On May 25th 2018 the new EU data privacy legislation (GDPR) comes into force. CEPI will require your explicit opt-in if you wish to continue receiving updates from us such as event invitations, press releases, our newsletter (CEPI Members and Partners only) etc. To make you sure don’t miss out on updates from one of Europe’s most innovative industries or to subscribe for the first time please click below.
Commission's proposal for a general data protection regulation-Position of the paper and print value chain
Our associations are part of the paper and print value chain - including paper manufacturing, paper converting, printing, postal services and direct marketing – and are committed to safeguarding the protection of personal data.
We acknowledge that recent globalisation trends and technology developments create the need for a review of the existing legal framework, i.e. Directive 95/46/EC on Data Protection, to ensure the privacy of personal data of European citizens. In this context, we welcome the Commission’s proposal for a general data protection Regulation as published on 25 January 2012.
The European strategy for growth and competitiveness emphasises the need for the development of the single European market with free movement of goods, services, labour and capital. With data being an integral part of this process, the ability to use and move data within the European Union must be considered as an essential requirement of a revised legislation. A balance needs to be found between consumer protection requirements and businesses’ development needs.
The review of the existing framework is primarily aimed at tackling the growing development of online technology. However, in doing so, the risk is to destabilise the more ‘traditional’ side of the communication industry, which is not being questioned for its ability to protect personal data.
As members of the paper and print value chain, we herewith wish to address some aspects of the proposed Regulation affecting postal direct mail.
“Legitimate interest” and “right to object”
We welcome the Commission’s proposal acknowledging the “legitimate interests” of the controller to process data (article 6) and retaining the “right to object” for data subjects at any time of the processing of personal data (article 19). And we strongly support the application of the latter to postal direct mail purposes (article 19.2) as it ensures the safeguarding of the efficient legal framework, which has been in place for nearly two decades and which has been complemented with self-regulatory initiatives from the business community.
In order to safeguard the efficient legal framework applicable to the postal direct mail, it is crucial that the “legitimate interest” of the controller to process data is being maintained and the “right to object” is not being replaced by a “prior consent” approach.
Measures based on profiling
Article 20 of the proposed Regulation relates to the activities of profiling. We are surprised to see that companies’ legitimate interest for doing profiling is not recognised in the draft legislation.
Profiling allows for the identification of categories of individuals (not for the identification of individuals), thereby ensuring that companies target the right audience with relevant information. Without profiling, the postal direct mail business will effectively become a doorto- door mail drop service. This is not in the interest of consumers, nor of companies, who would have to support unnecessary costs.
While profiling has indeed become more complex with the advent of OBA, (online behavioural advertising), the Commission must not ignore traditional profiling activities that remain valid today. Banning all profiling activities would seriously hamper businesses’ capacity to advertise, via postal direct mail, products and services to the relevant customer, thus limiting offers on the market and preventing customers from having a choice and getting the best out of the internal market.
Consequently we are of the opinion that the companies’ legitimate interest for doing profiling should be recognised as proposed in the Recommendation CM/Rec(2010)13 of the Committee of Ministers to member states on the protection of individuals with regard to automatic processing of personal data in the context of profiling.
CEPI – Confederation of European Paper Industries – www.cepi.org
FEDMA – Federation of European Direct and Interactive Marketing – www.fedma.org
FEPE – European Envelope Manufacturers Association – www.fepe.org
INTERGRAF – European Federation of Print and Digital Communication – www.intergraf.eu
Paper Chain Forum – www.paperchainforum.org
POSTEUROP – European Postal Operators – www.posteurop.org
The 2nd Industry Forum organised by CEPI brought together key players in the pulp and paper value chain, to discuss synergies as well as short term and long term objectives set out in the 2050 Roadmap. The European pulp and paper industry is facing problems, particularly on the graphic side, while packaging and tissue markets seem more promising. These problems, combined with macro-economic problems, present major difficulties for the European pulp and paper industry, which needs to face increased costs and be creative at the same time, said Berry Wiersum CEO of Sappi Fine Paper Europe in his welcome speech. The paper value chain needs partnership. The strategic role of the value chain in exploring synergies and passing through the benefits is a primary condition to achieve profit.
