Draft Technical Background Report on Tissue Paper

Green Public Procurement Tissue Paper --- Draft

Green Public Procurement

Tissue Paper

Technical Background Report

Report for the European Commission, DG-Environment by BRE, 2011

Owner, Editor: European Commission, DG-Environment-C1, BU 9, 1160 Brussels Disclaimer: The European Commission accepts no responsibility or liability whatsoever with regard to the information presented in this document


Contents 1 Introduction.......................................................................................................................1 2 Definitions, scope and background ...................................................................................2 3 Market availability ............................................................................................................3

3.1 Overview of the overall European paper sector ...........................................................3 3.2 Overview of the tissue sector .......................................................................................3

3.2.1 Global ..................................................................................................................3 3.2.2 European..............................................................................................................4

4 Key environmental impacts...............................................................................................7 4.1 Fibrous raw materials...................................................................................................7

4.1.1 Forest destruction and loss of biodiversity ...........................................................7 4.1.2 Legislation and forest certification.......................................................................8

4.2 Production considerations..........................................................................................13 4.2.1 Energy and water consumption during production.............................................13 4.2.2 Emissions to air and water during pulp and paper production............................13 4.2.3 Hazardous chemical substances .........................................................................15 4.2.4 Waste generation................................................................................................20

4.3 Other considerations ..................................................................................................21 4.3.1 Packaging...........................................................................................................21 4.3.2 Transport/distribution.........................................................................................21

4.4 Potential environmental benefits of virgin fibre vs recycled fibre.............................22 5 Cost considerations .........................................................................................................24 6 Public procurement needs ...............................................................................................26

6.1 Typical procurement ..................................................................................................26 6.2 Purchasing requirements/demands.............................................................................26 6.3 Recycled content of different tissue products.............................................................27

7 Conclusions and summary ..............................................................................................29 8 Existing ecolabels and other information sources ...........................................................31

8.1 EU Ecolabel and other ecolabels................................................................................31 8.2 GPP Guidance on tissue.............................................................................................32 8.3 Other Information sources .........................................................................................36

8.3.1 Websites from the European commission ..........................................................36 8.3.2 Studies and other information sources ...............................................................36

9 Proposal for the EU GPP criteria ....................................................................................38 9.1 Verification issues .....................................................................................................41

10 Relevant European legislation and policies................................................................42 11 Annex I – Comparison of ecolabel criteria.................................................................44


Away from home

Organic chlorine compounds

alkylphenolethoxylate

Best Available Technique Reference Document

chemical oxygen demand

Canadian Standards Association

1, 3 – dichloro-2-propanol

diethylenetriaminepentaacetic acid

European Commission

elementary chlorine free

epichlorohydrin

ethylenediaminetetraacetic acid

Eco-Management and Audit Scheme

European Union

Food and Agriculture Organization of the United Nations

Forest Law Enforcement, Governance and Trade Action Plan

Forest Stewardship Council

Green public procurement

Integrated Prevention and Pollution Control

International Standards Organization

3-monochloro-1, 2-propanediol

Northern bleached softwood kraft

Optical brightening agent

polychlorinated biphenyl

polyethylene

Programme for the Endorsement of Forest Certification

polypropylene Registration, Evaluation, Authorisation and Restriction of Chemicals

Sustainable Forestry Initiative

totally chlorine free

Timber Trade Federation

United Kingdom

United Nations Conference on Environment and Development

United Nations Environment Programme

Ultraviolet

Voluntary Partnership Agreement

Abbreviations

AfH

AOX

APEO

BREF

COD

CSA

DCP

DTPA

EC

ECF

ECH

EDTA

EMAS

EU

FAO

FLEGT

FSC

GPP

IPPC

ISO

MCPD

NBSK

OBA

PCB

PE

PEFC

PP

REACH

SFI

TCF

TTF

UK

UNCED

UNEP

UV

VPA


1

1 Introduction Tissue paper products are used in a wide range of non-domestic applications in the public sector widely referred to as the Away from Home (AfH) market. These products include: • Toilet tissue • Paper towels/towelling • Facial tissues This document provides the necessary background technical and market information on which to develop Green Public Procurement criteria for use by purchasing authorities in the public sector. The report examines • Market related issues • Key environmental impacts • Cost considerations • Public procurements needs Based on the output from these areas, a proposal for the EU GPP criteria for tissue paper products has been developed. This proposal describes both core and comprehensive criteria that shall be considered in any purchasing decision for such products.

� The core EU GPP criteria are those suitable for use by any contracting authority across the Member States and address the key environmental impacts. They are designed to be used with minimum additional verification effort or cost increases.

� The comprehensive EU GPP criteria are for those who wish to purchase the best products available on the market. These may require additional verification effort or a slight increase in cost compared to other products with the same functionality.

Where possible, the criteria presented in this report have been developed using the criteria underlying the EU Ecolabel1. Where the EU Ecolabel does not cover a product/service group, other criteria sources (such as further eco-labels or national guidance) have been used. This report accompanies the associated EU GPP criteria document that contains the proposed purchasing criteria and ancillary information for green tendering procedures. Both documents shall be read and used in conjunction with one another.

