SAPPI LIMITED

SAPPI
NOTES TO THE GROUP ANNUAL FINANCIAL STATEMENTS (Continued)
for the year ended September 2010
32. ENVIRONMENTAL MATTERS (Continued)
would establish new standards for emissions of hazardous air pollutants from commercial and industrial
boilers. Significant capital expenditures could be required for emissions control equipment at our mills in
order to comply with the Boiler MACT and/or other proposed rules regulating GHGs. The nature, scope
and timing of any proposed legislation, including climate change legislation, is highly uncertain and,
currently, we do not know what precise effect, if any, such legislation will have on our financial condition
and operations.
Europe
Our European facilities are subject to extensive environmental regulation in the various countries in
which we operate. For example:
The Integrated Pollution Prevention and Control directive (‘‘IPPC’’) regulates air emissions, water
discharges and defines permit requirements and best available techniques (‘‘BAT’’) for pollution
control. The revised BAT reference documents (‘‘BREFs’’) are expected to be finalised in 2011.
The national European laws regulate the waste disposal framework and place restrictions on land
filling materials in order to reduce contaminated leachate and methane emissions. Prevention,
reuse and recycling (material or thermal) are the preferred waste management methods. In
Austria, Germany, Switzerland and The Netherlands only inert ash or slag from thermal recycling
and incineration processes may be placed in landfills.
The EU Chemicals Regulation REACH (1907/2006/EC) intended to harmonize existing European
and national regulations to provide a better protection of human health and our environment is
not directly applicable to pulp and paper. It does, however, apply to a number of raw materials
that we source. We will also register some intermediate substances in our pulp production
processes. We expect this registration to be finalised by November 2010.
In The Netherlands we, together with other paper manufacturers, have signed an agreement with
the national government to improve environmental management and further limit emissions.
The countries within which we operate in Europe have all ratified the Kyoto Protocol and we have
developed a GHG strategy to comply with applicable GHG restrictions and to manage emission
reductions cost effectively.
South Africa
In southern Africa, the environmental regulatory legal framework is still evolving, as is the
enforcement process. We work with government authorities in striving to find a balance between
economic development and, social and environmental considerations.
The Minister of Water and Environmental Affairs considered it necessary to strengthen enforcement
of legislation by the Environmental Management Inspectors (EMIs) in her department. The EMIs
prioritised various sectors of industry and inspected those sectors in the course of the past four years. In
2008, 2009 and 2010, the EMIs focused attention on the pulp and paper sector, signalling more stringent
enforcement for Sappi mills.
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