In response to a fire that caused a temporary disruption in the production of several major US suppliers’ 30% post-consumer recycled content (PCRC) white copy paper, the U.S. General Services Administration (GSA) recently suspended the requirement that it comply with the US Environmental Protection Agency’s Comprehensive Procurement Guidelines (CPG) for office paper. We strongly encourage the US GSA and other federal agencies to rescind this policy as soon as possible, because:
- Recycled-content copy paper products continue to be widely available in the marketplace;
- The supply chain for 30% post-consumer recycled content (PCRC) white copy paper has been nearly restored since production resumed at the affected recycled-content pulp mill in early March; and
- Discouraging federal employees from purchasing EPA CPG-compliant copy paper sends a confusing message that undermines years of educating them to “Buy Recycled”.
Therefore, the GSA and other federal agencies should continue to implement responsible paper procurement policies, including a preference for copy paper with at least 30% PCRC, to the best of their ability until this short-term supply chain disruption fully resolves itself, which is expected by April or May 2023. In the meantime, they should look for other suppliers and brands of recycled content copy paper. And if absolutely necessary in the short term, they should select another environmentally preferable paper option such as FSC-certified products. Further recommendations for institutional purchasers are found below.
Background
To encourage the use of paper and other materials recovered through recycling, and thereby help to reduce the amount of waste that must be disposed of, Congress directed federal agencies to increase their purchases of recycled-content products. Section 6002 of the Resource Conservation and Recovery Act (RCRA) requires the U.S. Environmental Protection Agency (EPA) to designate products that can be made with recycled materials and recommend practices for buying these products, including minimum adoption of recycled-content requirements and price preferences. Once a product is designated by the EPA, procuring agencies are required to purchase it with the highest percentage of recycled content practicable and at least meet the minimum percentage listed in the applicable CPG. Executive Order 13423, signed on January 24, 2007, first directed agencies to implement sustainable acquisition practices, including purchasing products with recycled content. The current Executive Order in effect, EO 14057: Catalyzing Clean Energy Industries and Jobs Through Federal Sustainability, signed December 8, 2021, similarly directs federal agencies to purchase products that contain recycled content “in accordance with relevant statutory requirements, and, to the maximum extent practicable…”
The current determination
In December 2022, the US General Services Administration (GSA) issued a Determination to suspend the CPG for office paper products until July 2023. Although the Determination uses the term “paper” throughout, GSA staff have confirmed that it is intended to apply only to office paper, and not to other grades of paper. The action came at the request of a few large producers that are among the primary suppliers of office paper to government agencies, and who stated they were challenged in meeting the needs of their customers due to an “Act of God.”
This temporary suspension was deemed necessary by GSA due to a disruption in the availability of 30% PCRC copy paper caused by a large recovered paper warehouse fire (of still undetermined origin) in October 2022 in Menominee, Michigan. The fire resulted in a temporary shut down of the Resolute Forest Products recycled pulp mill, which is a primary supplier of market pulp to a number of producers who make 30% PCRC white copy paper that is sold at major retailers and through government contracts.
The GSA Determination, dated December 8, 2022, stated, “At present, supplies of recycled paper are estimated to run out in December 2022 and production will not come back on-line until the summer of 2023.” Yet, as of the start of March 2023, the Resolute pulp mill has restarted operations, and according to our interviews with several paper manufacturers, this supply chain disruption is now expected to be fully resolved by April or May.
Analysis
In order to assess the situation and advise the marketplace, the Environmental Paper Network (EPN), Responsible Purchasing Network (RPN) and our partners interviewed GSA staff and other institutional purchasers as well as major retailers and recycled pulp and paper manufacturers. While the pulp and paper industry has experienced some supply chain limitations over the past few years (due to the COVID-19 pandemic), the situation had improved generally and products were more reliably available in 2022 prior to the Resolute pulp mill fire. This was partly due to the fact that several major recycled paper manufacturers started making all of their white copy paper products in the United States. This has assisted in the resiliency of recovered paper production, and the anticipation of a return to normalcy from the disruptions caused by the fire in Menominee. While our interviews confirmed that there was a sizable disruption for several major producers of 30% post-consumer copy paper caused by this temporary shutdown of a major recycled pulp supplier, they also revealed that by sourcing deinked pulp from Sustana mills or their own pulping, a significant number of paper suppliers including Rolland, American Eagle, Badger Paper Milland New Leaf Paper were open for business and making recycled paper products.
Recommendations for GSA and Other Institutional Purchasers
- Don’t panic, recycled copy paper is still available, and availability will be returning to normal very soon.
- Don’t change your policies that require or give a preference to purchasing recycled paper, which will create confusion for procurement staff and other employees. If the allowable exceptions in your policy must be made due to temporary changes in availability or price, track and document all instances and return to normalcy as soon as possible.
- Take this opportunity to evaluate your paper consumption and look for opportunities to implement practices to reduce it as much as possible. This will not only save your organization money, but will also prevent negative impacts on the environment.
- Employ the following hierarchy to guide your paper purchasing decisions:
- Ask your current supplier, or an alternative one, for copy paper with 50% or 100% post-consumer recycled content. The fire most severely disrupted the supply chain of recovered fiber for 30% post-consumer recycled content copy paper, but many vendors still have these products in their inventory.
- Ask your current suppliers to provide CPG-compliant copy paper by finding new sources of recycled paper or pulp. If your current vendors cannot meet your needs, consider off-contract procurement methods until your current vendor’s supply chain is restored. In the long run, consider having multiple suppliers of office paper on contract in order to minimize the likelihood of supply chain disruptions and to foster price competition.
- If there is flexibility in your contracts, seek out different vendors or office supplies or paper that can provide 30% post-consumer recycled copy paper, or contact the companies making recycled paper directly. As noted above, while the supply has been reduced, there are a number of papermakers with recycled paper inventory available.
- Consider papers made from agricultural waste or alternative fibers. Avoid cotton fiber due to its heavy use of pesticides, and only consider bamboo fiber that is certified by the Forest Stewardship Council (FSC). The EcoPaper Database can help identify what is available and assist you with talking to your commercial printer or paper merchant.
- If other options have been exhausted and copy paper with 100% virgin tree fiber must be used temporarily, only purchase products certified by FSC. And be careful not to be confused by inferior certifications that may be offered by suppliers as a substitute for FSC such as SFI or PEFC.
Because the temporary supply chain disruption caused by an October 2022 fire at a recycled paper warehouse has now been resolved and a wide array of white copy paper products with 30-100% post-consumer recycled content, the US GSA should repeal its Determination and begin requiring federal agencies to once again purchase EPA CPG-compliant copy paper. Recycled paper purchasing can and should continue to be a key element of the federal government’s efforts to reduce its impacts on air and water quality, climate change and global biodiversity.
Please contact the Environmental Paper Network at info@environmentalpaper.org with any questions or assistance in navigating these issues.