Two Sides contributes to the industry response to European Commission’s Electronic Invoicing proposals

4 February 2011, London, UK – Two Sides has joined with other industry bodies to urgently request a meeting with the European Commission to discuss the role of print media, and a need for the European Commission to form a balanced view of the sustainability of print media in a multi-media world.

"We need to make sure", says Martyn Eustace, Two Sides Director, "that the Commission, in pursuing a digital agenda, takes due account of the concerns of all partners in the Print Value Chain and recognises not only the huge importance of print media as a major employer* in the European Community but also the increasing realisation that, being based upon a renewable and recyclable material, it may be the sustainable way to communicate."

As part of the industry stakeholder’s group, Two Sides, along with other representative bodies from the paper, printing and postal industries and linked sectors sent an open letter to the European Commission on 26 January, in reaction to its communication aimed at promoting e-invoicing. The proposed plan, which forms part of the European Digital Agenda, pushes for electronic invoices to become standard by 2020. Whilst expressing support for the development of digital communication and acknowledging potential economic benefits of e-invoicing, the group wishes to ensure that the Commission appreciate how paper can complement the Digital Agenda.

The print media value chain** maintains that the European Commission’s communication, released on 2 December 2010, does not take into account a number of important aspects needed for a balanced approach. For instance, the communication estimates that the move to e-invoicing from paper invoices could potentially save around €40 billion per year across the European Union. These savings would mainly be made by lower paper consumption, elimination of postage cost and better automation of bureaucratic practices on the side of the issuer. The group points out that the cited financial savings from reducing administrative burdens and costs to companies and businesses fail to take into account the transfer of these costs to the recipients.

The European Commission also argues that e-billing would reduce CO2 emissions. However, Two Sides asserts that there is now a growing understanding of the considerable environmental impact of electronic media and therefore encourages the Commission to carry out more analysis before making such claims. There are still serious worldwide environmental concerns surrounding the disposal of quickly outdated electronic equipment. With paper recycling rates in Europe at an all time high of 72.2%, encouraging the switch from paper-based to electronic communication, without the relevant environmental facts and without identifying and comparing the carbon impact of both media channels, is irresponsible.

Two Sides has already illustrated in its anti green washing campaign, which highlighted the misleading environmental messages being put out by Banks, Utilities and Telecoms, that print media is a renewable and recyclable product that, if responsibly produced and consumed, can be the sustainable way to communicate.

In Europe

• 44% of the land area is covered by forests
• 93% of our paper comes from Europe, where the area of forest has grown by 30% since 1950 and is increasing at a rate of 1.5 million football pitches every year.

In conclusion, the print media industries have asked the Commission to ensure a balanced perspective on electronic invoicing and not to pursue a ‘digital only’ agenda. It urges the Commission to recognise the economic benefits derived from the paper, printing and postal industries and to acknowledge that these sectors themselves are drivers of economic growth. Furthermore, the group maintains that print is an important means of communication and business development - vital for a healthy society. It also has a great social and economic value, as thousands of jobs and livelihoods are wholly or partly dependent on the wider paper, printing and postal industries. In addition, the group encourages the Commission to acknowledge the sustainability of paper and print media.

*The signatories represent 136,000 companies with 2.8 million people directly employed in this important business sector.

**The letter to the Commission was signed by a large group of stakeholders from the paper, printing and postal industry sectors and linked industries. It was sent to the Directorate General (DG) Enterprise and Industry, DG Environment and DG Information Society. The signatories were: International Confederation for Printing and Allied Industries (INTERGRAF); Confederation of European Paper Industries (CEPI); European E-commerce and Mail Order Trade Association (EMOTA); Federation of Direct and Interactive Marketing (FEDMA); European Envelope Manufacturers’ Association (FEPE); Paper Chain Forum; Postal Users’ Group; European Association of Public Postal Operators (PostEurop); PrintCity; Print Power and the Two Sides campaign. The signatories urge the relevant EU DGs to engage in a dialogue aimed at preventing discrimination based on false perceptions.