We speak only for paper-based packaging (not other materials) and of the particular situation we find ourselves in Canada. But to us, pushing for minimum recycled content levels doesn\’t make sense. Why?

1. They run counter to the life cycle of paper itself. Paper fibres can be recycled as many as nine times before they become too short and weak for further use. Like the human species, paper fibres eventually wear out and must be replaced with an infusion of the fresh and young. You can’t have age without youth. To have recycled content at all, you have to have that virgin infusion somewhere in the loop, to keep the whole cycle going.

Mandating a specific recycled content level interferes with that natural cycle. Taken to its extreme, one respected consultancy has estimated that if a significant number of governments or retailers or brandowners demanded 100% recycled content in paper packaging tomorrow, the world would run out of recycled fibre within months((Metafore Paper Life Cycle Project)). We would rapidly be forced back into the forest to meet the demand.

1. Virgin and recycled fibres frequently serve different packaging purposes. Virgin fibres are prized for their strength properties and are also commonly used in direct contact with food or beverages. It seems unfair to effectively penalise a package because of someone’s all-embracing (and probably unscientific) recycled content preference, when the package is ably performing the specific packaging function for which it was designed.

1. Multiple minimums. The nightmare scenario for the industry is widely divergent thresholds that bear no relationship to the global supply and demand for paper fibre (both virgin and recycled), and a tendency, driven by politics and public relations more than anything else, to leapfrog over someone else’s number.

1. There is no demonstrated need for average recycled content minimums for paper packaging in Canada. The overall average is already 76%, far higher than any other packaging material has achieved. Most Canadian packaging mills, in fact, already produce 100% recycled content board (see PPEC press release and backgrounder on Understanding Recycled Content)((PPEC press release and backgrounder 25 June, 2013 Understanding Recycled Content))

1. Such “green procurement” as it is sometimes called, will not grow or encourage markets for recycled materials such as corrugated or boxboard. We’re already there! We can’t get enough! Setting a higher recycled content average than is currently being achieved (76%) would simply mean that the mills would import more used paper and board to meet the new minimum threshold. Capture of material in Canada itself would be unlikely to increase.

1. There is even doubt that 100% recycled content is necessarily “environmentally better” than  virgin board overall (when energy factors, biomass versus fossil fuels, are taken into account)((ibid. Understanding Recycled Content))

No, we think there are better and more practical alternatives to imposing minimum recycled content levels on paper packaging. While there is no illegal logging in Canada, it should be banned wherever it exists (mostly in tropical countries)((FPAC press release, October 20, 2009. )). As well, all commercial forests should be independently third-party certified for responsible sourcing of fibre materials, and preferably meet strict chain-of-custody standards (as PPEC mill members do)((Chain-of-Custody Press Release, January 24, 2012)).  And where practical, perfectly recyclable paper materials should be banned from landfill (something we are also pushing for)((OCC Ban, June 18, 2012)).