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The Forest Stewardship Council released its new draft chain of
custody standard incorporating new requirements for verifying and
labeling recycled materials, including paper, on March 10, 2003.
It invites comments to Sofia
Ryder at FSC until May 10, 2003.
Conservatree provided advice to FSC on drafting the proposed paper
standards. (Materials
for the Future Foundation advised on reclaimed wood issues.)
We expect to assist FSC in evaluating the responses to this draft
standard, as well.
(Requires Acrobat Reader)
CONSERVATREE COMMENTS:
As an international organization promoting forest stewardship,
FSC wants to create a globally valid standard which provides for
verification and labeling of FSC virgin and recycled content products
whicih meet FSC requirements. The new standards will cover paper
as well as wood/chip/fiberboard products. Because of this, there
are a number of places in the draft standard that may raise questions
for those primarily interested in North American paper issues. Usually,
these can be explained by the need for adaptation to both global
and non-paper considerations. Following are some questions and Conservatree's
answers, based on our work with FSC on this standard. (These Q&As
represent only Conservatree's responses, not FSC's. For an official
FSC response, contact Sofia Ryder.)
Q: What is different in this draft standard from other already-existing
recycled paper requirements?
A: Besides the potential for adding FSC-certified wood fiber
to recycled papers, there are some differences from other standards:
U.S. recycled paper standards under Executive Order 13101 and the
EPA recovered (recycled) materials guidelines allow some materials
that never left the mills to be counted as "recovered"
content. These materials, such as trimmings from in-plant converting
operations (e.g. when papers are cut to sheet sizes), are produced
after the original papermaking process and are returned for repulping
and inclusion in new paper whether it is subsequently labeled "recycled"
or "virgin." The U.S. standards allow them to count as
part of the "recycled," "recovered" or "preconsumer"
part of the content claim. In contrast, the draft FSC standard excludes
all materials in the mill from being counted as recycled, which
is consistent with practice in non-North American mills.
U.S. government standards for federal agency paper purchases, which
are replicated by hundreds of state and local governments and also
used voluntarily by many private sector purchasers, require a minimum
of 30% postconsumer content in uncoated papers and 10% postconsumer
in coated papers. FSC's proposed standard allows 30% FSC certified
virgin AND/OR verified postconsumer reclaimed fiber. This could
result in FSC certified recycled papers that do not meet the U.S.
minimums. However, many other countries around the globe do not
have the postconsumer sources that are so abundant in the U.S. and
are likely not to be able to incorporate high amounts of postconsumer
content. This would be a serious problem for U.S. purchasers if
the FSC recycled paper logo were a "one-size-fits-all"
logo. However, we expect that they will approve a logo that requires
producers to state the actual percentages of postconsumer and FSC
contents. This will allow purchasers to determine whether individual
papers do actually meet their procurement requirements. Alternatively,
the 30% minimum threshold could be raised.
European and other non-North American mills generally do not track
postconsumer content nor declare it as part of their content claim.
They usually do not have a system for separating postconsumer from
preconsumer in collection or at brokers. Therefore, they are more
likely to use a "deinked" standard, which may include
both pre- and postconsumer, but does not necessarily include postconsumer
and does not verify the amount, if there is any. The FSC draft standard
requires mills to track and quantify postconsumer content.
Q: I'm concerned about the potential for FSC recycled papers
to be below the U.S. standards. How could this be workable?
A: We believe that it will only work if the FSC label that
is used for these products requires statements of the actual percentages
of postconsumer and other fibers in the papers. However, if this
is met, it would allow both more verified information than is usually
available currently, and also allow FSC standards to be global.
At present, most recycled papers are not certified as to their postconsumer
percentage and source. FSC proposes to require that, and in addition
will certify the virgin fiber in the paper as meeting FSC requirements.
Non-U.S. purchasers do not have the same requirements for purchasing
recycled paper, and mills in some parts of the world are likely
to have difficulty incorporating enough postconsumer without having
to import it from the U.S. This FSC draft standard allows them to
incorporate and certify recycled and FSC content and sell it in
their markets.
We found that there is no single standard that will work globally.
The U.S. requirements are most achievable in countries that have
high consumption and paper wasting habits. They are more difficult
in countries that, either because of habit or necessity, do not
have mountains of discarded paper. We don't want them to develop
that level of waste to meet these standards!
