United States Solid Waste and ,
Environmental Protection Eme'rgency Response EPA530-D-95-001
Agency (5101) March 1995
&EPA Draft Paper Products
RMAN - Supporting
Analyses
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Contents <-., . '
I. INTRODUCTION . . .'. , . . 1
A. Objectives .......... ^ .......:........ 1
B. The Procurement Guidelines Development Process 2
C. Paper Procurement Guideline History . ........ . : 4
1. The 1988 Procurement Guideline :.......... ....'.; 4
2. Interim Information Requests ....... 6
D. Approach to Recovered Materials Content Recommendations ... .... ... . ... >.. . . 7
1. One-part vs. Two-part Content Levels 7
2. Broad vs. Narrow Definition of "Postconsumer Materials" 8
' 3. Establishment of Minimum Recovered Materials Content
Levels and Ranges ........ :.................,....... 10
4. EPA's Methodology for Recommending Postconsumer and
Recovered Fiber Content Levels 11
II. RECOMMENDATIONS FOR NEWSPRINT .'.......... . , ". .... 14
III. RECOMMENDATIONS FOR TISSUE PRODUCTS ....;.. . . . . . ... . . ... . . .... 16
;A. Background , 16
B. Recovered, Fiber Content Levels ...... '. . . . ......... . . . . . . 16
C. Bathroom Tissue ... .... 18
1. Commercial/Industrial Bathroom Tissue Products . . . . ..:... 18
2. Consumer Bathroom Tissue Products . ... ........ 18
D; Paper Towels . 19
1. Commercial/Industrial Paper Towels .' ....;..... 19
2. Consumer Paper towels . . . . ; ............. : > .............. 19
E. Paper Napkins ^ ........ y . 20
1. Commercial/Industrial Paper Napkins 20
2. Consumer Paper Napkins 21
F. Facial Tissues 21
1.: Commercial/Industrial Facial Tissues 21
2. Consumer Facial Tissues . ... 22
G. Industrial Wipers v. .. 22
H. Doilies 23.
I. Summary of Tissue Products Recommendations 24
'. J. Summary of Request for Comments,on Recommendations for Tissue
Products 24
-TV. RECOMMENDATIONS FOR PAPERBOARD AND PACKAGING . . 26
A. Background . . . . '' 26
B. Reorganization of Paperboard and Packaging Recommendations .............. 27
C. Use of Recovered Fiber in the Manufacture of Paperboard .................. 27
D. Corrugated Containers and Solid Fiber Boxes 27
1. Corrugated Containers ......... '. 28
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2. Solid Fiber Boxes 30
E. Folding Cartons . 30
F. Industrial Paperboard ' ' ' ' \
, G. Miscellaneous Paperboard Products ' 32
H. Unbleached Packaging 33
I. Padded Mailers ' 33
J. Carrierboard . . . 34
K. Paperboard Products Used by Private Sector Purchasers 34
L. Summary of Paperboard and Packaging Recommendations . . 36
M. Summary of Request for Comments on Recommendations for Paperboard
and Packaging Products . 37
V. Recommendations for Printing and Writing Papers 38
A. .Background , ; 38
1. Overview 3°
2. Elimination of "High Grade Bleached" Distinction . 39
B. Uncoated Printing and Writing Papers 39
1. Executive Order Provisions 39
2. Terminology ' -, 41
3. Reprographic Papers 41
4. Offset Papers . . . ; 42
5. Tablet Papers 43
6. Forms Bond ......... 44
7. Envelopes , 45
8. Cotton Fiber Papers '
9. Text and Cover Papers 49
10. Supercalendered Paper 50
11. Safety Paper 51
12. Summary of Recommendations for Uncoated Printing and
Writing Papers ; 52
C. Coated Papers f3
1. Background . ., /.
2. Use of Recovered Fiber ...'.....:..... 54
3. Carbonless Paper . 55
4. Summary of Coated Paper Recommendations 56
D. Bristols r 56
1. Background 5o
2. Definition 57
3. Content Levels . . 57
4. Summary of Bristols Recommendations , . . 60
E. Summary of Request for Comments on Recommendations for Printing and
Writing Papers . . .-.-' 61
VI. OTHER ISSUES JJ2
' A. Measurement of Recovered Fiber Content :. . . "2
IV
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.1. Fiber Weight vs. Total Weight ............ r ................. 62
2. Recovered Fiber Component of Mill Broke . 63
B. Clarifications and Revisions to Definitions .... ... . . . . . . . 64
1. "Postconsumer Fiber" ^ .................. .:. ....... 64
2. "Recovered Materials" Definitions . ..... . . . . . ...... 64
3. "Mill Broke" . ............. .\ . .\ 65
4. "Recovered Fiber" , . , .66
C. Recyclability , . . i 69
D. Use of EPA's Recommendations 70
VII. SUPPORTING INFORMATION ....... 71
APPENDIX 74 v
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I. INTRODUCTION
The U.S. Environmental Protection Agency (EPA or the Agency) is publishing a draft
Recovered Materials Advisory Notice (RMAN), which contains recommendations for procuring
agencies to use when purchasing paper and paper products in accordance with section 6002 of the
Resource Conservation and Recovery Act (RCRA), This chapter of the supporting analyses document
explains EPA's objectives, EPA's process for designating procurement items and recommending
procurement practices for those items, and EPA's methodology for recommending recovered materials
content levels for paper and paper products.
In chapters II - V, EPA discusses the draft recommendations for newsprint, tissue products,
paperboard and packaging, and printing and writing papers, respectively. In addition, in chapter V,
EPA explains how the draft RMAN incorporates the minimum content standards for printing and
writing papers established in Executive Order 12873. In chapter VI, EPA addresses other paper
issues: definitions, measurement of recovered materials content, recyclability, and use of EPA's
recommendations. In chapter VII, EPA provides a list of the information sources used to develop the
recommendations in the draft RMAN. Finally, the draft recommendations are included in this
document as an Appendix.
A. Objectives .
In developing the draft recommendations for paper and paper products, EPA considered two
objectives. As required by RCRA section 6002, EPA's first objective is to recommend content levels
that will maximize the use of postconsumer recovered materials in paper and paper products. EPA's
second objective is to promote paper recycling by increasing both the usage of postconsumer
recovered materials in paper manufacturing and the availability of competitively-priced paper and
paper products containing postconsumer and other recovered materials.
EPA recognizes that while its recommendations are meant primarily for the use of
government procuring agencies, EPA's guidance is widely used by private sector purchasers, who
represent 95% or more of paper demand. EPA has found that when its recommendations for
postconsumer recovered materials content are too high, paper and paper products containing these
high percentages are often unavailable to government agencies and private sector purchasers or are
not consistently available throughout the U.-S. Also, while some paper and paper products containing
these high percentages of recovered materials are available, they are not price-competitive with other
paper and paper products offered to government agencies and private sector purchasers. As a result,
overall use of postconsumer recovered materials may not be maximized simply by EPA?s
recommending high postconsumer content levels.
Since designating paper and paper products as procurement items in 1988, EPA has found that
increasing demand from both public and private sector purchasers has resulted in greater recycling of
postconsumer recovered materials than simply increasing demand from the public sector. Therefore,
in establishing its draft content recommendations, EPA sought not only to challenge mills to use
postconsumer recovered materials, but to provide an incentive for mills to increase the availability to
both government and private purchasers of reasonably-priced paper and paper products containing
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postconsumer recovered materials. EPA believes; that this approach will maximize the recycling and
use of postconsumer recovered materials.
Therefore, to meet its twin objectives, EPA is adopting a different approach than was used in
1988 to recommend content levels for paper and paper products. As explained in more detail below,
EPA is recommending two-part content levels, consisting of a postconsumer fiber component and a
recovered fiber component. (See chapter VI for a discussion of these terms.) EPA believes that the
two-part recommendations will assure that there is a demand for all'recovered materials, including
postconsumer recovered materials and those materials generated during paper converting and printing
operations. ,
^ ...'-'
Further, EPA is recommending content ranges for each fiber component, whenever
appropriate, to encourage increased purchasing of paper and paper products containing postconsumer
and recovered fiber throughout the U.S. EPA recommends that government agencies specify that
paper and paper products contain postconsumer and recovered fiber levels at the high end of each _ .
range, consistent with RCRA's requirement that agencies purchase the highest levels of postconsumer
materials practicable. EPA anticipates that some private sector purchasers also will specify and
purchase products with the higher percentages of .postconsumer and recovered fiber. EPA anticipates
that private sector purchasers may be able to find paper and paper products available only at the
lower end of the ranges, however, because the large quantities of paper that these purchasers need
will be manufactured mainly by mills that use only lower levels of postconsumer and recovered fiber.
By using EPA's guidance, both government agencies and private'sector purchasers can encourage
their suppliers to provide paper and paper products containing the highest levels of postconsumer and
recovered fiber practicable.
By establishing ranges, EPA is taking into account the manufacturing diversity that exists
within the paper industry. The recommendations recognize that, in many grades Of paper, larger
quantities of paper and paper products are produced at mills that primarily use wood-based fiber than
at mills that primarily use postconsumer and other recovered fibers. While it is not currently
economically feasible for these mills to substitute high percentages of postconsumer fibers for the
wood-based fiber, it is technically and economically possible for them to use lower percentages of.
postconsumer and recovered fibers. EPA believes that ranges will provide;an incentive for all paper
mills to maximize their usage of postconsumer and recovered fibers. This will lead to greater
availability of competitively-priced paper and paper products for both public and private purchasers.
In the long run, this approach will lead to greater demand for both postconsumer and recovered
fibers.
B. The Procurement Guidelines Development Process .
Section 6002 of RCRA establishes a government agency buy-recycled program. It requires
each "procuring agency" subject to the statute to comply with its requirements with respect to "any
purchase or acquisition of a procurement item." These requirements include an obligation to procure
items composed of the highest percentage of recovered materials practicable except under defined
circumstances. Pub. L. No. 94-580, section 6002(c), 90 Stat. 2822 (1976). Under section 6002(i)
each procuring agency is required to develop an affirmative procurement program to "assure that
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items composed of the recovered materials will be purchased to the maximum extent practicable."
Hazardous and Solid Waste Amendments of 1984, Pub. L. No. 98-616, Title V, section 501(a) - (e),
983274-76. ,
RCRA section 6002(e) directs EPA to prepare guidelines for the,use of procuring agencies in .
complying with the statute's requirements and to revise these from time to time. EPA has three
responsibilities under section 6002(e): (1) to designate items that are or can be produced with
recovered materials; (2) to recommend non-binding procurement practices to assist procuring agencies
in developing procurement programs for recovered materials; and (3) to provide certain information
on recovered materials and items produced from recovered materials. See National Recycling
Coalition. Inc. v. Reillv. 884 F.2d 1431 (D.C. Cir. 1989).
Under the statute, responsibility for complying with the Act's requirements to purchase items
with recovered materials content rests with each individual procuring agency. EPA's published
recommendations are a first step for procuring agencies, but, as the statute indicates, they are
recommended practices, not strict requirements. Procuring agencies must revise their own programs
as needed to achieve the statutory goals.
The process EPA followed in developing procurement guidelines included Federal Register
notices of proposed and final rulemakings and solicitation of public comments. The final guidelines,
including the recommendations for use by procuring agencies, were codified in the-Code of Federal
Regulations. EPA's rulemaking efforts have proved to be increasingly time-consuming. Revising a
guideline and publishing it in the Federal Register,may take up to two years or more. EPA
consequently determined that inclusion of its recommended procurement practices within the
rulemaking effort delayed dissemination of current information about products with recovered
materials content and is therefore inconsistent with the statutory objective of promoting markets for
these products. .
In order to expedite the process of issuing procurement guidelines, Executive Order 12873
directs EPA to change the procedure used for designating items and providing procurement
recommendations. Under the Order, EPA is to issue a regulation, known as a Comprehensive
Procurement Guideline (CPG), which will contain the item designations. EPA proposed the CPG on
April 20, 1994 (59 FR 18852). In that Federal Register notice, EPA proposed to consolidate the
existing product designations, such as the designation of paper and paper products, into the CPG,
which will be codified in 40 CFR Part 247.
Executive Order 12873 also directed EPA to issue guidance documents, known as Recovered
Materials Advisory Notices, which will contain EPA's recommendations for purchasing the designated
items. In the April 20, 1994 Federal Register, EPA published the first draft RMAN, which
establishes eight product categories corresponding to the.categories used in the CPG. One of these
categories, Part A, is reserved for recommendations for paper and paper products.
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C. Paper Procurement Guideline History
1. The 1988 Procurement Guideline
RCRA section 6002(e), as amended by the Hazardous and Solid Waste Amendments of 1984,
required EPA to issue a "procurement guideline" for paper. Further, RCRA section 6002(c) requires
procuring agencies to purchase paper products containing the "highest .levels of postconsumer
materials practicable," as long as the products meet reasonable performance standards, are reasonably
available, and reasonably priced. Section 6002(h) provides a definition of "recovered materials,"
which includes a "postconsumer" subset, to be used when purchasing paper products.
In 1988, EPA designated the category "paper and paper products" and provided guidance for
purchasing items within this category (40 GFR Part 250, 53 FR 23546, June 22, 1988). This
.category includes all paper and paper products except building and construction grade papers.1 EPA
recommended minimum content levels for five broad subcategories of paper and paper products; high
grade bleached printing and writing paper, newsprint, tissue products, unbleached packaging, and ,
recycled paperboard. Although EPA provided recommendations for many papers and paper products
within these subcategories, the Agency did not provide recommendations for all of the many papers
and paper products manufactured by the paper industry, either because government agencies did not
purchase the items or because of performance, availability, competition, or price constraints. In the
draft Paper Products RMAN, EPA is issuing draft revisions to the 1988 recommendations and draft
recommendations for additional papers and paper products. "
As shown in Table 1, EPA recommended postconsumer minimum content levels for products
in all-subcategories except printing and writing paper. At that time, for technical and economic
reasons, few manufacturers of printing and writing papers used postconsumer materials in their
products. This was particularly true of the large, integrated paper mills (i.e., mills producing both
pulp and paper). Therefore, EPA recommended that procuring agencies use a 50 percent "waste
paper" content level for printing and writing papers. (See 53 FR 23554-23555, June 22, 1988.)
Because of concerns about availability and competition, EPA did not recommend content levels for
high-speed copier paper, forms bond, and computer and carbonless papers. In addition, EPA did not
address the use of recovered materials in bristols (e.g., file folders) and coated printing papers.
1 The -1989 building insulation products procurement guideline and the April 1994 proposed CPG
designate several building and construction grade paper products. These designations will be found in
the construction products category of the final CPG.
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Table 1. - EPA's 1988 Recovered Materials Content Recommendations for
Paper and Paper Products.
Item
High grade bleached printing and writing papers:
Offset printing
Mi moo and duplicator paper
Writing (stationery)
Office paper (e.g., note pads)
Paper for high-speed copiers
Forms bond including computer paper and
carbonless
Book papers
Bond papers
Ledger
Cover stock
Cotton fiber papers
Tissue products:
Toilet tissue
Paper towels '
Paper napkins
Facial tissue
Doilies
Industrial wipers
Unbleached packaging:
Corrugated boxes
Fiber boxes
Brown papers (e.g., bags)
Recycled paperboard:
, Minimum
percentage of
recovered
materials
25
: -
Minimum
percentage of
postconsumer
recovered
materials'
40
-
20
40
30
05
40
0
35
35
05
Minimum
percentage of
waste paper
50
50
50
50
*
50
*
50
50
50
50
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' ;
Item
Recycled paperboard products including folding
cartons .- ,
Pad backing
Minimum
percentage of
: recovered
materials
Minimum
percentage of
postconsumer
recovered
materials
80
90
Minimum
percentage of
waste paper
. * In 1988, EPA found insufficient production of these papers with recycled content to assure adequate competition. EPA
subsequently recommended that procuring agencies use a 50% waste paper standard for these items.
2. Interim Information Requests .
Since the 1988 designation of paper endpaper products, EPA has monitored the paper
industry's use of recovered and postconsumer fiber in manufacturing these items. In 1990, EPA
issued a request for comment on options for revising the recommended minimum content levels for
printing and writing papers (55 FR 40384, October 3, 1990). Additionally, in 1993, EPA conducted
a public forum to discuss options for revising the minimum recovered material content levels for all
categories of paper and paper products. EPA also conducted its own research into the use of
recovered and postconsumer fiber in the manufacture of paper and paper products. EPA has included
a summary of the 1990 public comments and the 1993 public forum in the public docket for the draft
RMAN. The research reports are listed in chapter VII of this document and also are available for
review in the RCRA docket (Docket F-95-PPRN-FFFFF).2
EPA found that mills have significantly increased their usage of recovered fiber, including
postconsumer fiber. According to data compiled by the Americanr Forest & Paper Association
(AF&PA), an industry trade association, the use of recovered fiber at domestic paper and paperboard
mills increased over 45%, from 19.68 million tons in 1988 to 28.87 million tons in 1993.
The paper industry also increased its ability to use postconsumer and-other recovered fiber
requiring deinking or other forms of cleaning and processing. According to data'published by
AF&PA, Pulp & Paper, Paper Recycler,,
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postconsumer fiber. Products such as high-speed copier paper, forms bond, computer paper,
carbonless, and coated printing papers now contain both postconsumer and other recovered fiber.
D. Approach to Recovered Materials Content Recommendations :
1. One-part vs. Two-part Content Levels ,\
As defined in RCRA section 6002(h), the term "recovered materials" refers to materials
generated after the end of the papermaking process. These materials can be generated by many
&viMuc.-. including paper mills, intermediate paper users such as printers and converters, merchants,
retailers, or the intended end user. They are sometimes divided into "preconsumer materials," which
refers to materials that have not passed through their intended end usage, and "postconsumer
materials," which refers to'materials that have passed through their intended end usage. In general,
procuring agencies can express minimum recycled content standards as a percentage of postconsumer
materials content, a percentage of recovered materials (or total recovered materials) content, or
percentages of both. For example, today, a common content standard for some printing and writing
papers is 50% total recovered materials, including 10%-postconsumer materials.
In 1988, EPA recommended postconsumer content levels for newsprint, tissue products,
paperboard, and packaging, and "waste paper" content levels for most printing and writing papers.
"Waste paper" included postconsumer materials and other specified materials generated after the end
of the papermaking process (see 53 FR 23551, June 22, 1988).
In response to the Agency's 1990 request for comment and the 1993 public forum, a group of
commenters suggested that EPA recommend two-part content levels consisting of a "total recovered
" materials" component in addition to a postconsumer recovered materials component. Within this
group, some commenters favor a postconsumer materials component defined consistently with the
postconsumer definition contained in RCRA section 6002(h). Others favor a broader component
consisting of these postconsumer materials plus certain preconsumer materials that require deinking or
cleaning, similar to postconsumer materials, prior to use. These commenters argue that two-part
content levels can achieve two goals: (1) assure markets for all recovered materials, regardless of
source and (2) increase demand for postconsumer materials. Because there is a limited amount of
preconsumer recovered materials, some commenters argue that pulp and paper mills will need to use
greater percentages of postconsumer materials in order to meet total recovered materials requirements
in their products. According to one commenter's estimate, the paper industry recovered and used
87% of available preconsumer materials (i.e., materials generated by sources other than the intended
end user of a finished product) in 1990.3 According to AF&PA, almost all preconsumer materials
are recovered and used (when exports are taken into account).
3 See the "Final Report on Recycled Paper Definitions, Standards, Measurement, Labeling
Guidelines, and Buy-Recycled Initiative," Addendum E, Recycling Advisory Council, February 6,
1992. EPA placed a copy of this report in the docket for the Paper Products RMAN. 'The report
also is available from the National Recycling Coalition.
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A second group of commenters favored a single, strictly postconsumer standard. These
commenters argue that most preconsumer material is already recovered, and that the focus for
government procurement should be on postconsumer paper because if is the single largest component
of municipal solid waste. They also believe that only a strictly postconsumer standard.will stimulate
markets for materials collected by municipal recycling programs.
1 ' ' "* ' ' - '
A third group of commenters argue in favor of a single, total recovered materials standard
encompassing both preconsumer and postconsumer materials. They believe that because most
preconsumer material is already recovered, virtually all additional recovered paper will necessarily _;
come from postconsumer sources. " '
EPA believes that the two-part approach is preferable to the postconsumer-only and total
recovered materials-only approaches because the two-part approach will result in greater usage of
postconsumer materials. A single, postconsumer level fails to acknowledge the continuing
contribution to solid waste management and the investments made by mills that have been using all
recovered materials, regardless of source, that require deinking/ cleaning, or processing prior to use.
Additionally, EPA believes that, because most preconsumer materials are now being used, total
recovered materials content levels will lead to higher use of postconsumer materials as mills seek
sufficient/materials to meet the total recovered materials content levels.
EPA also believes that a broad, single, total recovered materials content level will not fulfill
the statutory intent to encourage government agencies to procure paper products containing the highest
percentage of postconsumer recovered material practicable because it does not provide an incentive to
mills to use postconsumer materials in the products marketed to government agencies. In fact, under
a single, total recovered materials standard, it would be possible for a,mill to meet the standard by
manufacturing paper containing only clean materials such as converters scrap and never process
postconsumer materials.
2. Broad vs. Narrow Definition of "Postconsumer Materials"
Several groups recommended that EPA broaden the postconsumer definition to include certain
preconsumer materials that, like postconsumer materials, require deinking or contaminant removal
prior to use. These groups state that there is no reason, from a papermaking perspective, to separate
these materials. They further state that it is difficult to distinguish postconsumer and preconsumer
materials and-that tracking of postconsumer materials is not feasible and extremely costly to
implement.