1 http://ec.europa.eu/environment/ecolabel/ecolabelled_products/categories/tissue_paper_en.htm


2

2 Definitions, scope and background This sheet presents data on procurement actions for the purchase of tissue paper products used in non-domestic applications, widely referred to as the Away from Home (AfH) market. These products include:

• Toilet tissue • Paper towels/towelling • Facial tissues

This encompasses sheets or rolls of tissue paper fit for use for personal hygiene, absorption of liquids and/or cleaning of soiled surfaces. The tissue product consists of creped or embossed paper in one of several plies. Paper itself consists of both fibre and non fibrous materials, e.g. mineral fillers such as calcium carbonate. The fibre content of the product is expected to be at least 90%2.

It also covers: Paper towels that are made from tissue paper, used most often used for drying hands. There are two distinct classes of paper towels in existence: the "domestic" paper towel, and the "institutional" or AfH paper towel.

• The domestic ("household") paper towel, is a roll of highly-absorbent paper with

frequent perforations for easy removal. These are commonly used in homes, but are

also used in food preparation areas, offices, etc, and may be white, occasionally

other colours, but very frequently printed with colour designs.

• The institutional or AfH paper towel comes in a variety of types. These paper

towels are usually made of heavier, rougher paper than that used for domestic paper

towels. Institutional paper towels are usually made to be placed in metal or plastic

box-like dispensers. Institutional paper towels come in two main formats –a) long,

continuous rolls, or b) as folded towels.

Within an organisation, these products may be used in-house, or by third-party service providers offering cleaning and janitorial services and/or catering services. These recommendations do not cover any of the following: a) wet wipes and sanitary products b) tissue products laminated with other materials than tissue paper c) products as referred to in the EU Directive 76/768/EEC (Cosmetics Directive).3

2 Commission Decision of 9th July 2009 establishing the ecological criteria for the award of the Community Eco-label for tissue paper (2009/568/EC) 3 http://ec.europa.eu/consumers/sectors/cosmetics/documents/directive/


3

3 Market availability

3.1 Overview of the overall European paper sector After a difficult year, during which the industry encountered more down-time and capacity closures as a result of the weakened global economy the indications are that European CEPI member countries produced less than 90 million tonnes of paper and board in 2009, the lowest annual total production since 2001. This represents a fall in the region of around 11% over 2008, which is slightly better than the European manufacturing industry taken as a whole. In 2009, total European paper and board consumption was almost 81 million tonnes. Tissue paper represented 8.8% of the volume, with graphics papers (~45%) and packaging paper and board (~42%)4. An examination of paper consumption by paper grade from 2008 to 2009 indicates that tissue paper consumption fell by just 0.8% whilst more substantial reductions were noted in graphic papers (-14.6%) and packaging paper and board grades (-7%).

3.2 Overview of the tissue sector

3.2.1 Global Although the tissue sector is comparatively small in tonnage terms it has continued to show overall growth globally year on year since 2005, Figure 1.5

4 CEPI (Confederation of European Paper Industries). Key Statistics 2009. European Pulp and Paper Industry 5 RISI World Tissue Business Monitor Q3 2009


4

Figure 1: Growth in Global Tissue Consumption, 1998-2008

The tissue market in Asia is much more fragmented than in North America or Europe. In North America, the top three producers produce 73% of all retail tissue. In Asia, the top six producers hold a 53% market share (2 million tons per year). The largest producer in both Asia and Oceania accounts for 16% of the total share. It is followed by its nearest two rivals which hold shares of 9% and 8%, respectively. The total for the top three Asian producers is only 33%, far below that seen in North America and Europe6.

3.2.2 European The five largest economies, Germany, UK, France, Italy and Spain, together account for almost 60% of the consumption with Germany the largest consumers of tissue paper using 1,337 million tonnes, Figure 2.

6 Tissue competitive cost benchmarking study (source: RISI) 2008


5

Figure 2: Tissue paper consumption in (‘000) tonnes and % weight of total Western Europe consumption, 20097

Source: RISI Tissue Monitor Q2 2010

The European market is dominated by three major producers, SCA, Kimberley Clark and Georgia-Pacific, who all have operations in many countries across Europe. Together these producers account for 46.1% of the overall tissue output. The European market splits into the consumer (or domestic) sector and the AfH sector. The AfH sector accounts for around 30% of the overall market. SCA is the largest supplier in Europe of consumer tissue with a market share of 25% and has a leading position in the rapidly expanding Russian market. It is also the market leader for AfH tissue products in Europe with a market share of approximately 18%, Table 1.8

Table 1: European market shares of the leading tissue producers in the consumer and AfH tissue sectors, 2009

Company Consumer, % AfH, %SCA 25 18Kimberley Clark 13 15Georgia-Pacific 10 11Others 52 56

In the AfH market, many tissue producers make dispensing equipment for their

7 http://www.europeantissue.com/wp-content/uploads/Western-Europe-Tissue-Consu-by-Country-2010.pdf 8 http://www.sca.com


6

products. These developments have largely been in response to customer demands for ways to extend refill intervals, and reduce wastage, spillage and/or theft of tissue products (e.g. the development of cartridge and single folded-sheet dispensers in some toilet tissue and hand towel applications). However such dispensers may lead to difficulties when it comes to swapping suppliers, as the dispenser size, shape and/or operation may be unique to a single tissue supplier/product.

