European Commission
Rue de la Loi , 200
1049 Brussels
Belgium
Brussels, 6 March 2015
Dear Vice President of the European Commission,
Dear Mr Maroš Šefčovič,
The European wood based Federation (EPF) that counts members in 25 countries and represents the manufactures of particle board, MDF, OSB, hard and softboard with a turnover of about 22 billion euro every year and counting more than 5,000 enterprises in Europe, welcomes the adoption of the Draft European parliament legislative Resolution on the Council position at first reading with a view to the adoption of a directive of the European Parliament and of the Council amending Directive 98/70/EC relating to the quality of petrol and diesel fuels and amending Directive 2009/28/EC on the promotion of the use of energy from renewable sources. This Draft Resolution that was positively voted on 24 February 2014 by the Committee on the Environment, Public Health and Food Safety of the European Parliament, highlights several elements that are essential and vital for the competitiveness of the European wood based producers.
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In prevision of the conciliation procedure that officially will start next week in Strasbourg, EPF, on behalf of the industry it represents kindly invites you to support and keep the amendments proposed by the European Parliament related to the importance of producing biofuels always respecting the cascading use of resources and the waste hierarchy principle in the final agreement.
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Since woody biomass is currently by far the main source for renewable energy, it is necessary that this valuable resource be used in the most efficient way in order to respect the resource efficiency principle.
Indeed, wood ought to be used for its highest value before being converted into energy, thus observing the value-added and employment chains of wood. Wood can be used, reused and recycled several times, but it can only be burned once. The wood based panel producers are not opposed to the use of wood as a renewable energy source, but this should only be done when no other industrial uses are possible and by preference in highly efficient energy systems, such as combined heat and power.
In the European Study entitled 'Wood Flows in Europe (EU27), Professor Udo Mantau (Head of the Centre of Wood Science and project coordinator at the University of Hamburg) has examined the importance of the application of the cascade use of wood principle in order to guarantee a sustainable and efficient use of raw wood sources. The study reports that 'in the market process wood is used in cascades. A cascade use is defined as multiple use of the wood resources from trees by using residues, recycling (utilisation in production) resources or recovered (collected after consumption) resources. The more often by-products and recycling products are used, the higher the cascade factor gets. If the only wood resource comes from harvested trees and no other wood resources are used, the cascade factor is 1.00.' It is important to note that according to the cascade factor defined in this Wood Flow study, 'wood is used 1.57 times (cascade factor including energy use), almost all the cascade uses take place in the wood-based industries' (1.35).
Hoping you might take into consideration the concerns of the European wood based panels industries, I remain,
Yours sincerely,
Ladislaus Döry Kris Wijnendaele
President Secretary General
Silvia Melegari
Environment & Research Adviser
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European Panel Federation (EPF)
24 rue Montoyer, Box 20
B-1000 Brussels
Tel: +32 2 556 25 89
Fax: +32 2 287 08 75
E-mail: [email address]
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