EPA notes that it is not the intent of RCRA that pulp and paper mills track every piece Of
recovered paper or that mills incur unnecessary costs using recovered fiber. Under RCRA section
6002, procuring agencies are required to (1) obtain certifications that the product offered to them
meets the minimum content level and (2) purchase paper products containing the highest levels of
postconsumer materials practicable. Procuring agencies are not required to obtain certifications
regarding the exact amount of postconsumer or recovered fiber used. For example, if an agency
solicits copier paper containing .20% postconsumer fiber, bidders must certify that the product offered
contains this minimum percentage. The product may occasionally contain higher levels of
' ' v ., '
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postconsumer fiber, but the bidders and the mills supplying them are not required to conduct a
detailed analysis in order to determine the exact percentage of postconsumer fiber in the product.
Some degree of tracking is needed, however, to identify the postconsumer fiber content of
paper and paper products offered to government agencies in order to satisfy the statutory certification
requirement and to meet the statutory requirement that paper and pamper products contain the highest
levels of postconsumer materials practicable. Although it is, difficult, in some instances, to determine
whether a material is pre- or postconsumer, manufacturers of deinked market pulp and paper products
containing postconsumer fiber have been able to track postconsumer fiber successfully as part of their
normal operations.
EPA notes that, while several groups also urged the adoption of a broader postconsumer
definition for use in Executive Order 12873, the Executive Order contains a postconsumer definition
analogous to the statutory definition. EPA believes that its recommendations should be consistent
with the Executive Order.
As discussed in section I.C above, there have been significant increases in deinking and
processing capacity and various technology improvements that make it possible to manufacture
virtually all non-food4 grades of paper and paperboard using some percentage of postconsumer fiber.
Thus, EPA believes that it is not necessary to expand the definition of "postconsumer" used in the
1988 procurement guideline. For these reasons, EPA is using the statutory definition of
"postconsumer" in the draft RMAN.
EPA also notes that the type of postconsumer "material" of concern is fiber. For most
products, the fiber is derived from wood, but it also can be derived from textiles or agricultural
products. The availability of such fiber is limited and has been used primarily by manufacturers of
cotton fiber printing and writing papers, which represented less than 1% of printing and writing paper
capacity in 1993. Recognizing this, EPA will refer to "postconsumer fiber," rather than to
"postconsumer material." EPA believes that the statutory definition is broad enough to encompass
postconsumer fiber derived from textiles and other non-wood sources.
Thus, the two-part content levels recommended in the draft RMAN will consist of a
"recovered fiber" component and a "postconsumer fiber" component. These terms are discussed in
chapter VI.
As part of this approach, EPA will no longer use the term "waste paper" for printing and
writing papers. EPA prefers the term "recovered fiber" because the name reflects the fact that this
4 Manufacturers of food-grade paper and paperboard must be able to certify that their products
meet Food and Drug Administration requirements that the items contain ho hazardous and deleterious
substances that can migrate into the food. While it is technically possible to produce a food-grade
product with recovered and/or postconsumer fiber, the material miist be carefully selected. Limited
availability of suitable material precludes wide-spread use of recovered or postconsumer fiber in food-
grade paper products.
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material has value. As discussed in chapter VI, EPA is adapting the 1988 definition of "waste paper"
to define "recovered fiber." .
3. Establishment of Minimum Recovered Materials Content Levels and Ranges .
. f ' "*-
a. Content recommendations vs. minimum content standards. RCRA section 6002 requires
procuring agencies.to purchase paper and paper products containing the highest percentages of
postconsumer recovered materials practicable. EPA stated in the 1988 paper procurement guideline
that the use of minimum content levels' would satisfy this requirement (see 53 FR 23553, June 22,
1988). . ', '_ ' '
EPA notes that under RCRA section 6002(i), it is the procuring agencies' responsibility to
establish minimum recovered materials content standards, while EPA provides recommendations
regarding the levels of recovered materials in the designated items. To make it clear that EPA does
not establish the specific minimum content standards used by other agencies, EPA will no longer refer
to its recommendations as recovered materials content "standards," as was done in the 1988 paper
procurement guideline. Instead, EPA will refer to its recommendations as recovered materials cpntent
"levels," consistent with RCRA section 6002(e) and Executive Order 12873.
b. Recommended content ranges. Executive Order 12873 directs EPA to present "the range
of recovered materials content levels within which the designated recycled -items are currently
available." In meeting this provision, EPA will recommend ranges, where possible, that (1) reflect
the best information available to the^Agency about the use of postconsumer and other recovered fiber
in the manufacture of a designated item and (2) encourage manufacturers to use the maximum amount
of postconsumer and recovered fiber without compromising competition or product performance and
' availability. EPA recommends that procuring agencies use these ranges, in conjunction with their
own research into the content of items available to them, to establish their minimum content
standards. In some instances, EPA will recommend one level, rather than a range, because the item
is universally available at that recommended level. In such cases, EPA recommends that procuring
agencies use that level in establishing their minimum content,standards.
EPA believes that ranges are appropriate for three reasons. First, the Executive Order directs
EPA to recommend ranges. Second, while many agencies will continue to purchase paper products
centrally (or from the General Services Administration or the Government Printing Office), local
purchases will increase as a result of recent procurement reform, which increases the small purchase
threshold and allows greater local purchasing using government credit cards. Currently, the
postconsumer and total recovered fiber content of many paper products varies, as does product
availability, across the U.S. Procuring agencies can use the ranges as an information source in
establishing standards for local purchases. '
Third, as discussed in section I.A above, although EPA's recommendations are intended for
government purchasing agencies and their contractors, the Agency is aware that private sector
purchasers refer to EPA's recommendations when purchasing paper products. EPA wants to
encourage the continued broad use of its recommendations to foster greater demand for products
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containing postconsumer and recovered fiber, which, in turn, will lead to increased usage of these
materials. ,
There currently are insufficient quantities of paper and paper products containing high
percentages of postconsumer and recovered fiber to meet the demand of both public and private sector
purchasers. By recommending ranges, EPA is acknowledging that Some purchasers will be able to
buy products that contain higher percentages of postconsumer and recovered fiber, while others will
find that proujcw are available that contain lower percentages of these materials. Others, while not
being able to bu> products that contain postconsumer and recovered fiber even at the low end of the
ranges, will continue to seek such products, increasing overall demand for paper products containing
recovered fiber. EPA anticipates that this increased demand for and purchase of paper and paper
products containing postconsumer and recovered fiber, even at the low end of the recommended
ranges, will spur pulp and paper mills to make additional capital investments in the equipment and
systems needed to use greater percentages of these fibers.
Therefore, EPA encourages both public and private sector purchasers to establish their
minimum content standards at the highest levels practicable; if a product is not available at a content
level at the high end of the range, purchasers should set their standards at the highest levels available
to them, using the recommended range as a guide. In this way, EPA's recommended ranges will
encourage both public and private sector purchasers to purchase paper products containing the highest
levels of postconsumer and recovered fiber practicable.
4. EPA's Methodology for Recommending Postconsumer and Recovered Fiber Content Levels
EPA identified and evaluated pertinent data sources and information regarding the percentages
of postconsumer and recovered fiber contained in paper and paper products. Sources included EPA
research, responses to the 1990 Federal Register request for comment and the 1993 public forum,
procuring agency and industry data, manufacturers' information, and other published data. Based on
this information and the content levels established in Executive Order 12873, EPA established
recommended levels or ranges of levels for paper and paper products. .
a. Objectives. As discussed in section LA above, EPA has two objectives: (1) to maximize
the use of postconsumer and recovered fiber in paper and paper products and (2) to promote paper
recycling by increasing both the usage of postconsumer recovered fiber in paper manufacturing and
the availability of competitively-priced paper and paper products containing postconsumer and
recovered fiber. .
b. Establishing the recommended ranges. Whenever feasible, EPA will recommend ranges for
both recovered fiber and postconsumer fiber content. In selecting the ranges, EPA tried to ensure
achievement of the statutory objective of maximizing the use of postconsumer materials by ensuring
that paper products containing the highest levels of postconsumer and recovered fiber practicable will
be available at reasonable prices. This ensures their actual purchase by procuring agencies, thus
encouraging maximum use of postconsumer materials.
11
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The high end of each range will be set at the maximum content currently used in paper and
paper products that are available in sufficient quantities, and with adequate competition, to meet
procuring agency >needs. For many items, this level will be 100% for the recovered fiber component
of the two-part content recommendations. The high end of each range will direct procuring agencies
toward those levels that will meet the statutory requirement to purchase paper and paper products
containing the highest levels of postconsumer fiber practicable. Thus, EPA strongly encourages
procuring agencies to specify and seek paper and paper products containing both postconsumer and
recovered fiber at levels at or near the high end of the recommended ranges.
The low end of each range will be set at levels that can be met by the simple majority of mills
currently producing paper and paper products containing postconsumer and recovered fiber. These
levels could also be met by other mills if they decide to purchase or produce pulp made from
postconsumer and recovered fiber. For most items, these levels will be higher than the lowest
percentage currently in use, in order to provide an incentive for paper mills that now primarily use
wood-based fiber or lower levels of postconsumer or recovered fiber to increase their use of
postconsumer and recovered fiber in the manufacture of their products. For example, if the majority
of mills currently use 20% postconsumer fiber in a writing paper, but a few mills use 10%
postconsumer fiber, EPA would recommend 20% as the low end of the range.
In all five major paper and paperboard grades, there are groups of mills that use high levels
of postconsumer and recovered fiber and groups of mills that primarily use wood-based fiber,
sometimes in conjunction with low percentages of postconsumer and/or recovered fiber. EPA has
attempted to account for this diversity in establishing the recommended ranges. As a result, for some
items, there is a broad range for postconsumer or recovered fiber content. The high end of these
ranges generally reflects the percentages of postconsumer and recovered fiber used by mills that rely
on this type of fiber, while the low end of the ranges reflects the percentages of postconsumer and
.recovered fiber used by mills that rely primarily on wood-based fiber. For many items, the low end
of the recovered fiber range is the same percentage as the low end of the postconsumer fiber range.
In these instances, all of the recovered fiber used by these mills is postconsumer fiber. This means
that the item can contain either all postconsumer fiber (e.g., X% recovered fiber, all of which is
postconsumer) or blends of recovered and postconsumer fiber (e.g., 100% recovered fiber, including
Y% postconsumer fiber) and still fall within EPA's recommended ranges.
EPA believes that as more mills manufacture paper and paper products containing the
recommended levels of postconsumer and recovered fiber, paper recycling will increase to meet mills'
demand for fiber. EPA also believes that there' will be an .increase in the availability of paper and;
paper products containing postconsumer and recovered fiber to meet both public and private sector
demand^ -
It is EPA's intention to provide procuring agencies with the best and most current information
available to assist them in fulfilling their statutory obligations under RCRA section 6002. To do this,
EPA will monitor changes in manufacturing capacity and product content and .the progress made by
12
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procuring agencies in purchasing paper and paper products with the highest percentages of
postconsumer.and recovered fiber practicable. EPA will periodically adjust the recommended content
ranges to reflect these changes. EPA anticipates that over time, the recommended ranges will narrow
as tne-lower end of the ranges are raised. '
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II. RECOMMENDATIONS FOR NEWSPRINT , .
"Newsprint" refers to the type of paper generally used in the publication of newspapers. The
federal government uses newsprint for printing the Federal Register, Congressional Record, and
similar publications. ' .
Newsprint is made primarily of mechanical wood pulp (also known as groundwood). In
1993, U.S. newsprint mills shipped 7 million tons of newsprint, which represents 8% of domestic
paper and paperboard production. Domestic newsprint mills consumed nearly 3 million tons of
recovered fiber in 1993. , ,
In the 1988 paper procurement guideline, EPA recommended a content standard of 40%
"postconsumer material" for newsprint. Many newsprint mills are not yet using this level of
postconsumer fiber. However, EPA found that in the past five years, in response to demand from
newspaper publishers, North American newsprint mills invested billions.of dollars in equipment to
recycle newsprint. At least 35 mills now produce newsprint containing some percentage of
postconsumer or recovered fiber. These mills use old newspapers (ONP), old magazines (OMG), and
some over-issue publications. According to reports issued by the Newspaper Association of America
(NAA) and by the Northeast Recycling Council (NERC), use of postconsumer and recovered fiber
has increased significantly at North American newsprint mills but, on average^ is still below 40%.
NAA estimates that the average amount of recovered fiber in newsprint will be 25% by the end of
1994. . - ,
EPA also found that there are two groups of mills manufacturing newsprint: those using
100% recovered fiber, including high percentages of postconsumer fiber, and those using wood-based
fiber combined with lower percentages of postconsumer and recovered fiber. The ranges that EPA is
recommending today reflect the diversity in postconsumer and recovered fiber use between these two
groups of mills. EPA recognizes that while it is technically feasible for all newsprint mills to use
postconsumer and recovered fiber, it is not economically feasible at this time for mills that rely
primarily on wood-based fiber to substitute high percentages of postconsumer and recovered fiber for
their wood-based fiber. EPA also recognizes that newsprint containing 100% recovered fiber is not
uniformly available to purchasers throughout the U.S. It is EPA's intent that the ranges will
encourage all newsprint mills to use at least some postconsumer fiber, which will increase both
availability of "recycled" newsprint and demand for ONP and OMG. .
EPA does not have information'about the percentages of postconsumer fiber contained in each
U.S. newsprint mill's product. NERC provided data about the total recovered fiber content of the
newsprint made by 15 U.S. and 8 Canadian mills. Because most of these mills use wood-based fiber
and add percentages of postconsumer fiber in order to meet client demand for recycled newsprint,
EPA assumed that the recovered fiber percentages in NERC's data actually represent postconsumer
fiber usage. The median content level of newsprint made by the 23 mills is 40%. At least seven
mills use 40% or more recovered fiber; two of these mills' newsprint contains 40% recovered fiber,
and five mills' newsprint contains 50 - 100% recovered fiber. Another seven mills produced
newsprint containing 20-30% recovered fiber! Only three of the mills produced newsprint
containing 10 - 20% recovered fiber. - '
' ' ' 14
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In addition, five U.S. mills and one Canadian mill produce newsprint containing 100%
recovered fiber; their products can contain up to 85% postconsumer fiber. Together, they produce
1.1 million tons of newsprint annually, which represents 9% of total U.S. newsprint production.
Based on this information, EPA is recommending a postconsumer content range from 40 -
85%. .
In light of the fact that some newsprint mills use 100% recovered fiber and that the
Government Printing Office (GPO) has been able to purchase newsprint containing 100% total
recovered fiber, EPA is recommending that newsprint contain 40 - 100% recovered fiber. EPA is
setting the low end of the recovered fiber range at 40%, the same level as the low end bf the
postconsumer range, to reflect the fact that .the majority of newsprint mills use postconsumer fiber in
conjunction with wood-based fiber. In other words, the low end of the range is 40% recovered fiber,
all of which is postconsumer fiber. .
In sum, in section A-2 of the draft RMAN, EPA recommends that newsprint contain a range
of 40 - 100% recovered fiber and a range of 40 - 85% postconsumer fiber. EPA recommends that
both public and private sector purchasers establish their minimum content standards at the highest
levels practicable; if a product is not available at a content level at the.high end of the postconsumer
or recovered fiber ranges, purchasers'should set their standards at the highest levels available to them,
using the recommended ranges as a guide.
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III. RECOMMENDATIONS FOR TISSUE PRODUCTS
' . .'-.''' ':' '
A. Background
The tissue sector of the paper industry produces, both sanitary tissue products, such as
bathroom and facial tissue, towels, and napkins, and specialty products, such as wrapping tissue, .
waxing tissue, and cellulose wadding. Because U.S. General Services Administration (GSA) data
indicate that government agencies purchase sanitary tissue products, not specialty tissue products,
EPA's research efforts were limited to this product area. Similarly, EPA's recommendations only
cover sanitary tissue products. EPA requests comment on whether government agencies purchase
specialty tissue products and, if so, which products they use. EPA also requests information on the
use of postconsumer fiber and recovered fiber in the manufacture of specialty tissue products.
In 1993, domestic mills shipped over 5.8 million tons of sanitary tissue products, representing
just under 7% of domestic paper and paperboard production. They used 3.6 million tons of
recovered fiber. ., ,
The sanitary tissue industry has two distinct components consumer products (the "at-home"
market) sold at the retail level, and commercial/industrial products (the "away-from-home" market).
The commercial/industrial segment provides tissue products to industrial and institutional customers,
including government agencies. The "at-home" market represents about 70% of sanitary tissue
production, while most of the remainder is commercial/industrial tissue.
B. Recovered Fiber Content Levels
* ." ' . - -,
In 1991, EPA research indicated that there was a significant difference in the usage of
recovered fiber by producers of consumer tissue products and producers of commercial/industrial
tissue products. Producers of commercial/industrial tissue products used relatively high percentages
of recovered fiber ^ whereas the use of recovered fiber in consumer products was minimal. EPA's
1994 research showed that recovered fiber usage in consumer products increased substantially, but it
was still lower than the percentages used in commercial/industrial tissue products. Given that there
are these distinct differences in usage of postconsumer and recovered fiber between the two
components of the sanitary tissue industry, EPA concluded that it is appropriate to recommend
different content levels for each. As explained in the item-specific subsections below, EPA is
recommending different content levels for commercial/industrial tissue products and consumer tissue
products, where feasible. EPA lacks sufficient data on consumer paper napkins and consumer facial
tissues to recommend content levels for these items. EPA is requesting additional data in order to
recommend content levels in the future.
Recent'additions of deinking capacity and technical developments that improve product quality
are allowing many tissue producers to expand their use of recovered fiber. According to published
reports, 32 U.S. mills have the capacity for at least 2.8 million tons per year of tissue containing
16
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recovered fiber, representing 43% of total U.S. capacity.5 AF&PA's 1993 capacity survey reports
that these mills are expected to use 4.1 million short tons of recovered fiber by 1996.
However, tissue mills and printing and writing paper mills currently compete for the higher
quality recovered fiber. As printing and writing paper mills use more of the high grade postconsumer
fiber, tissue mills will be required either to pay more for this fibenor to invest in the processing
capability to handle lower grades of postconsumer fiber.
> . . , t
Trade publications report that there has been increased usage of postconsumer fiber in both
coiij. v,- and commercial/industrial tissue products. This fact, combined with the competition
betwetn tissue and printing and writing mills for higher grade postconsumer fiber, leads EPA to .
conclude that it is unlikely that tissue mills will further increase the percentages of postconsumer fiber
in their products in the near term.
In considering revisions to the Agency's 1988 content recommendations for tissue products,
EPA has concluded that it is important to encourage mills to use postconsumer fiber in their consumer
products, as well as in their commercial/industrial tissue products. Because consumer products
account for 70% of tissue production, they are a potential market for larger quantities of
postconsumer fiber. EPA research indicates that most mills currently.producing "recycled" consumer
tissue products are using percentages of postconsumer fiber at or around EPA's 1988 recommended
content levels. Many of these mills primarily use recovered and postconsumer fiber, rather than
wood-based fiber, however.
In 1991, only a few producers of commercial sanitary tissue products claimed that their
products contained postconsumer fiber levels meeting EPA's recommended minimum content levels.
Today, the majority of mills claim 100% total recycled content, and most manufacture products that
meet the 1988 postconsumer content levels. EPA believes that it is appropriate to recognize that
tissue mills provide a viable market for both recovered fiber and postconsumer fiber. Therefore, as
discussed in the following subsections, EPA is adding recovered fiber recommendations for tissue
products. " . .
EPA believes that use of higher percentages of postconsumer and recovered fiber by
manufacturers of tissue products will depend on several variables, including the availability of
sufficient fiber and expanded papermaking capacity. Should EPA obtain information indicating that
mills are able to produce products containing higher levels of postconsumer and recovered fiber at a
reasonable price, EPA will revise the ranges upward in the future.
5"New recycled tissue products court consumer markets," Paper Recyder, Vol. 4, No. 11,
November 1993, pg. 7.
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C. Bathroom Tissue " . .
In the 1988 paper procurement guideline, EPA recommended a 20% postconsumer content
level for toilet tissue (also known as.bathroom tissue). At present, there is great variability in usage
of postconsumer and other recovered fiber among bathroom tissue producers.
, > ^
1. Commercial/Industrial Bathroom Tissue Products '
EPA's current research reveals that manufacturers of commercial/industrial bathroom tissue
can be grouped by their usage of postconsumer fiber. Eight of the 16 mills for which EPA has data
are producing bathroom tissue for the commercial/industrial market containing a minimum of 20%
postconsumer fiber,. Three of these 16 mills use a minimum of 25% postconsumer Tiber, and one
uses 22% postconsumer fiber. Another mill uses slightly higher percentages of postconsumer
materials (35%). Of the producers supplying the federal government, three mills are able to use 60%
or more postconsumer fiber. Since at least five mills can !meet a minimum of 25% postconsumer
fiber and another four mills could meet this minimum by increasing their postconsumer content
slightly, EPA recommends 25% as the low end of the postconsumer fiber range for
commercial/industrial bathroom tissue. EPA recommends 60% as the high end of the postconsumer
fiber range for this item.
In addition to postconsumer fiber, almost all manufacturers of commercial lines of bathroom
tissue use 100% recovered fiber. Therefore, EPA is recommending that commercial/industrial
bathropm tissue products contain 100% recovered fiber.
