Printed products - in or out of EU FLEGT?
Any action to prevent illegal logging should be welcomed. So on the face of it, the proposed regulations from the European Commission requiring those who supply timber and timber products (including paper) to take certain defined steps to minimize the use of illegally harvested timber, is good news. There is a "but" however, with potentially far reaching consequences for the European paper industry.
Such legislation creates a loophole. This loophole could see Europe's papermakers, obliged to provide greater evidence of sustainability, competing in the print market against suppliers which might have no obligation to prove the source of their raw material.
The draft regulations do not include printed products, and CEPI is urging European Parliamentarians to put this right. The EU imports some Euro 3.2 billion's worth of printed products annually, and rising. Some 25 percent of this comes from China alone. For example, a quarter of all children's books sold in Germany are printed in China.
Under the radar
By virtue of being converted into printed products, thousands of tonnes of paper could slip into Europe's markets under the EU's regulatory radar - circumventing rules with which papermakers inside the EU must comply.
This is not to suggest that printed products from sources outside the EU are automatically suspect, nor to question the scruples of Europe's print buyers and their suppliers from wherever in the world. Many publishers have an impeccable commitment to sustainability. It is simply that in any game whose participants are playing to different rules, the outcome is unlikely to be fair.
A greater burden others can ignore
Clearly the legislation proposed represents a position with respect to illegal logging which is already adhered to by most European papermakers through voluntary initiatives and commitments. The difference is that they will be required to provide chain of custody information, comply with risk management procedures and participate in risk mitigation activities, which outside suppliers can choose to ignore. Those who are less regulated would be at a competitive advantage created by the EU's own rules.
At best the proposed legislation will incentivize print buyers to favor non-European suppliers and leave behind EU-based paper makers and their suppliers. At worst it will, in addition, see products based on illegally-logged sources reaching our markets - the very situation the proposed legislation seeks to avoid.
We are of course in favor of raising the benchmark within the EU for sustainability, but only if it is the same benchmark for all those who have access to EU markets. Without the amendment we propose, that will simply not be the case. The European paper industry and its suppliers must create a groundswell of concern that member state Governments will feel compelled to voice via their European representatives. A simple amendment is required to level the playing field. The alternative is to risk value seeping away to less-regulated competitors, by inadvertently providing an incentive to place business outside the EU.