Petri Vasara's keynote speech focused on constant re-invention which, according to him, is the norm for the forest-based industries; a paper plant will probably look quite the same in 2050, but it will differ thanks to resource efficiency and by-products use. There is not one unique model for future developments and we should not be afraid of partnership and collaboration along the value chain.
The central point of the discussion between printers and paper producers was the need for more trust. There is a need to talk more to each other as industry sectors and not only as companies, individual suppliers and customers. This is already happening but there is still room for progress. There are 3 Cs to apply: cooperation, coordination and competition. It is all about an evolution rather than a revolution. Sustainability can and should be the industry’s edge.
The next panel focused on customers and the need for an improved dialogue between them and the packaging industry. Customers are driving changes with challenging demands. The following panel, composed of suppliers, addressed the necessity for the creation of platforms where suppliers and customers can enjoy fruitful dialogue and identify short-term and long-term challenges and their related solutions. A top priority should be the an improved use of resources. In the paper industry, resource consumption can be substantially diminished by improving and rationalising the production process. Suppliers should be more pro-active and bring solutions that contribute to this rationalisation process.
The debate which followed revolved around the current economic crisis and the fact that the legislative environment does not help the industry. Over-regulation and legislation unpredictability in European policy should be reduced to offer support to the industry, as seen in the USA. The future of the industry and the value chain depends on today’s choices. New minds are needed to make change happen in the industry.
The final point on the agenda was Marco Mensink's presentation of the Two Team Project (www.unfoldthefuture.eu). Teresa Presas, CEPI Director General wrapped up the event, reminding the participants of CEPI’s role: to bring the various actors of the value chain together and move forward.
The event included inspiring talks and discussions. The programme as well as the three presentations from the event are available below.
Keynote speech – The future: a permanent reinvention, Petri Vasara, Pöyry Consulting
- Printer: Nigel Stubley, Northend Creative Print Solutions
Robert McClements, Grange Consulting
- Paper producer: Terry Hamilton, Norske Skog
Henrik Sjölund, Holmen Paper
Panel I: Customers at the centre of choice and engagement
- Response from paper packaging producer: Jurgita Girzadiene, Smurfit Kappa
Panel II: Chemical and machine suppliers: unexplored synergies?
- Chemical supplier: Jay Hunsberger, AkzoNobel
- Machine supplier: Jouko Yli-Kauppila, Metso
- Paper producer: Massimiliano Vannucchi, Sofidel
Kai Vikman, Metsä Board Corporation
Two Teams to breakthrough, Marco Mensink, CEPI
Photos from the event:
Jacki Davis, Moderator
Petri Vasara, Pöyry Consulting
Nigel Stubley, Northend Creative Print Solutions, Robert McClements, Grange Consulting, Terry Hamilton, Norske Skog, Henrik Sjölund, Holmen Paper
Philippe Diercxsens, Danone, Jurgita Girzadiene, Smurfit Kappa
Jay Hunsberger, AkzoNobel, Jouko Yli-Kauppila, Massimiliano Vannucchi, Sofidel, Kai Vikman, Metsä Board Corporation
A strong European bio-economy will make a significant contribution to Europe's competitive position in global markets, as well as to its low-carbon future. It will create wealth and jobs. But this cannot happen without the pulp and paper industry and its development into the forest fibre sector.
The EU Commission’s Industrial Policy Communication was launched today and is warmly welcomed by CEPI – the Confederation of European Paper Industries. The expectations from the paper industry are high, in a time of economic crisis and political and financial uncertainty, in which a clear direction is needed.
We call upon Vice President Tajani to implement a strong industrial policy, integrating other policies in a coherent way, and shaping them to reverse the current trend of de-industrialisation, shrinking investments and industrial employment contraction.