In sum, in section A-3 of the draft RMAN, EPA is recommending two-part content levels for
commercial/industrial bathroom tissue products. For the postconsumer fiber component, EPA
recommends a range of 25 - 60%, and for the recovered fiber component, EPA recommends a
content level of 100%. EPA further recommends .that procuring agencies continue to seek and
purchase products at the high end of the postconsumer range for their purchases. , ,
2. Consumer Bathroom Tissue Products '
Three of the. largest producers of consumer bathroom tissue products use no or low levels
(20% or less) of postconsumer fiber. These mills produce tissue products primarily from wood pulp.
In order to encourage greater use of postconsumef fiber by all producers of consumer bathroom tissue
products, EPA is recommending 20% postconsumer fiber as the low end of the postconsumer range
for these products. In addition, three other mills that currently produce consumer bathroom tissue
products using primarily recovered fiber, are able to use 60% or more postconsumer fiber. Based on
this information, EPA is recommending 60% postconsumer fiber as the high end of the range for
consumer bathroom tissue products.
Consumer tissue products can contain 100% recovered fiber, depending on the product and
the manufacturer. Some mills only use low levels of recovered fiber, all of which is postconsumer
fiber, while others use 100% recovered fiber, including postconsumer fiber. Based on this
information, and considering that 20% is the low end of the recommended postconsumer range, EPA
'
. ' ' - . . 18 , . ,. ' ,
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recommends a range of 20 - 100% for the recovered fiber content of consumer bathroom tissue
products. Using this range, EPA expects that some mills will produce consumer bathroom tissue
containing 20% recovered fiber, all of which is postconsumer fiber, while other mills will produce
consumer bathroom tissue containing as much as 100% recovered fiber, including percentages of
postconsumer fiber. EPA encourages all manufacturers of consumer bathroom tissue products to use
postconsumer fiber meeting EPA's recommendations and to seek ways to increase recovered fiber ,.
usage in their products. .. .
D. Paper Towels
In the 1988 paper procurement guideline, EPA recommended a 40% postconsumer content
level for paper towels. Currently, there is great variability in usage of postconsumer and recovered
fiber among paper towel-producers.
1. Commercial/Industrial Paper Towels
EPA's current research reveals that manufacturers of commercial/industrial paper towels can
be grouped by their usage of postconsumer fiber. Eleven of the 19 mills for which EPA has data are
producing paper towels for the commercial/industrial market containing a minimum of 40%
postconsumer fiber. A twelfth mill is using a slightly lower level (35%). Five of the 19 mills are
able to use 60% or more postconsumer fiber. Since at least 11 mills can meet a minimum of 40%
postconsumer fiber and another mill could meet this minimum by increasing its postconsumer content
slightly, EPA recommends 40% as the low end of the postconsumer fiber range for commercial/
industrial paper towels. EPA recommends 60% as the high end of the postconsumer fiber range for
this item.
Most mills manufacture commercial/industrial paper towels containing 100% recovered fiber.
For this reason, EPA recommends that this item contain 100% recovered fiber.
In sum, in section A-3 of the draft RMAN, EPA is recommending two-part content levels for
paper towels. For the postconsumer fiber component, EPA recommends a range from 40 - 60%, and
for the recovered fiber component, EPA recommends a content level 100%. EPA further
recommends that procuring agencies continue to use the high end of the postconsumer fiber range for
their purchases.
2. Consumer Paper Towels ,
EPA knows of only one large producer of consumer paper towels that is using postconsumer
fiber (at a 10 - 20% content level), although a second large manufacturer is testing a line of
"recycled" paper towels. These mills produce paper towels primarily from wood pulp. In order to
encourage greater use of postconsumer fiber by all producers of consumer paper towels, EPA is
recommending 20% postconsumer fiber as the low end of the postconsumer range for these products.
In addition two other mills that currently produce consumer paper towels using primarily recovered
fiber, are able to use 60% or more postconsumer fiber. Based on this information, EPA recommends
60%'postconsumer fiber as the high end of the range for consumer paper towels.
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Consumer paper towels can contain '100% recovered fiber, depending on the product and the
manufacturer. Some mills will only use low levels of recovered fiber, all of which is postconsumer
fiber, while others will use 100% recovered fiber, including percentages of postconsumer fiber. In
fact, six mills currently produce consumer paper towels using 100% recovered fiber (or, in the case
of one mill, 70 - 100% recovered Tiber). Based on this information, and considering that 20% is. the
low end of the recommended postconsumer range, EPA recommends a range of 20 - 100% for. the
recovered fiber content'of consumer paper towels. Using this range, EPA expects that some mills
will produce consumer-paper towels containing 20% recovered fiber, all of which is postconsumer
fiber, while other mills will produce consumer paper towels containing as much as 100% recovered
fiber, including percentages of postconsumer fiber. EPA encourages all manufacturers of consumer
paper towels to use postconsumer fiber meeting EPA's recommendations and to seek ways to increase
recovered fiber usage in their products. '
E. Paper Napkins
In the 1988 paper procurement guideline, EPA recommended a 30% postconsumer content
level for paper napkins. As with the other tissue products, there is great variability in usage of
postconsumer and recovered fiber among paper napkin producers.
1. Commercial/Industrial Paper Napkins
EPA's current research reveals that manufacturers of paper napkins for the
commercial/industrial market can be grouped by their usage of postconsumer fiber. Three of the 10
mills for which EPA has data are producing paper napkins containing a minimum of 30%
postconsumer fiber. A fourth mill uses slightly less postconsumer fiber (20 - 30%), and a fifth mill
uses slightly higher percentages of postconsumer fiber (35%). At least three of the ten mills are able
to use 60% or more postconsumer fiber. Since at least four mills can meet a minimum of 30%
postconsumer fiber and another mill could meet this minimum by increasing its postconsumer content
slightly, EPA recommends 30% as the low end of the postconsumer fiber range for
commercial/industrial paper napkins. EPA recommends 60% as the high end of the postconsumer
fiber range for this item.
All but two manufacturers of paper napkins for which EPA has data are using 100%
recovered fiber. One of the two mills uses at least 40%, and the other mill uses at least 50%
recovered fiber. Because most of mills manufacture commercial/industrial paper towels containing
100% recovered fiber, EPA recommends that this item contain 100%-recovered fiber.
In sum, in section A-3 of the draft RMAN, EPA,is recommending two-part content levels for
paper napkins. For the postconsumer fiber component, EPA recommends a range of 30 - 60%, and
for the recovered fiber component, EPA recommends a range of 30 - 100%. EPA further '
recommends that procuring agencies continue to use the high end of the postconsumer fiber range for
their purchases.
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2. Consumer Paper Napkins
EPA's data on use of postconsumer fiber in consumer paper napkins is limited. The Agency
has data on four mills that produce consumer paper napkins primarily from recovered and
postconsumer fiber, but lacks data about the use of postconsumer and recovered fiber by consumer
napkin manufacturers that primarily use wood pulp. EPA believes that the introduction of additional
"recycled" consumer paper napkins will follow the same pattern as the other tissue products made
primarily from wood-based fiber: manufacturers of these products can be expected to use only low
levels of postconsumer fiber. In order to encourage greater use of postconsumer fiber by all
producers of consumer paper napkins, EPA is considering setting the low end of the-'postconsumer
range for consumer paper napkins at 30% postconsumer fiber, which is the low end of the range .
recommended for commercial/industrial paper napkins. EPA requests comment on whether
manufacturers that primarily use wood-based fiber can produce consumer paper napkins containing
this level of postconsumer fiber.
One of the four mills for which EPA has data currently produces consumer paper napkins
containing 60% postconsumer fiber; the other three mills use no or lower levels of postconsumer
fiber. Based on this limited information, EPA is considering recommending 60% postconsumer fiber
as the high end of the postconsumer range for consumer paper napkins. EPA requests comment on
this content level.
Consumer paper napkins can contain 100% recovered fiber, depending on the product and the
manufacturer. EPA expects that some mills will only use low levels of recovered fiber, all of which
is postconsumer fiber, while others will use 100% recovered fiber, including percentages of
postconsumer fiber. In fact, three mills currently produce consumer paper towels using 100%
recovered fiber (and a fourth mill uses up to 100% recovered fiber). Based on this information, and
considering that 30% is the low end of the recommended range for commercial/industrial paper
napkins, EPA is considering recommending 30% as the low end of the recovered fiber range for
consumer paper napkins as well. Further, EPA is considering recommending 100% as the high end
of the recovered fiber range for consumer paper napkins. EPA requests comment on this range for
consumer paper napkins. ''."'
F. Facial Tissues
EPA's 1988 recommendation for facial tissue was 5% postconsumer fiber, reflecting the
limited use of postconsumer fiber in this item. As discussed below, facial tissue is available
containing higher levels of postconsumer fiber, as well as recovered fiber.
1. Commercial/Industrial Facial Tissues
Today, facial tissue is available at postconsumer content levels as high as 100%. One of the
five mills for which EPA has data uses 30% postconsumer fiber, while two other mills use less (20%)
or slightly more (up to 35%). A fourth mills uses up to 100% postconsumer fiber. Since three mills
can meet a 30% content level, and the fourth mill can meet it by increasing its percentage of
21
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postconsumer fiber slightly, EPA is recommending a 30% postconsumer fiber content level for
commercial/industrial facial tissues. _
Three of the five manufacturers for which EPA has information use 100% recovered fiber in
facial tissue for the commercial/industrial market, and a fourth mill uses up to 100% recovered fiber.
For this reason, EPA recommends that this item contain 100% recovered fiber.
In sum, in section A-3 of the draft RMAN, EPA is recommending two-part content levels for
facial tissue products. For the postconsumer fiber component, EPA recommends a content level of
30%, and for the recovered fiber component, EPA recommends a content level of 100%.
2. Consumer Facial Tissues
As with consumer paper napkins, EPA's data on use of postconsumer fiber in consumer facial
tissues is limited. The Agency has data on four mills that produce consumer paper napkins primarily
from postconsumer and other recovered fiber. One of these four mills uses a minimum of 20%
"postconsumer fiber. A second mill uses higher levels (30 - 45%). A third mill uses almost no
postconsumer fiber (up to 3%). The fourth mill uses 100% postconsumer fiber.
EPA lacks data about the use of postconsumer fiber by manufacturers that primarily use fiber
derived from wood to produce facial tissues. EPA is not aware of any major manufacturers of
consumer facial tissue using postconsumer fiber. EPA believes that the introduction of "recycled"
consumer facial tissues by these manufacturers will follow the same pattern as the other tissue
products made primarily from wood-based fiber: manufacturers of these products can be expected to
use only low levels of postconsumer fiber. In order to encourage greater use of postconsumer fiber
by all producers of consumer facial tissues, EPA is considering recommending a 20% postconsumer
content level for this item. Three of the four mills currently producing consumer facial tissues from
recovered and postconsumer fiber can meet this content level. EPA requests comment on whether
manufacturers that primarily use wood-based fiber can produce consumer facial tissues containing this
level of postconsumer fiber.
Consumer facial tissues can contain 100% recovered fiber; depending on ths product and the
manufacturer. EPA expects that some mills will only use low levels of recovered fiber, all of which
is postconsumer fiber, while others will use 100% recovered fiber, including percentages of
postconsumer fiber. In fact, two mills currently produce consumer facial tissues using 100%
recovered fiber (and two other mills use up to 100% recovered fiber). Based on this information,
EPA is considering recommending a range of 20 - 100% recovered fiber for consumer facial tissues.
EPA requests comment on this range.
G. Industrial Wipers
EPA did not recommend postconsumer or other recovered fiber content levels for industrial
wipers in the 1988 paper procurement guideline. EPA research indicated that this product was not
available containing postconsumer or recovered fiber at that time.
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Industrial wipers are a type of lint-free, absorbent paper towel used to wipe up water,
industrial oils, and other liquids. Paper-based wipers are produced on standard paper machines and
now can be made with recovered fiber. There also are other types of "high tech" wipers that are
manufactured with virgin spun-woven materials which often are held together by a polymer binding
or other chemical treatment. Wipers represent a very small percentage of total tissue production.
GSA maintains over 30 Commercial Item Descriptions (CIDs) for wipers. These CIDs
describe the end-use and related functional performance requirements of the product and do not
specify material. Bidders offer products made from various functionally equivalent materials,
including recovered paper, synthetics, textiles, and blends of these materials.
At least one GSA vendor offers a wiper containing 100% total recovered fiber, including 33%
postconsumer recovered fiber. Of the other three known wiper manufacturers, one uses 100%
recovered fiber, including 10 - 95% postconsumer fiber; another uses 75% recovered fiber, including
40% postconsumer fiber; and the third uses 10 - 50% recovered fiber including 10 - 40%
postconsumer fiber. Thus, three manufacturers can produce wipers containing 40 - 100% total
recovered fiber, including 40% postconsumer fiber. The fourth mill could meet a 40% postconsumer
content level by slightly increasing its use of postconsumer fiber.
Based on this information, EPA recommends recovered fiber ranges of 40 - 100%, including
40% postconsumer fiber. - EPA encourages procuring agencies to use the high end of the range when
purchasing industrial wipers.
H. Doilies
The term doilies, as used in the 1988 paper procurement guideline, referred to placemats used
to line food trays, rather than to the die-cut doilies used as a decorative food service liner for items
such as pastries and hors d'oeuvres. EPA has learned that placemats or tray covers are manufactured
from printing and writing papers, such as tablet paper, rather than from tissue papers. Based on this
information, EPA is removing "doilies" from the sanitary tissue products category and listing 'tray
liners" in a new Miscellaneous Paper Products category, which is found in section A-5 of the draft
RMAN. .
EPA is aware that McDonald's Corporation is purchasing tray liners containing 100%
recovered materials, including 75% postconsumer materials. Based on this information, in section
A-5 of the draft RMAN, EPA recommends a content level of 100% recovered fiber, including 75%
postconsumer fiber. EPA requests information about the availability of tray liners containing other
percentages of recovered fiber, including postconsumer fiber.
In the past, GSA has expressed concern that the use of postconsumer fiber could violate Food
and Drug Administration (FDA) restrictions on migration of contaminants into food. McDonald's
indicated to EPA that use of postconsumer or other recovered fiber is not a concern with tray liners.
EPA requests comment on this issue.
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L Summary of Tissue Products Recommendations .
Table 2 lists the revised recommended content levels for tissue products. , /
Table 2. Recommendations for Tissue Products
Item
Bathroom tissue
Commercial/industrial
Consumer
Paper towels
Commercial/industrial
Consumer
Paper napkins
Commercial/industrial
Facial tissue
Commercial/industrial
Industrial wipers
Recovered Fiber
(%)
100
. 20 - 100
100
20-100
v 100
100
40 - 100
Postconsumer Fiber
'(*)
25-60.
20-60
40 -.60
20-60
. . 30-60 ,
30
40
J. Summary of Request for Comments on Recommendations for Tissue Products
EPA requests comment on each content level recommendation for tissue products dis.cussed in
this chapter. In this chapter, EPA also requested comment or information on the following issues:
. o Do government agencies or their contractors purchase specialty tissue products?
o Is postconsumer or other recovered fiber used in the manufacture of specialty tissue
products and, if so, in what percentages?
o Can manufacturers of consumer paper napkins and consumer facial tissues, that
primarily use wood-based fiber produce these items using a minimum of 30% and
20%*-postconsumer fiber, respectively? If not, what levels of postconsumer fiber can
be used in these items? ...
o Can manufacturers of consumer paper napkins and consumer facial tissues use a range
of recovered fiber from 30 - 100% and 20 - 100%, respectively?
.o Are tray liners available containing percentages of recovered fiber, including
postconsumer fiber, other than 100% recovered fiber, including 75% postconsumer
fiber?
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Can postconsumer fiber be used in tray liners and meet Food and Drug
Administration (FDA) restrictions on migration of contaminants into food?
25
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IV. RECOMMENDATIONS FOR PAPERBOARD AND PACKAGING
A. Background : t
Paperboard is a major segment of the paper industry and a major consumer of recovered
fiber. In 1993, U.S. mills produced 43.2 million tons of paperboard, nearly 51 % of total paper and
paperboard production. They used 18.4 million tons of recovered fiber.
The paperboard segment encompasses both packaging and products made from paperboard
(e.g., notebook binders). In the 1988 paper procurement guideline, EPA provided content
recommendations for paperboard and packaging under two categories, "Unbleached Packaging" and
"Recycled Paperboard." The unbleached packaging category included corrugated boxes, fiber boxes,
and brown papers (e.g., bags), while the recycled paperboard category included folding cartons and.
pad backing. ,
Subsequent EPA research, and information submitted by various groups, indicates that the
categories and item listings used in the 1988 procurement guideline do not accurately reflect the
widely accepted groupings of paperboard and packaging grades used by paper purchasers and the
paper industry. For example, within the paper industry, the paperboard segment includes
containerboard, which, in turn, includes the components used to make corrugated containers
(linerboard and corrugating medium). Because corrugated boxes are listed under "Unbleached
Packaging" in the 1988 guideline, however, EPA has received inquiries about which standard applies
- the 35% postconsumer minimum for corrugated boxes,or the 80% postconsumer minimum for '
recycled paperboard, which could apply to the linerboard component of corrugated boxes.
Additionally, others have suggested that the recommended 80% postconsumer minimum
content standard for recycled paperboard is too high arid does not reflect industry's ability to
incorporate postconsumer fiber into this product.
AF&PA statistics list three subgroupings of paperboard: containerboard, boxboard, and all
other. "Containerboard" includes linerboard and corrugating material used in corrugated containers.
"Boxboard" includes folding cartons (e.g., cereal boxes), set-up boxes (e.g., shoe boxes), and milk
cartons and items Used in food service. "All other", includes anything from tubes and cores to
specialty boards used in games, book covers, and .lottery tickets.
Another problem with the 1988 guideline is that it lists "recycled paperboard" as a distinct
category, rather than as a subcategory of paperboard and packaging. By contrast, within the
paperboard segment of the paper industry, ."recycled paperboard" refers to a particular type of
paperboard that can be used in the manufacture of several products. In fact, corrugating material,
linerboard, and folding cartons can be made at mills using only fiber from recovered materials (i.e.,
"recycled paperboard"), at mills using only fiber from wood, and at mills that use a combination of
fiber from wood and fiber from recovered materials. This has led to confusion about the applicability
of the 1988 "recycled paperboard" content recommendations to products manufactured from
paperboard containing fiber derived from wood.
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B. Reorganization of Paperboard and Packaging Recommendations
In the draft RMAN, EPA is combining recommendations for paperboard and most packaging
into one category, which is entitled "Paperboard and Packaging." Within this category, EPA is
retaining an unbleached packaging subcategory for brown paper products. Reflecting the groupings
used by paperboard manufacturers, the Paperboard and Packaging category also contains the
following additional five subcategories:
o Corrugated containers and solid fiber boxes
o Folding cartons
o . Industrial paperboard (e.g., tubes, cores, drums, and cans)
o Miscellaneous board products (e.g., pad backs, book covers, mailing tubes, protective
packaging)
o Carrierboard
The Paperboard and Packaging category does not include most bristols, which are thicker
papers used for such items as filing and indexing products and greeting cards. Thicker bristols such
as railroad board fall within the paperboard category however. As will be explained in chapter V of
this document, bristols can be considered to be either paperboard products or printing and writing
paper products, depending on their thickness. In the draft RMAN, recommendations for most bristols
are found under printing and writing paper because these items have characteristics that are more like
paper products than paperboard products in use, function, and aesthetics. In addition, this distinction
is consistent with paper industry practice; mills manufacturing bristols generally are considered to be
printing and writing paper mills, not paperboard mills.
C. Use of Recovered Fiber in the Manufacture of Paperboard
Paperboard is a thicker, stiffer type of paper product. It can have a single ply structure or a
multi-ply structure. Multi-ply boards, which typically contain recovered fiber, are used in the
manufacture of folding cartons, rigid boxes, and similar products. In a multi-ply product, the top and
bottom layers, or liners, contribute strength and, in the case of the top liner,vprintability. Therefore,
the top and bottom layers are usually made from recovered fibers that are cleaner and retain their
fiber strength. Currently, these are most often made from preconsumer fiber but, increasingly,-they
are being made from postconsumer fiber as well. ,
The inner, or filler plies, provide thickness to increase the stiffness of the board. Because
these plies are not visible, they can be made from lower grade fibers, such as printed postconsumer
fibers, that can be darker or dirtier in appearance. The grades usually used for the filler plies are
ONP, mixed paper, old corrugated containers (OCC), and used brown kraft bags.
D. Corrugated Containers and Solid Fiber Boxes
The paper industry uses the term "containerboard" to describe paperboard used to make
corrugated containers and solid fiber shipping boxes. EPA's 1991 research indicated that
containerboard was made primarily from virgin fiber. This has begun to.change as production -
21
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capacity for making both linerboard and corrugated medium from recovered fiber is increasing. In
1991, recycled containerboard accounted for 11% of production: 2.7 million tons out of total
cpntainerboard production of 24.4 million tons. Two years later, in 1993, recycled containerboard
accounted for 15% of production: 4.0 million tons out of a total of 26.4 million tons: The recycled
containerboard mills used 4.6 million tons of recovered fiber in 1993.6 AF&PA projects that ,
containerboard producers will increase their use of recovered fiber predominantly postconsumer '
fiber - by more than 50% by the year 2000.7
1.,Corrugated Containers ;
a. Postconsumer and recovered fiber recommendations. In the 1988 paper procurement
guideline, EPA recommended a 35% postconsumer fiber content level for corrugated boxes. Based
on product availability, GSA specifies 40% postconsumer fiber for corrugated containers with burst
strengths up to 300 pounds per square inch (psi), which is the predominant type of corrugated
container that the agency purchases. GSA found that stronger boxes (with bursting strengths
exceeding 300 psi) are not available with this level of postconsumer fiber, but are available containing
30% postconsumer fiber. ' ' '
Because corrugated containers are a composite product, postconsumer and recovered fiber
content must be calculated from the content of each component. The calculation method is discussed
in the following subsection and Appendix A-l to the draft RMAN. EPA used this method to calculate
fiber content using the fiber percentages currently available in corrugating medium and linerboard.
