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Revision of European Ecolabel Criteria for Wooden floor coverings
Summary 2nd AHWG and discussion points
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2nd proposal for criteria
Timing of the project 2nd Working Document 2nd proposal for criteria Stakeholder consultation document / questionnaire 1st Working Document Background + 1st proposal Final proposals for Ecolabel criteria Preliminary Report Product Definition Market Analysis Technical Analysis Improvement Potential 1st AHWG 2nd AHWG Jan 2014 Sept 2014 Oct 2014 Sept 2014 April 2015 Oct 2015 May 2015
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Feedback using the BATIS system
Timing of the project: some details Feedback using the BATIS system 30th June 2015
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Timing of the project: coming next
1. Stakeholders can provide comments on TRv2.0 and draft criteria proposals for EU Ecolabel (before 30th June 2015). 2. Comments need to be transmitted in the HTML version using online BATIS tool. 3. Minutes and slides 2nd AHWG meeting uploaded in BATIS and on the official website: susproc.jrc.ec.europa.eu/wooden_floor_coverings/documents.html 4. June 2015: EUEB progress report - summary of the discussions - discussion points to take decisions 5. Technical Report v3.0 ~ October 2015. 6. Process finalised 1st half 2016
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Statistics 1. Number of BATIS registered stakeholders: 197 stakeholders 2. Number of participants in AHWG meetings: - 1st AHWG meeting: 20 registered stakeholders - 2nd AHWG meeting: 28 registered participants 3. Number of participants providing active feedback - 1st AHWG meeting: 5 stakeholders - 2nd AHWG meeting: 9 stakeholders Industry members from laminate, parquet, bamboo flooring, sustainable wood certifications and wood industry associations, adhesives producers, CBs, etc 4. Number of license holders: 1 (IT) Number of trials to get a license: 3 (2IT and 1NE)
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Table of content 1. Scope and definition 2. Simplification and reduction in the number of criteria 3. Wording and implications of the sustainable wood and plant-based materials 4. Wording and implications of the general restrictions on hazardous substances 5. Implications of the way of compliance with VOCs and Formaldehyde 6. Need for clarification on the energy consumption criteria 7. Withdrawal of the waste management requirement
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Current Ecolabel wooden floor coverings: type of products
Scope and definition Current Ecolabel wooden floor coverings: type of products Materials Finishing Function Parquet & solid wood Pre-finished Structural Laminate Unfinished Non-structural Cork Indoor Bamboo Outdoor Hybride Wall covering Pre-finished floorings are ready to install floorings on which the surface treatment has been applied by the manufacturer: - higher amount of chemicals used - compliance with criteria guarantees a certain level of env performance Unfinished floorings need surface treatment to be applied at user's place - lower amount of chemicals used by the manufacturers easier compliance with the Ecolabel criteria - out of CB's hands which is the env performance of these floorings - niche market in comparison to pre-finished floorings
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Plant-based material content
Scope and definition Plant-based material content Minimum wood and plant-material quantity - currently: 90%wt - proposed 1st AHWG meeting: 80% wt - proposed 2nd AHWG meeting: 75% wt Market share 90%wt 80%wt 75%wt Parquet & solid wood 25 Yes yes Laminate 70 No Partial Cork 3 Bamboo 2 Hybride -- no TOTAL (estimation) < 30% < 50% 100% Discussion points: 0.1 Should the scope of the product group be narrowed to only 'pre-finished' products? 0.2 Should the percentage of wood and/or plant-based material (in the final product) be reduced to 75%?
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Simplification of criteria Current EU Ecolabel
Proposed simplified criteria Raw materials Sustainable forest management Certified sustainable wood Recycled wood and plant materials Impregnating substances and preservatives Genetically modified wood Use of dangerous substances Dangerous substances for the raw wood and plant treatments General restriction on hazardous substances Dangerous substances in the coating and surface treatments Adhesives - VOC content Biocides and preservatives Formaldehyde Flame retardants Plasticisers Plasticizers Biocides Heavy metals in paints and varnishes Production process Energy consumption Waste management Use phase Release of dangerous substances from the final product Packaging Fitness for use Information Consumer information User information Information appearing in the EU Ecolabel
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Sustainable certified wood and plant based materials
All wood, cork and bamboo shall be covered by chain of custody certificates issued by an independent third party certification scheme such as FSC, PEFC or equivalent. All virgin wood, cork and bamboo shall be covered by valid sustainable forest management certificates issued by an independent third party certification scheme such as FSC, PEFC or equivalent. Where certification schemes allow mixing of uncertified material with certified and/or recycled materials in a product or product line, a minimum of 70% of the wood, cork or bamboo shall be sustainable certified virgin material and/or recycled material. Uncertified material shall be covered by a verification system which ensures that it is legally sourced and meets any other requirement of the certification scheme with respect to uncertified material. The certification bodies issuing forest and/or chain of custody certificates shall be accredited or recognised by that certification scheme.
