forestry regulation for 2021-2030 which commits Member States, for the first time in EU law, to compensate land use and forestry sector emissions by CO2 removals within the sector.
- The European Commission proposal for a taxonomy of sustainable investments which recognizes the central importance of sustainable forest management for protecting ecosystems.
- The EU Renewable Energy Directive that sets out bioenergy sustainability criteria related to forest management and GHG emissions savings.
- The updated EU Bioeconomy Strategy that encourages the transition to a more bio-based circular economy, bringing new opportunities for jobs and growth to rural areas.
- The future CAP which is the main instrument at EU level to finance measures that support SFM and investments for enhancing the sustainability and competitiveness of the forestry sector.
- The EU Biodiversity Strategy which aims to halt the loss of biodiversity and ecosystem services in the EU and which the Commission has recently started to evaluate.
The consequences of these policies and strategies on forests and their sustainable management still need to be ascertained. Therefore, their implementation during the period 2020-2030 and beyond must be closely monitored from a forestry perspective. In this context, the EU Forest Strategy can and should provide a consistent basis on which to strengthen and further establish effective links between forests and the forest-based sector and any relevant EU policies.

Beyond consistency throughout its legislation and policies, the EU also needs an efficient tool to address forest and forest-related issues on the pan-European and international agendas. Member States and their pan-European partners in Forest Europe are determined to continue discussions on a legally binding agreement on forests. At global level, a well-prepared and coordinated input is needed to the UN Strategic Plan for Forests 2030 and the Global Forest Goals. A robust EU Forest Strategy is the appropriate instrument to ensure consistent input to these processes, thereby making the EU a strong and committed partner.

Over the last years the Strategy has undoubtedly played a positive role in this context.
However, more needs to be done both at EU and national level to ensure even better policy consistency and coherence in the future. The roles of the Standing Forestry Committee and also of the Civil Dialogue Group on Forestry and Cork are very important in this context.

While the progress report highlights the importance of continued implementation of the strategy, it refrains from concrete recommendations for the post-2020 period. Therefore the undersigned organizations call on the European Commission, Parliament and Council to propose an updated and stronger EU Forest Strategy, before the end of 2019, which encompasses recent and upcoming EU policies and is adequately resourced at the appropriate levels of the European institutions.

CEETTAR – European Organisation of Agricultural, Rural and Forestry Contractors
CEI-BOIS – European Confederation of the Woodworking Industries
CEPF – Confederation of European Forests Owners
CEPI – Confederation of European Paper Industries
COPA COGECA - European Farmers and European Agri-cooperatives
ELO – European Landowners’ Organization
EUSTAFOR – European State Forest Association
UEF – Union of European Foresters USSE – L’Union des Sylviculteurs du Sud de l’Europe


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09 Oct.2018

European paper industry position on separate collection

Clarifications on Cepi's position on the separate collection of paper and board from residual waste and other recyclables, as well as the collection and recyclability of paper products that are multi-layered or have been in contact with wood.

This paper targets decision makers in countries, where separate collection systems are not yet well established and guidance is needed.

The full position paper can be downloaded below.

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18 May.2018

CEPI position on the update of a Circular Bioeconomy Strategy

The European pulp and paper sector has a long expertise in bioeconomy and has a significant role in providing solutions to many global challenges such as climate change, urbanization and ageing with using sustainable renewable materials. The European pulp and paper sector also offers easily recyclable solutions and answers to EU Circular Economy, Strategy on plastics in the circular economy and the UN Paris Agreement. Our sector operates in a circular way and resource efficiency is at the core of our operations. The growth volume of forests in Europe exceeds their use. Ensuring the growth of forests and their sustainable use is an important part of sustainable bioeconomy.

In its “2050 Roadmap to a low-carbon bioeconomy”, CEPI foresees that a growing part of the value added generated by the pulp and paper industry in Europe will come from breakthrough technologies and from the provision of a wider range of bio-based products, beyond pulp and paper. These products will contribute simultaneously to:

• a massive reduction of greenhouse gas emissions,
• substituting fossil-based materials,
• a transformation from a fossil-dependant economy to a renewable economy,
• fulfilling a number of sustainability challenges (as identified by the United Nations with the Sustainable Development Goals (SDG)).


To achieve a competitive circular bioeconomy, stable and enabling policy conditions in various fields (including environment, infrastructure, transport, energy, agriculture, etc.) must be in place. The review of the 2012 European Bioeconomy Strategy provides the opportunity to set up such conditions. CEPI welcomes it and wants to be an active partner in preparing a new Circular bioeconomy strategy for Europe.


