Romanian Wood Industry Association – Prolemn submitted to the Ministry of the Environment, Waters and Forests comments and proposals on the projected Ministry Order regarding changes and additions to the SUMAL 2.0 methodology.
Considering the draft Order regarding changes and additions to the Methodology for the organization and operations of SUMAL 2.0 applications, as well as SUMAL 2.0 users’ obligations, Prolemn submitted to the Romanian Ministry of the Environment, Waters and Forests several comments and proposals:
- We consider inapplicable the provision regarding the filling, within 24 hours from the request of the control bodies, of the minutes for sorting, sawing, internal consumption.
- The operation of the minutes of sorting, sawing, transformation involves inventories of stocks. It cannot be done on flow in almost any technological flow. Inventory can be demanding and time-consuming, and can take several days, depending on the size of the inventory. This operation can be done monthly, until the 15th of the following month.
- The draft order refers to an amendment of GD 497/2020. We consider that it is not possible to have a debate on the order without being submitted to the decision-making transparency procedure and the amendment of GD 497/2020: We ask you to send us the current form of the draft normative act.
Romanian Wood Industry Association – Prolemn suggests having a public debate on the project on the draft Order for the modification and completion of the Methodology regarding the organization and operation of SUMAL 2.0 applications and the obligations of SUMAL 2.0 users.