The majority of corrugating medium manufacturers providing information to EPA indicated that they
used postconsumer fiber content of 9Q% or higher. More than half of the linerboard producers
contacted indicated that they used postconsumer fiber content of 35% or less. Calculating the
postconsumer content of a corrugated container that is made with medium and linerboard meeting the
90% and 35% content levels, respectively, EPA concludes that the high end of the range of
postconsumer content levels for corrugated containers can be set at 50% postconsumer fiber.
In section A-4 of the.draft RMAN, EPA is recommending content ranges of 40% - 50%
postconsumer fiber for corrugated containers rated at less than 300 psi, and a level of 30% ,
postconsumer fiber for containers rated at 300 psi. These recommended content levels are based on
the results of EPA's.calculation of maximum fiber content and the information supplied by GSA.
While EPA has data on the total recovered fiber content of the components of corrugated
containers, the Agency does not have data on the recovered fiber content, other than postconsumer
fiber, of the assembled corrugated containers. Therefore, in the draft RMAN, EPA is recommending
that the recovered fiber consist entirely of postconsumer fiber. In EPA's table of recommendations,
6 There is a difference between the volume of fiber used and the volume of containerboard
produced because some fiber is lost during the manufacturing process. '.'- , ^
7"The Ciutlook for Paper Recovery to the Year 2000," prepared for AF&PA by Franklin
Associates, Ltd., November 1993.
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the content level for corrugated containers rated at less than 300 psi is displayed as 40 - 50%
recovered fiber and 40-50% postconsumer fiber. This means that the total recovered fiber content
of these corrugated containers should be 40 - 50%, all of which is postconsumer Tiber. Similarly, the
recommended content level for corrugated containers rated at 300 psi is displayed as 3Q% recovered
fiber and 30% postconsumer fiber, meaning that all of the recovered fiber used should be
postconsumer fiber. EPA requests information on the use of recovered fiber other than postconsumer
fiber in the manufacture of corrugated containers. EPA also requests information on the availability
of stronger containers (rated at 300 psi or greater).containing more than 30% postconsumer fiber.
EPA notes that OCC comprises one of the largest recovered materials grades'-used in
corrugated containers. In 1993, OCC was recovered at a rate of 62%. AF&PA projects that between
1992 and the year 2000, linerboard mills will increase OCC consumption by over 25%. At the same
time, recycled paperboard mills will increase use, of OCC by over 40%. In addition, 12 mini-mills
that produce 100% recycled linerboard and corrugating medium are expected to start-up in 1995, and
several existing mills are retrofitting equipment to use greater amounts of OCC. With-this imminent
significant increase in new capacity, there has been speculation in the trade press that shortages of
OCC could result.
In fact, there was a shortage of OCC during the summer of 1994, which drove up fiber and
manufacturing costs. While mills can substitute some ONP and mixed paper for OCC, the use of
these other recovered materials is limited because they do not provide the same strength properties as
does OCC. In addition, shortages of ONP for use by newsprint mills is reported in some parts of the
U.S., limiting the amount of this recovered material available for use in paperboard products.
EPA does not have information indicating that the recent shortages of OCC have impacted the
availability of corrugated containers containing 40 - 50% postconsumer fiber. EPA requests comment
regarding the impact on the recommended content levels for corrugated containers of (1) the increased
demand for OCC and (2) the imminent additional capacity to make linerbbard containing 100%
recovered fiber.
b. Method for calculating fiber content. Corrugated containers are made by sandwiching
fluted corrugating medium between two layers of linerboard. Because.corrugated containers are a
composite, recovered fiber content must be calculated from the content of each component relative to
the weight each contributes to the total weight of the container. There are many corrugated board
combinations, four basic flute sizes used in corrugating medium, and a number of paper weights that
must be considered when making an estimate of the recovered material content of the finished
product.
Appendix A-l to the draft RMAN provides an example calculation for how to determine the
recovered material content of corrugated containers. The variables used in this example result in a
corrugated container which meets and, in fact, slightly exceeds, a 35% postconsumer content level.
The example uses data for the most commonly manufactured box, 200 psi test, C-flute made with 42
Ib/thousand square feet (MSF) linerboard and 26 Ib/MSF medium.
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2. Solid Fiber Boxes . ,
Solid fiber boxes are made by laminating several plies of paperboard together. The outer
-plies are usually linerboard made from wood pulp, while the inner plies may contain either a wood-
based fiber linerboard or a high bulk filler board (chipboard), which is made from recovered fiber.
The laminated structure is highly resistant to puncture and is durable and strong. Solid fiber boxes
are used for specialized packaging needs, such as army ration boxes, dynamite packaging, and for
packaging hard, dense items such as machine parts and hardware.
. , In the 1988 paper procurement guideline, EPA recommended a 35% postconsumer content
level for fiber boxes. Based on product availability, GSA uses the same 40% postconsumer fiber
standard for solid fiber boxes as it uses for corrugated containers. EPA has no other information
about the recovered fiber or postconsumer fiber content of this item.
In section A-4 of the draft RMAN, EPA recommends a content level of 40% recovered fiber,
all of which is postconsumer fiber, for solid fiber boxes. This level is based on the information
provided by GSA. In EPA's table of recommendations, this recommendation is displayed as 40%
recovered fiber and 40% postconsumer fiber.
E. Folding Cartons " .
In the 1988 paper procurement guideline, EPA recommended an .80% postconsumer consent
level for "recycled paperboard products including folding cartons." This recommendation raised two
issues.. First, as discussed above in the Background section, folding'.cartons can be made from
recycled paperboard or from other types of paperboard, so the recommendation did not address all
types of folding cartons. Second, the other types of paperboard are made primarily from fiber
derived from wood, rather than fiber derived from recovered materials. As with printing and writing
paper mills and some tissue mills, it is not economically viable for paperboard mills dependent on
wood for their fiber to use high percentages of postconsumer fiber. Some of,these mills have begun
to use low percentages of postconsumer fiber, however. ,
The paperboard segment of the paper industry considers folding cartons to be a subset of
boxboard. Folding cartons can be clay coated, white lined, and plain. There are differences in the
production of coated and uncoated paperboard which might impact the type of recovered fiber used.
The coating operation is similar to that used for coated printing papers, and similar problems can be
created by contaminants in fiber derived from postconsumer materials.8 For this reason, the top ply
of coated cartons is usually made from virgin or preconsumer fiber, which generally is longer,
stronger, and cleaner fiber, than postconsumer fiber. Inner or "filler" plies can be made from lower
grade, postconsumer fibers. , -
Manufacturers of coated folding cartons use varying percentages of postconsumer fiber,
depending oh customer specifications. Of the ten manufacturers of folding cartons for which EPA has
8 Goated printing papers are discussed in section V.C.
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data, two companies use 35% or more postconsumer fiber, while six use 40% or more postconsumer
fiber. Half of the mills reported that the high end of their range of postconsumer fiber content is
80% (or higher).
Manufacturers of uncoated folding cartons also use varying percentages of postconsumer
fiber depending on customer specifications. EPA's 1991 research indicated that uncoated folding
cartons were available containing 60% postconsumer fiber. EPA has more recent data from only one
mill, which uses 45 - 50% postconsumer fiber. Based on EPA's 1991 finding that it is easier to use
higher percentages of postconsumer fiber in uncoated folding cartons than in coated cartons, EPA
believes that, like coated carton manufacturers, uncoated carton manufacturers should be technically
able to use up to 80% postconsumer fiber.
Finally, EPA notes that, in 1992, many major packaged goods producers started claiming an
average minimum content of 35% postconsumer fiber in paperboard packaging. Based on product
availability, however, GSA specifies a 40% postconsumer content standard for folding cartons. The
EPA research discussed above indicates that six Of the coated folding carton manufacturers and the
one uncoated carton manufacturer can meet a 40% postconsumer fiber content level.
All of the folding carton mills for which EPA has data use 100% recovered fiber in their
products Based on this data and the information discussed above, in section A-4 of the draft RMAN,
EPA is recommending content levels for folding cartons of 100% recovered, fiber, including 40 - 80%
postconsumer fiber.
EPA notes that its 1991 research suggested that there should be different postconsumer
content recommendations for coated and uncoated folding cartons because there were significant
differences in the type and quantities of recovered fiber used. More recent EPA research and
correspondence from paper industry sources suggests that there should be no distinction between
coated and uncoated folding cartons for purposes of postconsumer and recovered fiber content levels.
EPA requests additional information about differences in postconsumer fiber content, if any, currently
used in coated and uncoated folding cartons.
Further, EPA notes that manufacturers of the paperboard used in folding cartons recover fiber
from OCC. As discussed in the corrugated 'container section above, there was a short supply of OCC
during the summer of 1994, which drove up fiber and manufacturing costs. EPA does not have
information indicating that the OCC shortages affected the availability of folding cartons containing
higher levels of postconsumer fiber. EPA requests comment on the impact of the increased demand .
for OCC on the availability of folding cartons containing higher percentages of postconsumer fiber.
F. Industrial Paperboard ,
EPA did not recommend content levels for industrial paperboard products in the 1988 paper
procurement guideline. Because these items can contain high levels of both recovered and
postconsumer fiber, EPA received inquiries about whether the content level for these items should be
the 80% postconsumer level recommended for recycled paperboard or some other level.
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Products made from industrial paperboard include tubes, cores, cans, and drums. End uses
for these products range from very lightweight cores for rolls of bathroom tissue to extremely dense
industrial cores, canisters, and drums.
EPA's data and correspondence from industry sources indicate that there can be hundreds of
applications for industrial paperboard products, requiring wide variability in the type of fiber used for
dSeren end uses. Of the four manufacturers for which EPA has data, one manufacturer reported
postcon umer content levels ranging from 90 - 100%. A second manufacturer did not provide its
^consumer nercentages A third manufacturer reported using 69% postconsumer fiber. The fourth
-S^SSdSS; postconsumer content of its drums ranged from 45 - 100%. All use 100%
recovered fiber in their products. ' .
In section A-4 of the draft RMAN, EPA is recommending content levels of 100% recovered
fiber including 45 - 100% postconsumer fiber, for the industrial paperboard products subcategory.
Becau ete Agency's information is limited, EPA requests comment on whether there should be
different content recommendations based on the specific applications) of the various industrial
, paperboard products.
G. Miscellaneous Paperboard Products ,' - ' ' ,
There are various miscellaneous paperboard products, including pad backings, book covers,
covered binders containing chipboard, mailing tubes, and protective packaging such as video cassette
sleeves. There also are a variety of consumer items, such as game boards and puzzles In thM988.
paper procurement guideline, EPA recommended a 90% postconsumer conten level for pad backing,
bu?didP not address Sher miscellaneous paperboard products. EPA has since learned that m?ny of
Lse products are purchased by government agencies and can contain high levels of postconsumer
fiber.
: The miscellaneous paperboard products are composed of multiple plies. They also can be
coated or uncoated, depending on their use. EPA's 1991 research indicated that; coated products
typically contained a minimum of 45% postconsumer fiber, while uncoated products typically
Stained a minimum of 60% postconsumer fiber. EPA's 1994 research provides jnsuff.c^nt data to
distinguish separate postconsumer fiber content levels for coated and uncoated products. It includes
information from only two of the ten manufacturers of the paperboards used in miscellaneous
PIS One manufacturer can use up to 100% postconsumer fiber, while the other manufacturer
uses 75 - 100% postconsumer fiber. As with other paperboard products, the percentage ot
postconsumer fiber depends on the product and customer specifications.
In 1991 coated and uncoated miscellaneous paperboard products contained 90 - 100% total
recovered fiber.' Both manufacturers for which EPA has current data use 100% recovered fiber.
In section A-4 of the draft RMAN, EPA is recommending a content level of 100% recovered
fiber including 75 - 100% postconsumer fiber for both coated and uncoated miscellaneous paperboard
products EPA requests comment on whether there should be different postconsumer ranges for
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coated and uncoated miscellaneous paperboard products and whether there should be different content
recommendations based on the specific applications) of the products.
H. Unbleached Packaging '
In the 1988 paper procurement guideline, EPA recommended a 5% postconsumer content
level for brown papers. At that time, little postconsumer fiber was used in brown papers, which are
used for products such as wrapping paper and bags.
Currently, some manufacturers are producing bags containing more than 5% 'postconsumer
fiber. At least one grocery sack manufacturer uses up to 20% ONP. GSA informed EPA that 20%
is a feasible content level from a performance perspective. GSA has not been able to purchase
grocery sacks containing 20% postconsumer fiber at this time, but has been able to purchase sacks
containing 5% postconsumer fiber. Based on this information, EPA recommends that unbleached
packaging contain 5-20% postconsumer fiber.
EPA has insufficient data on which to base recommended ranges for recovered fiber content.
Research conducted by other organizations and submitted to EPA suggests that 40% recovered fiber
can be used in unbleached packaging. Based on the availability information provided by GSA, EPA
concludes that some manufacturers of unbleached packaging will use only low levels of recovered
fiber, all of which is postconsumer fiber. For this reason, EPA is recommending a recovered fiber
content range of 5 - 40% for unbleached packaging.
In sum, in section A-4 of the draft RMAN, EPA is recommending a content range of 5 - 40%
recovered fiber, and a postconsumer fiber range of 5 - 20% for unbleached packaging.
I. Padded Mailers ' .
In the 1988 paper procurement guideline, EPA included padded mailers with envelopes. EPA
recommended a 50% waste paper content level for all envelopes.
EPA has since learned that padded.mailers are not considered to be "envelopes" by either
GSA or the envelope sector of the paper industry. Instead, they are considered to be packaging
materials. For this reason, EPA is including padded mailers with other packaging items in the draft
RMAN.
Padded mailers must be strong and durable to protect the items shipped in them. Therefore,
padded mailers are made from kraft paper, which contains a high percentage of softwood fiber for
strength. While it is possible to obtain softwood postconsumer or recovered fibers, these fibers
generally are considered to be a replacement for virgin hardwood fiber because they are shorter.
EPA has limited information regarding the postconsumer fiber content of padded mailers. GSA
currently purchases padded mailers containing 5% postconsumer fiber. At least one manufacturer
uses 15% postconsumer fiber. In addition, EPA is aware that some manufacturers have been using
shredded postconsumer paper and other postconsumer materials as the padding inside the mailer but
EPA does not know the total postconsumer fiber content of these mailers.
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Based on this information, in the draft RMAN, EPA is recommending that padded mailers
contain 5 - 15% postconsumer fiber. EPA requests additional information regarding the use of
postconsumer and other recovered fiber in padded mailers.
J. Carrierboard
» , .
The 1988 paper procurement guideline did not specifically address carrierboard. EPA
subsequently received inquiries about the recommended content level for this item.
Carrierboard is a paperboard impregnated with "wet strength" chemicals, suitable for
converting into folding cartons used for packaging. It typically is used for packaging beverage
containers. EPA knows of three companies that make this product. Ninety percent of carrierboard is
made by two of the companies from a type of paperboard known as solid unbleached sulfate (SUS).
Traditionally, SUS has been made as a single ply paperboard, using little or no recovered fiber. In
response to demand from their private sector customers, two of the largest SUS manufacturers are
now producing carrierboard from SUS containing up to 25% recovered fiber, including 15%
r postconsumer fiber. ' >
The third manufacturer produces carrierboard from 100% recovered fiber. This manufacturer
uses recycled paperboard, rather than SUS. As discussed above, recycled paperboard is a multiply
product. Although postconsumer fiber is used in the inner plies of multiply products, EPA does not
have data on the specific postconsumer fiber content of the carrierboard made from recycled
paperboard.
As far as EPA knows, government agencies do not make direct purchases of carrierboard. It
is possible, however, that government agencies will purchase this item in the future for food service
applications. Therefore, EPA is recommending content levels for carrierboard in the draft RMAN.
Based on the information presented above, in section A-4 of the draft RMAN, EPA recommends
content ranges for carrierboard of 25 - 100% recovered fiber, including 15% postconsumer fiber.
Procuring agencies should be aware that, because the vast majority of carrierboard is SUS, most of
the available "recycled" carrierboard will contain 25% recovered fiber, rather than 100% recovered
fiber. EPA requests comment on whether there are different performance characteristics of the two
different types of carrierboard (SUS and recycled paperboard) that would require listing them
separately in the final RMAN.
EPA notes that the percentages of postconsumer and recovered fiber used in carrierboard .
varies with the caliper (thickness) of the product required for a given end use. EPA recommends that
. procuring agencies select the highest levels of postconsumer and recovered fiber practicable for the
required end use of the carrierboard. Because carrierboard is used principally for private sector
applications, EPA encourages private sector users to seek carri'erboard containing postconsumer fiber.
K. Paperboard Products Used by Private Sector Purchasers , ,
During the past three years, private sector purchasers of paperboard products increased their
demand for products containing postconsumer fiber. In response, manufacturers introduced several
. 34 '".'. ..
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new paperboard products for applications previously made from paperboard principally containing
wood pulp. Carrierboard is one example.
Other examples include plates, cups, and "clam shells" for hot and oily foods. '.These
products are made from a type of paperboard known as solid bleached sulfate (SBS). SBS is used in
milk cartons, food service products (e.g.,-cups and plates), folding Cartons, linerboard for corrugated
containers and solid fiber boxes, and other packaging and non-packaging uses. As with SUS
paper-board, SBS is used primarily in products purchased by the private sector. Government agencies
might purchase these items indirectly, as packaging or through food service contractors.
Because it is used in food applications, SBS products must meet federal Food and Drug
Administration regulations. These state that manufacturers can use reclaimed fiber "excluding that
which bear- ,.-. -.tains any poisonous or deleterious substance which is retained in the recovered
pulp and that migrates to the food." (21 CFR 176.260)
At least two manufacturers have developed the technical capability to use postconsumer fiber
in SBS and meet the FDA requirements. In 1993, one manufacturer introduced an SBS board
containing 20% postconsumer fiber. In 1994, another manufacturer introduced disposable food
service products containing recovered fiber and 10-35% postconsumer fiber. These products include
polycoated drinking cups, carryout cartons, "clamshells," and drink carriers. Both manufacturers
restrict the grades of postconsumer paper used in order to meet the FDA requirements. EPA
applauds the manufacturer's commitment to using postconsumer fiber and encourages other SBS
manufacturers to do so. EPA also encourages additional private sector users of these products to
" specify products containing postconsumer fiber.
Because of the FDA requirements, most SBS paperboard manufacturers have been reluctant to
use fiber from postconsumer or other recovered materials. They informed EPA that they are
concerned that, if they use this fiber, they will not be able to certify to their customers that there are
no poisonous or deleterious substances in the product. They also informed EPA that neither
polycoatings nor waxed coatings provide a barrier to migration of deleterious substances.
Because there are limited sources and availability of SBS containing postconsumer fiber, EPA
is not recommending content levels for this item in the draft RMAN. EPA requests additional
information regarding (1) the use of postconsumer and other recovered fiber in SBS products, in
general, and in food grade items in particular, (2) whether and to what extent procuring agencies
purchase SBS products, and (3) whether EPA should recommend content levels for these items.
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L. Summary of Paperboard and Packaging Recommendations
Table 3 contains EPA's recommended content ranges for paperboard and packaging products.
Table 3. Recommendations for Paperboard and
. Packaging Products *
Item
Corrugated containers*
(<300 psi>
(300 psi)
Solid, fiber boxes
Folding cartons**
Industrial paperboard
(e.g!, tubes, cores,
drums, arid cans)
Miscellaneous (e.g., pad
backs, covered binders,
book covers, mailing
tubes, protective
packaging)
Padded mailers
Carrierboard
Brown papers (e.g., wrap-
ping paper and bags)
Recovered Fiber (%)
40-50
30
40
100 ,
100
* -
100
.5-15
25 - 100
40
Postconsumer Fiber
' (%)
40-50
30
40
; 40-80
45 - 100
75- 100
5-15
15
' 20
*The recovered and postconsumer fiber content levels are calculated from the content of each
component relative to the weight each contributes to the total weight of the box. Appendix I to the
draft RMAN provides an example of how to make this computation..
** The recommended content ranges are not applicable to all types of paperboard used in folding
cartons. Cartons made from solid bleached sulfate or solid unbleached sulfate contain no. or small
percentages of postconsumer fiber, depending on the paperboard source*
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M. Summary of Request for Comments on Recommendations for Paperboard and Packaging Products
EPA requests comment on each content level recommendation for paperboard and packaging
products discussed in this chapter. In this chapter, EPA also requests comment or information on the
following issues: .
o Is recovered fiber other than postconsumer,fiber used in the manufacture of
corrugated containers?
o Are corrugated containers rated at 300 psi or greater available containing more than
30% postconsumer fiber? . '
o Will the recent increased demand for OCC affect .the ability of manufacturers to meet
the recommended content levels for corrugated containers?
o Will the imminent availability of additional capacity to make linerboard containing
100% recovered fiber allow manufacturers to exceed the high end of the ranges of
recommended content levels for corrugated containers'?
o Are there differences in the postconsumer fiber content currently used in coated and
uncoated folding cartons?
o Should recommendations for coated and uncoated folding cartons be listed separately
because of the differences in their, ability to incorporate postconsumer fiber content?
o Will the recent increased demand for OCC affect the availability of folding cartons
containing higher percentages of postconsumer fiber?
o Should" EPA recommend different content levels for the various industrial paperboard
products, based on the specific applications) for those products?
o Should EPA recommend different postconsumer ranges for coated and uncoated
miscellaneous paperboard products, and should there should be different content
recommendations based on the specific application^) of the products?
o Are percentages of postconsumer fiber greater than 15% used in padded mailers?
