Federal Procurement Policies


Federal procurement policies that mandate minimum recycled content in products – or require certain preferences, standards or labels for paper products – distort the market-based flow of materials, reduce U.S. company competitiveness, and unnecessarily add costs for U.S. paper manufacturers without adding measurable benefits to society.

  • AF&PA opposes recycled content mandates as an ineffective path to increasing paper recovery.1 The distinction between pre- and post-consumer content is meaningless in the current marketplace, constrains the amount of recovered fiber available for recycling, and should not be used in government policies.
  • AF&PA opposes government selection of environmental product standards and ecolabels for federal procurement without public notice and comment, which imposes standards that cannot be met, creates marketplace distortions, or makes choices with incomplete information.

Background

Based on an Executive Order2 issued by the Obama administration in 2015 regarding federal sustainable procurement, a Proposed Rule was issued in January 2017 by the Department of Defense, the General Services Administration, and the National Aeronautics and Space Administration that would amend the Federal Acquisition Regulations (FAR)3. The FAR requires government procurement of products that meet or exceed environmentally preferable recommendations made by EPA.

While well-intentioned, the procurement policies would lead to negative economic and environmental consequences, including:

  • Fewer, not more producers of recycled-content printing paper;
  • Forcing recovered fiber to uneconomical end uses, which in turn will have negative ripple effects on the economics of the broader market-based recovery system;
  • A product selection process that adds unnecessary costs and ignores all credible labeling systems.

AF&PA believes that mandates are ineffective for increasing paper recovery and utilization, and therefore opposes increasing the recycled content mandate for the following reasons:

  • Increasing recovered fiber mandates for communications papers will drive up the cost of manufacturing, creating risk and job losses in a paper segment already under great economic pressure to compete.
  • Mandates are not needed to spur increased utilization of recovered fiber as recovered fiber markets are robust, paper recovery rates are high (67.2 percent in 2016), and global demand is increasing.
  • Mandating post-consumer recycled content for fiber-based products creates the misleading perception that certain types of recovered fiber are better than others. Current third-party certification standards treat pre- and post-consumer content equally, supporting the fact that all paper fiber that can be recovered should be recycled into new paper products.
  • EPA’s post-consumer requirement negatively affects U.S. paper industry competitiveness because, unlike the broader International Standards Organization standards applied to many imported products, it limits the type of recycled fiber used in U.S. products.

EPA should not arbitrarily mandate minimum post-consumer content in products. The aim should be to increase paper recovery, and the U.S. paper industry has demonstrated its commitment by setting and working towards an industry-wide goal to exceed 70 percent recovery by 2020.

EPA should not be identifying or requiring sustainable product standards based on limited information, or making choices based on a process lacks transparency. Sustainable attributes of paper are not static, but change and continuously improve over time. Government adoption of certain standards may reduce product innovation and should be avoided.



1. RISI: White Paper on Federal Recycled Content Guidelines (2014)
2. Executive Order 13693, March, 2015
3. FAR Case2015-033