The assets of our industry in the bioeconomy

1. What did the existing strategy deliver that the paper industry welcomes?
As confirmed in the review of the 2012 Strategy that has been publicised in November 2017 , the strategy has deliverd several positive results that the European paper industry welcomes.
Its mere existence has raised awareness on the likely benefits that the bioeconomy can bring to Europe’s economy and environment and therefore placed it on the policy radar screens. It has enabled the setup of an Institutional Public-Private Partnership, the Bio-based Industries Joint Undertaking (BBI-JU), endowed with a EUR 3.7 billion budget over 7 years to support research, innovation, demonstration and flagship installations, and which has proved to be a success.
It has also triggered the development of several national and regional bioeconomy strategies that further amplify and tailor the benefits of the bioeconomy to the local circumstances.

2. The bioeconomy potential to address grand societal challenges
The smart development of a circular bioeconomy in Europe will contribute to remedy a number of critical environmental, economic and social challenges. Renewable and recyclable bio-based products:
• must be part of the climate change mitigation policies, thanks to their ability to store carbon, but also to avoid emissions of greenhouse gases from fossil-based or GHG intensive products that they are replacing
• help take environmental responsibility and achieve economic benefits through self-sufficiency (use of mainly locally sourced renewable resources and recycled resources).
• help limit the extraction and depletion of non-renewable resources.
• can reduce the amount of waste landfilled or spread in the environment (land and sea) thanks to their recyclability, but also their biodegradability and compostability.
• contribute to rural development and livelihood, as they depend on natural renewable resources growing on land and in the marine environment.

3. Towards a successful circular bioeconomy strategy
What makes the paper industry unique is both the renewable biomass and recyclable feedstocks , grown , renewed and recycled in Europe. This contributes to a genuinely circular bioeconomy. In order to enhance the contribution and benefits of the circular bioeconomy to Europe’s economy and environment, CEPI calls on the EU to put further emphasis in the updated strategy on:
• Increasing the availability and mobilisation of biomass (including its transport): this requires notably the promotion of active forest management, the redress of policies that distort biomass supply chains and the adjustment of waste legislation to promote the recycling and recovery of waste and notably of the biomass in the waste.
• Boosting investors’ confidence, notably by de-risking investments made in Europe, and directing EU money (ESIF, EFSI, Research and Innovation) to sustainable sectors in a predictable and stable manner.
• Easing access to markets for a wide range of bio-based products by lifting obstacles to their circulation within the single market and by indicating clear preference for sustainable, circular and bio-based products.

4. Implementing concrete, measurable and time-bound actions
Next to updating the strategy, the related Action Plan must focus on a limited number of actionable and realistic actions that should be implemented in the short term.
• Capitalising on its current success (investments triggered, SME participation, leapfrogging innovations, …), the Bio-based Industries Joint Undertaking must be reconducted with at least the same budget.
• Research and innovation must remain a priority of the EU. The next Framework Programme for Research must factor in a “mission” that targets the climate challenge thanks to sustainable renewable resources.
• The development of a sustainable and circular bioeconomy must be a shared ambition across the European Institutions. Synergies and leverages within complementary policy initiatives
must be seeked and enhanced, especially when it comes to the Circular Economy Package and the Climate and Energy policies.
• There must be mechanisms established – e.g. under rural development policy of the CAP –to boost the sustainable production of biomass, allowing for sharing the benefits of the bioeconomy between biomass producers and bio-based industries, while taking care of land, soil, water and biodiversity.
• Separate collection and sorting of biodegradable waste streams (incl. paper and board products) must become the standard and waste lanfilling must be effectively drastically restricted or banned in order to increase both the quality and quantity of waste feedstocks that can be recycled into high value bio-based products.
• Specific funding programmes (including venture capital) should be established to support technology transfer and entrepreneurial iniatives.
• While there exist already provisions for greening public procurement, such policy must also prescribe a preference for bio-based products (inspired by the US Bio-preferred programme). As public buyers, the EU Institutions themselves can already play an exemplary role.
• It is also of utmost importance to overcome misconceptions and misunderstandings concerning the bioeconomy. Ensuring the rapid availability of undisputable data and facts on the expected environmental, climate, social and economic benefits of the bioeconomy and bio-based products, is a must in order to raise awareness and promote the bioeconomy across Europe’s society at large.

1Review of the 2012 European Bioeconomy Strategy, European Commission, Directorate General For Research and Innovation, November 2017,


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20 Oct.2017

Industry4Europe joint reaction paper on the EU industrial strategy

Industry4Europe is a coalition of around 130 manufacturer associations committed towards the achievement of an ambitious EU industrial strategy.

#Industry4Europe initiative, CEPI's a part of, has released a paper to react to "Investing in a smart, innovative and sustainable Industry. A renewed EU Industrial Policy Strategy" published by the European Commission.

The reaction paper tackles the issues of:

  • Business-Friendly Environment and Governance
  • Skills & Training
  • Research and Innovatin
  • Access to Finance
  • Internal Market
  • Trade and International Market Access


The full document is available here.