What percentages of recovered fiber other than postconsumer fiber are used in padded.,
mailers?
o Are there different performance characteristics of the two different types of
carrierboard (solid unbleached sulfate and recycled paperboard) that would require
listing them separately in the final RMAN?
o Is postconsumer or other recovered fiber used in solid bleached sulfate paperboard
products, in general, and in food grade items in particular?
o Do procuring agencies purchase solid bleached, sulfate paperboard products, either
directly or indirectly? If yes, to what extent?
' o Should EPA recommend content levels for solid bleached sulfate paperboard products?
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V. Recommendations for Printing and Writing Papers . ,
A. Background
1. Overview . -
* i " - =
Printing and writing paper is abroad category of office, writing, and printing papers. It is
the largest category of paper products purchased by government agencies. It includes both coated and
uncoated papers and bleached and unbleached papers. In 1993, U.S. mills supplied 24 million tons of
printing and writing paper, representing 28% pf all paper and paperboard. These mills used 2.3
million tons of recovered paper that year.
Printing and writing papers can be made from wood fiber, cotton and linen fiber, and other
materials, although cellulose from wood is the predominant fiber used. It is obtained.using
mechanical or chemical processes, or hybrids of chemical and mechanical processes, to separate the
fiber from the other components of the wood. The process used affects the characteristics of the fiber
and, therefore, the paper made with that fiber. Papers containing fibers obtained by mechanical
pulping processes are referred to as "groundwood" papers, while papers containing fibers obtained by
chemical pulping processes are referred to as "freesheet." "Free" refers to; the^absence of mechanical
wood pulp. Pulps obtained by chemical pulping contain little or no lignin, the substance that causes
paper such as newsprint to yellow or become brittle. ".....
The 1988 paper procurement guideline provided recommendations for offset printing papers,
rriimeo and duplicator paper, writing paper (stationery), office papers (e.g., note pads), high-speed
copier paper^ envelopes, forms bond including computer paper and carbonless, book papers, bond
papers, ledger, cover stock, and cotton fiber papers. EPA recommended a 50% waste paper standard
for most of these items and a 25% recovered materials standard for cotton fiber papers.
Executive Order 12873 establishes minimum content levels for specified uncoated printing and
writing papers. EPA has received inquiries on issues related to the terminology used in the Executive
Order. As explained in section V.B below, EPA is incorporating the Executive Order content levels
into the draft recommendations for printing and writing papers. EPA also addresses the terminology
issues in this section.
In the 1988 procurement guideline, EPA did not differentiate between coated and uncoated
papers and did not provide specific recommendations for bristols (e.g., file folders, accordion'files,
hanging folders). This created confusion about the content level to be used for these items. In the
draft RMAN, EPA is recommending content levels for coated printing papers and bristols to remove
ambiguity about the content levels applicable to these items. EPA's recommendations for coated
papers and bristols are discussed in sections V.C and V.D, respectively.
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2. Elimination of "High Gr,ade Bleached" Distinction .
The 1988 paper procurement guideline categorized all printing and writing papers as "high
grade bleached" paper. However, agencies purchase envelopes and other types of printing and writing
paper products which are not made from bleached paper. As a result, agencies, mills, and vendors
have been confused about the applicability of EPA's recommendations to unbleached items.
It is EPA's intent that agencies purchase the broadest range of paper and paper products
available. To end any confusion about the scope of EPA's recommendations, EPA is eliminating
"high grade bleached" from the description of the printing and writing paper category. Procuring
agencies should seek to purchase all printing and writing papers, whether bleached or unbleached,
which can be" made with postconsumer and other recovered fiber satisfying the agencies' minimum
content standards.
B. Uncoated Printing and Writing Papers
Uncoated printing and writing papers can be made from either freeshe,et or groundwood pulp.
EPA has been asked whether the 1988 recommendations and the standards in Executive Order 12873
are limited to freesheet papers. EPA wishes to emphasize that both the standards in Executive Order
12873 and the EPA recommendations in the draft RMAN apply to printing and writing papers made
from either type of pulp. . .
1. Executive Order Provisions
Section 504 of Executive Order 12873 requires Federal procuring agencies to purchase
selected printing and writing papers meeting or exceeding the following minimum content standards:
o ' For high speed copier paper, offset paper, forms bond, computer printout paper,
carbonless paper, file folders, and white wove envelopes, the standard is 20 percent
postconsumer materials beginning December 31, 199Vincreasing to 30 percent
postconsumer materials beginning December 31, 1998.
o For other uncoated printing and writing papers, such as writing and office paper,
book paper, cotton fiber paper, and cover stock, the minimum content standard is 50
percent recovered materials, including 20 percent postconsumer materials beginning
on December 31, 1994, increasing to 30 percent postconsumer materials beginning
December 31, 1998. ,
o As an alternative to these standards, the standard is no less than 50 percent recovered
materials that are a waste material by-product of a finished product other than a paper
or textile product which would otherwise be disposed of in a landfill, as determined
by the State in which the facility is located.
Prior to the Executive Order, it generally was thought that the way to foster greater use of
postconsumer materials was to establish high postconsumer and recovered fiber content levels.
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However, most of the printing and writing paper manufactured in the U.S. is made on the industry's
large papermaking machines at vertically integrated mills that produce both wood pulp and paper.
Because the operating economics and energy balance at these mills is tied to their use of wood to
produce pulp, it is not economically feasible for them to reduce their existing wood pulp-making /
capabilities significantly in order to substitute high percentages of pulp made from postconsumer or
other recovered paper. Paper meeting the 1988 guideline typically have been produced by the
industry's small and medium-sized mills. As a result, the paper industry has been able to
manufacture only limited quantities of printing and writing papers meeting the 50% "waste paper"
content level recommended in the 1988 paper procurement guideline.
Executive Order 12873 establishes, a paradigm shift in the way procuring agencies should
establish minimum content standards in order to encourage the large printing and writing paper mills
to use postconsumer fiber. It establishes lower, postconsumer-only content standards for the types of
printing and writing papers commonly manufactured by these larger mills. These papers are often
referred to as commodity papers and include reprographic paper, offset paper, forms bond, computer
printout paper, and carbonless paper. ;
Because small and medium-sized paper mills are able to produce printing and writing paper
using higher levels of recovered fiber, the Executive Order retains a 50% total recovered materials
content level for other types of paper that can be produced by these mills. These papers are often
referred to as "specialty" papers and include text and cover papers', cotton fiber papers, and high
quality writing and book papers. In order to foster the continued use of postconsumer materials by
these smaller mills, the Executive Order also requires that text and cover papers, cotton fiber papers,
and high quality writing and book papers purchased by federal agencies contain 20% postconsumer
materials.
/ - ' - , ,
Executive Order 12873 also provides that agencies can use an alternative standard of "50%
recovered materials that are a waste material byproduct of a finished product other than a paper or
textile product." Paper or paper products meeting this standard can only contain a specific subset of
recovered materials. Two examples of materials that may meet the alternative standard are sawdust
and materials such as cotton linters that are a byproduct of processing cottonseed into oil. Procuring
agencies should note that these materials meet the alternative standard only if they would be disposed
in a landfill if they were not used in paper products.
EPA encourages state and local government agencies, contractors, and private sector
purchasers to adopt the new approach used in Executive Order 12873 in order to ensure uniform
recovered material content requirements and to foster greater use of postconsumer fiber by all printing
and writing paper mills.
Procuring agencies also should note that the 20% postconsumer content levels established by
Executive Order 12873 increase to 30% postconsumer content beginning December 31, 1998. EPA
considered including both the 20% and 30% content levels in the draft RMAN. Because the draft
RMAN differs significantly from the 1988 paper procurement guideline in scope, approach to content
levels, and some terminology, EPA concluded that it would be less confusing to agencies if the
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RMAN incorporates only the 20% content level at this time. EPA plans to issue revised
recommendations incorporating the 30% postconsumer content levels in the future.
2. Terminology ' '
Like the 1988 paper procurement guideline, the Executive Order uses generic industry terms
suev - "hook," "bond," and "offset." Based on conversations with paper company representatives
and purchasing agents, EPA has found that the printing and writing papers used for book, bond, and
offset applications currently are often used interchangeably. As a result, there is confusion about
which content level a paper should contain, because the Executive Order establishes postconsumer-
only content levels for offset papers, but two-part content levels for book, writing, and other office
papers.
In the draft RMAN, EPA uses new terminology for listing printing and writing papers. The
terms "book" and "bond" are no longer used. Instead, EPA is providing more descriptive terms that
are based largely on recommendations made by AF&PA's Printing-Writing Paper Division. EPA
believes that the new format better reflects the way in which terms are currently used by mills,
vendors, and procuring agencies. The following subsections discuss the new terms and EPA's
recommendations for each item. ,
3. Reprographic Papers
In the 1988 paper procurement guideline, EPA recommended 50% waste paper content levels
for mimeo, duplicator, and bond papers. The current paper industry terminology for these items is
"reprographic paper," which refers to a category of commodity papers that includes business paper
grades (both cut-size and copier rolls) such as bond, electrostatic copy, mimeo, duplicator, and
reproduction papers for commercial, institutional, and home use. Table 4 identifies the
characteristics, common terms/names, and applications or end uses of reprographic papers.
Executive Order 12873 establishes a 20% postconsumer content level for these items. In
section A-,1 of the draft RMAN, EPA incorporates this content level. In EPA's table of
recommendations, the content level is displayed as 20% recovered fiber and, 20% postconsumer fiber.
This means that the total recovered fiber content of reprographic papers should be 20%, all of which
is postconsumer fiber.
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Table 4. - Reprographic Papers Characteristics
Characteristics
Usually small size sheets (8
1/2 x 11", 8 1/2 x 14", or 11 ..
x 17") -..
Usually ream-wrapped
Purchases for both high-
volume and low-volume needs
Terms/Names
Office bonds
(white and colored)
Copier paper
Writing paper (white and
colored)
Cut-size
Multipurpose bond
Laser paper
Applications and End Uses
(High & Low speed, .
equipment)
:^====^==
Business communications
Xerographic
Laser . - -. ,
InkJet
Typewriter
Mimeo
Duplicator
Fax
Desktop publishing
Electronic publishing
4. Offset Papers
In the 1988 paper procurement guideline, EPA listed offset printing paper, book papers, and
bond papers separately and recommended 50% waste paper content levels for each item. In current
paper industry terminology, however, "offset paper" is a broad category of relatively inexpensive
commodity paper used primarily for book publishing, commercial printing, direct mail, technical
documents, and manuals. Offset paper can be used for both book and bond applications.
In the 1988 paper procurement guideline, EPA defined "offset printing paper" as uncoated or
coated paper. In current paper industry,terminology, however, "offset paper" refers to uncoated
paper. For this reason, as used in the draft RMAN, "offset" will refer to uncoated papers, while
coated offset, papers are included with other coated papers.
Offset papers were originally designed primarily for use in offset lithography. They are used
on both sheet-fed and web presses. Important properties are good internal bondmgrhigh surface
strength, dimensional stability, lack of curl, and freedom from fuzz and foreign surface material.
Table 5 identifies the characteristics, common terms/names, and applications or end uses ot ottset
papers.
Executive Order 12873 establishes a 20% postconsumer content level for these papers. In
section A-l of the draft RMAN, EPA incorporates this content level. In EPA's table of
recommendations, the content level is displayed as 20% recovered fiber and 20% postconsumer fiber.
This means that the total recovered fiber content of offset papers should be 20%, all of which is
postconsumer fiber. . ' . >
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Table 5. - Offset Paper Characteristics
Characteristics
;
Used in commercial printing
Generally high volume roll
and ineet applications
Terms/Names
Web offset
Sheet-fed offset
Opaque offset
Offset book
Book
Applications and End Uses
Books
Manuals
Brochures
Return postcards
Direct mail
Catalogs
Letterpress-
5. Tablet Papers
In the 1988 paper procurement guideline, EPA recommended a 50% waste paper content level
for "office paper (e.g., note pads)." In current paper industry terminology, "tablet paper" can be
used for this and other applications. Tablet papers are considered to be commodity papers. They
must have a good writing surface and resist penetration by inks. Table 6.identifies the characteristics,
common terms/names, and applications or end uses of tablet papers. ,
Executive Order 12873 establishes a content level of 50% recovered materials, including 20%
postconsumer materials for "writing and office paper." There are two types of "writing and office
papers " however: premium papers and the less expensive papers such as writing tablets. EPA
believes that the content levels in the Executive Order were meant for premium writing and office
papers that typically are manufactured at small and medium-sized paper mills using 50% recovered
fiber, including a percentage of postconsumer fiber. Because tablet papers are a commodity item,
EPA'believes that they should contain 20% postconsumer fiber, like the other commodity papers.
For this reason, in section A-l of the draft RMAN, EPA is recommending a 20% postconsumer fiber
content level for tablet papers. In EPA's table of recommendations, the content level is displayed as
20% recovered fiber and 20% postconsumer fiber. This means that the total recovered fiber content
of tablet papers should be 20%, all of which is postconsumer fiber.
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Table 6. - Tablet Paper Characteristics
Characteristics
Terms/Names
Applications and End Uses
Mainly a converting pap'er
Must accept ink without
"feathering"
Designed to be hole punched
Add roll
Loose leaf paper
Note tablets
Notebooks
3-hole punched filler paper
Adding machine tape
0. Forms Bond
In the 1988 paper procurement guideline, EPA listed "form bond including computer paper
and carbonless.". EPA did not recommend content levels for these items in 1988, but subsequently
issued an advisory notice recommending a 50% waste paper content level. In the 1988 guideline,
EPA also listed ledger and recommended a 50% waste paper content level for this item.
In current paper industry terminology, "forms bond" includes all bond type papers used for
business forms end uses such as continuous, register, sales book, unit set, computer printout, and
related multicopy forms, excluding carbonless. Forms bond also is used for some ledger applications.
Forms bond papers are.generally used in roll form in basis weights ranging from 11 Ib to 28 Ib (17""
x 22" - 500). Table 7 identifies the characteristics, common terms/names, and applications or end
uses of these papers.
1 . '
Executive Order 12873 establishes a 20% postconsumer content level for these papers. In
section A-l of the draft RMAN, EPA incorporates this content level. In EPA's table of
recommendations, the content level is displayed as 20% recovered fiber and 20% postconsumer fiber.
This means that the total recovered fiber content of forms bond papers should be.20%, all of which is
postconsumer fiber.
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Table 7.- Forms Bond Characteristics
Characteristics
Terms/Names
Applications and End Uses
Generally high-volume rolls
for fan-folded applications
Must perforate and hole punch
effectively
For impact and non-impact
printing
Register bond
Continuous forms bond
Computer printout (CPO)
Computer printing paper
(Green bar)
MICR/OCR forms
Ledger paper
Printing of bills, checks, etc.
Fan-folded, perforated forms
Multi-part forms
Computerized reports
Sales books .
Ledgers
7. Envelopes
In the 1988 paper procurement guideline, EPA listed envelopes and recommended a 50%
waste paper content level for these items. EPA defined "envelopes" as brown, manila, padded, or
other mailing envelopes not included with "stationery." In other words, this category included both
wove and kraft envelopes. As explained below, in the draft RMAN, EPA differentiates between
wove and kraft envelopes and provides separate content recommendations for each because their
differing strength requirements impact their ability to be manufactured with postconsumer and other
recovered fiber. . -
Envelopes can be made from many different types of printing and writing papers. There are
three basic types of envelopes: custom, wove, and kraft.
Custom envelopes are made to match letterhead, cards, or other printed material and are made
from paper specified by the purchaser. As the name implies, custom envelopes are made from
specialty papers. This category includes envelopes made from cotton fiber papers and text
(stationery) papers. EPA's recommendations for cotton fiber papers and text papers, including
matching envelopes, are discussed below in subsections V.B.8 and V.B.9, respectively.
Because of the applications for which envelopes are used, envelope papers must have different
characteristics than other papers. Generally, an envelope's function is to contaih and protect its
contents and to ensure safe delivery via mail, courier, or other mode of delivery. Envelope paper
must withstand the stresses to which it is subjected during its functional life, from forming on the
paper machine, through converting into envelopes, printing, inserting, mailing, sorting, and delivery.
Not only must envelope paper have adequate strength and printability, but it also must not interfere
with the optical scanning equipment used by the U.S. Postal Service. In particular, dirt count,
brightness, and use of fluorescent brighteners can affect optical scanners.
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a. Wove envelopes. Wove envelopes are made from "envelope converting grade," which is a
commodity paper. Wove envelopes generally are white, although they also can be colored.
Executive Order 12873 establishes a 20% postconsumer content level for white wove
envelopes. In section A-l Of the draft RMAN, EPA incorporates this content level. In EPA's table
of recommendations, the content level is displayed as 20% recovered fiber and 20% postconsumer
fiber. This means that the total recovered fiber content of white wove envelopes shquld be 20%, all
of which is postconsumer fiber.
The Executive Order did not establish a content level for colored wove envelopes. Only two
mills manufacture colored wove envelope paper. Currently, one of these mills does not use recovered
fiber, while the other manufactures colored wove envelope paper containing 50% recovered fiber,
including 10% postconsumer fiber. EPA believes that colored wove envelope paper should be viewed
as analogous to white wove envelope paper for purposes of postconsumer and recovered fiber content.
Therefore, in section A-l of the draft RMAN, consistent with the Executive Order's goal of
encouraging use of postconsumer fiber in commodity grade papers, EPA recommends a content level
of 20% postconsumer fiber for colored wove envelope papers. As with white wove envelopes, the
content level is displayed as 20% recovered fiber and 20% postcorisumer fiber, meaning that-the total
recovered fiber content of colored wove envelopes should be 20%, all of which is postconsumer
fiber. . . . ." , ' , :
b. Kraft envelopes. Kraft envelopes, which are often used for mailing large, thick
documents, are made from papers containing a high percentage of softwood fiber for strength. Kraft
envelopes can be made from bleached, semibleached,. of unbleached kraft paper. White kraft
envelope paper is bleached. Bleached kraft envelope paper can be tinted or colored to produce
"golden," "brown," or "manila" envelopes. Unbleached or natural kraft envelopes have a dark brown
appearance similar to grocery bag paper and are primarily sold to government markets.
Executive Order 12873 did not establish a content level for kraft envelopes. Use of
postconsumer and recovered fiber has been difficult in kraft envelope papers because these fibers are
inherently weaker than kraft fiber from wood. While it is possible to obtain postconsumer or
recovered fiber with high softwood content, these fibers generally are considered to be a replacement
for virgin hardwood fiber because they are shorter in length, similar to virgin hardwood fiber. The
fact that kraft envelope papers must be strong affects the amount of postconsumer and recovered fiber
that can be used. , ..'.''
- With one exception, the mills'producing kraft envelope paper are.fully integrated mills that
purchase market pulp for the postconsumer fiber component of their products. A 50% recovered
fiber content level would be an economic barrier to increased production of envelope paper containing
postconsumer or recovered fiber, just as it is for other commodity grade printing and writing papers.
There are five major manufacturers of kraft envelope paper. The two manufacturers of white
kraft envelope paper and the three manufacturers of colored kraft envelope paper use 10-20%
postconsumer fiber. .Of the two manufacturers of unbleached kraft envelope papers, one uses no
postconsumer or recovered fiber and the other uses 10% postconsumer fiber.
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Based on this information, in section A-l of the draft RMAN, EPA recommends the
following content levels for kraft envelope papers: white and colored kraft envelope papers - 10 -
20% postconsumer fiber; and unbleached kraft envelope papers - 10% postconsumer fiber. In EPA's
tables of recommendations, the content level for white and colored kraft envelopes papers is displayed
as 10 - 20% recovered fiber and 10 - 20% postconsumer fiber. This means that these envelopes can
contain either all postconsumer fiber (e.g., 20% recovered fiber, albpf which is postconsumer) or.
blends of recovered and postconsumer fiber (e.g., 20% recovered fiber, including 10% postconsumer
fiber). The content level for unbleached kraft envelope papers is displayed as 10% recovered fiber
and 10% postconsumer fiber, meaning that these envelopes should contain 10% recovered fiber, all of
which is postconsumer fiber.
Based on past experience with manufacturers' response to the Agency's recommendations,
EPA believes that these content levels will stimulate all kraft envelope paper mills to increase their
usage of postconsumer fiber. EPA notes that availability of both white kraft and unbleached kraft
envelopes containing postconsumer fiber is currently limited, and these items might not be price
competitive. Therefore, while EPA is recommending content levels for these items, procuring
agencies should research product availability in their local markets.
c. Padded envelopes. Padded envelopes are not considered to be "envelopes" by either GSA
or the envelope sector of the paper industry. Instead, they are considered to be packaging materials
and were addressed previously in chapter IV.
8. Cotton Fiber Papers
Cotton fiber papers are high quality printing and writing papers used for stationery,
invitations, currency, ledgers, maps, and other specialty uses. They contain a minimum of 25%
recovered cotton or linen fiber and can contain as much as 100% of this fiber. The recovered
materials include cotton linters and other materials recovered from cottonseed processing, as well as
trimmings from cotton and linen textile mills.