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Sustainable certified wood and plant based materials
Assessment and verification: The applicant shall provide valid, independently certified chain of custody certificates for all wood, cork or bamboo used in the product or product line and demonstrate that the at least 70% of the material originates from forests managed according to Sustainable Forestry Management principles and/or from recycled sources that meet the requirements set out by the relevant independent chain of custody scheme. FSC, PEFC or equivalent schemes shall be accepted as independent third party certification. If the product or product line includes uncertified virgin material, proof should be provided that the content of uncertified virgin material does not exceed 30 % and is covered by a verification system which ensures that it is legally sourced and meets any other requirement of the certification scheme with respect to uncertified material.
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Sustainable certified wood and plant based materials
Cork certification Cork products are made of the bark of oaks, not of the trunks of the oak trees. Cork and articles of cork are excluded from the EUTR without a certification, legal origin is not covered/ensured Products are made of by-products of the bottle stopper industry Cork is certified by FSC and PEFC: Production certified: aprox 14% Land surface certified: 10.6% Other cork certification schemes are on the market but equivalence should be assessed by the CBs (eg SysteCODE: international code of cork stoppers manufacturing practice)
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Sustainable certified wood and plant based materials
Bamboo certification Bamboo products are made of bamboo that is a grass. Bamboo harvesting did not cause deforestation: not a tree. Bamboo is certified by FSC and PEFC at international level Land surface: 263mha by PEFC and mha by FSC CoC: by PEFC and by FSC and other national schemes: US (SFI ad ATFS), Indonesia (LEI and IFCC), Canada (CSA), Malasia (MTCC), Australia (ASF), Chile (Certfort) and China (CFCC) Bamboo certification schemes are different from forest management certification: No requirement on annual allowance cut – Very short term management plan– More intensive management– Less heavy machinery– Not so strict requirements on biodiversity, due to a kind of plantation specially monoculture– More strict requirements on chemical use, especially for bamboo for food
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Sustainable certified wood and plant based materials
Discussion points: 1.1 Should cork and bamboo be included into this criterion? 1.2 Assessment and verification: Should the flooring manufacturer be covered by the chain of custody? Should the balance sheet be accepted as a proof of verification? 1.3 Comments on the criteria wording
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General and specific restrictions on hazardous substances
Main changes introduced in the 2nd AHWG meeting proposal: Criterion 2 (general restriction in hazardous substances) includes: 1) Restrictions on SVHC that cannot be derogated 2) Substances classified with H-phrases that can be derogated if needed. General threshold: 0.10%wt in the final product. a) only the product as a whole is proposed to be considered. Threshold not applicable to component parts b) Concentration limits for hazardous substances would be: - 2% wt of classified substances in the resin for a resin content of 5% wt - 5% wt of classified substances in the surface treatment for a surface treatment content of approx 2% wt This means, criterion 2 is too loose
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General and specific restrictions on hazardous substances
Main changes introduced in the 2nd AHWG meeting proposal: Criterion 3 (specific restriction in hazardous substances) includes: 1. Pollutants in recycled wood and plant-based materials: Opened to equal or stricter national schemes Extended to cork and bamboo although not separately collected at the moment 2. Ban on preservatives, biocides and flame retardants Exempt for those required as in-can preservatives or required by national legislation, etc 3. VOC and formaldehyde in resins and adhesives 4. Heavy metals in paints and varnishes 5. VOC in surface treatment (paints and varnishes) 6. Halogens 7. Plasticizers
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General restrictions on hazardous substances Main changes foreseen after the 2nd AHWG meeting: Criterion 2 (general restriction in hazardous substances) will change: List of derogations: a new derogation was announced to be sent. This request will be evaluated and if needed included in the proposed list.
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Specific restrictions
on hazardous substances Main changes foreseen after the 2nd AHWG meeting: Criterion 3 (specific restriction in hazardous substances) will change: Restriction on halogens will be withdrawn: as it was pointed out by several industry members that are not used in this product group. Restriction on plasticizers will be reintroduced, especially if the plant-based material content is lowered.
