Day 056 - 28 Nov 94 - Page 18
1 its raw material from somewhere other than the country in
2 which it is situated.
3
4 MR. JUSTICE BELL: You refer to some imported hardwood market
5 pulp ---
6 A. Yes.
7
8 Q. -- at the bottom of page 4 when you are doing some
9 arithmetic.
10
11 MR. MORRIS: Page 3?
12 A. That is specific to that example, yes.
13
14 MR. MORRIS: Sorry, yes. There are two things; there is the
15 bottom of page 3 which is the imports into the EEC from
16 Scandinavia, USSR and Canada. So, I am just trying to
17 identify, these imports, where they go to. What happens to
18 the pulp that is imported from those countries into the
19 EEC?
20 A. It depends upon the mill and its need. Certain mills
21 may have a shortage of a particular variety. For example,
22 they may have insufficient hardwood to be able to produce
23 some of the particular types of paper they are making. In
24 the case of packaging, on the whole, the raw material is
25 local rather than imported.
26
27 Q. But it would include some imported material that inevitably
28 finds its way?
29 A. It could. That is to say, not every product will be
30 100 per cent from the resource of forests in the country
31 where the paper product is made.
32
33 Q. Right. So, all I am trying to say is that if a company is
34 buying a large amount of paper products throughout the
35 countries which you have -- throughout the EEC really, let
36 us say the EEC, the sources will be those countries which
37 you have identified and also those countries which are
38 importing into the EEC, such as former USSR, Scandinavia
39 and Canada, you have mentioned Canada anyway, Sweden and
40 Finland -- all I am saying is on your list, although you
41 have not any obviously accurate details, that would also
42 include the former USSR, it will inevitably find its way
43 into some of the products?
44 A. It is possible for a particular mill to have a need for
45 a particular product which it cannot satisfy from the
46 forestry sources of its own country and, therefore, it is
47 reasonable to say that, for example, birch required for a
48 particular type of paper finish, in other words, quality of
49 paper, the birch could come from the USSR and be turned
50 into a product in Finland.
51
52 Q. So, in your example that you use on page 4, you have
53 specified that it would include some imported hardwood
54 market pulp, that, for example, maybe from former USSR, for
55 example?
56 A. It might be. This is an economic decision made by the
57 individual mill which will decide which resource provides
58 the product it needs most economically.
59
60 Q. But you included that example because it is a practice that
