“If It Ain’t Broke, Don’t Break It”

The Lifecycle of Paper Products is Already Circular

In so many fundamental ways, environmental sustainability is baked into the nature of the paper and paper-based packaging industry – from the ability and financial incentive to regrow its primary raw material to the biodegradability of its products. As the call for the circularity of product lifecycles is growing louder, paper has always had a head start. And the industry’s strong support and investment in recycling has transformed the circularity of paper products from vision to reality. At a time when there is growing alarm about the low recycled rates of other materials, paper recycling is a stark exception.

While the recycling rate of other materials is as low as the single digits – for example, the U.S. Environmental Protection Agency reports the recycling rate for plastics is just 8.7%  – 66% of all paper products in the United States and 70% in Canada are being recycled. This is near the theoretical maximum recycling rate when items like hygiene products and long-held items such as archived records and books are excluded. For those grades that can be almost entirely recovered and reused, such as corrugated cardboard boxes, recycling rates are higher than 90%.

This level of success is only possible because the paper industry and consumers interact in the free market that drives the paper lifecycle. Since the early 90s, manufacturers have voluntarily responded to the market’s need for greater supplies of recovered fiber with massive voluntary investment in capital-intensive machinery and transport. And according to the American Forest and Paper Association (AF&PA), U.S. pulp and packaging producers are committed to investing an additional $4.1 billion in manufacturing infrastructure between 2019 and 2023. Now, approximately 80% of all U.S. paper mills use some recovered fiber to make everything from paper-based packaging and printing papers to newspaper and tissue. The continuing investment in recycling technology is allowing paper manufacturers to reach further into the wastepaper stream to use fiber that was previously unrecoverable.

In fact, the AF&PA’s just-released Design Guidance for Recyclability tackles one of the remaining challenges to even higher recycling rates for paper-based packaging. The Guide provides a clear understanding of how packaging gets recycled in paper mills and how various non-fiber elements (inks, coatings, adhesives, polymer windows, et. al) affect the recyclability of paper-based packaging. It’s intended to help consumer products companies and their manufacturing supply chain partners more effectively design and produce packaging that meets growing customer demand for recyclability.

At the other end of the lifecycle, millions of households and tens of thousands of North America’s businesses and municipalities willingly participate in what amounts to a continent-wide partnership with industry, driven by paper’s ease of recovery and decades of local investment in the collection infrastructure. A 2014 survey found that 96% of Americans have access to community curbside or drop-off paper recycling programs, or both.  Access numbers for Canadians are in the 94% to 96% range.

However, in a blind rush to address other materials that have never come close to the recycling rates of paper, especially those like plastics that don’t readily degrade in the environment and that often contain toxic substances, some state governments are considering actions that make no environmental or economic sense.  Their latest prescription is a legislative mandate for all materials, including paper, called extended producer responsibility (EPR).

EPR shifts financial responsibility for recycling from the existing network of producers and communities to the manufacturers alone, with no evidence that it can or would improve recycling rates, lower costs, or extend the life of materials any longer than it is already.  In fact, recent experience – for example, the EPR program in British Columbia – suggests EPR leads to higher systemwide costs that get passed on to consumers with less net tonnage diverted from the waste stream.

EPR would take a wrecking ball to the market forces that drive the success of the U.S. paper recycling enterprise, and for no purpose. Unlike the other materials that EPR is supposed to address, paper is not toxic, it does not contribute to ocean and other surface water waste, and it doesn’t take long to degrade in the environment. Yet EPR would target paper products with the same mandates and fees as those other materials, disrupting the economics and overwhelming success of paper recycling.

Compared to the efficiency of established markets, repeated experience teaches us that artificial government mandates are, at best, a testament to confused objectives, unintended consequences, and wasted money and effort. EPR does nothing to make paper recycling more circular than it already is. It is the well-established paper recycling network that is already getting the job done, delivering proven environmental benefits, and making itself ever more circular from year to year.