Table 8 identifies the characteristics, common terms/names, and applications or end uses of
cotton fiber papers.
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Table 8. Cotton Fiber Paper Characteristics
Characteristics
Terms/Names
Applications and End Uses
Cotton/linen fiber used as ,a
portion of the sheet's fiber
content
Special quality, durability, and
texture .
Watermarked bond
Premium bond/writing paper
Rag paper
Cotton content sheet
Premium letterhead and
stationery, including
matching envelopes
Ledgers .
Permanent records
Art and engineering papers
Wills, deeds, stocks, bonds
Premium advertisements
In the 1988 paper procurement guideline, EPA recommended a content level of 25%
"recovered materials" for cotton fiber papers. EPA explained that these papers contained fiber from
materials recovered from cottonseed processing and textiles, rather than fiber from recovered paper.
, Executive Order 12873 establishes a standard of 50% recovered materials, including 20%
postconsumer materials for cotton fiber papers. In section. A-l of the draft RMAN, EPA incorporates
this content level. - !
r '.. -
/' '.,'
Stationery (i.e., writing papers, including matching envelopes) is the type of cotton fiber
paper most commonly purchased by government agencies. Procuring agencies also purchase ledger,
maps, invitations, and other items containing cotton fiber paper. EPA is not aware of any technical
or performance constraints on the use of 50% recovered fiber, including 20% postconsumer fiber, in
these other cotton fiber paper products.
Cotton fiber paper manufacturers raised three issues regarding interpretation of Executive
Order 12873. First, they requested that their product be treated the same under the Executive Order
as it was under EPA's 1988 guideline. They argue that the term "recovered materials," as applied to
their product, should include recovered cotton and linen, rather than being limited to fiber from
recovered paper. They provided information, which EPA has placed in the public .docket, regarding
the quantities Of cotton/linen fiber generated, the quantities of recovered cotton/linen fiber that they .,-
consume, and the lack of alternative uses for these materials.
In brief, their submittal states that 680 million pounds of cotton linters were generated in
1993. The majority of this material was converted into pulp for use by the paper industry:
Correspondence from the four states in which most of this material is generated (Texas, Arkansas,
Tennessee, and Mississippi), indicates that there are no significant alternative uses for this material.
Based on this information, EPA recommends that, in implementing the standard for cotton
fiber papers established by Executive Order 12873, procuring agencies specify that the recovered
fiber component can include recovered cotton/linen fibers. '
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Second, cotton fiber paper manufacturers also inquired whether fiber from postconsumer
cotton or linen could be used to meet the Executive Order's 20% postconsumer content level.
According to anecdotal information related to EPA, some cotton fiber mills are using postconsumer
cotton or linen fiber. At least one of the cotton fiber mills also uses recovered old currency to
produce stationery and office supplies such as Post-It notes. Based on this information, EPA
recommends that procuring agencies specify that the 20% postconsumer fiber component can be
derived either from postconsumer paper or textiles. In other words,-the postconsumer fiber
requirements for cotton fiber papers can. be met by the use .of fiber derived .either from postconsumer
paper or postconsumer cotton/linen materials.
Finally, cotton fiber paper manufacturers asked whether their product met the Executive
Order's alternative standard of 50% recovered materials that are a by-product of a finished product
other than a paper or textile product. EPA believes that cotton fiber papers containing 50% fiber
from cotton linters satisfies the criteria of the alternative standard in the Executive Order. Cotton
linters are derived from cottonseeds during production of cottonseed oil. As a result, they are an
agricultural by-product, rather than a by-product of the paper or textile industries.
In sum, in section A-l of the draft RMAN, EPA is incorporating the Executive Order
provision that cotton fiber papers contain 50% recovered fiber, including 20% postconsumer fiber.
The recovered fiber component can consist of fiber derived from cotton linters, cotton or linen
textiles, or similar materials, as well as from recovered paper. Similarly, the postconsumer fiber can
be'derived either from postconsumer cotton and fiber materials or postconsumer paper. Procuring
agencies also can choose to use the Executive Order's alternative standard when purchasing cotton
fiber papers.
9. Text and Cover Papers
In the 1988 paper procurement guideline, EPA recommended 50% waste paper content levels
for writing paper (stationery), book papers, and cover stock. The paper industry term, "text and
cover paper," encompasses these items. Traditionally, text and coyer papers are considered to be
specialty papers. They are premium uncoated printing and writing papers manufactured from either
wood-based fiber or cotton fiber. They are made in a wide variety of finishes, including smooth,
antique, vellum, laid, felt-marked, patterned and/or embossed surfaces, and are characterized by
excellent folding qualities, printability, and durability. They are used for a wide range of graphic
techniques. Table 9 identifies the characteristics, common terms/names, and applications or end uses
of text and cover papers.
Executive Order 12873 establishes a standard of 50% recovered fiber, including 20%
postconsumer fiber for these papers. In section A-l of the draft RMAN, EPA incorporates this
content level. In EPA's table of recommendations, the content level is displayed as 50% recovered
fiber and 20% postconsumer fiber. This means that the total recovered fiber content of text and coyer
papers should be 50%, including 20% postconsumer fiber.
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Table 9. - Text and Cover Paper Characteristics
Characteristics
Terms/Names
Applications and End Uses
Full range of basis weights,
palette of colors, and sheet
finishes, including embossed
products ..
Generally used in specialty, ,
sheet-fed printing applications
Premium text
Premium cover
Duplex cover
Premium bond/writing
Parchment
Fine books
Premium brochures, booklets,
annual reports, advertise-
ments
Premium letterhead and
stationery, including
matching envelopes
Covers, inserts, pocket
folders, menus
10. Supercalendered Paper
The 1988 paper procurement guideline did not address supercalendered paper, which was not
then available containing postconsumer or recovered fiber. Executive Order 12873 also did not
establish a content level for this paper. As explained in this subsection, this type of paper currently is
available containing postconsumer fiber.
Calendering is a process for pressing paper with rolls to create a smooth surface for printing.
In supercalendering, paper is passed between a series of hard and soft rolls to create a smooth, highly
glazed surface. Supercalendered paper is used for printing applications such as advertising inserts,
catalogs, mail order inserts, and some magazines. It often competes with a coated paper known as
lightweight coated groundwood in magazine publishing applications. (Coated papers are discussed
below in section V.C.)
In the past five years, magazine publishers have increased their use of supercalendered paper.
Manufacturers of supercalendered paper recently began using postconsumer fiber in their product to
meet demand from the magazine publishers. Supercalendered paper containing postconsumer fiber is
expected, to account for one-third of the supercalendered paper used by magazine publishers in 1995.
According to GPO, federal agencies are not currently using supercalendered paper. However,
because it competes with lightweight coated groundwood, which is used in some federal publications,
EPA anticipates that supercalendered paper could be used for federal printing applications in the
future. For this reason, EPA is adding a recommended content level for supercalendered paper in.the
draft RMAN. . . : . , . . .
There are three manufacturers of supercalendered printing papers. They currently are using
10% postconsumer fiber in some of their products. They are not able to use higher percentages of
postconsumer fiber at this time because they have found that higher percentages adversely affect the
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technical performance of the paper. Specifically/higher percentages affect the optical qualities of the
paper.
Based on this information, in section A-l of the draft RMAN, EPA recommends a content
level of 10% postconsumer fiber for this item. In EPA's table of recommendations, the content level
is displayed as 10% recovered fiber and 10% postconsumer fiber. This means that the total recovered
fiber content of supercalendered paper should be 10%, all of which is postconsumer fiber.
11. Safety Paper
"Safety" paper is used in the manufacture of commercial and government checks. The U.S.
Treasury Department specifies special properties for the safety paper used in federal government
checks and U.S. Savings Bonds in order to deter Counterfeiting and tampering. Treasury's paper
suppliers experimented with postconsumer fiber but were unable to produce a paper meeting
Treasury's requirements. Treasury officials informed EPA that they will continue to pursue use of
postconsumer fiber in safety paper, particularly for savings bonds. Executive Order 12873 did not
establish content levels for this type of paper.
EPA notes that check paper containing postconsumer fiber is available to commercial printers.
At least three manufacturers produce check safety paper containing 10% postconsumer fiber. Paper
containing higher levels of postconsumer fiber currently are not available and may not be available in
the foreseeable future for two reasons. First, there is limited availability of the grades of recovered
fiber that meet manufacturers' specifications. Second, checks are run through high-speed sorting
equipment, and the manufacturers report that higher levels of postconsumer fiber can lead to
increased jamming in the equipment. EPA encourages banks and commercial check printers to
purchase check safety paper containing postconsumer fiber and encourages mills to increase their
postconsumer fiber usage, if possible without affecting performance.
Based on this information, in section A-l of the draft RMAN, EPA is recommending a
content level of 10% postconsumer fiber for check safety paper. In EPA's table of recommendations,
the content level is displayed as 10% recovered fiber and 10% postconsumer fiber. This means that
the total recovered fiber content of check safety paper should be 10%, all of which is postconsumer
fiber.
It is EPA's intent that this recommendation be used by state and local government agencies
and by private sector purchasers of checks. As previously discussed, paper containing postconsumer
fiber currently does not meet federal specifications. EPA encourages the U.S. Treasury Department
to continue to work with its suppliers to develop safety paper containing postconsumer fiber for use in
federal checks and U.S. savings bonds.
EPA requests information on state agency requirements for the paper used to, print state
checks, including differences, if any, from federal and commercial check requirements. Further,
EPA requests information on the availability of paper containing recovered and postconsumer fiber to
meet the state agencies requirements.
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12. Summary of Recommendations for Uncoated Printing and Writing Papers
Table 10 displays the content recommendations found in the draft RMAN. It also summarizes
the terminology changes. ,'.'.'..
V . . . - ' .
Table 10. Uncoated Printing and Writing Papers
Revised or New Item
Reprographic Paper
Offset Paper
Tablet Paper
Forms Bond
Envelope Paper
' Wove
Kraft
White
Coiored
(including
manila)
, Unbleached
Cotton Fiber Paper, ,
Including Cotton Fiber
Envelopes
1988 Item
Mimeo and duplicator paper
Paper for high-speed copiers
Bond paper
Offset printing
Book paper
Bond paper
Office paper (e.g., note
pads)
Form bond including
computer paper and
carbonless* .
Ledger
Envelopes
Writing (stationery)
Ledger
Cotton fiber papers
The Content
Recommendation
Postcbnsumer
Fiber (%)
20
- '20
,20
2Q
20'
,
10-20 v
10-20
10 :
20
(including
postconsumer
textile fiber)
Recovered
Fiber (%)
20
20
20
20
20
«
10 - 20
10 - 20
- ' .'
10 '
50
(including
recovered
cotton and linen
fiber)
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Revised or New Item
Text & Cover Paper,
Including Matching
Envelopes
Supercalendered
Check Safety Paper**
1988 Item
Writing (stationery)
Book paper
Cover stock
,
The Content
Recommendation
Ppstconsumer
Fjber (%)
20 .
10
10
'Recovered
Fiber (%)
50
10
10
*Carbonless is now listed under coated papers.
**This recommendation is not intended for paper used in federal checks and U.S. savings bonds.
EPA encourages the U.S. Treasury Department to continue to work with its suppliers to develop
safety paper containing postconsumer fiber for use in these items.
C. Coated Papers
The 1988 paper procurement guideline did not differentiate between uncoated and coated
papers. Because some of the definitions (e.g., offset paper) referred to both coated and uncoated
papers, it was unclear whether the 50% waste paper recommendation applied to coated papers. Since
1988, mills have developed coated papers containing recovered fiber, including postconsumer fiber.
In addition, EPA found that some agencies are purchasing small quantities of coated paper.
Therefore, EPA is recommending content levels for coated papers in the draft RMAN.
1. Background
*
Coated papers consist of an uncoated base paper coated with pigments, clays, adhesives,
and/or other additives to provide improved gloss, slickness, color, printing detail, and brilliance to
the paper. The base paper can be either groundwood or freesheet. Coated groundwood papers
represented 54% of all U.S. coated paper shipments in 1992, while the remainder of coated papers
were freesheet.
Coated papers can be finished in gloss, dull, or matte finishes. They generally are used in
printing and publishing applications (e.g., annual reports, posters, brochures).
Coated papers are available in six grades, from Premium to No. 5, corresponding to the
brightness and basis weights of the paper. The heavier basis weight sheets (i.e., premium coated
papers and No. 1 - 3) are freesheet papers. Half of the No. 4 papers and all of the No. 5 papers are
groundwood papers. The federal government purchases primarily No. 1, No. 3, and No. 4 coated
papers, although No. 5 papers are used for some publications.
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Coatings are applied by rolls, air knives, or trailing blades. Blade coating, in particular, is
the predominant coating technology used in the U.S. During the blade coating process, a slurry of
clay-based coating is applied, and excess material is immediately scraped off with a blade which runs
extremely close to the sheet. Blade coating machines can run up to 5,000 feet per minute and can
coat both sides of the sheet simultaneously.
In addition to excess coating materials, the blade picks up any contaminants not previously
dissolved in the fiber cleaning process. Contaminants can stick to the blade and drag through the wet
coating to create scratch marks or streaks. Because coated papers are used for high-quality printing,
streaks or drag marks are unacceptable. In addition to being aesthetically displeasing, the scratches
can create weaknesses in the base paper, which can result in breaks either during the paper
manufacturing process or during high-speed printing operations.
Coated printing papers come in basis weights ranging from 28 lb. to 100 Ib. There are both
coated one-side (CIS) papers for labels, packaging, and covers, and coated two-side (C2S) papers for
book, publication, and commercial printing. The lighter weight sheets, particularly lightweight coated
groundwood sheets, are used primarily for high volume, four-color publications, including magazines,
newspaper inserts and supplements, catalogs, advertising packages, and flyers.
2. Use of Recovered Fiber ,
During the past several years, paper mills began to use. recovered fiber, including
postconsumer fiber, in the production of coated printing papers. Due to the nature of the
manufacturing process and printing performance requirements, it is necessary that the pulp used in
coated paper base sheets contain high-quality, consistent materials. In the past, mills had reported
problems with sheet cleanliness, dirt, and brightness, and with contaminants on the blade coater when
using postconsumer fibers. As the quality of deinked pulps have improved, however, mills have been
able to use 10% or more postconsumer fiber in their coated paper products.
Mills use varying amounts of postconsumer fiber, depending on pulp availability, economics,
and the basis weight of the sheet being manufactured. In a coated sheet, coatings can account for 25-
35% of the basis weight of the sheet. As a result, the base sheet is thinner than the finished sheet,
and the fibers used to produce it must be relatively strong. For example, a typical 40 lb. lightweight
coated groundwood sheet contains a 28 lb. basis weight uhcoated base sheet. This means that the
base sheet must have the proper fiber mix to retain sheet strength. Long, consistent fibers are
necessary to m'aintain the strength of the paper both on the manufacturing equipment and on high-
.speed printing equipment. .
While base sheet strength is a concern in all coated sheets, it is particularly critical in lighter
weight sheets. In order to maintain consistency from one lot to another, the fiber characteristics must
be the same from batch to batch. The use of high percentages of postconsumer fiber introduces
inconsistent fibers, which can weaken the base sheet.
During the past three years, partly due to demand from private sector "customers such as
magazine and catalog publishers and direct marketers, mills have gained experience using
'-:' . 54 - ' - .''''.".'
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postconsumer fiber. Magazine publishers purchase over 50% of the No. 4 and No. 5 grades of
coated paper. They have been increasing their use of lighter weight papers containing recovered fiber
depending on the availability and price of these products.
The major manufacturers of coated papers containing postconsumer fiber informed EPA that
they have recently experienced a deterioration, nationwide, in the quality of recovered paper. As a
result they have found an increase in down-time due to streaks, holes, and breaks in the paper (web
breaks), as well as a 4 - 6% increase in the quantity of paper rejected at the end of the papermakmg
process.
Currently all 19 U.S. companies that manufacture coated.papers produce at least one line of
coated papers containing recovered fiber. Most of these papers are in basis weights of 38 Ib. or
greater and are coated freesheet papers, not coated groundwood papers. Supplies of this paper are -
limited, however. In 1993, coated freesheet papers containing postconsumer fiber accounted for only
350,000 tons out of the 3.9 million tons supplied.
Every domestic "recycled" coated paper contains at least 10% postconsumer fiber: The
"recycled" content papers tend to cost more than competing papers made with virgin fibers. The
lighter weight sheets (basis weight of 38 Ib. or less) typically contain 10% postconsumer fiber. While
some of the heavier basis weight coated papers now contain up to 15% postconsumer fiber with one
mill producing heavier weight coated papers containing up to 30% postconsumer fiber, only 5,000
tons of lightweight coated paper containing 15% or more postconsumer fiber was manufactured in
1994 All of it was used by magazine publishers. Manufacturers informed EPA that they will not
produce significantly increased quantities of coated paper containing 15% postconsumer fiber because
of the increased levels of contamination that they are finding in recovered paper supplies.
Based on this information, EPA concludes that it is unlikely that coated papers containing
more than 10% postconsumer fiber will be available at this time in appreciable quantities or at
competitive prices. For this reason, in section A-l of the draft RMAN, EPA recommends a 10%
postconsumer content level for coated papers. In EPA's table of recommendations, the content level
is displayed as 10% recovered fiber and 1.0% postconsumer fiber. This means that the total recovered
fiber content of coated papers should be 10%, all of which is postconsumer fiber.
EPA will monitor the availability of coated papers containing higher levels of postconsumer
fiber and increase the recommended content level in the future, as appropriate.
3. Carbonless Paper ' . ,
In the 1988 paper procurement guideline, EPA included carbonless paper with forms bond.
EPA did not recommend a content level for carbonless paper in 1988, but subsequently issued an
advisory notice recommending a 50% waste paper content level.
Carbonless paper is used in the production of multiple impact copy forms. The paper
contains special coatings and/or encapsulation on the back of the top sheet (coated back or CB) and
55
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front of the bottom sheet (coated front or CF) in a two-part form. In multi-part forms,; some of the
sheets are coated on the front and back (CFB).
- Executive Order 12873 establishes a 20% postconsumer content level for carbonless paper.
In section A-l of the draft RMAN, EPA incorporates this content level. In EPA's table of
recommendations, the content level is displayed as 20% recovered Tiber and 20% postconsumer fiber.
This means that the total recovered fiber content of carbonless papers should be 20%, all of which is
postconsumer fiber.
4. Summary of Coated Paper Recommendations
Table 11 summarizes the coated paper recommendations.
Table 11.-Recommended Coated Paper Content Levels
Item
/
Coated Printing Papers ,
Carbonless
Postconsumer Fiber (%) , ,
,-10%
20%
D. Bristols
EPA has received numerous inquiries about the appropriate recovered fiber content standards
for products such as greeting cards and file folders. The paper grade used to make these items is
generally known as "bristols" within the paper industry.
1, Background
' Bristols account for only a small portion (3%) of U.S. paper production. Federal government
purchases of bristol products such as file folders and index paper constitute a significant percentage of
all federal paper purchases, however. Between July 1, 1989 and December 3, 1990, purchases of file
folders and index paper accounted for about 9% of all paper purchases by GSA.
*> , -' , ' ' ' '. ' - . .-.'"
"Bristols" is a generic term for a heavy-weight class of paper. Bristols can be classified as
either printing and writing papers or paperboard, depending on the thickness, end use, and type of
paper machine used to produce them. The differences in the manufacturing process and ultimate end
use determine how much postconsumer and other recovered fiber can be used in them.
The 1988 paper procurement guideline included general definitions of "paper" and
"paperboard," which distinguished between them based on their thickness (caliper). The definition of
"paperboard" states, in part, that sheets that are 0.012 inch /12 pt.) or more in thickness are generally
classified as paperboard. The 1988 guideline did not specifically address bristols, which created
confusion about the appropriate minimum content level to use for these items. Based on their varying
. . ' . '.""56 ' '
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thicknesses of 6 pt. to 36 pt., bristols straddle the line between printing papers and paperboard. This
distinction is significant because, in the 1998 paper procurement guideline, EPA recommended a 50%
waste paper level for printing and writing papers and an 80% postconsumer'materials level for
recycled paperboard.
2. Definition .
There is no universally accepted definition of the term "bristoi." AF&PA defines a category
known as "solid bleached bristols" as a "class of heavy-weight papers used primarily for graphic
communications, for business, office, and school supplies. End uses include such items as advertising
pieces, soft bound book covers, -greeting cards, menus, file folders, note cards, and baggage tags."
For statistical purposes, AF&PA further defines printing and writing bristols to include tabulating
index, tag and file folder, coated cover bristols, and uncoated bristols (index, printing, and postcard).
AF&PA considers other bristols to be paperboard for statistical purposes.
Paper merchants use the term bristoi to refer to a specific end-use for a grade of heavy-weight,
paper. Examples are "wedding bristols" and "vellum bristols." Paper manufacturers often use the
type of paper machine on which a grade is produced to determine its classification as either printing
and writing paper or paperboard. For example, CIS (coated one side) bristol/cover is produced on a
Fourdrinier machine and is classified under, printing and writing papers. Railroad board and similar
items, while similar in thicknesses and appearance to CIS, are grades produced on cylinder machines
and are considered to be paperboard grades. "
Rather than trying to resolve the question of the appropriate definition of bristols, EPA
concludes that the best approach to recommending recovered and postconsumer fiber content levels
for this grade is to list individual items commonly procured by government agencies. These items are
used in printing and office products applications, so they will be added to the list of printing and
writing papers for which EPA recommends content levels. This approach is consistent with industry
practice of using product application as a criterion for categorizing bristols.
