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Draft FSC Chain of Custody Standard for Chip and Fibre Material and Products

Comment Deadline: May 10, 2003

The Forest Stewardship Council released its new draft chain of custody standard incorporating new requirements for verifying and labeling recycled materials, including paper, on March 10, 2003. It invites comments to Sofia Ryder at FSC until May 10, 2003.

Conservatree provided advice to FSC on drafting the proposed paper standards. (Materials for the Future Foundation advised on reclaimed wood issues.) We expect to assist FSC in evaluating the responses to this draft standard, as well.

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As an international organization promoting forest stewardship, FSC wants to create a globally valid standard which provides for verification and labeling of FSC virgin and recycled content products whicih meet FSC requirements. The new standards will cover paper as well as wood/chip/fiberboard products. Because of this, there are a number of places in the draft standard that may raise questions for those primarily interested in North American paper issues. Usually, these can be explained by the need for adaptation to both global and non-paper considerations. Following are some questions and Conservatree's answers, based on our work with FSC on this standard. (These Q&As represent only Conservatree's responses, not FSC's. For an official FSC response, contact Sofia Ryder.)

Q: What is different in this draft standard from other already-existing recycled paper requirements?

A: Besides the potential for adding FSC-certified wood fiber to recycled papers, there are some differences from other standards:

U.S. recycled paper standards under Executive Order 13101 and the EPA recovered (recycled) materials guidelines allow some materials that never left the mills to be counted as "recovered" content. These materials, such as trimmings from in-plant converting operations (e.g. when papers are cut to sheet sizes), are produced after the original papermaking process and are returned for repulping and inclusion in new paper whether it is subsequently labeled "recycled" or "virgin." The U.S. standards allow them to count as part of the "recycled," "recovered" or "preconsumer" part of the content claim. In contrast, the draft FSC standard excludes all materials in the mill from being counted as recycled, which is consistent with practice in non-North American mills.

U.S. government standards for federal agency paper purchases, which are replicated by hundreds of state and local governments and also used voluntarily by many private sector purchasers, require a minimum of 30% postconsumer content in uncoated papers and 10% postconsumer in coated papers. FSC's proposed standard allows 30% FSC certified virgin AND/OR verified postconsumer reclaimed fiber. This could result in FSC certified recycled papers that do not meet the U.S. minimums. However, many other countries around the globe do not have the postconsumer sources that are so abundant in the U.S. and are likely not to be able to incorporate high amounts of postconsumer content. This would be a serious problem for U.S. purchasers if the FSC recycled paper logo were a "one-size-fits-all" logo. However, we expect that they will approve a logo that requires producers to state the actual percentages of postconsumer and FSC contents. This will allow purchasers to determine whether individual papers do actually meet their procurement requirements. Alternatively, the 30% minimum threshold could be raised.

European and other non-North American mills generally do not track postconsumer content nor declare it as part of their content claim. They usually do not have a system for separating postconsumer from preconsumer in collection or at brokers. Therefore, they are more likely to use a "deinked" standard, which may include both pre- and postconsumer, but does not necessarily include postconsumer and does not verify the amount, if there is any. The FSC draft standard requires mills to track and quantify postconsumer content.

Q: I'm concerned about the potential for FSC recycled papers to be below the U.S. standards. How could this be workable?

A: We believe that it will only work if the FSC label that is used for these products requires statements of the actual percentages of postconsumer and other fibers in the papers. However, if this is met, it would allow both more verified information than is usually available currently, and also allow FSC standards to be global. At present, most recycled papers are not certified as to their postconsumer percentage and source. FSC proposes to require that, and in addition will certify the virgin fiber in the paper as meeting FSC requirements.

Non-U.S. purchasers do not have the same requirements for purchasing recycled paper, and mills in some parts of the world are likely to have difficulty incorporating enough postconsumer without having to import it from the U.S. This FSC draft standard allows them to incorporate and certify recycled and FSC content and sell it in their markets.

We found that there is no single standard that will work globally. The U.S. requirements are most achievable in countries that have high consumption and paper wasting habits. They are more difficult in countries that, either because of habit or necessity, do not have mountains of discarded paper. We don't want them to develop that level of waste to meet these standards!