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General and specific restrictions
on hazardous substances Discussion points: 2.1 Comments on the structure of both criteria dealing with hazardous substances: - general restrictions with a threshold of 0.10 % wt in the final product - specific restrictions of substances that can be contented in the final product below the 0.10%wt threshold or that can be used in the manufacturing process. 2.2 Comments on the content of both criteria.
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VOCs and formaldehyde where to check?
VOCs and formaldehyde can be checked: - as VOCs and formaldehyde content in the raw materials (SDS) - as VOCs and formaldehyde emissions in the final product (chamber test) Options for EU Ecolabel criteria: 3.1) Testing of the raw materials: - cheaper and easier way for demonstrating compliance by the industry (SMEs): providing suppliers declarations and calculations - CBs have to understand how chemicals are used. - if no VOCs or formaldehyde are used best way, if VOCs and formaldehyde are used in low amount, this method does not ensure the amount released during the use-phase - testing ensures low release of formaldehyde in the end-of-life - criteria reduced in one
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VOCs and formaldehyde where to check?
Options for EU Ecolabel criteria: 3.2) Testing of the final product: - This method ensures that the final product is low-emitting during the use phase - Very easy to verify by the CBs - It is more expensive for the industry (approx 1000euro/test) - Reduction in the number of criteria (3 criteria less) 3.3) Two alternatives for testing: - Provides flexibility to the industry - Not sure that the level of ambition is the same in both alternatives - No reduction in the number of criteria 3.4) Keeping double testing: raw materials and final product
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VOCs and formaldehyde where to check?
Discussion points: 3.1 Which is the best way to verify the low-emission of pollutants? - verification at the raw materials level - verification at the final product level - verification either at raw materials or at the final product level - verification at both raw materials and at the final product level
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Main changes introduced in the 2nd AHWG meeting proposal:
Waste management plan Main changes introduced in the 2nd AHWG meeting proposal: Implementation of the waste management plan prior to the application: 1. Proposed to be applied one year before applying New companies have no data to demonstrate 2. Proposed to be applied at least three months before applying 3. Difficulties for assessing and verifying the criterion: - proposed to withdraw the criterion - proposed to be verified through ISO 14001 - removal of the criterion will be coherent with other Ecolabel criteria sets Discussion points: 4.1 Should waste management plan criteria be kept? 4.2 If so, how should it be verified?
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Energy consumption This criterion addressed the identified main environmental impacts Implementation of the energy consumption criteria as set in the Nordic label scheme: It does not award the use of RE such as solar or wind It does not award the use of green electricity It does not differ between primary and secondary energy It does not account for the energy used in transport: no penalization if the raw materials and floorings are delivered for long distances.
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Energy consumption This criterion addressed the identified main environmental impacts Need for: Further information on how the current formula was developed and if it can be extended across Europe: conversion factors proposed, benchmarks, etc Understanding the possible advantages and drawbacks of using this criterion/formula Discussion points: 5.1 Information about how the formula was developed and if it can be extrapolated across Europe: bonus for green electricity, purchased or on-site produced, % of the RE fuels, fuels accounted as primary or secondary energy, conversion factors to be used, etc 5.2 Any other idea how to tackle this environmental impact?
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Other criteria Formaldehyde from the core board it was considered as not relevant by the industry. Kept or withdrawn depending on the decision on how to test VOCs and formaldehyde Indoor climate it was considered as relevant by the industry. Kept or withdrawn depending on the decision taken Fitness for use it should be revised regarding technical standards Maintenance It was considered to be out of the scope of this criterion. Feedback is needed. Information no comments
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Summary Discussion points Scope and definition 0.1 Should the scope of the product group be narrowed to only 'pre-finished' products? 0.2 Should the percentage of wood and/or plant-based material (in the final product) be reduced to 75%?
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Summary Discussion points Sustainable certified plant-based materials 1.1 Should cork and bamboo be included into this criterion? 1.2 Assessment and verification: Should the flooring manufacturer be covered by the chain of custody? Should the balance sheet be accepted as a proof of verification? 1.3 Comments on the criteria wording
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Summary Discussion points Hazardous substances 2.1 Comments on the structure of both criteria dealing with hazardous substances: - general restrictions with a threshold of 0.10 % wt in the final product - specific restrictions of substances that can be contented in the final product below the 0.10%wt threshold or that can be used in the manufacturing process. 2.2 Comments on the content of both criteria.