Import/export trade of tissue is only a fairly marginal activity in this paper sector, primarily due to the bulky nature of the material. Just under 1 million tonnes was exported in Europe in 2009 with Germany and Italy being the largest exporters. European imports in 2009 amounted to around 750,000 tonnes with Germany and France being the largest importers. Much of the trade is intra EU either serving countries with limited domestic production or providing grades of tissue not manufactured domestically, e.g. Italy is a key producer of virgin based tissue. Tissue products are manufactured using virgin fibre derived from a range of wood pulps and from recycled fibre derived from a number of recovered paper grades. In 2009, 49.6 % of the fibre used for production of tissue in Europe was sourced from recovered paper9. This equated to 7.3% of the total use of recovered paper by the European paper industry.

9 CEPI Key Statistics 2009


7

4 Key environmental impacts

The most important environmental impacts relating to pulp and paper production, its conversion and distribution, on the basis of the Best Available Technique Reference Document (BREF),10 developed by the European IPPC Bureau within the framework of the IPPC Directive (96/61/EC), on best available technologies for paper production and the main paper ecolabels, are as follows.

• Forest destruction and potential loss of biodiversity

• Energy and water consumption during production

• Emissions to air and water during pulp and paper production

• Hazardous chemicals used during production

• Waste generation

• Excessive packaging

• Transport and distribution.

4.1 Fibrous raw materials

4.1.1 Forest destruction and loss of biodiversity

The chief economic product of forests is wood, but the economic benefits, in terms of climate control, pollution abatement, and wildlife maintenance, have rarely been calculated. The economic importance of nontimber forest products is also increasing. The forest is also vital as a watershed. Because of the thick humus layer, loose soil, and soil-retaining powers of the trees' long roots, forests are vitally important for preserving adequate water supplies. Almost all water ultimately feeds from forest rivers and lakes and from forest-derived water tables. In addition, the forest provides shelter for wildlife, recreation and aesthetic renewal for people, and irreplaceable supplies of oxygen and soil nutrients. The principle uses of the 3.3 billion cubic metres of wood consumed worldwide each year are energy (approx. 50%); sawn wood (approx. 28%) and pulp and paper production (approx. 17%).11 Much of this wood used by the pulp and paper industry is in the form of woodchips and other residues left behind from sawmill operations. Deforestation, particularly in the tropical rain forests, has become a major environmental concern, as it can destabilize the earth's temperature, humidity, and carbon dioxide levels. It occurs for many reasons: trees or derived charcoal are used as, or sold, for fuel or as timber, while cleared land is used as pasture for livestock, plantations of commodities and

10ftp://ftp.jrc.es/pub/eippcb/doc/ppm_bref_1201.pdf. 11 http://www.tappi.org/paperu/all_about_paper/faq.htm


8

settlements. The removal of trees without sufficient reforestation has resulted in damage to habitat, biodiversity loss and aridity. It has adverse impacts on biosequestration of atmospheric carbon dioxide. Deforested regions typically incur significant adverse soil erosion and frequently degrade into wasteland. The water cycle is also affected by deforestation.

Industrial logging in virgin or primary forests (in Amazonia, Indonesia, Russia, Canada etc.) and the substitution of functioning ecosystems with tree plantations leads to a loss of biodiversity and makes it increasingly difficult to guarantee that wood derives from legal forestry activities.

Illegal logging takes place when timber is harvested in violation of national forestry laws. The clandestine nature of illegal logging makes its scale and value difficult to estimate in relation to the global trade in forest products, but strong evidence suggests that it is a substantial and growing problem. The World Bank’s 1999 review of its global forest policy observed: "In many countries, illegal logging is similar in size to legal production. In others, it exceeds legal logging by a substantial margin”.12 Deforestation has shown some signs of decreasing in some countries but continues at a high rate in others. Around 13 million hectares of forest were converted to other uses or lost through natural causes each year in the period 2000-2010 compared with 16 million hectares per year in the 1990s. Both Brazil and Indonesia, which had the highest net loss of forest in the 1990s, have significantly reduced their rate of loss, while in Australia, severe drought and forest fires have exacerbated the loss of forest since 2000.13 But it is not just a tropical country problem; countries of the former Soviet Union are facing problems regulating their forests. Russia, for example, is thought to have rates of illegal logging at around 25%14. Fast-wood plantations are neither inherently good nor inherently bad15. They can generate negative environmental impacts compared to natural, indigenous forests, such as a loss of biodiversity, disruption of local water cycles, loss of soil productivity and increased risk of pests and diseases, however such effects can be balanced if careful and intelligent assessment of the social, environmental and economic consequences is carried out and if they are well-designed and managed, and do not replace natural forests16.

4.1.2 Legislation and forest certification

4.1.2.1 European legislation The legality and sustainability of wood fibres is important as, in the EU, approximately 25% of pulpwood and 17% of market pulp is imported.17. Thus the procurement and use of wood is increasingly subject to a range of laws and regulations.

12 Timber Trade Federation. http://www.ttf.co.uk 13 Global Forest Resources Assessment 2010,FAO ISSN 0258 6150 14 Timber Trade Federation. http://www.ttf.co.uk 15 Christian Cossalter and Charlie Pye-Smith. Fast-wood forestry. Myths and realities. CIFOR, the Centre for international forestry research. 2003: http://www.cifor.cgiar.org/Publications/pdf_files/books/forestperspective.pdf, 16 Arborvitae, the IUCN/WWF Forest Conservation Newsletter nº31. September 2006. Article: Forest plantations threatening or saving natural forests? 17 Annual Statistics 2009. European Pulp and Paper Industry. Confederation of European Paper Industries (CEPI). 2009.


