This report is the Finnish contribution to the second exchange of information defined in the Council Directive 96/61/EC and to the preparation of the second Reference Document of the European Commission on Best Available Techniques in the Pulp and Paper Industry (BREF). The report is the work of Poyry Forest Industry Consulting Oy on behalf of the Finnish Forest Industries Federation and Finnish Environment Institute. In this report, a series of suggestions for improvements to the BREF are given. The suggestions are shored up with reasoning and examples behind them. Among key messages in this document we find: • Uphold and emphasise the key principles of the BAT BREF, and increase the readability of the BREF. • The need for ensuring smooth running and minimising accidental releases should be emphasised in the BREF. One way to ensure smoother running is to use simpler processes. • Cross-media effects should be further emphasised in the BREF. Lack of cross-media information and integrated views in decision making can result in wrong measures taken. • The chapters dealing with new techniques could be improved by reshaping them into a readable, clear and concise analysis of the current technology trends and selected techniques, not forgetting key principles of the BREF. • Based on information on both Finnish and international mills, it seems that not all the BAT ranges are on same level of stringency. In addition, BAT techniques do not necessarily go hand in hand with BAT emissions levels. It is recommended that this report is read together with the first pulp and paper BREF.