NSF 426 Section 8 Packaging
JC Action Items on Recycled Fiber Criteria from 12-9-14 call
On the JC call on 12/9, the JC requested additional information on recycled content fiber
packaging, including definitions of postconsumer and total recycled content. This information
was requested to address a concern raised about the geographic differences in the definition
and tracking of postconsumer sources.
Section 8 Questions for the Joint Committee.
1. Which option for recycled fiber packaging is preferred by the Joint Committee?
2. For the chosen option, what % thresholds are preferred; for example, establish a “floor” or
leadership criterion?
This document contains the following background information.
o
Definitions
 ISO 14021 Environmental Labels and Declarations
 US EPA Comprehensive Procurement Guidelines (CPG) Guidelines
 Forest Stewardship Council
 IEEE 1680 standard
 NSF 426 – proposed definition from TG 7 Preferable Materials Use
o
Recovered (recycled) fiber criteria in current standards on the EPEAT Registry and %
products claiming these criteria
o
Recycled content corrugated in different regions
o
Section 8 criteria options – language for JC consideration (taking into account
discussions from 12/9/14)
Options for Recycled Fiber Criteria
1. Required and optional criteria (as proposed by TG)
 Required – total recycled fiber
 Optional – higher total recycled fiber plus post-consumer content
2. Required criterion only for total recycled fiber (similar to 1680.2/.3)
3. Optional criterion only for total recycled fiber (possibly consider higher %, given #
of products claiming optional criterion in 1680.1?)
4. No recycled fiber criterion
Definitions
In summary:
1) The definitions of post-consumer in ISO and EPA differ around the return of material
within distribution chain. A good illustration of the difference is provided by the “The
Paper Lifecycle” a project of GreenBlue at http://thepaperlifecycle.org/recovery/indepth/recovered-and-recycled-paper-fiber-types-defined/. Both ISO and EPA exclude
material recycled within the same manufacturing plant.
“The International Organization for Standardization (ISO) considers magazines that reach the
newsstand, are not sold, and are used again for recycled paper to be post-consumer material.
According to the U.S. Environmental Protection Agency (EPA), magazines that reach the
newsstand, are not sold, and are used again for recycled paper are considered pre-consumer
material.”
2) The Forestry Stewardship Council (FSC) Reclaimed Materials Sourcing standard used
for supply chain certification allows both post-consumer and pre-consumer sources to
receive “reclaimed” status.
3) A brief article written by a paper industry representative provides a good, short
explanation of the inconsistency among definitions, and suggests “percentage recycled
content fiber” as a common term.
http://www.environmentalleader.com/2011/09/20/defining-recycled-content-in-paperproducts/) This article sums up by saying:
“Regardless of whether you are looking at ISO or EPA definitions, both post industrial
and post consumer fiber falls in the category of recycled fiber content. So when making
claims it is safest to simply state a certain percentage of recycled fiber. But if you want to
be more specific about the type of fiber for making a claim (or when trying to understand
a supplier’s claim) be sure to check the definitions and more specifically whether the
definition in use is coming from the EPA or ISO.
Definitions
Note: green highlights emphasize point #1 above. That is, difference in post-consumer
definitions between ISO & EPA and the common exclusion of plant waste in pre-consumer/postindustrial.
1) International Organization of Standardization (ISO)
Recycled content is defined by ISO 14021 (from
Recycled content: Proportion, by mass, of recycled material in a product or packaging. Only preconsumer and post-consumer materials shall be considered as recycled content, consistent with
the following usage of the terms:
o
o
Pre-consumer material: Material diverted from the waste stream during a manufacturing
process. Excluded is reutilization of materials such as rework, regrind or scrap generated in a
process and capable of being reclaimed within the same process that generated it.
Post-consumer material: Material generated by households or by commercial, industrial and
institutional facilities in their role as end-users of the product, which can no longer be used
for its intended purpose. This includes returns of material from the distribution chain.
2) EPA Definitions from Comprehensive Procurement Guidelines
See: http://www.epa.gov/epawaste/conserve/tools/cpg/products/define.htm
Postconsumer fiber means:



Paper, paperboard, and fibrous wastes from retail stores, office
buildings, homes, and so forth, after they have passed through
their end-usage as a consumer item, including: used corrugated
boxes; old newspapers; old magazines; mixed waste paper;
tabulating cards; and used cordage; and
All paper, paperboard, and fibrous wastes that enter and are
collected from municipal solid waste.
Postconsumer fiber does not include fiber derived from printers'
over-runs, converters' scrap, and over-issue publications.
Recovered fiber means:
Postconsumer fiber such as:
 Paper, paperboard, and fibrous materials from retail stores,
office buildings, homes, and so forth, after they have passed
through their end-usage as a consumer item, including: used
corrugated boxes; old newspapers; old magazines; mixed
waste paper; tabulating cards; and used cordage; and
 All paper, paperboard, and fibrous materials that enter and are
collected from municipal solid waste, and
Manufacturing wastes such as:
 Dry paper and paperboard waste generated after completion of
the papermaking process (that is, those manufacturing
operations up to and including the cutting and trimming of the
paper machine reel into smaller rolls or rough sheets) including:
envelope cuttings, bindery trimmings, and other paper and
paperboard waste resulting from printing, cutting, forming, and
other converting operations; bag, box, and carton
manufacturing wastes; and butt rolls, mill wrappers, and
rejected unused stock; and
 Repulped finished paper and paperboard from obsolete
inventories of paper and paperboard manufacturers, merchants,
wholesalers, dealers, printers, converters, or others.
Mill broke means any paper waste generated in a paper mill prior to completion of the
papermaking process. It is usually returned directly to the pulping process. Mill broke is
excluded from the definition of "recovered fiber."
3)
Forest Stewardship Council
In its standard for Sourcing Reclaimed Materials in its Chain of Custody Program
definitions of post-consumer and pre-consumer align with US EPA. A complete list of
examples of pre & postconsumer can be found at: https://ic.fsc.org/reclaimedmaterial.93.htm
Reclaimed material: Material that demonstrably would have otherwise been disposed
of as waste or used for energy recovery, but has instead been collected and reclaimed
as input material, in lieu of virgin material for re-use, recycling, re-milling in a
manufacturing process or other commercial application. Inputs of the following material
categories are classified as reclaimed materials:
-
FSC Recycled material
Post-consumer reclaimed material
Pre-consumer reclaimed material
(FSC – STD-40-007 (V2-0)
4) IEEE 1680 Standards (appear to use EPA CPG definitions)

postconsumer: A material or finished product that has served its intended use and
has been discarded for disposal or recovery, having completed its life as a consumer
item; part of the broader category of “recovered” items.

recovered: Waste materials and by-products reclaimed or diverted from solid waste,
not including those materials and by-products generated from, and commonly
reused within, an original manufacturing process.

recovered fiber: Postconsumer fiber such as paper, paperboard, and fibrous
materials from retail stores, office buildings, homes, and so forth, after they have
passed through their end-usage as a consumer item, including used corrugated
boxes, old newspapers and magazines, mixed waste paper, tabulating cards, and
used cordage; and all paper, paperboard, and fibrous materials that enter and are
collected from municipal solid waste, and manufacturing wastes such as dry paper
and paperboard waste generated after completion of the papermaking process (that
is, those manufacturing operations up to and including the cutting and trimming of
the paper machine reel into smaller rolls or rough sheets) including, envelope
cuttings, bindery trimmings, and other paper and paperboard waste resulting from
printing, cutting, forming, and other converting operations; bag, box, and carton
manufacturing wastes; and butt rolls, mill wrappers, and rejected unused stock; and
repulped finished paper and paperboard from obsolete inventories of paper and
paperboard manufacturers, merchants, wholesalers, dealers, printers, converters, or
others. Mill broke means any paper waste generated in a paper mill prior to
completion of the papermaking process. It is usually returned directly to the pulping
process. Mill broke is excluded from the definition of recovered fiber.
5) NSF 426 proposed by TG 7 on Preferable Material Use
Postconsumer recycled material: Material generated by the end users of products that
has fulfilled its intended purpose or can longer be used, this includes material returned
from within the distribution chain.
Current Standards on EPEAT Registry – Focus & Declared Products

1680.1
o Criterion 4.8.3.2 (Optional)
Packaging shall meet or exceed minimum postconsumer content of CPG over
the year using weighted average.
Based on table above, the minimum postconsumer content:
 Corrugated
25%
 Folding cartons 40%
o
o
Definitions

postconsumer: A material or finished product that has served its intended
use and has been discarded for disposal or recovery, having completed its
life as a consumer item; part of the broader category of “recovered” items.

recovered: Waste materials and by-products reclaimed or diverted from
solid waste, not including those materials and by-products generated from,
and commonly reused within, an original manufacturing process.
Products on EPEAT Registry claiming optional point
US
China
Taiwan
Latvia
Brazil