3. Content Levels
Bristols produced on papermaking machines that typically run at high velocities and produce
paper in high volumes can accommodate only limited amounts of postconsumer fiber, for the same
economic, technical, and product quality reasons that apply to other commodity grade printing and
writing papers. Bristols produced on'papermaking machines that produce multi-ply papers can handle
higher postconsumer content because these fibers are contained in the inside plies.
Items made from bristols include manila file folders, dyed filing products (e.g., red accordion
files and hanging file folders), index and postal cards, pressboard report covers, pressboard binders,
and tags and tickets. .
a. File folders. This category includes both manila folders and brightly-colored file folders.
Executive Order 12873 establishes a 20% postconsumer content level for file folders. In section A-1
Of the draft RMAN, EPA incorporates this content level. In EPA's table of recommendations, the
' 57 -
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content level is displayed as 20% recovered fiber and 20% postconsumer fiber. This means that the
total recovered fiber content of file folders should be 20%, all of which is postconsumer fiber.
EPA research indicates that there are technical difficulties in using high levels'.of
postconsumer fiber in file folders, which may result in limited availability of file folders containing
20% postconsumer fiber in the immediate future. In particular, mills report the need for adequate
fiber bonding and strength and for consistent pulp to meet shade and cleanliness requirements. Fiber
bonding and strength are very important in file folder grades because the fibers must withstand
repeated folding and unfolding without breaking (tearing) during file folder handling. File folders
generally are made with virgin softwood kraft fiber, and displacing it with recovered fiber could
adversely affect fold, burst, and tensile strength.
As a result, procuring agencies might find limited availability of file folders containing 20%
postconsumer fiber in the short-term. Based on past history with manufacturers' response to the
Agency's recommendations, however, EPA believes that the content levels established by the
Executive Order .will foster increased availability of file folders containing higher levels of
postconsumer fiber.
b. Dyed filing products. Items such as red wallets and hanging folders are dyed. By
contrast, brightly colored file folders are printed with' colored inks. The pulps used to produce dyed
filing products must have a high kraft content to impart the strength, stiffness, and fold characteristics
required for the end use. Because the products are dyed, however, the manufacturers do not require
as "clean" a mix of postconsumer fiber as do manufacturers of mariila file folders. For this reason,
EPA believes that dyed filing products should contain the same minimum percentage of postconsumer
fiber as file folders. While EPA has only limited information on dyed filing products, the Agency is
aware that some manufacturers are producing these products containing up .to 50% total recovered
fiber.
Based on this information, in section A-l of the draft RMAN, EPA recommends content
ranges for dyed filing products of.20 - 50% recovered fiber, including 20% postconsumer fiber.
c. Index and card stock. The Federal government purchases a high volume of index and
postal card stock. For example, GPO reported that between July 1992 and July 1994, it purchased
3.5 million sheets of index stock and slightly over 13 million sheets of U.S. postal card stock.
Between July 1989 and December 1990, GSA purchased over $4 million worth of index paper
products.
Manufacturers of index stock have been able to use higher levels of recovered fiber, including
postconsumer fiber. At least three manufacturers produce index stock containing 50% recovered
fiber, including 10% postconsumer fiber. One manufacturer uses 50% recovered fiber, including
20% postconsumer fiber. A cotton fiber mill produces index stock containing 50% recovered fiber,
including 15% postconsumer fiber. No manufacturers indicated that there are technical constraints to
increasing postconsumer content to 20% or that ranges of postconsumer or recovered fiber in these
products. ,
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Based on this information, EPA believes that index and card stock can be produped containing
50% recovered fiber, including 20% postconsumer fiber. In section A-l of the draft RMAN, EPA is
recommending this content level for index and card stock.
Although EPA's recommendations are intended for government agencies, EPA recognizes that
greeting card manufacturers developed product lines containing postconsumer and recovered fiber in
response to the 1988 paper procurement guideline. The manufacturers requested that EPA (1) clarify
that bristols used in greeting cards fall under printing and writing paper, rather than paperboard, and
(2) recommend minimum content standards for their products. EPA agrees.that the bristols used in
the manufacture of greeting cards are properly considered to be printing and writing papers.
As far as EPA knows, government agencies do not typically purchase greeting cards:
Because it is conceivable that they could purchase these products, EPA would like to add
postconsumer and recovered fiber content recommendations for greeting cards. EPA notes that
greeting card manufacturers have been able to produce cards containing 50% recovered fiber,
including 10% postconsumer fiber. EPA is unaware of any performance constraints that would
preclude greeting card manufacturers from using 20% postconsumer fiber. However, EPA lacks
current research on greeting card manufacturers ability to use paper containing higher levels of
postconsumer fiber. For this reason, EPA is not recommending content levels for greeting cards in
the draft RMAN. EPA requests comment on the performance and availability of greeting card stock
containing higher percentages of postconsumer fiber.
d. Pressboard. In the April 20, 1994 CPG, EPA proposed to designate binders. EPA noted
that chipboard and other paperboard binders are covered by the paper procurement guideline (59 FR
18880). Commenters requested that EPA clarify that pressboard and chipboard are two different
products and that different content levels should be used for pressboard, chipboard, and other
paperboards.
Pressboard is a high-strength paperboard that is laminated in several plies to form a stiff,
strong product used in the manufacture of office products such as binders and report covers.9 It is a
different product from chipboard, which is a low density, solid or lined paperboard that is used in
low-strength applications.
Pressboard used for binders and report covers is aesthetically and functionally different from
chipboard because it is not covered with cloth or plastic. > The pressboard performs the hinge function
while at the same time providing the aesthetic attributes appropriate to its function as a binder cover.
By contrast, chipboard is used as filler and is covered by cloth or plastic, which provide the hinging
function. : '
Although pressboard is made, in a similar papermaking process as other paperboards, it is a
thinner product more like bristols than paperboard. Additionally, it shares performance
"Pressboard is also used in construction and insulation applications. These applications are
addressed as laminated paperboard in EPA's April 20, 1994 CPG and companion RMAN.
59
*»»
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characteristics with printing papers because printing can be applied to it. For these reasons, EPA is
providing recommendations for pressbqard in the printing and writing category, rather than in the
paperboard category. (Chipboard was discussed in chapter IV.)
At least three manufacturers produce pressboard. Only one manufacturer provided .
information to EPA on the recovered fiber content of its products. This manufacturer uses 50%
recovered fiber,, including 25 - 30% postconsumer fiber. The manufacturer commented, however,
that higher postconsumer content levels wbuld affect the aesthetic and strength characteristics of their
product. EPA has no technical information indicating that this content level is infeasible for the other
manufacturers of pressboard. Therefore, in section A-l of the draft RMAN, EPA recommends a
content level of 50% recovered fiber, including 25 - 30% postconsumer fiber, for this item.
e. Tags,and tickets. Tag and ticket grades are available from at least four mills with
postconsumer fiber content ranging from 10 to 20%. Three of the four offer a product containing
20% postconsumer fiber. Only one manufacturer uses recovered fiber (at a 50% level) in addition to
postconsumer fiber. Based on this information, in section A-l of the draft RMAN, EPA is
recommending content levels of 20 - 50% recovered fiber,'including 20% postconsumer fiber for tags
and tickets.
f. Solid unbleached sulphate. Another type of bristol, often referred to as solid unbleached /
sulphate (SUS), is considered to be a packaging product by the paper industry, although it can be
printed when used in packaging. SUS was addressed in chapter IV. ;
4. Summary of Bristols Recommendations .'..-':,'
Table 12 summarizes EPA's recommended content levels for printing and writing bristol
productSi EPA recommends that procuring agencies establish minimum content standards for bristols
consisting of a percentage of recovered fiber, including a percentage of postconsumer fiber. For
some items, these percentages will be the same. For example, for mahila file folders, a procuring
agency can express the standard as 20/20 (meaning 20 recovered fiber, all of which is postconsumer)
or simply as 20% postconsumer fiber.
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Table 12. - Recommended Printing and Writing Bristols Content Levels.
Item
File folders (manila and colored)
Dvad filing products
Cards (index, postal, and other, including index
sheets)
Pressboard report covers and binders
Tag:, and tickets
Postconsumer Fiber
(%)
20
20
20
25-30
- '20
Recovered Fiber
(%)
20
20 - 50
50
50
20 - 50
E. Summary of Request for Comments on Recommendations for Printing and Writing Papers
EPA requests comment on each content level recommendation for printing and writing papers
discussed in this chapter, with the exception of the content levels established by Executive Order
12873. In this chapter, EPA also requested comment or information on the following issues:
o State agency requirements for the paper used to print state checks, including
differences, if any, from federal and commercial check requirements.
o The availability of safety paper containing recovered and postconsumer fiber to meet
the state agencies requirements.
o The performance and availability of greeting card stock containing higher percentages
of postconsumer fiber.
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VI. OTHER ISSUES , ' ,:
In addition to the inquiries about content levels for specific products that were discussed in the
previous chapters, EPA has received inquiries about the following issues: (1) whether postconsumer
and recovered fiber content should be measured as a percentage of fiber weight or total sheet weight,
(2) whether mill broke generated by a papermaking process that uses postconsumer or recovered fiber
can be included in content calculations, (3) whether the definition of "postconsumer" includes
printers' over-runs, converters' scrap, and/or over-issue publications, (4) which definition of
"recovered, materials" applies to the content standards established in Executive Order 12873, and (5)
whether 'a paper product converted from off-specification paper or obsolete inventory contains
"recovered material." In addition, several commenters suggested that EPA expand the definition of
"mill broke" and narrow the definition of "waste paper." EPA addresses these issues in the following
subsections. > : '' - '.
A. Measurement of Recovered Fiber Content '
1. Fiber Weight vs. Total Weight -
. " > '-!-, , .
Postconsumer ahd recovered materials content can be measured in two ways; (1) as a
percentage of the total weight of all materials used in a paper or paper product, or (2) as a percentage
of the weight of the fiber used in the paper or paper product. The 1988 paper procurement guideline
did not recommend a method for measuring recovered fiber content. In response to a 1989 inquiry
from the Joint Committee on Printing, EPA stated that content should be measured as a percentage of
the fiber weight of the paper. Since then, GSA and GPO have been using the fiber weight method to
determine content. Because some states and the Canadian EcoLogo program require total weight
calculations, however, some mills remain uncertain about the appropriate approach. In the draft
RMAN, EPA's recommended content ranges are expressed by fiber weight. In addition, in section
A-6 of the draft RMAN, EPA recommends that procuring agencies establish percentages of
postconsumer and recovered fiber content using the fiber weight method.
A measurement protocol based on total weight presumes that all of the materials used to make
paper or a paper product can be recovered and accounted for in recovered content measurements. In
addition to cellulose fiber, non-cellulosic materials such as clay, calcium carbonate, moisture, dyes,
and starches are sometimes used in varying amounts to produce paper. The amount,and type of
coatings, fillers, and other materials depend on the paper's end use and the chemistry (acid versus
alkaline) of the manufacturing process. Fiber, however, is the predominant ingredient in paper and .
currently is the primary recovered resource of high economic value. Paper processing and deinking
technologies are designed to recover and reuse the fiber fraction of paper. While it may be
technically possible to recover clay, water, and the other ingredients of paper, currently such practices
are not commercially viable in the U.S. .
These technical factors make it nearly impossible, using the total weight approach, to certify a
paper or paper product as containing 100% recovered fiber even when the only fiber used in the
production of the item is recovered fiber. More importantly, a total weight measurement makes it
unnecessarily complicated to compare any two grades of paper or paper products because of the
62 . ' .''
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differing amounts of non-cellulosic material they may contain, even if they both use precisely the
same type and amount of recovered fiber and are intended for the same end use. This could lead to
unintended adverse impacts on waste generation. For example, if a procuring agency uses a heavier,
uncoated paper, rather than a thinner, coated paper for a printing application, a greater, volume of
waste will be generated (assuming that the printed product is discarded).
* *
For these reasons, EPA recommends that procuring agencies use the fiber weight method of
calculating postconsumer and recovered fiber content. This method accounts only for the fiber and
does not consider the coatings, fillers, and other materials used in the manufacture of paper. EPA
believes that the fiber weight method provides a uniform approach for accounting for postconsumer
and recovered fiber content in all papers and paper products, regardless of the manufacturing process
used and the inclusion of other materials in the sheet. .
2. Recovered Fiber Component of Mill Broke
In the 1988 paper procurement guideline, EPA defined "mill broke" as any paper waste
generated before the completion of the papermaking process. Because RCRA section 6002(h) defines
"recovered materials" as materials generated after the completion of the papermaking process, EPA's
1988 definition of "mill broke" stated that this material cannot be counted toward recovered materials
content.
Since then, mills have inquired whether mill broke generated in a papermaking process that
uses postconsumer or recovered fiber can be included in content calculations. Other commenters
suggested that mill broke that contains postconsumer or recovered fiber should be counted. The 1988
guideline did not address this issue.
The mills and other commenters stated that there are two types of mill-broke to consider:
mill broke generated in a papermaking process using only wood-based pulp and mill broke generated
in a papermaking process using pulp made with some or all postconsumer or recovered fiber. The
mills suggested to EPA that broke generated in a process.using postconsumer or recovered fiber as
feedstock should be considered differently from broke generated by a mill using only wood-based
fiber. EPA agrees that such material should count toward "postconsumer fiber" or "recovered fiber"
content, although only to the extent that the feedstock contains materials which would qualify as
postconsumer or recovered fiber.
All paper mills generate small percentages of mill broke, and this material is commonly
repulped. For this reason, use of mill broke does not remove materials from solid waste, and mill
broke ordinarily is not considered to-be a recovered material. If broke is generated in a papermaking
process that uses postconsumer or recovered fiber for feedstock, however, but cannot be counted
toward postconsumer or recovered fiber content, then the mill will not be able to account for all of
the postconsumer and recovered fiber actually used as feedstock. EPA believes that such an outcome
is illogical and presents an unnecessary obstacle to the manufacture of paper and paper products
containing postconsumer or recovered fiber. Therefore, in section A^6 of the draft RMAN, EPA
recommends that procuring agencies permit mills to count mill broke generated in a papermaking
process using postconsumer and/or recovered fiber as feedstock toward "postconsumer fiber" or
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"recovered fiber" content, to the extent that the feedstock contained these materials. In other words,
if a mill uses less than 100% postconsumer or recovered fiber, only a proportional amount of broke
can be counted towards postconsumer <>r recovered fiber content.
The following examples illustrate how mill broke should be counted:'
. ^ ,
o ' A newsprint manufacturer uses 100% postconsumer old newspapers (ONP) as
feedstock and generates some mill broke, which is returned to the manufacturing
process. All ofthe mill broke can be counted as postconsumer fiber.
o A manufacturer of printing and writing papers uses pulp containing 50% recovered
fiber (none of which is postconsumer fiber) and generates 100 pounds of broke.
" Because recovered fiber constituted half of the pulp, only half of the broke (50
.pounds) should be counted as recovered fiber. In addition, because no postcpnsumer
fiber was used, the'broke cannot be counted as "postconsumer fiber."
B. Clarifications and Revisions to Definitions \
1. "Postconsumer Fiber" : .
EPA has been asked whether the definition of "postconsumer" includes printers' over-runs,
converters' scrap, and/or over-issue publications. EPA notes that the definition of "recovered
materials" in RCRA section 6002(h) differentiates between "postconsumer materials" and materials
generated by manufacturers and others, including converters, printers, wholesalers, and retailers. As
a result, items such as printers' over-runs, converters' scrap, arid over-issue publications are not,
considered to be postconsumer materials and cannot be counted toward meeting postconsumer fiber
requirements. , -
.In .section A-7 of the draft RMAN, EPA is using the definition of "postconsumer" found in
RCRA section 6002(h) as the definition of "postconsumer fiber." EPA is adding a clarifying
statement that fiber derived from printers' over-runs, converters' scrap, and over-issue publications is
not postconsumer fiber.
' v "''' i ' ' i.
2. "Recovered Materials" Definitions
RCRA contains two definitions of "recovered materials." RCRA section 6002(h) provides a
specific definition of "recovered materials" to be used when purchasing paper products. RCRA
section 1004 contains a more general definition of "recovered materials" that applies to other
procurement items. Because Executive Order 12873 includes the general definition of "recovered
materials" found in RCRA section 1004, but not the more specific "recovered materials" definition
found in RCRA section 6002(h), procuring agencies and paper mills have asked EPA about which
definition of "recovered materials" applies to the paper content levels in the Executive Order.
. \ ,
The Executive Order is a management directive to federal executive agencies. As such,
agencies should implement its provisions consistently.with applicable federal law. Therefore, federal
' 64 . ''
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agencies and manufacturers should note that the specific definition of "recovered materials" found in
RCRA section 6002(h) is the applicable definition to be used for purposes of implementing the content
levels listed in Section 504(b) of the Executive Order. .
Procuring agencies and manufacturers also should note that, as used in Section 504(b) of the
Order, the term "recovered materials" is synonymous with "recovered fiber" as used in the draft
RMAN. It includes postconsumer materials and certain preconsumer materials. Thus, the definition
of "recovered fiber" found in the draft Paper Products RMAN should be used when purchasing the
paper products for which section 504(b) specifies a minimum percentage of "recovered materials."
Procuring agencies and manufacturers also should note that section 504(c) of Executive Order
12873 provides an alternative content standard for paper products containing a specific subset of
industrial byproducts. The term "recovered materials," as found in section 504(c), should only be
used when purchasing printing and writing paper meeting this alternative standard.
3. "Mill Broke"
In the 1988 paper procurement guideline, EPA defined "mill broke" as follows:
"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 materials."
Several groups suggested to EPA that the mill broke definition should be expanded to include
certain materials that are generated after the completion of the papermaking process, including
materials generated in finishing operations. These materials are commonly re-pulped, sold to others
for pulping, or otherwise used in or converted to paper products. The comnienters argued that
allowing these materials to count toward recovered fiber content neither provides an incentive for
mills to use materials diverted or recovered from the waste stream nor provides an incentive for mills
to invest in the capability to use materials that must be cleaned, deinked, or processed prior to use.
EPA agrees with the commenters that allowing these materials to count toward recovered fiber
content does not provide an incentive for mills to use materials recovered from solid waste and,
therefore, does not meet the RCRA objective of increasing markets for postconsumer materials. For
this reason, EPA believes that these materials should no longer be included in the definition of
"recovered materials." In section A-7 of the draft RMAN, EPA is using the following new definition
of "mill broke:"
"Mill broke" means any paper or paperboard scrap generated in a mill prior to
completion of the papermaking process and/or specific materials generated during
finishing operations that occur after the end of the papermaking process. It includes
the following materials, whether generated prior to or after the completion of the .
papermaking process: paper machine trim, offgrade or off-specification rolls (also
referred to as rejected, unused stock), culls, stub rolls, side rolls, end rolls, and
obsolete inventories of paper and paperboard. Although mill broke is occasionally
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sold from one mill to another, such a sale does not alter its classification or exclusion
from the definition of "recovered fiber." , ,
This new definition identifies materials that will be considered to be mill broke, regardless of
whether they are generated before or after the end of the papermaking process. It also clarifies that a
sale of these materials does not change them into "recovered materials."
The specific materials identified in the'new "mill broke" definition are paper machine trim,
offgrade or off-specification rolls, culls, stub rolls, side rolls, end rolls, and obsolete inventories of
paper and paperboard. Some of the materials clearly are generated prior to the end:of the
papermaking process, such as trim and rejected stock. Others can be generated either before or after
the completion of the papermaking process. Examples of these latter materials are off-grade or off-
quality paper, side rolls, and obsolete inventory. ' . _
Off-grade or off-quality paper has a quality variation which renders it unsuitable foi: sale as
the grade of intended manufacture. EPA has learned that it is frequently sold as a lower grade or as a
job lot. Job lot paper contains a defect which the intended customer would find objectionable. This
grade is usually sold by a seconds dealer at a lower price, and the purchaser is told of the defect.
Side rolls are narrow rolls of paper which are created when paper the width of the paper machine reel
is cut into the specific widths ordered by the customer. EPA has been informed that most side rolls
have commercial value and are sold as first quality rolls of paper, although some side rolls are treated
as off-grade, job lot, or obsolete inventory. Obsolete inventory is finished paper stocked by a mill or
merchant which has become unsellable because of changes in trade conditions or because of age.
EPA requests comment on the revised "mill broke" definition.
4. "Recovered Fiber" : . ,.
As explained in section I.D.I, EPA is substituting the term "recovered fiber" for the term
"waste paper" used in the 1988 paper procurement guideline. Like "waste paper," "recovered fiber"
consists of fibers from postconsumer materials, preconsumer materials that require cleaning or
processing, and certain other unprinted, relatively clean materials generated after the end of the
papermaking process.
The term "recovered fiber" is a more appropriate description of the materials used than is
"waste paper." Because these recovered materials have value as a feedstock for pulp and
papermaking, the Paper Recycling Coalition, an industry group, suggested to EPA that it is more
appropriate to refer,to them as "recovered" rather than as."waste." EPA agrees that perception of
these materials is important to general acceptance of paper and paper products made from them. EPA
believes that these materials will gain wider acceptance as a fiber source when mills, paper specifiers,
paper purchasers, and end users stop viewing them, and paper made from them, as <"trash,"
"garbage," or "waste." ,'
In addition to the name change, EPA is making three significant revisions to the 1988 "waste
paper" definition. First, the definition found in section A-7 of the draft RMAN clarifies that
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materials must be repulped, not just recovered, in order to count toward recovered fiber content. Job
letters and others asked EPA whether obsolete inventory or off-specification paper containing no .;
recovered fiber could be converted into products such as writing tablets and sold as recycled products.