The paper industry has a clear strategy to develop its own competitive advantages and strengths. By using natural and renewable raw materials, creating record recycling rates, using its knowledge of the value chain, utilising new business models such as industrial symbiosis and by setting a vision for resource efficiency in the CEPI 2050 Roadmap, the paper industry is already part of the new industrial revolution described in the EU Communication. It also ticks off all the boxes for the bio-economy, with the potential to deliver bio-based products, rightly highlighted as an important focus area in the communication.
The paper industry is supplying the European market, and at the same time has one fourth of the global market share. Paper is “made in Europe” as 91% of its raw materials are sourced in Europe and its suppliers are large European companies. But a number of policies and practices are putting the raw material supply at risk and a robust and consistent policy approach is needed in this area.
Investment in new technologies and innovation are of paramount importance. “We, the paper industries, believe that one size does not fit all. We are starting our own work on breakthrough technologies that will allow our factories to release resources that can be invested in new added value products” said Teresa Presas, CEPI Director General. “The communication on EU Industrial Policy must be more than an update. It has to set the grounds for sector specific policies”. The support for the Bio-based industries Public Private Partnership is a clear sign of direction, which is appreciated by CEPI.
No long-term growth and sustainability goals can be achieved without industry. Industry is a real partner to contribute to growth and jobs in Europe, provided it gets the right legislative pro-investment environment. Only coherent, stable, competitiveness proofed policies and legislation, taking into account business values, investment cycles and the strategic importance of value chains can reset virtuous conditions to manufacture in Europe.
For more information, please contact Daniela Haiduc at firstname.lastname@example.org, mobile: +32 473 562 936
Note to the Editor
European Commission Industrial Policy press release: http://europa.eu/rapid/pressReleasesAction.do?reference=IP/12/1085&format=HTML&aged=0&language=EN&guiLanguage=en
CEPI aisbl - The Confederation of European Paper Industries
The Confederation of European Paper Industries (CEPI) is a Brussels-based non-profit organisation regrouping the European pulp and paper industry and championing industry’s achievements and the benefits of its products. Through its 18 member countries (17 European Union members plus Norway) CEPI represents some 520 pulp, paper and board producing companies across Europe, ranging from small and medium sized companies to multi-nationals, and 1000 paper mills. Together they represent 25% of world production.
The Council announced that a compromise agreement on sulphur content of marine fuels has been reached with the European Parliament. The European paper industry believes this agreement is a major blow to its competitiveness at a time where the EU is desperately looking for growth and jobs. Sulphur content limits will be 0.1% in the North of Europe from 2015 – 1.0% today – compared to 3.5% in other European sea areas until 2020, and the rest of the world until 2025. Sulphur emissions have to be reduced indeed but in a cost-efficient and fair way. This requires more time and better coordination.
CEPI deeply regrets that the agreement does not take full account of the concerns of the business community in times of an economic recession in Europe. CEPI has continuously drawn the attention of the European Parliament and the Member States towards the huge impact this agreement will have on the companies operating in the North of Europe – an additional cost of around 4 billion euros per year according to the most recent studies. For the paper industry an estimated increase in shipping costs of 20-45% further to a 50-80% price increase in marine fuels is expected, because of the foreseen low sulphur fuel scarcity and lack of reliable abatement methods. Further market and competition distortion within the EU and with foreign competitors outside the EU is to be expected.
Accompanying measures at EU and national levels through existing or new financial support schemes will be required, if the impact of the Sulphur Directive on companies is to be mitigated. “Companies will have to revert to their member state support in order to be able to comply to the prescribed limits within such a short period of time. But state aid will not compensate for increased costs and the resulting loss of competitiveness", said Teresa Presas, CEPI Director General. "The EU once again did not consider the competitiveness of its industry", she added.
The European paper industry asks the European Parliament and the Council to call for more flexibility in the rules of the IMO - the International Maritime Organisation.
- END -