9

Timber Regulation (EU) No 995/2010 18 of the European Parliament and of the Council of 20 October 2010 lays down the obligations of operators who place timber and timber products on the market. Also known as the (Illegal) Timber Regulation, it counters the trade in illegally harvested timber and timber products through three key obligations:

1. It prohibits the placing on the EU market for the first time of illegally harvested timber and products derived from such timber;

2. It requires EU traders who place timber products on the EU market for the first time to exercise 'due diligence';

Once on the market, the timber and timber products may be sold on and/or transformed before they reach the final consumer. To facilitate the traceability of timber products economic operators in this part of the supply chain (referred to as traders in the regulation) have an obligation to

3. Keep records of their suppliers and customers.

The Regulation covers a wide range of timber products using EU Customs code nomenclature. The application of the Regulation will start from 3rd March 2013 to allow sufficient time for EU operators, timber producers and Member States, as well as trading partners, to prepare. During this period the Commission will adopt more detailed rules.

Timber due diligence is defined in the regulation.

The core of the 'due diligence' notion is that operators undertake a risk management exercise so as to minimise the risk of placing illegally harvested timber, or timber products containing illegally harvested timber, on the EU market.

The three key elements of the "due diligence system" are:

• Information: The operator must have access to information describing the timber and timber products, country of harvest, species, quantity, details of the supplier and information on compliance with national legislation.

• Risk assessment: The operator shall assess the risk of illegal timber in his supply chain, based on the information identified above and taking into account criteria set out in the regulation.

• Risk mitigation: When the assessment shows that there is a risk of illegal timber in the supply chain that risk can be mitigated by requiring additional information and verification from the supplier.

The European Commission will adopt more detailed rules on the "due diligence system" by 3rd June 2012.

4.1.2.2 Certification schemes All the major sustainable forest management certification schemes allow the certification of plantations (provided they meet certain requirements, e.g. the FSC only allows certification of plantations in areas converted from natural forests before November 1994).

18 http://faolex.fao.org/docs/pdf/eur98848.pdf & http://www.ecolex.org/ecolex/ledge/Regulation995/2010


10

The certification of sustainable forest management (such as the FSC, PEFC, CSA, or SFI)19 guarantees both legality and the respect of environmental and social standards in forest exploitation, although the standards and verification systems differ between the various certification schemes.

Third-party forest certification schemes are essentially communication tools that enable forest owners and forest product companies to provide assurance to traders and consumers that the products they are purchasing have been grown in well-managed forests. The schemes set detailed criteria for the source forest, covering issues such as biodiversity, consultation with local stakeholders, legal rights to log the forest, rights of forest-dependent peoples and so on. They also set ‘chain of custody’ (CoC) requirements, which involve an audit process to track the raw material from source forest to final product.

The two leading paper accreditation organisations are FSC and PEFC.

a) The Forest Stewardship Council (FSC) (http://www.fsc.org)

The Forest Stewardship Council (FSC) is an independent, not for profit, non-government organization established to support environmentally appropriate, socially beneficial, and economically viable management of the world‘s forests. FSC’s vision is where the world’s forests meet the social, ecological, and economic rights and needs of the present generation without compromising those of future generations.

The FSC labels are:

a) 100% label for products containing 100% material from FSC certified forests. The label text is “[Product type] from well-managed forests”.

b) Mix label for products containing a combination of material from FSC certified forests, FSC controlled wood and eligible recycled fibre. The label text is “[Product type] from responsible sources”.

19 FSC (Forest Stewardship Council), PEFC (Programme for the Endorsement of Forest Certification schemes) CSA (Canadian Standards Association) and SFI (Sustainable Forestry Initiative).


11

c) Recycled label for products containing only recycled fibre. The label text is “[Product type] made from recycled material”.

b) Programme for the Endorsement of Forest Certification schemes (PEFC) (http://www.pefc.org) .

PEFC was previously known as the Pan-European Forest Certification Scheme. The PEFC Council is an independent, non-profit, non-governmental organisation, founded in 1999, which promotes sustainably managed forests through independent third party certification.

The PEFC provides an assurance mechanism to purchasers of wood and paper products that they are promoting sustainable forest management.

Standard Labels: PEFC offers two on-product labels and one off-product label:

On product labels

PEFC certified

At least 70% of wood comes from PEFC certified forests that meet or exceed PEFC’s Sustainability Benchmark, and wood comes from controlled sources.


12

PEFC certified and recycled

?

At least 70% of wood comes from PEFC certified forests that meet or exceed PEFC’s Sustainability Benchmark and/or post-consumer recycled material, and wood comes from controlled sources.

