European Organisation of the Sawmill industry

European Organisation of the Sawmill Industry aisbl REVIEW OF THE REQUIREMENTS FOR PACKAGING AND OTHER MEASURES TO PREVENT PACKAGING WASTE– EOS COMMENTS Forest and forest products (when legally harvested from sustainably managed forests) are a key factor in developing a green, sustainable and climate friendly circular bio-based economy in Europe. The European Organisation of the Sawmill Industry (EOS) represents the wood mechanical industry, i.e. the industry that -minimizing wood waste- turns logs into sawn timber, packaging, construction wood, furniture and interior fittings; while sawmill residues are sold to other wood based industries (and then transformed in wooden products) or become a source of bioenergy. Timber products are not only long-lasting, but can be easily repaired, re-purposed or recycled.

…a source of bioenergy. Timber products are not only long-lasting, but can be easily repaired, re-purposed or recycled. Even when the useful life of a timber product has ended, it can still be burned in order to generate heat (as excellent alternative to fossil fuels) and/or can be shredded or cut for a range of sustainable uses, including products such as insulation and animal bedding. The natural qualities of timber make wooden packaging an environmentally friendly packaging solution. Wood pallets and wood-based packaging are almost completely made out of wood. And wood’s strong environmental credentials have been captured in various Life-Cycle Assessment studies and Environmental Product Declarations. Generally speaking, wooden packaging as divided into two subgroups:

…studies and Environmental Product Declarations. Generally speaking, wooden packaging as divided into two subgroups: 1. Custom made packaging solutions to protect and transport for instance large industrial pieces of equipment. The final destination for wooden packaging and the piece of equipment is, according to our experience, often outside of Europe, as exporting companies are large customers of wooden packaging. The packaging is used to protect the equipment, which normally has a very large value. The wooden packaging is easy to demount, but rarely it is reused in its form, since it is custom made. Once dismantled, wood can be used for different new applications, including building purposes or for bioenergy generation. Since the packaging market is global, a strict European perspective in packaging recycling and or reusing solutions might not be coherent with the reality. 2.

…strict European perspective in packaging recycling and or reusing solutions might not be coherent with the reality. 2. More standardized products- meaning primarily pallets. Pallets are used to support and facilitate transportation. There are common European standards for pallets, but many logistics providers also have their own systems in place. Pallets are by definition reused as long as they provide the functionality needed, after that, the wood is often used for bioenergy generation. As export and import flows today are very global, a strict European perspective won’t reflect reality. Additional considerations: • As explained above, both the recyclability and “reusability” factor depend very much on the global market. Any mandatory demand in relation to these two concepts would be highly problematic.

…very much on the global market. Any mandatory demand in relation to these two concepts would be highly problematic. Moreover, restricting the use to certain packaging applications will be problematic and even lead to market distortions. For this reason, any possible restrictions should be first evaluated through an accurate and extensive market impact assessment and accompanied by scientific based evaluations regarding the environmental concerns. • “Functionality” is also utterly important, especially for custom made wooden packaging. A packaging solution is chosen since it delivers what is needed concerning functionality, cost, etc. Ref. Ares(2020)4128380 - 05/08/2020 European Organisation of the Sawmill Industry aisbl • Mandatory recycled content could be a major obstacle, not only for wooden packaging, but for all paper and board products based on fresh fibres.

…could be a major obstacle, not only for wooden packaging, but for all paper and board products based on fresh fibres. As previously explained, many of the wooden packaging solutions are sold and transported outside EU. Getting back the wooden packaging solution e,g from China, would not make any economic or environmental sense. Regarding paper and board, recycling rates are already high. Both fresh fibres and recycled fibers co-exist in the same value chain. It’s not a matter of one or the other, instead both of them need each other to be successful. A demand for mandatory recycled fibres would actually mean that producers in North Europe - mainly running on fresh fibres- would have to import recycled fibers from continental Europe. Costs would go up as well as emissions from transport.

…would have to import recycled fibers from continental Europe. Costs would go up as well as emissions from transport. Feedstock would be pulled away from those that are 100% recycled based and their business would be hampered. • It goes without saying that having a “one size fits all” approach for the packaging solution is not possible for a both economical and environmental prospective. Different packaging materials need specific considerations and evaluations that shall not be disregarded. • Minimum mandatory GPP would most likely not affect wooden packaging, as the public (authorities etc) are small buyers. Instead the dominant buyers are industrial and from the logistics sector. Sustainable and environmentally friendly packaging solutions, should be overall promoted and encouraged particularly in the private sector.

…friendly packaging solutions, should be overall promoted and encouraged particularly in the private sector. The European Sawmill Industry: The European sawmill industry, according to the latest available information, comprises around 35,000 enterprises which employ around 250,000 people across Europe. Most of these enterprises are microenterprises (1-9 full time employees – FTEs – according to the EU classification), while large enterprises (more than 250 FTEs) are not many but play an important role, particularly when it comes to innovation. The sector is responsible for a total production value of more than EUR 36 billion. European sawmills manufacture sawn boards, timber frames, glulam, decking, flooring, joinery, fencing and several other wood products. The European sawmill industry is a traditional sector, strongly anchored to local territories.

…other wood products. The European sawmill industry is a traditional sector, strongly anchored to local territories. At the same time, it is also a forward-looking sector, deeply entangled in global trade dynamics. Finally, the European sawmills are responsible for about 80% of the forest owners' profits on the sale of timber and are key for the sustainable management of the European Forests.

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