1680.2 & 1680.3
o Criterion 4.8.3.1 (Required)
% of products declared to 4.8.3.2
93.6% (1487 of 1589 )
95.5 % (405 of 424)
96.9 %(375 of 387)
96.3 % 336 of 349)
96.9% (345 of 356)
Packaging materials meet or exceed the minimum total recovered fiber content
specified. Give preference to post-consumer content.
Corrugated
Paperboard
Total recovered fiber
25%
80%
Recycled Content Fiber
US (based on TG 8 research – multple sources)

47% recycled fiber (from old corrugated containers) is industry average for corrugated in US
(http://www.fibrebox.org/upload/2009/WMT%20Packaging%20Material%20Brief%20Corrugate
d%2011-2007%20final.pdf)

At least 3 major packaging companies in US (Cascade, Rack10, SP Fiber Technology) offer 100%
recycled content. Two breakpoints for post-consumer for cartons (with 100% total recycled): 35
% & 50-60 %. Cascade sold 100% recycled content with 40% PCR

For corrugated the fluted part (~1/3 of box) is often PCR, since less sensitive to quality;
therefore 30% PCR not unreasonable.
Europe
Source: FEFCO & CEPI ContainerBoard, 2012 European Database for Corrugated Board Life
Cycle Studies; downloaded at
http://www.fefco.org/sites/default/files/documents/LCA%20report%202012_0.pdf
Taiwan
One supplier offers 3 grades (which are listed on their MSDS); other suppliers in Taiwan &
China are expected to be similar, according to one manufacturer. This manufacturer uses A &
B2 for server products, but mostly B2. Using grades with less recycled content is more
expensive. Post-consumer content is not differentiated.
Grade
Recycled Waste
A
75-85%
B2
80- 90%
B4
100%
Options for Recovered Fiber Criteria
1. Required and optional criteria (as proposed by TG)
 Required – total recycled fiber
 Optional – higher total recycled fiber plus post-consumer content
2. Required criterion only for total recycled fiber (similar to 1680.2/.3)
3. Optional criterion only for total recycled fiber (possibly consider higher %, given #
of products claiming optional criterion in 1680.1?)
4. No recycled fiber criterion
Option #1 – as proposed by the TG (with exclusion for alternatives per 12/9 discussion)
Required + Optional
8.1.3 Total Recycled Fiber Content in Packaging TG Recommendation (Required)
Fiber-based packaging materials shall contain the a minimum total percentage recycled content fiber
content (by fiber weight) as specified shown in Table 8.1. In their packaging specifications, m
Manufacturers shall give also state a preference in purchasing specifications for a minimum to the
maximum 25 percent postconsumer recycled content fiber content (by fiber weight). Fiber-based
content derived from alternative sources (such as bamboo or mushrooms) to traditional paper mill
products are exempt from this recycled fiber requirement.
“Not Applicable” may be declared on the Product Registry by manufacturer if the product packaging
does not contain fiber-based packaging, or if fiber-based packaging is derived from exempt alternative
sources.
Table 8.1
Packaging Category
Corrugated containers
Percentage Total Recycled Content
Fiber (by fiber weight)
50
All other fiber-based packaging
80
8.2.1 Higher Total Recycled Fiber and Post Consumer Content TG Recommendation (Optional)
Fiber-based packaging materials shall contain a minimum percentage total and PCR recycled content
fiber (by fiber weight) as specified in Table 8.2.
Table 8.2
Packaging Category
Percentage Total Recycled Content
Fiber
Percentage PCR Content
Fiber (by fiber weight)
(by fiber weight)
Corrugated containers
80
35
All other fiber-based packaging
100
40
Manufacturer shall document of the source of post consumer recycled content to demonstrate that the
fiber meets the definition of post consumer recycled content in this standard.
“Not Applicable” may be declared on the Product Registry by manufacturer if the product packaging
does not contain fiber-based packaging.
This criterion may be declared differently in different countries or regions.
Option #2 (Required)
Required criterion from Option #1 only
Option #3 (Optional)
Optional criterion only with higher thresholds for recycled content; no PCR
8.2.1 Higher Total Recycled Fiber and Post Consumer Content TG Recommendation
Fiber-based packaging materials shall contain a minimum percentage total recycled content fiber (by
fiber weight) as specified in Table 8.2.
Table 8.2
Packaging Category
Percentage Total Recycled Content
Fiber (by fiber weight)
Corrugated containers
80
All other fiber-based packaging
100
“Not Applicable” may be declared on the Product Registry by manufacturer if the product packaging
does not contain fiber-based packaging.
This criterion may be declared differently in different countries or regions.
Option #4
No recycled fiber criterion