Metsa Board Oyj

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Comprehensive	Metsä Board discloses a very high level of detail about its climate-policy lobbying. It names a wide range of individual files it seeks to influence, including the EU Eco-design Regulation, the Packaging and Packaging Waste Regulation and Directive, the EU Deforestation Regulation, revisions to RED II and the EU Emissions Trading System, LULUCF, the industrial carbon-management framework COM(2024) 62, the EU Taxonomy and the Finnish climate and energy strategy, among others, demonstrating clear transparency on which pieces of legislation are in scope. The company also explains how it engages: “Corporate Affairs representatives meet policy makers and other stakeholders” at “the EU level, the Nordics and Germany,” while “other experts from our company participate in industry and trade association working groups,” and it confirms direct communications with the European Commission, providing direct contact details for its Vice-President of Corporate Affairs. Finally, it is explicit about the results it seeks, advocating for “an EU-wide compulsory forest regeneration after harvesting,” “effective and proportionate measures to halt deforestation,” the promotion of “recyclable materials from renewable sources,” a science-based definition of renewable carbon, recognition of bio-CCU and bio-CO₂ in EU policy, and balanced, LCA-based rules that do not compromise food and product safety. By setting out concrete legislative targets, the specific channels it uses, the jurisdictions addressed and the precise policy outcomes desired, the company shows comprehensive transparency around its climate-related lobbying activities.	4

Lobbying Governance

Overall Assessment	Comment	Score
Moderate	Metsä Board’s climate lobbying governance is embedded within Metsä Group’s centralized Corporate Affairs function, under which “Metsä Group’s Executive Board sets group wide policies, defines sustainability targets and advocacy priorities and monitors the progress,” and “SVP Corporate Affairs reports to the CEO and President of Metsä Group,” reflecting formal oversight and accountability. The group’s environmental policy, which covers both sustainability and lobbying, “has been approved by the Board of Directors of Metsäliitto Cooperative, and it is owned by the director reporting on sustainability to the President and CEO,” and local-level activities “are aligned with group level policies through environmental management systems” applied across all production units. The company actively engages in direct advocacy by influencing EU initiatives such as the deforestation regulation and participates indirectly through memberships in trade bodies including the Finnish Forest Industries Federation, CEPI, and the 4evergreen alliance. However, while “the activities are thus coordinated under one management which also considers needed actions if any inconsistencies would occur,” the company does not disclose any dedicated process to assess the climate alignment of its trade-association memberships or a standalone climate-lobbying audit or review, and we found no evidence of any criteria for evaluating or withdrawing from associations whose positions might conflict with its climate objectives.	2