ENVIRONMENTAL PRODUCT LABELING
There are no laws that tell printing and writing paper manufacturers
what products they must make. There are no laws telling private
consumers what types of paper they must buy, with the exception
of newsprint in a handful of states, and even those requirements
have been falling by the wayside. Instead, the U.S. has chosen to
rely on the "free market" to favor or reject new products and production
processes. Theoretically, this gives enormous power to consumers
to make or break a product.
In practice, though, consumer power is limited by the amount and
credibility of the information they receive and by the choices they
are offered. At the very least, consumers need product labeling
which is not misleading. Even better, labels should be informative.
Better yet, consumers should be able to compare two products that
appear similar. But this type of information is difficult to come
by for environmentally concerned consumers because U.S. manufacturers
are regulated by so few labeling requirements and have such wide
U.S. PUBLIC LABELING INITIATIVES
Most other developed nations have established some type of multi-dimensional
environmental product labeling that includes components of life
cycle analysis (which attempts to measure a product's impact from
"cradle to grave"). But in the U.S., all the states that once had
labeling requirements stricter than the Federal Trade Commission
(FTC) environmental marketing claims guidelines (the Green Guides) now defer to the weaker national standards. The
FTC guidelines require no postconsumer content for an advertising claim of "recycled content,"
although they do advise that labels indicate the percentage of recycled content if it is less than 100%.
In 1995, when the FTC was considering revisions to its guidelines,
many commenters urged it to add a requirement for products labeled
"recycled" to either contain postconsumer content or identify the
percentage of postconsumer, even if it is zero. But the FTC declined.
Eventually, though, the FTC declared that any product that displays
the "chasing arrows symbol" ()
must meet both the requirements that it contain 100% recycled content
and that it be recyclable in a reasonably available collection system.
If the product does not meet both those criteria, the label must
include text next to the symbol clarifying what claims it makes
about the product. Therefore, if the product only has 50% recycled
content, it must state that on the label.
Unfortunately, that 50% need not be postconsumer. The FTC only
specifies recovered content, which can be either preconsumer or postconsumer. Therefore, a product
labeled with the recycling symbol could have up to 100% preconsumer
manufacturing scrap and no postconsumer, yet still be compliant
with FTC guidelines. But most companies that label their product
as "recycled" nowadays also include a notice about the
postconsumer content. If the label does not indicate postconsumer
content, buyers should assume there is none until further research indicates otherwise.
INTERNATIONAL VS. U.S.
Canada and many Asian nations, as well as European nations both
individually and as a community, have developed voluntary government
labeling programs that incorporate a wider range of environmental
considerations based on some quantifiable aspects of life cycle
review. Canada, in particular, has taken the lead with an innovative
"load point" system, which measures a product's environmental burden
in several categories.
The U.S. has no government-sponsored "seal of approval" program
for recycled products. U.S. environmental labeling laws focus only
on single attributes and give wide latitude to allowable information.
However, people increasingly recognize that single attribute labels
do not adequately inform consumers about a product's overall environmental
In the U.S., only private organizations are tackling the identification
and balancing of more complex multiple environmental impacts. Green
Seal, a national nonprofit organization, develops environmental
standards for products through a public review process involving
manufacturers, environmentalists, consumers and government agencies
and then awards its seal-of-approval to products that meet its standards and that have gone
through its certification process. Scientific
Certification Systems (SCS), a for-profit business, will substantiate
single attributes for manufacturers wishing to certify particular
claims. It also pioneered the "certified eco-profile," a "report
card" that profiles a product's environmental burdens on a long
list of indices. The Chlorine
Free Products Association certifies chlorine free (TCF and PCF)
papers. It also has developed a Sustainable Manufacturing and Marketing Initiative (SMMI) that evaluates a paper manufacturer across many dimensions.
PUSH FOR GLOBAL HARMONIZATION
An international network of ecolabeling programs operates informally
to attempt some cross-cultural harmonization between programs. But
the primary focus is the International Organization for Standardization
(ISO) in Switzerland.
Multi-national U.S. companies are subject to many different labeling
requirements around the globe. They want global standards so that
they can make their labels consistent across all their markets rather
than manufacturing or labeling by many different criteria country-by-country.
However, meaningful access to the ISO process is so expensive that
very few non-corporate entities can afford to participate in meetings
all over the globe. Therefore, standards have been developed by
corporate attendees, with very little input or oversight by the
environmental community, often resulting in definitions and standards
weaker that those in the U.S.
Some international programs, however, go far beyond anything contemplated
in the U.S. and require that manufacturers take responsibility for
the life cycle impacts of their products. Germany, in particular,
requires companies to take back packaging and refill, reuse or recycle
Many U.S. multinational companies are already complying with international
requirements for manufacturer responsibility, including reducing
packaging and using refillable bottles, in countries that require it, while at the
same time they refuse to provide such opportunities here. Some states and cities have become interested in the potential for manufacturer
responsibility rules tailored to the unique U.S. solid waste management
system, in order to reduce the enormous financial burden the U.S.
production system places on local governments to recycle,
landfill or incinerate consumer discards. Interest in "extended producer responsibility" (EPR) has become especially active regarding computer and
electronic disposal issues.
What Are Buyers To Do?
If U.S. public labeling programs are offering little of the information
that recycled paper buyers want and private labeling programs cover
only a limited number of products, how can buyers assure themselves
that they're getting the most environmentally sound products possible?
Buyers can research the papers they plan to buy as thoroughly as
possible, including questioning the manufacturer and using product
guides such as the one on this site. Environmental claims from vendors and printers should be verified with the manufacturer if they are critical to a purchase decision. Paper purchasers can also check whether
papers have been certified by Green Seal, SCS or others. Major buyers,
in particular, can influence manufacturer decisions on what feedstocks
and processes they use to make their papers by requiring specific criteria or setting a timetable for developing papers to meet their specifications. But for the most part,
U.S. purchasers are left to rely on manufacturers' voluntary labeling.