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Summary Discussion points VOCs and formaldehyde emissions/content 3.1 Which is the best way to verify the low-emission of pollutants? - verification at the raw materials level - verification at the final product level - verification either at raw materials or at the final product level - verification at both raw materials and at the final product level
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Summary Discussion points Waste management plan criteria 4.1 Should waste management plan criteria be kept? 4.2 If so, how should it be verified?
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Summary Discussion points Energy consumption 5.1 Information about how the formula was developed and if it can be extrapolated across Europe: - bonus for green electricity, purchased or on-site produced, - % of the RE fuels, - fuels accounted as primary or secondary energy, conversion factors to be used, etc 5.2 Any other idea how to tackle this environmental impact?
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Next steps? Following on from this 2nd AHWG meeting
-Draft minutes will be circulated - Please check them for accuracy, we will give a deadline -Deadlines for written comments: 30th JUNE 2015 - June 2015: EUEB progress report - Technical Report v3.0~ October 2015
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Thanks for your attention
Contact: Alicia Boyano Larriba Tel
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Table 1 Grouping of Candidate List SVHCs and CLP hazards
Hazardous substances The presence in the product of substances that are identified according to Article 59 of Regulation (EC) No 1907/2006 (the 'REACH Regulation') or substances or preparations that meet the criteria for classification according to Regulation (EC) No 1272/2008 of the European Parliament and of the Council (the 'CLP Regulation) for the hazards listed in table 1, shall be restricted in accordance with sub-criteria 2.1 and 2.2. Table 1 Grouping of Candidate List SVHCs and CLP hazards
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Hazardous substances 2.1 Restriction of substances of very high concern (SVHCs) The floor covering product shall not contain substances that have been identified according to the procedure described in Article 59(1) of Regulation (EC) No 1907/2006 and included in the Candidate List of SVHCs, at concentrations greater than 0.10% (weight by weight). No derogation from this requirement shall be given to Candidate List SVHCs present in the product or in its component parts shall be given to Candidate List SVHCs present in the product or in its sub-assemblies in concentrations greater than 0.10% (weight by weight). Assessment and verification The applicant shall provide a declaration of compliance for the product regarding the non-presence of SVHCs above the specified concentration limit. Declarations shall be with reference to the latest version of the Candidate List published by ECHA.
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Hazardous substances 2.2. CLP Restrictions of substances and preparations used in the floor covering product (a) CLP restriction of substances and preparations used by the floor manufacturer Adhesives, paints, primers, varnishes, stains, preservatives, resins and sealants but not lubricating oils used by the floor manufacturer during assembly and any other treatment of the floor product shall not be classified with any of the CLP hazards listed in Table 2. However, the use of such restricted substances or preparations shall be permitted if one or more of the following conditions apply: That the restricted substance or preparation was used in quantities that amount to less than 0.10% of the weight of the floor product. That the restricted substance or preparation changes its properties upon processing (e.g. becomes no longer bioavailable or undergoes chemical modification) so that the restricted CLP hazards no longer apply and that any unreacted residual content of the restricted substance or preparation is less than 0.10% (weight by weight) in the floor product. That compliance with specific derogation conditions for specific restricted substances or preparations, as set out in Table 2, is demonstrated.
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Hazardous substances (b) CLP restriction of substances and preparations used by suppliers in defined materials Suppliers shall demonstrate that the following materials have not been produced using substances or preparations that are classified with any of the CLP hazards listed in Table 1, by providing information about specific substances or preparations used in in the production of solid wood and wood-based panels: classification information for any adhesives, paints, pigments, primers, varnishes, stains, preservatives, resins and sealants. However, the use of such restricted substances or preparations shall be permitted if one or more of the following conditions apply: That the restricted substance or preparation was used in quantities that amount to less than 0.10% of the weight of the floor product. That the restricted substance or preparation changes its properties upon processing (e.g. becomes no longer bioavailable or undergoes chemical modification) so that the restricted CLP hazards no longer apply and that any unreacted residual content of the restricted substance or preparation is less than 0.10% (weight by weight) in the floor product. That compliance with specific derogation conditions for specific restricted substances or preparations, as set out in Table 2, is demonstrated.
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Hazardous substances Substance / preparation Derogated
classification(s) Derogation conditions* (a) Biocides / preservatives All group 3 hazards listed in table 1 See criterion 3.2 (f) (b) Flame retardants H317(1B), H373, H411, H412, H413 The product must be intended to be used in applications in which it is required to meet fire protection requirements for ISO, EN, Member State or public sector procurement standards and regulations.
