Policy Priorities for Tissue Manufacturers

Jun 13, 2016
Harman_Donna-WebBy Donna Harman
President & CEO
May/June PaperAge

Products such as facial and bathroom tissue, paper towels and napkins are at the forefront of new technologies and innovation. Tissue manufacturers are achieving increasingly sustainable production while improving quality and product options for consumers.

To focus on legislative and advocacy issues of importance to the tissue industry in particular, AF&PA established a tissue sector to provide a forum for companies that manufacture tissue products to work with our experts on a number of policy and marketplace advocacy issues. 

False Claims

For several years, AF&PA has utilized technical and legal resources to constructively engage companies making specific false and/or misleading marketing claims about our industry’s products. For the tissue industry, we have concentrated on false or misleading marketing messaging relating to electric hand dryers that suggest paper towel use is damaging to the environment, while hand dryer use is not.

One company had a misleading infograph on their website that failed to include the use of recovered fiber in its depiction of the paper towel manufacturing process and claimed “hand dryers are the better choice for our environment and future generations.” We reached out to the company to request correction of the infograph and developed a paper towel fact sheet that highlights the advantages of paper towels to aid our efforts. The company responded by removing all graphics about the tissue manufacture process from their website.  

Recovered Fiber

Paper recovery is one of our industry’s most positive sustainability messages and AF&PA advances policies for a continuing and expanding domestic recovered fiber supply to help meet global demand. Most tissue products include recycled paper content: 90 percent of the 74 U.S. mills that produce tissue paper use some recovered paper to make new tissue products, and 18 of these mills use only recovered paper.


Concerns over the “flushability” of tissue products have continued to grow in state legislatures and municipalities across the northeast United States. Products like cleaning wipes and baby wipes are not explicitly labeled as “flushable,” but can be assumed incorrectly to be flushable in personal septic and public sewer systems. Incidents where these products have clogged waste water systems are triggering regulatory and legislative action targeting all flushable products.

Work by the industry is underway to refine flushability and labeling guidelines and consumer awareness via a Technical Workgroup on Flushability led by INDA, the industry association for nonwovens. We believe labeling requirements regarding flushability should be set by the industry at large or at the federal level to provide consistency for companies operating in more than one state to avoid having to comply with different rules in each jurisdiction. An additional layer of state regulation inadvertently could inhibit business and the technological innovation of tissue and paper products.

Combustible Dust

AF&PA recently took action on several combustible dust-related issues that have significant financial implications for manufactures and converters of tissue. The Occupational Safety and Health Administration (OSHA) had been using improper enforcement criteria for tissue paper combustible dust. The 1/32 inch upper limit for combustible dust accumulation OSHA was using to issue warnings and citations is representative of coal dust, which, like many other materials, has a significantly higher bulk density than dust from tissue paper.

AF&PA submitted comments to OSHA, convincing them to explicitly acknowledge that “very low bulk density materials, such as tissue paper dust, may not create a deflagration hazard even at an accumulation level of ¼ inch…” or more, depending on the bulk density and other attributes of the dust. We also developed a one-page document summarizing OSHA’s revised guidelines to ensure that companies are aware of how tissue paper dust is assessed.

Chemical Regulation

California Proposition 65, the Safe Drinking Water and Toxic Enforcement Act of 1986, requires companies doing business in California to provide a clear and reasonable warning before knowingly and intentionally exposing someone to a Proposition 65 chemical. The Proposition 65 list currently contains over 900 chemicals and is updated constantly, increasing the risk of noncompliance and liability.

To save our members’ time, money and personnel resources, we developed California Proposition 65 Assessment Software, a proprietary tool that assists organizations with determining whether their products are in compliance with Proposition 65.


To comply with new environmental regulations, electric utilities are expending billions, transitioning to natural gas and, in some cases, shutting down plants, jeopardizing access to an affordable and reliable energy supply required for the manufacture of tissue products.

AF&PA helped establish and is committed to maintaining very favorable national demand response policies, which allow electricity customers to reduce their consumption at critical times or in response to market prices. We also are working to shape government policies related to the coordination of natural gas and electric markets to minimize energy cost increases resulting from the utilities’ transition to natural gas.

Learn More about AF&PA’s Tissue Sector

If your company manufactures tissue, we would love to talk to you about our work and how you can engage as a member of the tissue sector to shape the policies that AF&PA advocates for on your behalf. For more information about the tissue sector, contact membership@afandpa.org.