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21 Jun.2017

Unlock demand side flexibility for European consumers, innovation and the climate

Signatories of this letter welcome the Clean Energy Package as the means to set in place new rules for a consumer-centred European energy system, by implementing the three stated EU objectives: putting energy efficiency first, achieving global leadership in renewable energies and providing a fair deal for consumers.

Demand side flexibility is a resource that not only benefits and empowers individual consumers, both private and professional, but also reduces total system costs, facilitates renewables integration and contributes to building Europe’s smart energy leadership.
This remarkable resource however suffers from important market failures that the ‘Clean energy for all Europeans’ package attempts to address. Signatories of this letter, all strong advocates for demand side flexibility, urge you to include the necessary proposals to develop demand side flexibility in the final legislation, and ensure consistent enforcement through thorough planning and reporting obligations in the Governance regulation report.

The stakes are high. Not delivering Europe’s demand side flexibility potential risks affecting Europe’s competitiveness, undermining its decarbonisation efforts, undermining its benefits for consumers and jobs and growth opportunities for Europe as a whole.
The following points highlight key steps necessary to develop demand side flexibility by creating functioning wholesale energy markets; opening markets to consumers and third parties; and remunerating demand side flexibility fairly.

1. Creating functioning wholesale energy markets
The electricity directive and regulation can significantly contribute to establishing well-functioning energy markets that reflect the availability or scarcity of supply and the adequacy of the network. In particular,
• Reform short-term markets functioning to help increase the overall flexibility of the power system (Electricity Regulation Chapter 2).

• Harmonise features of intraday and balancing markets to encourage trading of energy across borders, and as close as possible to the time of delivery (Electricity Regulation, Articles 5 and 7).

• Tackle overcapacity of generation to re-establish long term price signals for investors and minimise the risks that capacity mechanisms create for the development of efficient wholesale markets, as well as consumer empowerment, demand response and the deployment of innovative low carbon and energy efficiency technologies. The best way to minimise such risks is to:

o Only implement capacity mechanisms as a last resort, when proven strictly necessary by a European adequacy assessment which factors in the contribution of renewables, self-consumption and on-site generation (including cogeneration) and assesses flexibility needs (Electricity Regulation, Article 18).
o Ensure capacity mechanisms are open to all resources such as energy efficiency, demand response, storage, all generation technologies, and cross border capacity (to add to Electricity Regulation, Article 23).
o Review the need for capacity mechanisms regularly:
- So as to ensure consistency between procurement of capacity and the size of the adequacy concerns (to add to Electricity Regulation, Article 23) on the basis of the latest European resource adequacy assessment
- So as to ensure consistency with the overall competitiveness and decarbonisation objectives
o Ensure that the duration of the capacity contract is short enough to correspond to the regular reviews.
o Require Transmission System Operators (TSOs) to report on redispatch and countertrading measures they undertake, including underlying costs, and the level of effectiveness and openness of market-based curtailment or re-dispatching mechanisms to all energy resources. In turn, the creation of liquid and efficient markets and the deployment of demand side flexibility resources will reduce the need for additional measures to guarantee system adequacy.

2. Ensuring market access for consumers and third parties

Rules must be established and enforced so that demand-side resources have unhindered access to all energy markets (wholesale, balancing, ancillary services) in all timeframes, including through product requirements fit for supply and demand-side resources alike. This also means direct market access for consumers and new market entrants, including third party aggregators and ESCOs.
In particular:

• Give consumers the right to participate in energy markets with dynamic price contracts. This includes providing customers information on actual time of use at near real time and the right to respond to price signals, as well giving consumers the right to sell flexibility independently of any contractual arrangements to procure energy, directly or through an (independent) aggregator. Smart metering is a pre-requisite as the certified basis for billing consumer using multiple tariffs for market-based pricing. It also forms the foundation for the development of additional consumer services (Electricity Directive, Articles 11, 17, 20, 21).

• Enable fair market access for Demand Response and service providers. Deployment of demand side flexibility has so far been impeded by outdated market rules, insufficient market access for service providers and ineffective price signals. Demand response should have non-discriminatory access to all markets (Electricity Regulation, Articles 1, 3, 4, 5, 6, 7, 11, 12, Electricity Directive, Articles: 3, 15, 16, 17) and Demand Response Aggregators should be enabled to access the market without prior agreement of other market parties who are often competitors (Electricity Directive Article 17).

• Network tariffs should be fully transparent and allow the development of self-consumption and self-generation. They should be based on the marginal costs of the use of the system and take into account the avoided capital (e.g. grid investments) and operational expenditures due to flexible generation and flexible load embedded at the local level, as well as avoided CO2 emissions. (Electricity Regulation Article 16; Electricity Directive Article 15).

