Recycled Content Mandates
EPA is considering changes to federal purchasing guidelines that would require communication papers to have 100 percent post-consumer recycled content. Initiated under the purview of Executive Order 13693, this overly-simplistic “more is better” policy would ignore the realities of paper recovery and manufacturing and lead to undesirable economic and environmental consequences.
AF&PA opposes recycled content mandates as an ineffective path to increasing paper recovery.1 Additionally, the distinction between pre- and post-consumer content constrains the amount of recovered fiber available for recycling and should not be used in government policies.
EPA establishes federal agency procurement requirements under the Comprehensive Procurement Guideline program and Recovered Material Advisory Notices.
While well-intentioned, the proposed changes in procurement policy incorrectly assume that higher post-consumer recycled fiber content mandates will incentivize manufacturers to use more recovered fiber in their processes and, as a result of this theoretical increase in demand, recycling rates will increase.
In reality, recovered fiber markets are robust and highly complex and this new proposed rule by EPA will have far-reaching negative environmental and economic consequences.
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:
- A mandate that requires 100 percent recycled content in communications papers would divert recovered fiber from being recycled into other types of paper products where it can be efficiently utilized to its greatest environmental and economic benefit — the opposite of what EPA seeks to accomplish.
- Increasing recovered fiber mandates for communications papers will drive up the cost of manufacturing and create additional 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 global demand is increasing.
- The recovery rate of paper is high — currently at 66.8 percent — which, according to EPA, is much higher than the recovery rates of glass, aluminum or plastics. While recycled content mandates may contribute to increasing paper recovery when rates are low, such policies have little if any effect on recovery rates when recovery rates are high, as they are now in the U.S.
- Mandating post-consumer recycled content for fiber-based products creates the misleading perception that certain types of recovered fiber are better than others. All paper fiber that can be recovered should be recycled into new paper products.
- Not all types of recovered fiber are suitable for recycling into communications papers, and available post-consumer sources of recovered fiber are declining. Of all the recovered fiber consumed by U.S. paper mills, only 29 percent of post-consumer fiber is suitable for making communication papers.
- 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.
Rather than arbitrarily mandating 100 percent recovered content in communications papers, EPA should take a more measured approach that accounts for all of the environmental and economic consequences that mandates impose. 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.
1. RISI: White Paper on Federal Recycled Content Guidelines (2014)↩