While EPA believes that this practice is consistent with the Agency's goals of promoting diversion of
materials from solid waste, these products are not made from paper containing fibers recovered from
recovered materials and, therefore, do not meet the statutory definition of "recovered materials."
Second, consistent with the revised definition of "mill broke," the definition of "recovered
fiber" excludes'materials such as obsolete inventory or off-specification product generated at mills
after the end of the papermaking process.
Third, EPA is clarifying that forest residues do not count toward "recovered fiber" content.
Because the introductory phrase to subsection (2) of the 1988 waste paper definition contains the
words "forest residues," it was not clear whether the use of forest residues could be counted toward
"waste paper" content. It was not EPA's intent that forest residues count toward "waste paper"
content. In the draft RMAN, the words "forest residues" are deleted from the introductory phrase to
subsection (2) in order to clarify that fiber derived from these materials are not counted toward
recovered fiber content.10
Table 13 summarizes which materials can be counted toward "recovered fiber" content under
the new definition. .
10 Section 504(c) of Executive Order 12873 provides an alternative standard for uncoated printing
and writing papers made from materials such as sawdust. This provision is discussed in section VI of
this document.
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Table 13.. Materials in Recovered. Fiber Definition
, . Material
Postconsumer
Envelope cuttings
Bindery trimmings
Mills' obsolete inventory
Converting scrap
Printers scrap
Side, trimmings
Gull
End rolls
Mills' stub rolls
Butt rolls
Mills' rejected, unused stock
Counts Toward Recovered Fiber
' . v ' ₯'.- ; '
' Y
.'.-' Y ' :
' N ..'.--
-'-" Y ', ,- : . ..
Y" .. . .'
'-,.'. N '
".'" N , ; ' . ::
' N ' '',''
! N ''.'
' . ;.'' " ' .N . -..
'..-.- N
Following is the revised "recovered fiber" definition:
"Recovered fiber" means the following materials:
(1) Postconsumer fiber such as:
(A) 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
(B) All paper, paperboard, and fibrous wastes that enter and are collected from
municipal solid waste.
(2) Fiber derived from printing and converting operations, excluding any paper
generated in a paper mill prior to the completion of the paper manufacturing process. .
"Recovered fiber" includes repulped fiber from dry paper scrap generated after the
paper machine reel has been rewound and/or cut into smaller rolls or rough sheets,
including but not limited to:
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(A) Envelope cuttings, finishing trim, bindery trimmings, and other paper and
paperboard resulting from printing, cutting, forming, and other converting operations;
and bag, box, and carton manufacturing wastes; and
(B) Repulped finished paper and paperboard-from obsolete inventories of paper
m;!-. hints, wholesalers, dealers, printers, converters, or consumers.
EPA requests comment on this definition.
C. Recyclability
The underlying purpose of RCRA section 6002 is to use the stimulus of governmental
purchasing to foster markets for recovered materials. Therefore, EPA encourages materials recovery
to conserve valuable natural resources and to provide alternatives-to landfillmg and incineration. In
order to achieve both of these objectives, EPA believes that procuring agencies should consider the
impact of purchases on their recyclables collection programs. ;.'
Depending on their fiber or other characteristics, some paper products containing
postconsumer or other recovered fiber may have a wider variety of potential markets and, therefore,
may be easier to recycle than others. Certain characteristics can lower the value of collected paper or
limit its reuse as a feedstock for new products. Other characteristics might require adjustments in an
agency's collection program.
For example, office white paper is a highly valued recovered material. Depending on its
market an office white paper collection program might exclude other office papers that are colored,
coated,'or contain groundwood. Thus, if a procuring agency decided to purchase a colored paper or
a paper containing groundwood for office use, the agency should expect that these materials would
affect the office white paper collection program. The agency could find that the paper is recyclable,
but that (1) the value of the recovered paper is reduced because it is now mixed paper rather than
white office paper, or (2) a separate sort is required in order to maintain the value of the white office
paper. Alternatively, the agency could find that the paper must be disposed of because there is no
market for it in the geographic area in which the agency is Located.
Yet other characteristics might make a paper product more recyclable or generate less
material because the product is source reduced. For example, manufacturers may be using less
packaging or reusable packaging, resulting in less waste.
EPA believes that procuring agencies should consider these impacts prior to purchasing paper
products containing postconsumer or other recovered fiber. Therefore, in section A-6 of the draft
RMAN EPA is recommending that procuring agencies consider the effect of their procurement
actions on their paper collection programs by assessing the impact of their decisions on their overall
contribution to the solid waste stream.
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D. Use of EPA's Recommendations
EPA encourages state and local agencies and private sector purchasers to use the
recommendations in the draft RMAN when purchasing paper and paper products. EPA recommends
that purchasers establish their minimum content standards at the highest percentages available to them,
even if'these standards are above EPA's recommended ranges. *
s : _ :
EPA has found that some state agencies have been using the Agency's 1988 content
recommendations as a starting point in establishing product labeling requirements. While EPA's
recommendations were not intended for use as labeling standards, they can be used as an information
source for agencies establishing recycled product labeling programs.
EPA cautions persons using the Agency's recommendations, whether to establish purchasing :
specifications or labeling standards, to .use them only for the specific items for which they were
intended. It is not appropriate to analogize from one item in a paper grade (e.g., printing and writing
paper, tissue products, paperboard) to another item that could also fall within that grade, without first
researching the use of postconsumer and recovered fiber in the other item. The two items could have
different performance requirements necessitating different levels of postconsumer or recovered fiber.
In addition, one item could be made primarily by mills that use high percentages of postconsumer or
recovered fiber, while the other item could be made primarily by mills that use low or no percentages
of this fiber. ?
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VII. SUPPORTING INFORMATION
EPA used the following reports and other information in developing the draft
recommendations for paper and paper products. EPA placed these documents in the RCRA docket
under docket number F-95-PPRN-FFFFF. . . ,
General -
"1994 Statistics of Paper, Paperboard, and Wood Pulp," American Forest & Paper Association,
September 1994, Tables II, III, IV, VII, and VIII.
"Paper, Paperboard, Pulp Capacity, and Fiber Consumption, 1992 - 1996," American Forest & Paper
Association, December 1993, p. 26.
"Final Report on Recycled Paper Definitions, Standards, Measurement, Labeling Guidelines, and
Buy-Recycled Initiative," Recycling Advisory Council, February 6, 1992.
"Summary of Public Comments Submitted to U.S. EPA in Response to 10/3/90 Federal Register
Notice on the Paper Procurement Guideline," prepared for U.S. EPA by E.H. Pechan & Associates,
Inc., January 31, 1991.
"Research on Costs to Track Postconsumer Materials in Recycled Paper," Revised Draft Report,
prepared for U.S. EPA by E.H. Pechan & Associates, Inc., June 1993.
Newsprint
"Meeting U.S. Newspaper Publishers' Recycled Content Purchasing Goals: An Analysis of
Availability," presentation by Michael Alexander, Northeast Recycling Council, before the Newspaper
Association of America, April 27, 1993.
Tissue Products
"Commercial Sanitary Tissue Product Research," Revised Draft Report, prepared for U.S. EPA by
E.H. Pechan & Associates, Inc., December 1991.
"New recycled tissue products court consumer markets," Paper Recycler, Vol. 4, No. 11, November
1993.
"Supplementary Sanitary Tissue Research," Final Draft, prepared for U.S. EPA by Eastern Research
Group, Inc., August 26, 1994. ,
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. Paperboard and Packaging
"Recycled Paperboard Research," Final Draft, prepared for U.S. EPA by E.H. Pechan & Associates,
Inc., October 1991.
"Supplementary Paperboard Research," Final'Draft, prepared for U.S. EPA by Eastern Research
Group, Inc., September 9, 1994. ,
Letter to Dana Arnold, Office of Solid Waste, U.S. EPA, from Terese Colling, Washington
Representative, Paper Recycling Coalition, November 9, 1994. '
"Containerboard Research," Revised Draft Report, prepared for U.S. EPA by E.H. Pechan &
Associates, Inc., March 1992.
"Supplementary Containerboard Research," Final Draft, prepared for U.S. EPA by Eastern Research
Group, Inc., August 31, 1994.
Printing and Writing Papers
Uncoated Printing and Writing Papers
Executive Order 12873, "Federal Acquisition, Recycling, and Waste,Prevention," October 20, 1993
(58 PR 54911, October 22, 1993).
Letter to Dana Arnold, Office of Solid Waste, U.S. EPA, from Sara Freund, Manager, Printing-
Writing Paper Division, American Forest & Paper Association, July 15, 1994.
"Definitions of Printing-Writing Grades for August 3 EPA Procurement Meeting," Printing-Writing
Paper Division, American Forest & Paper Association. '
Letter to Dana Arnold, Office of Solid Waste, U.S. EPA, from John M. Evans, Printing-Writing
Paper Division, American Forest & Paper Association, August 19, 1994.
Envelopes . ','.'" .
"Research on Recycled-Content Envelope Performance Requirements," Revised Draft Report,
prepared for U.S. EPA by E.H. Pechan & Associates, Inc., July 1993.
"Supplementary Envelope Research," Final Draft, prepared for U.S. EPA by Eastern Research
Group, Inc., August 26, 1994. :
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Cotton Papers .
"Recycled Fiber Use in Cotton Content Paper," Draft Report, prepared for U.S. EPA by E.H.
Pechan & Associates, Inc., October 1991.
Letter to Robert Dellinger and Dana Arnold, Office of Solid Waste; U.S. EPA, from Sara Freund,
Manager, Printing-Writing Paper Division, American Forest & Paper Association, January 12, 1994.
"Position Paper - Presidential Executive Order and Proposed EPA Implementation Guidelines,"
prepared by the Cotton Fiber Paper Manufacturers and the American Forest & Paper Association,
January 1994. /
Coated Printing and Writing Papers
"Coated Printing Paper Research," Draft Report, prepared for U.S. EPA by E.H. Pechan &
Associates, Inc., October 1991.
"Update of Coated Printing Paper Research," Draft, prepared for U.S. EPA by E.H. Pechan &
Associates, Inc., December 20, 1993.
"Bristols Research," Draft Report, prepared for U.S. EPA by E.H. Pechan & Associates, Inc.,
December 1991. . ,
"Supplementary Bristols Research," Final Draft, prepared for U.S. EPA by Eastern Research Group,
Inc., August 26, 1994. ,
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APPENDIX
Draft Paper Products Recovered Materials Advisory Notice
Contents . -
Part A - Paper, and Paper Products
Section A-l--Printing and Writing Papers
Section A-2 -- Newsprint
Section A-3 Sanitary Tissue Products
Section A-4 - Paperboard artd Packaging .
Section A-5 - Miscellaneous Paper Products
Section A-6 - Other Recommendations for Paper and Paper Products
Section A-7. - Definitions !.
Appendix I. Example Calculation of Postconsumer Fiber Content of a Corrugated
Container - ,
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Part A - Paper and Paper Products
Section A-l - Printing and Writing Papers
Preference Program: EPA recommends that procuring agencies establish minimum content standards expressed as a percentage of
recovered fiber, including a percentage of postconsumer fiber. EPA recommends that procuring agencies base their minimum content
standards for printing and writing papers on the content levels shown in Tables A-la, A-lb, and A-lc. Percentages are based on the fiber
weight of the product.
Table A-la. - Recommended Recovered Fiber Content Levels for Uncoated Printing and
Writing Papers
Item
Reprographic Paper (e.g., mimeo and
duplicator paper, high-speed copier paper,
and bond paper*)
Offset Paper (e.g., offset printing paper*,
book paper*, bond paper*)
Tablet Paper (e.g., office paper such as
note pads, stationery* and other writing*.
papers)
Forms Bond (e.g., forms, computer
printout paper, ledger*)
Recovered Fiber (%)
20
20
20
20
Postconsumer Fiber (%)
20
20
*
20
20
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Item
Envelope Paper
Wove
Kraft
White and colored
.(including
manila)
Unbleached
Cotton Fiber Paper (e.g., cotton fiber
papers, ledger*, stationery* and matching
envelopes, and
other writing* papers)
Text & Cover Paper (e.g., cover stock,
book paper*} stationery* and matching
envelopes, and other writing* paper)
Supercalendered
Check Safety Paper ,
Recovered Fiber (%)
20
10-20
10
50
50 .
10
10
Postconsumer Fiber (%)
20
10-20
10
20
20
10
10
* These items can be made from a variety of printing and writing papers, depending on the performance characteristics of the item. Some of
.the papers are a commodity-type and some are specialty papers. EPA recommends that procuring agencies determine the performance
characteristics required of the paper prior to establishing minimum content standards. For example, bond, ledger, or stationery made from
cotton fiber paper or a text & cover paper have different characteristics than similar items made from commodity papers.
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Table A-lb. - Recommended Recovered Fiber Content Levels for Coated Printing
and Writing Papers
Item
.
Coated Printing Paper
Recovered Fiber (%)
-5
10
Postconsumer Fiber (%)
-^'j. j-i-i
10
Carbonless
/ 20
20
Item
File Folders (manila and
colored)
Table A-lc. - Recommended Recovered Fiber Content Levels for Bristols
Recovered Fiber (%)
"
20
Postconsumer Fiber (%)
20
Dyed Filing Products
20-50
20
Cards (index, postal,
and other, including
index sheets)
50
20
Pressboard Report Covers
and Binders
50
20
Tags and Tickets
20 - 50
20
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Section A-2 Newsprint .
Preference Program: EPA recommends that procuring agencies establish minimum content standards expressed as a percentage of recovered
fiber, including a percentage of postconsumer fiber. EPA recommends that procuring agencies base their minimum content standards for
newsprint on the content levels shown in Table A-2. Percentages are based on the fiber Weight of the product.
Table A-2. ~ Recommended Recovered Fiber Content Levels for Newsprint
Item ; .
Newsprint
Recovered Fiber (%)
40-100
Postconsumer Fiber (%) |
40-85 ./ |
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Section A-3 - Sanitary Tissue Products ,
Preference Program: EPA recommends that procuring agencies establish minimum content standards expressed as a percentage of
recovered fiber, including a percentage of postconsumer fiber. EPA recommends that procuring agencies base their minimum content
standards for sanitary tissue products on the content levels shown in Table A-3. Percentages are based on the fiber weight of the product.
Table A-3. - Recommended Recovered Fiber Content Levels for Sanitary Tissue Products
Item
Bathroom tissue
Commercial/industrial
Consumer
Paper towels
Commercial/industrial
Consumer
Paper napkins
Commercial/industrial
Facial tissue
Commercial/industrial
Industrial wipers
1 -
Recovered Fiber (%)
100
20 - 100
100
20 - 100
100
^100
40-100
Postconsumer Fiber (%)
25-60
20-60
40-60
20 - 60. -
30-60'
30
40 .-
! ^^ - l^^^ 1 1 ^^ " ""-'.
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Section A-4 - Paperboard and Packaging Products
* *
Preference Program: EPA recommends that procuring agencies establish minimum content standards expressed as a percentage of
recovered fiber, including a percentage of postconsumer fiber. EPA recommends that procuring agencies base their minimum content
standards for paperboard and packaging products on the content levels shown in Table A-4. Percentages are based on the fiber weight of the
product.
Table A-4. ~ Recommended Recovered Fiber Content Levels for Paperboard
and Packaging Products
Item
Corrugated containers? .
(<300 psi)
(300 psi)
St)lid Fiber Boxes
Folding cartons**
Industrial paperboard
(e.g., tubes, cores,
drums, and cans)
Miscellaneous (e.g., pad
backs, covered binders,
book covers, mailing
tubes, protective
packaging) .
j
Padded mailers
Carrierboard
Recovered Fiber (%)
40-50
30
40
100
100
90-100
; 5-15
25 - 100
Postconsumer Fiber (%)
40-50
30
40
40-80
45-100
75-100
5-15
15
80
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Item
Brown papers (e.g., wrap-
ping paper and bags)
Recovered Fiber (%)
5-40
Postconsumer Fiber (%)
5-20
* The recovered and postconsumer fiber content is calculated from the content of each component relative to the weight each contributes to
the total weight of the box. See Appendix I for an example.
** The recommended content ranges are not applicable to all types of paperboard usedjn folding cartons. Cartons made from solid bleached
sulfate or solid unbleached sulfate contain no or small percentages of postconsumer fiber, depending on the paperboard source.
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Section A-5 - Miscellaneous Paper Products
Preference Program: EPA recommends that procuring agencies establish minimum content standards expressed as a percentage of
recovered fiber, including a percentage of postconsumer fiber. EPA recommends that procuring agencies base their minimum content
standards for the listed paper products on the content levels shown in Table A-5. Percentages are based on the fiber weight of the product.
Table A-5. Recommended Recovered Fiber Content Levels for
..'.'' . Miscellaneous Paper Products
Item
Tray liners
Recovered Fiber (%)
100
Postconsumer Fiber (%)
75
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Section A-6 - Other Recommendations for Paper and Paper Products
Measurement: EPA recommends that procuring agencies express their minimum content standards as a percentage of the fiber
weight of the paper or paper product. EPA further recommends that procuring agencies specify that mill broke cannot be counted toward
postconsumer or recovered fiber content, except that procuring agencies should permit mills to count mil! broke generated in a papermakmg
process using postconsumer and/or recovered fiber as feedstock toward "postconsumer fiber" or "recovered fiber" content, to the extent that
the feedstock contained these materials. In other words, if a mill uses less than 100% postconsumer or recovered fiber, only a proportional
amount of broke can be counted towards postconsumer or recovered fiber content.
Specifications: EPA recommends that procuring agencies review specifications provisions pertaining to performance and aesthetics
and revise provisions that can impede use of postconsumer and recovered fiber, unless such provisions are related to reasonable performance
standards Agencies should determine whether performance provisions are unnecessarily stringent for a particular end use. Agencies also
should revise aesthetics provisions^- such as brightness, dirt counter shade matching - if appropriate, consistent with the agencies'
performance requirements, in order to allow for a higher use of postconsumer and recovered fiber.
EPA recommends that procuring agencies document determinations that paper products containing postconsumer and recovered fiber
will not meet the agencies' reasonable performance standards. Any determination should be based on technical performance information
related to a specific item, not a grade of paper or type of product. -
EPA recommends that procuring agencies watch for changes in the use of postconsumer and recovered fiber in paper and paper
products When a paper or a paper product containing postconsumer and recovered fiber is produced in types and grades not previously
available, at a competitive price, procuring agencies should either revise specifications to allow the use of such type or grade, or develop
new specifications for such type or grade, consistent with the agencies' performance requirements.
V . ...
Recyclability: EPA recommends that procuring agencies consider the effect of a procurement of a paper product containing
recovered and postcopsumer fiber on their paper collection programs by assessing the impact of their decision on their overall contribution to
the solid waste stream.
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Section A-7 -- Definitions '
For purposes of the recommendations contained in this Part, terms shall have the following meanings:
"Postconsumer fiber" means:
(1) 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 -_-..'.
'(2) 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 the following materials, excluding mill.broke:
(1) Postconsumer fiber such as:
(A) 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
(B) All paper,.paperboard, and fibrous wastes that enter and are collected from municipal solid waste.
' _ * ~ - . - '' -
(2) Fiber derived from paper manufacturing, printing, and converting operations, excluding any paper generated in a paper
mill prior to the completion of the paper manufacturing process. Recovered fiber includes repulped fiber from dry paper
wastes generated after the paper machine reel has been rewound and/or cut into smaller rolls of rough sheets, including but
not limited to.: t . .
(A) Envelope cuttings, finishing trim, bindery trimmings, and other paper and paperboard resulting from printing, cutting,
forming, and other converting operations; and bag, box, and carton manufacturing wastes; and
' . .--''' , '- - ' " " . 84 / .- ' . .- - .
-------
(B) Repulped finished paper and paperboard from obsolete inventories of paper merchants, wholesalers, dealers, printers,
converters, or consumers.
"Mill broke" means any paper or paperboard scrap generated in a mill prior to completion of the papermaking process and
specific materials generated during finishing operations that occur after the end of the papermaking process. It includes the
following materials whether generated prior to or after the completion of the papermaking process: paper machine trim,
offgrade or off-specification rolls (ajso referred to as rejected, unused stock); culls, stub rolls, side rolls, end rolls, and
obsolete inventories of paper and paperboard. Although mill broke is occasionally sold from one mill to another, such a sale
does not alter its classification or exclusion from the definition of "recovered fiber."
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Appendix I. Example Calculation of Postconsumer Fiber Content of a Corrugated Container
C-flute has a take-up factor of approximately 1.44, Vj-hich means that for each one foot of
combined corrugated board there is 1.44 feet of fluted medium. This factor is used to. calculate the
weight of paperboard in a given area of combined corrugated board, from which the basis weight of
the board is derived. Each linefboard contributes 35% of the basis1 weight (42/121.4). The medium
contributes 30% of the total basis weight (37.4/121.4).
Board Basis Weight
. , (Ibs/MSF) '
Linerboard #1 42 x 1.00= 42.0
Medium " . 26x1.44= 37.4
Linerboard #2 , 42x1.00= 42,0
Combined Board Weight . ' ' 121.4 Ibs/MSF
If the linerboard used has 20% postconsumer fiber and the medium has 80% postconsumer
fiber, the resulting total postconsumer fiber content of the containerboard is as follows:
Linerboard: .35 x .20 = .07 x 2 = .14 (or 14%) . .
Medium: .30 x .80 = .24 (or 24%)
, Total postconsumer fiber: .14 + .24 = .38 (or 38%) : .
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