Recycled Content
Mandates
July 2016
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
recovery1. 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.
Background
EPA establishes federal agency procurement requirements under the Comprehensive
Procurement Guideline (CPG) 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.
1
RISI: White Paper on Federal Recycled Content Guidelines (2014)
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Recycled Content Mandates
P. 2
• 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.
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@ForestandPaper
The American Forest & Paper Association (AF&PA) serves to advance a sustainable U.S. pulp, paper, packaging, tissue and wood products
manufacturing industry through fact-based public policy and marketplace advocacy. AF&PA member companies make products essential
for everyday life from renewable and recyclable resources and are committed to continuous improvement through the industry’s sustainability initiative - Better Practices, Better Planet 2020. The forest products industry accounts for approximately 4 percent of the total U.S.
manufacturing GDP, manufactures over $200 billion in products annually, and employs approximately 900,000
men and women. The industry meets a payroll of approximately $50 billion annually and is among the
top 10 manufacturing sector employers in 45 states.