However, if the contents are clearly labeled, then purchasers and
environmental/recycling advocates will be able to identify the FSC
recycled papers that meet their requirements and reject those that
do not. This will also require paper manufacturers to know their
markets, and to make products that meet the legislative and specification
requirements of those markets. We hope that manufacturers will recognize
the advantage to achieving much higher percentages than these minimums
in order to meet the environmental expectations of North American
purchasers.
Because of the potential for varying levels of recycled content,
we do not support an FSC label that does not break out the percentages
for each type of fiber.
Q: Why are wood products combined with paper in this standard?
A: FSC wanted to harmonize definitions for all types of
recycled products, which can also include wood products. In addition,
some recycled fiber can be used for either paper or products such
as chipboard and fibreboard. FSC approaches this as a forest issue;
they're looking at the products from the point of view of how forest
materials are used in, and diverge into, different kinds of products,
of which paper is only one.
However, there are some points at which there are differences significant
enough that they need to be pointed out. That is why there are different
lists in Annex 5 for paper (FSC Guidance on categories of reclaimed
fibre materials) vs. wood products (FSC Guidance on categories of
reclaimed wood material). Also, the paper listing points out that
sawdust, which is allowed as recycled material in wood products,
is not accepted as a recycled material for paper.
Q: It appears that even with the requirement that FSC recycled
paper have at least 30% FSC certified virgin and/or postconsumer
material, section 17.2 allows it to have as little as 10%. How could
this be?
A: First, the reality is that many paper mills do not have
a steady input of postconsumer content, but vary it by availability
and market economics. For some, the percentage stated on their label
is a guaranteed minimum but they often have more. For others, it
is a guaranteed average over a certain amount of time, frequently
a FY quarter. This is true already for recycled papers.
This particular section, though, is intended to address problems
more common to wood products and virgin fibres. In particular, some
mills are not be able to get a sufficient supply of FSC-certified
wood fibre during the winter months, and may drop below the minimum.
This is why labeling is required to cover a specific period of time.
A mill that has a low percentage at one point must make it up by
having a higher-than-required percentage at another point within
that batch period, so that over the claim period their products
will meet or exceed their claimed minimum.
Q: Why is FSC getting into certifying recycled papers?
A: Some FSC labeled products can already carry up to 82.5
% recycled material. FSC is committed to promote activities that
demonstrate FSC's commitment to forest stewardship, to "help society
at large sustain forest resources" and to "promote the development
of all kinds of activities addressed to the preservation and maintenance
of forests." This approach also reduces current anxieties that
use of wood from well-managed forests is in conflict with efforts
to encourage recycling.
An immediate incentive is government requirements in some countries
for fibreboard producers to start increasing recycled content in
their products. However, in the U.K. for instance, retailers require
high FSC content in the fibre/chipboard products they sell. Further
complicating fibreboard producers' attempts to meet both requirements
is the fact that they cannot get a source of 100% FSC-certified
fiber; it is always mixed with non-certified fibres, which results
in a pro-rated FSC fibre source. To maintain their viability and
meet both recycled and retailer-FSC requirements, the producers
need FSC approval to include higher recycled content in their products
along with lower FSC fibre percentages.
We believe that this focus on recycled papers is also helpful in
the U.S., where FSC papers have recently been introduced that do
not, in fact, meet the EO/EPA minimum recycled content requirements.
Rather than FSC competing with recycled paper, it is better that
they meet the postconsumer requirements and then also add FSC-certified
fibre. Under the proposed standards, purchasers would need to know
the postconsumer contents of papers they plan to buy, to be sure
they meet required minimums. If they do, then FSC-certified virgin
wood fibre would add information about the appropriateness of the
virgin fibre sources that we do not currently have for most papers.
If they do not meet the postconsumer minimums, both purchasers and
North American environmental groups will ensure that those papers
are not accepted in U.S. environmental paper markets until they
do increase to at least the EO/EPA minimums, or higher.
This draft standard could also allow paper with only postconsumer
content, and no FSC-certified virgin wood content, to qualify. Nevertheless,
any virgin material in such papers would have to meet FSC requirements
and should not be harvested from areas where traditional or civil
rights have been violated, from uncertified old growth forests,
from genetically modified trees or illegally harvested timber. FSC
says that it wants to be known for certifying "good environmental
papers." This makes sense to us when certifying 100% recycled
papers, although we know that some environmental groups still have
reservations about this. We are still thinking through the implications
of FSC certification of papers with less than 100% recycled and
no FSC fiber.
See FSC's discussion of recycled content
considerations.
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