The European sawmill Industries believes that the cascading principle is a living principle that can enhance circularity in the EU Economy. Nevertheless this principle shall not be translated into legislation because it will certainly lead to distortive effects on the wood and wood residues market. 

➢ In order to comply with the spirit of this principle, Members States should create a positive economic environment that allows the development of new forest bio-based products & solutions obtained by using residues from mechanical wood industries. In parallel, improving the overall recyclability of products should be supported by innovative design solutions while the necessary infrastructure to collect, sort and clean post consumer wood should be reinforced in order to comply with the aim of the cascading principle and further enhance circularity and resource efficiency in Europe. 

Overall, wood products and wood applications can foster a green and sustainable growth while playing a key role in decarbonising energy- and emission-intensive sectors, such as construction, plastics, and textiles. In sawmill plants, the whole log is utilised for products, particularly for making construction materials. From the logs an average of 35/40% becomes residues in the form of chips, sawdust and bark. These residues or by-products can be sold and used to for the production of other fiber-based materials, such as pulp and paper, oriented strand boards, a number of engineered wood products, and more recently polymers filled /reinforced with wood and other natural fibers, e.g. wood-plastic/polymer-composites. Obviously sawmill residues/by-products can also be used for process energy, heat and power, pellets production or transport fuels for substitution of fossil fuels. Moreover, the use of woody biomass in heat production is helping dramatically reduce dependency on fossil fuels. Pellet stoves are a widespread heating system and make an important contribution to the CO2 neutrality of Europe’s heating infrastructure. Due to a relatively high transport cost compared to the value, the sawmill residues are sold on the market depending on the regional market conditions, including the presence of downstream users. From what is mentioned above, it should be clear that the cascading principle is already integrated in the sawmill business models. It should be also recalled that the EU Commission in its Communication “on the Interpretative Communication on waste and by-products” clearly states that the excess material from a primary wood production process shall be considered to fall outside of the definition of waste. 

It is essential to note that the review of existing definitions and concepts around the cascading principle shows that there is still no commonly agreed concept of what cascading use exactly is and what are – from a practical point of view – the possible consequences of a legislative implementation. Moreover, besides the local market conditions, a multitude of policies and legislative measures influence the cascading use and the wood sector in general, e.g. bioeconomy strategies, forestry management, waste policy, bioenergy policy, and building regulations. This is why it is reasonable to think that a legislative application of the cascading principle will immediately lead to distortive effects of the wood and wood residues market, but the effects vary depending on specific local factors, for example, proximity to downstream industries and other potential buyers. In addition, political ideas on cascading use can severely hamper the possibilities for development and innovation. A binding legislation on cascading should therefore be avoided. 

On the other hand, for waste such as post-consumer wood, national implementation of the European waste hierarchy is important. Reliable classification and sorting systems are needed for functional recycling systems. Cascading can encompass different activities as recycling, reuse, remanufacture.

For this reason, putting in place the necessary infrastructure to collect, sorting and cleaning post consumer wood is important in order to implement the cascading principle and further enhance circularity and resource efficiency. On the basis of these considerations , the EU Commission should proceed to update its “Guidance on cascading use of biomass with selected good practice examples on woody biomass”. 

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