Off product label

Promoting Sustainable Forest Management

c) To guarantee that wood is legally harvested, the European Union has also established a licensing system in the framework of its Forest Law Enforcement, Governance and Trade (FLEGT) Action Plan designed to identify the legality of the production of imported products, the FLEGT license. In order to obtain the license, Voluntary Partnership Agreements (VPAs) have to be signed between timber-producing countries and the EU. Timber products, which have been legally produced in VPA partner countries, will be licensed with a FLEGT license for the legality of production by a third-party, and only licensed products from these partner countries will be allowed access to the EU.20 21As yet no FLEGT license exists as the voluntary partnership agreements are currently under negotiation.22

The Timber Trade Action Plan, managed by the Timber Trade Federation (TTF) in the UK in partnership with a number of European Timber TTFs, is an EU FLEGT trade response to tackle the problems of illegal logging which results in market and policy failure. It aims

20 Article 4, paragraph 1 of the Council Regulation (EC) No 2173/2005 of 20 December 2005 on the establishment of a FLEGT licensing scheme for imports of timber into the European Community. 21 This system is similar in effect to other systems already in place in several international agreements, including, amongst others, the Convention on International Trade in Endangered Species (CITES) and the Kimberley Process on conflict diamonds, which feature license or permit systems, and tracking mechanisms, designed to exclude particular categories of products from international markets. The regulation to implement the FLEGT licensing system was adopted by the EU Council in December 2005. There is also an Implementing Regulation (No 1024/2008) that gives the detailed measures for the implementation of the FLEGT licensing scheme, (October 2008) 22 More information at: http://ec.europa.eu/environment/forests/flegt.htm


13

to ensure that only legally verified timber is traded in Europe.23 d) The legal origin of wood can also be demonstrated through a tracing system being in place. These voluntary systems may be 3rd party certified, often as part of ISO 9000 and/or ISO 14000 or EMAS management system

4.2 Production considerations The main steps in pulp and paper manufacturing are raw material preparation, such as wood, debarking and chip making; pulp manufacturing; pulp bleaching; paper manufacturing; and fibre recycling. Pulp mills and paper mills may exist separately or as integrated operations. These processes require energy and water. The significant environmental impacts of the manufacture of pulp and paper arise principally from the pulping and bleaching processes. In some processes, sulphur compounds and nitrogen oxides are emitted to the air, and chlorinated and organic compounds, nutrients, and metals are discharged to the wastewaters.

4.2.1 Energy and water consumption during production The water and energy consumption levels can vary widely depending on the grade/type of tissue paper produced, the different techniques applied and depending on whether pulp and paper are produced in the same plant (integrated plant) or if the pulp for paper production is bought on the market (non-integrated plant). Detailed information on the Best Available Techniques in the Pulp and Paper industry and the associated emission and consumption levels during production are available in the BREF report for the Pulp and Paper industry.

Tissue mills require substantial amounts of steam for heating of water, pulp, air and chemicals to the demanded process temperature and above all for drying the tissue paper product. Large quantities of electricity are also required for driving the machinery, pumping, vacuum, ventilation and wastewater treatment. Pulp and paper industries in the EU have substantially improved their technology, developing and using, in many cases, best available technologies in order to minimise their environmental impacts. More than half of the European pulp and paper industry’s total primary energy is based on biomass (54.4% in 2008), with the remaining part coming from gas24. This indicates that whilst the paper sector is energy intensive it is less and less reliant on finite fossil fuels. For tissue products to be considered for the application of the EU Ecolabel award, the sum of the electricity used in the pulp and the tissue paper production stages shall not exceed 2,200kWh electricity/t. The electrical energy consumed by a recently built stock preparation unit (200t/day) is estimated at 230kWh/t of deinked pulp.

4.2.2 Emissions to air and water during pulp and paper production

Air

The pulp and paper industry is a major user of energy. There remains significant opportunity for reduction of emissions to air caused by energy use and choice of energy source. The principal emissions of concern are CO2, SOx and NOx which contribute to

23 http://www.tft-forests.org/ttap/ 24 Cepi Sustainability Report 2009


14

global warming and acidification. The maximum air emission values relating to tissue production are 1500 kg/ADT CO2; 0.5 kg/ADT NOx; and 0.03 kg/ADT SO2 (as S).

Such emissions have continued to decline. For example, around 900 mills are part of the EU Emission Trading Scheme and in 2008 emitted over 37 million tonnes of CO2. Specific emissions per tonne were reduced by 40% compared to 1990 levels 27, Table 2.

Table 2: Direct CO2 emissions

Direct CO2 emissions*

1990 2000 2005 2006 2007 2008

Absolute (million tonnes)

39.89 41.94 41.29 41.15 39.83 37.26

Specific (kt CO2/kt of product)

0.57 0.43 0.38 0.36 0.35 0.34

*Direct CO2 emissions are the fossil emissions by the pulp and paper mills and connected energy plants.

Water

Over the past 20 years there has been a marked decoupling between rising paper production and reduced emissions to water. This decoupling has arisen largely as a result of improved use of environmental technology and through reduced specific water consumption. The reduction of discharges of eutrophic or toxic substances into water still remains a priority for the industry. The principal emissions that concern producers of tissue based on virgin/recycled fibre differ and are indicated below:

- chemical oxygen demand (COD). Even with the best conventional effluent treatment, mills can release significant quantities of unidentified substances with poor biodegradability. The identity of the components of COD in treated effluents remain an issue for both producers of tissue from virgin/ recycled fibre

- persistent substances, such as pentachlorophenol, cadmium and mercury, which are not deliberately added, but nonetheless can sometimes be detected at low levels (~ 1-2µg/l ) in wastewaters arising from mills using recycled fibre

- halogenated organic compounds (measured as Adsorbable Organic Halide –


15

AOX). AOX is usually only of concern if chlorine compounds are used for the bleaching of pulp

- chlorate emissions from chemical pulp production.