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Hazardous substances Assessment and verification:
The applicant shall provide a declaration of compliance with criterion 2.2(a), supported by a list of all the preparations used during the assembly and any treatment of the floor product together with their hazard classifications (if any). The applicant shall compile declarations of compliance with criterion 2.2(b) from suppliers of any of the defined materials. These declarations shall be supported by lists of any relevant substance and preparations used and their hazard classifications (if any). The following information shall be provided in relation to the hazard classifications or non-classification for each substance or preparation: (i) The substance’s CAS, EC or list number; (ii) The physical form and state in which the substance or preparation is used; (iii) Harmonised CLP hazard classifications; (iv) Self-classification entries in ECHA's REACH registered substance database10. Self-classification entries from joint submissions shall be given priority when comparing entries in the REACH registered substance database.
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Hazardous substances Assessment and verification (2):
Where a classification is recorded as ‘data lacking’ or ‘inconclusive’ according to the REACH registered substance database, or where the substance has not yet been registered under the REACH system, toxicological data meeting the requirements in Annex VII to Regulation (EC) No 1907/2006 shall be provided that is sufficient to support conclusive self-classifications in accordance with Annex I to Regulation (EC) No 1272/2008 and ECHA's supporting guidance. In the case of 'data-lacking' or 'inconclusive' database entries, self-classifications shall be verified, with the following information sources being accepted: - Toxicological studies and hazard assessments by ECHA peer regulatory agencies11, Member State regulatory bodies or Intergovernmental bodies; - A Safety Data Sheet fully completed in accordance with Annex II to Regulation (EC) No 1907/2006; - A documented expert judgment provided by a professional toxicologist. This shall be based on a review of scientific literature and existing testing data, where necessary supported by results from new testing carried out by independent laboratories using methods approved by ECHA; - An attestation, where appropriate based on expert judgment, issued by an accredited conformity assessment body that carries out hazard assessments according to the GHS or CLP hazard classification systems.
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Hazardous substances Assessment and verification (3):
Information on the hazardous properties of substances of preparations may, in accordance with Annex XI to Regulation (EC) No 1907/2006, be generated by means other than tests, for instance through the use of alternative methods such as in vitro methods, by quantitative structure activity models or by the use of grouping or read- across. For criterion 2.2(a) or 2.2(b), as appropriate, where substance or preparations with the restricted hazards listed in Table1are considered to no longer exhibit any restricted hazardous properties in the final product due to physical and/or chemical changes during processing, and residual levels in the final product, can be considered to be present at concentrations less than 0.10 % w/w, the applicant shall specifically mention this in their declaration and provide supporting arguments. For both criterion 2.2(a) or 2.2(b), as appropriate, where the use of restricted substances or preparations may be subject to derogation as per Table 2, the applicant shall provide proof that all the derogation conditions are met, as described in Table 2. Where test reports are required, they shall be valid at the time of application for a production model
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Bamboo forest management certification for timber– Similar to forest management certification For sustainable management– Many schemes (international and national) just use forest management certification standard to audit it– Only two countries have special bamboo forest management certification standards: China and Ecuador (Guadua bamboo) Bamboo forest management certification: Different from forest management certification: No requirement on annual allowance cut (AAC)– Very short term management plan– More intensive management– Less heavy machinery– Not so strict requirements on biodiversity, due to a kind of plantation specially monoculture– More strict requirements on chemical use, especially for bamboo for food PEFC just endorses national schemes, does not directly certify forest in China FSC certified 100 forest management units in China– Including 17 forest management units of bamboo forest management certification Using FSC international generic principles and criteria All for timber, and further chain of custody for bamboo products for export, such as bamboo flooring, bamboo furniture (such as garden furniture)
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Challenges for industry: More and better opportunities than challenges– Both for bamboo forest managers– And for bamboo processing industries– As well as bamboo products export traders Brief analysis is both for bamboo forest managers and for bamboo processing industries Challenges for bamboo managers: As mostly small and household operation– Higher standard management system, such as bamboo forest management plan– Higher requirements for management practices, environmental, social and economic– Higher costs, both direct for auditing and indirect for improvement– Stronger coordination for association, due to group certification But benefits:– Increased economic income– Better marketing– Better social responsibility– Better environmental conservation Challenges for bamboo manufactures Challenges for bamboo processing industries: As mostly small and medium enterprises (SME)– Higher standard management system– Not very easy access to certified bamboo raw materials– Not stable order for export– Higher costs, but not significant But benefits:– Increased economic income– Better international market access– Better image for social responsibility and environmental conservation
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