However, if the contents are clearly labeled, then purchasers and environmental/recycling advocates will be able to identify the FSC recycled papers that meet their requirements and reject those that do not. This will also require paper manufacturers to know their markets, and to make products that meet the legislative and specification requirements of those markets. We hope that manufacturers will recognize the advantage to achieving much higher percentages than these minimums in order to meet the environmental expectations of North American purchasers.

Because of the potential for varying levels of recycled content, we do not support an FSC label that does not break out the percentages for each type of fiber.

Q: Why are wood products combined with paper in this standard?

A: FSC wanted to harmonize definitions for all types of recycled products, which can also include wood products. In addition, some recycled fiber can be used for either paper or products such as chipboard and fibreboard. FSC approaches this as a forest issue; they're looking at the products from the point of view of how forest materials are used in, and diverge into, different kinds of products, of which paper is only one.

However, there are some points at which there are differences significant enough that they need to be pointed out. That is why there are different lists in Annex 5 for paper (FSC Guidance on categories of reclaimed fibre materials) vs. wood products (FSC Guidance on categories of reclaimed wood material). Also, the paper listing points out that sawdust, which is allowed as recycled material in wood products, is not accepted as a recycled material for paper.

Q: It appears that even with the requirement that FSC recycled paper have at least 30% FSC certified virgin and/or postconsumer material, section 17.2 allows it to have as little as 10%. How could this be?

A: First, the reality is that many paper mills do not have a steady input of postconsumer content, but vary it by availability and market economics. For some, the percentage stated on their label is a guaranteed minimum but they often have more. For others, it is a guaranteed average over a certain amount of time, frequently a FY quarter. This is true already for recycled papers.

This particular section, though, is intended to address problems more common to wood products and virgin fibres. In particular, some mills are not be able to get a sufficient supply of FSC-certified wood fibre during the winter months, and may drop below the minimum. This is why labeling is required to cover a specific period of time. A mill that has a low percentage at one point must make it up by having a higher-than-required percentage at another point within that batch period, so that over the claim period their products will meet or exceed their claimed minimum.

Q: Why is FSC getting into certifying recycled papers?

A: Some FSC labeled products can already carry up to 82.5 % recycled material. FSC is committed to promote activities that demonstrate FSC's commitment to forest stewardship, to "help society at large sustain forest resources" and to "promote the development of all kinds of activities addressed to the preservation and maintenance of forests." This approach also reduces current anxieties that use of wood from well-managed forests is in conflict with efforts to encourage recycling.

An immediate incentive is government requirements in some countries for fibreboard producers to start increasing recycled content in their products. However, in the U.K. for instance, retailers require high FSC content in the fibre/chipboard products they sell. Further complicating fibreboard producers' attempts to meet both requirements is the fact that they cannot get a source of 100% FSC-certified fiber; it is always mixed with non-certified fibres, which results in a pro-rated FSC fibre source. To maintain their viability and meet both recycled and retailer-FSC requirements, the producers need FSC approval to include higher recycled content in their products along with lower FSC fibre percentages.

We believe that this focus on recycled papers is also helpful in the U.S., where FSC papers have recently been introduced that do not, in fact, meet the EO/EPA minimum recycled content requirements. Rather than FSC competing with recycled paper, it is better that they meet the postconsumer requirements and then also add FSC-certified fibre. Under the proposed standards, purchasers would need to know the postconsumer contents of papers they plan to buy, to be sure they meet required minimums. If they do, then FSC-certified virgin wood fibre would add information about the appropriateness of the virgin fibre sources that we do not currently have for most papers. If they do not meet the postconsumer minimums, both purchasers and North American environmental groups will ensure that those papers are not accepted in U.S. environmental paper markets until they do increase to at least the EO/EPA minimums, or higher.

This draft standard could also allow paper with only postconsumer content, and no FSC-certified virgin wood content, to qualify. Nevertheless, any virgin material in such papers would have to meet FSC requirements and should not be harvested from areas where traditional or civil rights have been violated, from uncertified old growth forests, from genetically modified trees or illegally harvested timber. FSC says that it wants to be known for certifying "good environmental papers." This makes sense to us when certifying 100% recycled papers, although we know that some environmental groups still have reservations about this. We are still thinking through the implications of FSC certification of papers with less than 100% recycled and no FSC fiber.

See FSC's discussion of recycled content considerations.


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