Emissions resulting from phosphorous and nitrogen are not normally of concern since wastewaters from tissues mills (either integrated with virgin pulp production, or non-integrated tissue mills using virgin fibre or tissue mills using recycled fibre) are usually deficient in these minerals. In these cases nitrogen and phosphorous are added so that biological treatment is not limited.

4.2.3 Hazardous chemical substances A large number of chemicals are used both for process application in virgin pulp manufacture, processing of recycled fibre and in tissue papermaking; and for product enhancement in tissue manufacture. Some of these can have negative effects on health and the environment. On-going research by chemical and polymer manufacturers is continually seeking to reduce the negative effects of such substances through the development of more benign substances or through improving the efficacy of existing products which can lead to reduced addition levels. Paper products or any part of it thereof shall not contain substances or mixtures meeting the criteria for classification with the hazard classes or categories in accordance with Regulation (EC) No.1272/2008 nor shall it contain substances referred to in Article 57 of REACH Regulation (EC) No. 1907/2006. Specific substances are detailed in the following sections. Table 3 gives a list of hazard statements for the Risk (R) Phrases particularly noted for tissue. Table 3: Hazard statements and risk phases GHS Hazard Statement25 EU Risk Phrase26 H340 May cause genetic defects R46 H350 May cause cancer R45 H360F May damage fertility R60 H360D May damage the unborn child R61 H400 Very toxic to aquatic life R50 H400 Very toxic to aquatic life H410 Very toxic to aquatic life with long lasting effects

R50-53

H411 Toxic to aquatic life with long lasting effects

R51-53

H412 Harmful to aquatic life with long lasting effects

R52-53

H344 May cause allergy or asthma symptoms or breathing difficulties if inhaled

R42

25 Regulation (EC) No.1272/2008 on classification, labeling and packaging of substances and mixtures amending and repealing Directives 67/548 EEC and 1999/45/EC, and amending Regulation (EC) No. 1907/2006 26 Directive 67/548/EEC with adjustment to REACH according to Directive 2006/121/EC and Directive 1999/45/EC as amended


16

H317 May cause allergic skin reaction R43

4.2.3.1 Chlorine and chlorine substances Chlorine is a toxic, corrosive, greenish yellow gas with a pungent, irritating odour. It belongs to the halogen family of elements, found in group VIIa of the periodic table. Uncombined chlorine does not occur in nature due to its high degree of reactivity, but its compounds are numerous. It is used in the manufacture of a wide range of industrial and consumer products. These include water purification, bleaching, plastics e.g poly vinyl chloride (pvc), dry cleaning solvents, etc. Elemental chlorine, as chlorine gas, was used widely as a pulp bleaching agent up until 1990. However, considerable scientific evidence indicated that elemental chlorine reacted with organic substances in water to create organic chlorine compounds (as measured by Adsorbable Organic Halide –AOX), including dioxins and furans which are toxic to the environment. From 1990 onwards the use of elemental chlorine as a bleaching agent was substantially reduced and replaced by ECF (Elemental Chlorine Free) and TCF (Totally Chlorine Free). ECF pulp is bleached with chlorine dioxide. TCF pulp is the culmination of several technologies involving oxygen, ozone, hydrogen peroxide and various other peroxygens. In 2005, elemental chlorine was used in 19-20% of kraft pulp production globally, down from over 90% in 1990. 75% of kraft pulp used ECF, with the remaining 5-6% using TCF bleaching techniques. Bleaching without chlorine gas does not form dioxins and furans and the degree of chlorination of the remaining chlorinated compounds is greatly reduced falling to below 0.15kg AOX/ADt for pulp mills using modern technology. This level of emissions align with limits specified in the EU Ecolabel, where the weighted average value of AOX released from the production of pulps used in the eco-labelled tissue product must not exceed 0.12kg/ADt. AOX emissions from each individual pulp used in the paper must not exceed 0.25kg/ADt pulp27. Emissions at these levels have no noticeable impact on the environment.28 ECF pulp, bleached with chlorine dioxide, now accounts for almost 90% of the bleached chemical pulp market (totalling more than 88 million tonnes in 2007) with TCF making up just less than 5% of global production. ECF bleaching offers a number of benefits over TCF bleaching, including:

• ECF bleaching allows a higher pulp brightness without sacrificing pulp strength chracteristics

• ECF bleaching sequence is simpler • ECF bleaching allows the mills to terminate cooking at a higher kappa number,

thereby increasing yield. The dominance of ECF pulp production is expected to continue with a further 30 million tonnes of new production expected in Australia, Russia, Chile, Uruguay, Brazil and

27 EU Ecolabel 28 Justification for AOX levels in the requirement by Nordic Swan. Nordic Ecolabelled, Tissue Paper, Background to ecolabeling, Version 5.0, Draft – March 2011


17

Indonesia.