• Accelerate the cost-efficient decarbonisation of the existing building stock, notably through reaping the flexibility benefits of technical building systems and other appliances to support consumer empowerment: set in place a proper framework for the deployment of infrastructures (i.e. on-site renewable electricity generation, high efficiency cogeneration, smart metering or electro-mobility) and of demand-responsive devices that will facilitate the buildings’ integration into a wider energy ‘eco-system’ where active prosumers self-generate, self-consume, aggregate, trade and sell surplus electricity to the grid. In this new setting, buildings will no longer be a load but a micro-energy hub contributing to consumer empowerment and cost-efficiency of the energy system. The smartness indicator of buildings should support consumer empowerment and the development of buildings as part of the energy system.

• Create a comprehensive framework for grid monitoring, so as to increase the visibility of flexibility, including demand-side flexibility. It should be based on information that TSOs and DSOs would publish regularly as regards to the performance of their networks , in particular the volumes and sources of curtailed energy (Electricity Directive, Article 59). Comprehensive reporting on grid evolution, together with appropriate tariff structure, will be an essential basis for cost-effective network management and enable the targeted acquisition of flexibility services from the market by system operators instead of CAPEX only investments (Electricity Directive, Article 32).

• Ensure enforceability of the right for citizens and businesses to self-generate, self-consume, and valorise their flexibility; (Electricity regulation Article 16; Electricity directive Article 15).

• Establish a constructive framework for energy storage which takes into account the specificity of the energy storage technologies, and recognizes that TSOs and DSOs should not own, develop, manage or operate storage assets, unless a market based procurement based on an open and transparent tendering procedure is proven of not being possible and is regularly reviewed. (Electricity Directive, Articles 36 and 54)

Signatories of this letter are convinced that such a way forward will provide consumers with the satisfaction of managing their own energy consumption while optimising their overall carbon and environmental performance.




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19 May.2017

Statement from the alliance of energy intensive industries on the clean energy for all Europeans package

We, the Alliance of Energy Intensive Industries representing more than 30,000 companies that are Europe’s largest energy consumers and together, directly employ more than 2.8 Million people, want to make a success of the Energy Union. We see it as a potential enabler of European industry’s competitiveness and a unique opportunity to deliver on Europe’s ambitious transition to a low-carbon energy system. Energy Intensive Industries make a series of recommendations to reach this ambition in an effective, secure and cost-conscious way that delivers value for investment to European economic contributors such as industry. The Alliance would welcome a new energy framework that:

- ENABLES INNOVATION IN INDUSTRY SECTORS THAT DEVELOP PRODUCTS AND TECHNOLOGIES leading to lower greenhouse gas emissions (GHGs) across value chains. Our industries offer low-carbon solutions to help Europe transitioning to a low-carbon, energy efficient region. Our products and innovative processes have a strong potential to enable greater energy efficiency or help the wider deployment of renewables;

- PUTS THE GLOBAL COMPETITIVENESS DIMENSION HIGH Our industries will be key in delivering several elements of the Clean Energy Package. The Governance of the Energy Union must acknowledge this and not relegate the competitiveness dimension as secondary to other aspects, but increase its prominence;

- SECURES INDUSTRY’S ACCESS TO COMPETITIVE, RELIABLE, AND SUSTAINABLE ENERGY through a fully liberalised European electricity market. The growing share of variable renewable energy production in the grid represents both a challenge and an opportunity for industry. Negative impact of system changes on industry and on security of energy supply must be avoided. Policy framework conditions should be nondiscriminatory, technology-neutral and predictable over the longer term to enable sustainable investment decisions;

- AVOIDS COSTLY AND UNNECESSARY OVERLAPPING LEGISLATION: The EU ETS and the Market Stability Reserve will lead to a higher price of carbon under the 2030 framework. It is therefore important that new measures do not overlap with ETS, adding an additional layer of obligations for industry, but rather target untapped potential laying in e.g. buildings or mobility sectors. Enabling better energy performance in those sectors would stimulate our economy and create new jobs and growth opportunities;

- CLEARLY DIFFERENTIATES ENERGY EFFICIENCY AND REDUCTIONS IN INDUSTRIAL ACTIVITY: looking at levels of energy consumptions in the different sectors of our economy, it is clear that so far the 2020 objective is being partly met through reduced levels of production. Our industries wish to contribute to growth in Europe while, at the same time, improving their energy efficiency performance; in this framework, it is relevant to assess reduction of energy consumption in relative terms;

- INTEGRATES RENEWABLE ENERGY SOURCES IN A COST-EFFICIENT MANNER: as long as it is in place, support to renewable energies must become cost-efficient and must focus on technology-neutral innovation. Support
schemes should be market-based and market responsive. They should only benefit technologies that are not yet mature, on a temporary basis.

As key players in the transition to a low-carbon economy, energy intensive industries and value-chain partners will provide constructive input into the decision-making process.



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