As the owner and manager of the Paper Calculator, the Environmental Paper Network would like to take this opportunity to address recent communications from paper industry-related groups that include misleading and inaccurate information regarding the Paper Calculator.

Summary
The Paper Calculator is supported by a respected coalition of over 150 not-for-profit organizations working together toward a common goal that paper production and use contribute to a clean, healthy, just and sustainable future for life on earth. Our network stands by the Paper Calculator as the most independent, comprehensive, credible and transparent calculator of environmental impact estimates for a wide variety of paper choices. The Paper Calculator is backed by an advanced scientific methodology based in life cycle assessment that was created in partnership with SCS Global Services, a trusted leader in third-party sustainability standards development. The Paper Calculator Version 4.0 development process was conducted in cooperation with several multi-stakeholder committees consisting of representatives from the fields of science, academia, life cycle assessment, industry and conservation-focused non-governmental organizations (NGOs). Throughout the development process, these committees consulted with a variety of external stakeholders and conducted multiple rounds of public outreach, including a 90-day public comment period. There is a 60+ page methodology document available on the Paper Calculator’s website in order to provide complete transparency about its methods and data sources. Thousands of high-profile companies and organizations agree that the Paper Calculator is credible, scientific, independent and transparent, and use it and cite its results.

The Development of Paper Calculator Version 4.0
In July of 2018, the Environmental Paper Network released version 4.0 of the Paper Calculator. Version 4.0 is based on new Product Category Rule modules for roundwood, pulp and paper that include comprehensive environmental impact analyses and performance data. These progressive new rules incorporate a more inclusive and science-based accounting of greenhouse gas emissions in order to consider current knowledge regarding climate science and the urgent and near-term consequences of emissions on the climate. Companies that want to make the most informed sustainable purchasing decisions are using these new rules to guide their efforts to protect people and planet.

The methodology behind the Paper Calculator was extensively peer-reviewed during the three-year development process to create Paper Calculator Version 4.0. Its framework is based on rules that exceed the International Standards Organization’s (ISO) Life Cycle Assessment (LCA) standards, and they aim for greater transparency and leadership in the forest products sector. The Product Category Rule and LCA methodologies used are strongly supported by major NGOs, academics, and scientists. These modern approaches set a new bar for ensuring inclusive and transparent environmental claims because they consider all impacts associated with wood and paper production.

Facts About the Paper Calculator

  • The Paper Calculator is the only tool available to users today that slices through the many competing messages from the paper marketplace to show truly sustainable choices. Since many paper manufacturers do not release their environmental data or do not reveal the methodologies they use when they calculate their products’ environmental footprints, the Paper Calculator provides the independent guidance that consumers need to evaluate the environmental impacts of various paper types and choices.
  • The Paper Calculator provides a comprehensive “cradle to grave” environmental impact estimate that covers paper’s entire life cycle – from sourcing to the end of its life – not just the paper manufacturing process. This is one reason why the Paper Calculator’s data is such a valuable resource for so many.
  • The Paper Calculator is not a Product Category Rule or a Life Cycle Assessment (which are tools that provide frameworks for analysis). The Paper Calculator is an environmental impact estimator based upon those frameworks that uses industry national average data. To compare it side by side to those processes is not an accurate assessment as each of these tools perform different functions.
  • The Paper Calculator is transparent about the fact that it uses primarily North American industry average data to make estimates about the environmental impacts of paper. This is noted throughout the tool and the website.
  • To the greatest extent possible, datasets representing North American paper production are used in the Paper Calculator model. Respected life cycle databases, which use global average datasets, such as Ecoinvent, were used to fill information gaps when data from the North American industry was not available or was outdated. Ecoinvent data sets that were used in the Paper Calculator typically show lower environmental impacts than the North American paper industry data sets, so these data sets do not result in overestimation of impacts from the North American paper industry in the Paper Calculator. A detailed and transparent list of data sources is presented in Table 7 of the Life Cycle Impact Assessment Methodology for Environmental Paper Network Paper Calculator v4.0
  • Previous versions of the Paper Calculator employed the “number of uses” allocation method for recycled paper. This method was critiqued by some industry stakeholders due to its inherent assumptions regarding recycled paper’s multiple Paper Calculator version 4.0 employs the alternative recognized approach, the “cut-off method,” whereby it is not assumed that recycled paper has multiple lives and does not provide landfill avoidance credits for the recycling of waste paper into recycled pulp. A sensitivity analysis for the greenhouse gas, ocean acidification and solid waste impacts is provided in the methodology document to model the alternative allocation method.
  • The Paper Calculator takes a progressive approach by including indicators for forest disturbance, ocean acidification and threatened species because these are important yet commonly omitted impacts which conservation-focused NGOs believe should and must be measured in order to combat climate change. The impacts and methods for calculation are clearly defined and described in the website and the methodology document.
  • The scientific, academic and NGO communities agree that not all biomass is carbon neutral and it is reported as such in the Paper Calculator.
  • The Paper Calculator’s use of the U.S. EPA’s Toxic Release Inventory data is an appropriate source of data to calculate hazardous waste generated by the forest products industry because the Toxic Release Inventory provides waste transfer/quantity reports, which include on-site and off-site disposal of hazardous waste under the Resource Conservation and Recovery Act (RCRA) Subtitle C.
  • The Paper Calculator’s uses EPA’s Municipal Solid Waste database to measure the solid waste generated at the end-of-life disposition (i.e., landfill, recycling, or incineration) and not impacts from solid waste disposal from paper manufacturing. The solid waste impacts generated from paper manufacturing are predominantly based on the U.S. Life Cycle Inventory database.
  • The Paper Calculator estimates average tree diameters from the U.S. Forest Inventory database, not an ecoregion database.
  • The Paper Calculator includes short-lived climate pollutants, such as carbon black, because they have been studied extensively and are known by the Intergovernmental Panel on Climate Change (IPCC) to contribute to climate change.
  • Industry representatives were included in panels for the development of the methodologies that underlie the Paper Calculator. Representatives of ChemPap, Inc. and New Leaf Paper were members of the Product Category Rule Working Group and a representative of Kimberly Clark was a member of the Product Category Rule peer review panel.
  • All of the Paper Calculator’s data sources are clearly documented in the publicly-available methodology document and are from industry-recognized licensed databases or publicly available government data sources.

The Environmental Paper Network does not have a vested economic interest in paper purchasing or choices. Our goal is to provide independent information to help consumers make more sustainable paper use and purchasing decisions. Our network applauds paper manufacturers, sellers and purchasers who seek and provide transparent and accurate information about their environmental impacts. We are enthusiastic to work with producers, sellers and consumers to compare results from specific mills and the industry as a whole. However, there is currently no other independent, transparent calculator in the NGO or corporate landscape that matches the comprehensive scope of the Paper Calculator. Because there is also no industry/NGO consensus on the full scope to be included in a life cycle assessment of paper, using an independent, third-party tool like the Paper Calculator is the best way to ensure access to scientifically credible and unbiased information.

Conclusion
The Environmental Paper Network operates with full transparency regarding the Paper Calculator’s methodology, and invests significant time and funds to research, update and verify the information in the Paper Calculator with independent sources. We stand by the methodology, data and environmental impact estimates provided, and so can you. Please visit the “About” and “FAQ“ sections of the Paper Calculator website to learn more and contact us at info@environmentalpaper.org anytime with questions.