Chlorine compounds are also used in some additives used in papermaking e.g. wet strength agents and these may also result in further sources of AOX. Products must not contain more than 0.7% of the chloro-organic substances, epichlorohydrin, 1, 3-dichloro-2-propanol and 3-monochloro-1, 2-propanediol (MCPD), calculated as the sum of the three components and related to the dry content of the wet strength agent.

4.2.3.2 Alkylphenolethoxylates Alkylphenolethoxylates (APEO) are derivatives of alkylphenols such as nonylphenol and octylphenol. These are used in a range of end uses including:

• Industrial detergents, such as those used for wool washing and metal finishing.

• Some industrial processes, such as emulsion polymerisation

• The spermicidal lubricant nonoxynol-9.

• Various laboratory detergents, including Triton X-100.

• In some pesticide formulations.

In the paper industry they may find application as cleaning agents, felt washing and as dispersants in the deinking of recycled fibres where they are used to separate the ink particles from the fibre. APEOs are transformed in the environment into metabolites that are more toxic than the original surfactant, and both APEOs and metabolites are suspected to have hormone-mimicking, estrogenic effects affecting the reproductivity of male organisms, and have high bioaccumulation factors. Neither APEOs nor alkyl phenol derivatives shall be added to cleaning chemicals, deinking chemicals, foam inhibitors, dispersants or coatings2.

4.2.3.3 Surfactants and deinking formulations for recycled fibres Surfactant is the abbreviation of surface active agents. To be surface active, the chemicals must have a lyophilic (liquid-loving) and lyophobic (liquid-hating) group. For an aqueous solution, these are usually called hydrophilic and hydrophobic groups. From this broad definition, any chemical that has both a hydrophilic and a hydrophobic portion shall more or less have surface activity (reducing the surface energy of liquid or solid) and can be called a surfactant in general. By this definition, defoamers, dispersants, foaming agents, and collectors used in deinking are all surfactants. Surfactants from a commercial chemical supplier are often blends of many different functional surface active and nonsurface active agents, such as sodium hydroxide, sodium silicate, etc. The chemical structure of surfactants used for deinking may differ significantly; they can be cationic, anionic, nonionic, or amphoteric. However, anionic fatty acids and nonionic surfactants are more commonly used.29 For surfactants that are used in quantities of at least 100g/t (summed over all the surfactants used in all the different formulations used in deinking return fibres) each surfactant shall be readily biodegradable. Where such surfactants are used in quantities of less than 100g/t, each surfactant shall be either readily biodegradable or ultimately biodegradable2.

29

Yulin Zhao, Yulin Deng, and J.Y. Zhu Progress in Paper Recycling / Vol. 14, No. 1, November 2004


18

4.2.3.4 Biocides

The conventional method of controlling microbial growth in papermachine systems is through the use of biocides. Biocides are generally divided into two main groups: oxidizing; and non-oxidizing. They act on the microorganisms in one of three ways: either by attacking the cell wall, the cytoplasmic membrane, or the cellular constituents. To control biological fouling, the affected water systems are treated with certain chemical substances in concentrations sufficient to kill or greatly inhibit the growth of the causative organisms. A range of chemical products have been developed. These include methylenebis(thiocyanate), dithiocarbamates, haloorganics, and quaternary ammonium surfactants. While many of these are quite efficient in killing microorganisms or inhibiting their growth, they also tend to be toxic or harmful to humans, animals, or other non-target organisms.

Therefore the active components in biocides or biostatic agents used to counter slime-forming organisms shall not be potentially bioaccumulative2.

4.2.3.5 Residual monomers

A range of polymer products are used within the papermaking process. Such polymer products ( retention agents and wet strength agents*) may contain a maximum of 100ppm residual monomers (calculated on the dry matter content of the product) classified as environmentally harmful with risk phrase R50,-R53, R51-R53 or R52-R53 or classified as harmful to health with risk phrases R45, R46, R60 or R6130.

700ppm limit set for acrylamide in retention aids. *Epichlorohydrin is regarded as a residual monomer in this requirement

4.2.3.6 Foam inhibitors/defoamers Most paper mills make use of defoamers to prevent excessive foaming during the approach flow system and during sheet formation. They are surface active agents such as polyethylene glycols, and esters or amides of fatty acids. None of the constituent substances that have a foam inhibiting or foam retarding effect in foam inhibitors/defoamers shall be classified as environmentally harmful in accordance with EU Directive 67/548/EEC with risk phrases R50-R53, R51-R53 or R52-R5328.

4.2.3.7 Wet strength agents Wet strength agents are used in a number of tissue related products. These are usually based on polyamine-polyamide-epichlorohydrin resins. As the organo-chlorine content of epichlorohydrin resins give rise to measurable AOX in products and water systems, any wet strength agents used must not contain more than 0.7% of the chloro-organic substances epichlorohydrin (ECH), 1, 3- dichloro-2-propanol (DCP) 30 http://www.svanen.se/en/Svanenmarka/Kriterier/Criteria/?productGroupID=47001


19

and 3-monochloro-1, 2-propanediol (MCPD), calculated as the sum of the three components and related to the dry content of the wet strength agent2. Glyoxal which has been used in wet strength agents has been identified as a substance of concern. Through the recycling of fibre, there may be carry over of glyoxal with the recycled fibre. The limit value for the presence of glyoxal in tissue is 1.5mg/dm2. Wet strength agents shall no longer contain glyoxal.

4.2.3.8 Softeners, lotions, fragrances and additives of natural origin

Tissue products may be treated with softeners, lotions or added perfume to get the right properties or "feeling". None of any of the constituent substances or preparations/mixtures used in these softeners, lotions, fragrances and additives of natural origin used as additives can be classified as hazardous to the environment, sensitizing, carcinogenic or mutagenic with risk phrases R42, R43, R45, R46, R50, R51, R52 or R53 in accordance with Council Directives 67/548 EEC and 1999/45/EC. Any ingredient added to the product as a fragrance must be manufactured, handled and applied in accordance with the code of practice of the International Fragrance Association2.

4.2.3.9 Dyes, pigments, optical brightening agents and inks There are many different techniques and chemical systems for the application of colour to paper. Each will be influenced by factors such as the type of pulp and fibre used, water quality and other additives present. Dyes used in tissue products require good fastness properties. Dyes, pigments and inks Any of the dyes, pigments and inks used shall not contain aluminium, mercury, lead, copper, cadmium, manganese, nickel or hexavalent chromium compounds. In addition, phthalates shall not be present and the dyes, pigments and inks shall not contain azo-substances that may cleave to any of the amines according to EU directive 2002/61/EC31 as listed in Table 428, 32. Table 4: Amines that azo substances in dyes, pigments and inks shall not cleave to

Amine CAS-

number 4-amino-biphenyl 92-67-1 Benzidine 92-87-5 4-chloro-toluidine 95-69-2 2-naphtylamine 91-59-8 o-aminoazo-toluene 97-56-3 2-amino-4-nitro-toluene 99-55-8 p-chloroaniline 106-47-8

31 http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2002:243:0015:0018:en:PDF

32 http://www.blauer-engel.de/en/products_brands/search_products/produkttyp.php?id=459


20

2,4-diamino-anisol 615-05-4 2,4'-diamino-diphenylmethane 101-77-9 3,3'-dichlorobenzidine 91-94-1 3.3'-dimethoxybenzidine 119-90-4 3,3'-dimethylbenzidine 119-93-7 3,3'-dimethyl-4,4'-diamino-diphenylmethane 838-88-0 p-cresidine 120-71-8 4,4'-methylenebis (2-chloroaniline) 101-14-4 4,4'-oxydianiline 101-80-4 4.4'-thiodianiline 139-65-1 o-toluidine 95-53-4 2,4-toluilenediamine 95-80-7 2,4,5-trimethylaniline 137-17-7 O-anisidinedimethoxyaniline 90-04-0 2,4-xylidine 87-68-1 4,6-xylidine 87-62-7 4-aminoazobenzene 60-09-3

Dyes and optical brighteners In addition for dyes and optical brightening agents, no bleeding shall be observed according to test method EN 646/648. A minimum of level 4 is required. Ionic impurities in dyes and pigments Levels of ionic impurities in any dyes and pigments used shall be limited and shall not exceed Ag 100 ppm; As 50 ppm; Ba 100 ppm; Cd 20 ppm; Co 500 ppm; Cr 100 ppm; Cu 250 ppm; Fe 2500 ppm; Hg 4 ppm; Mn 1000 ppm; Ni 200 ppm; Pb 100 ppm; Se 20 ppm; Sb 50 ppm; Sn 250 ppm; Zn 1500 ppm.

4.2.3.10 Chelating agents Chelating agents are reactive compounds used during the bleaching process to ‘bind’ heavy metal ions that may affect the efficiency of the bleaching process. As they biodegrade only very slowly, they can re mobilize heavy metals in river sediments when they are discharged into the aquatic environment. The most commonly used are ethylenediaminetetraacetic acid (EDTA) and diethylenetriaminepentaacetic acid (DTPA). Pulp manufacturers shall specify quantity of chelating agents used28.

4.2.4 Waste generation Producers of pulp, paper and converted tissue products shall have a system for handling of waste and residual products arising from the production plant. The system shall include the following points as a minimum:

• Procedures for separating and recycling materials from the waste stream

• Procedures for recovering materials for other uses, such as incineration for raising process steam or agricultural use


21

• Procedures for the handling of hazardous waste.

The generation of paper sludge as a by-product of tissue made from recycled fibre is significant and ranges between 28-30% depending on the type of recovered paper used. Manufacturers need to demonstrate that the chosen route for recovery or disposal of paper sludge represent the best environmental option considering but not limited to:

• Use in insulating building blocks

• Recycling within the process or, at least to a waste paper machine

• Filler recovery (directly from sludge or from waste to energy ash)

• Other commercial uses such as fillers for plastics and rubber products, high performance drilling muds for the oil industry, or industrial absorbents,

• Landspreading shall be permitted when the manufacturer

o can demonstrate genuine agricultural benefit or ecological improvement, and

o has identified the pollutants likely to be present from a knowledge of the process and that these are typically only one tenth of those found in sewage sludge

o has identified the ultimate fate of the substances in the soil33.

4.3 Other considerations

4.3.1 Packaging Packaging (article, group or transport packaging) must not be made from chlorine based plastics. The selected packaging shall follow the principals established directive 94/62/EC on packaging and packaging waste34; namely:

• to limit the weight and volume of packaging to a minimum in order meet the required

level of safety, hygiene and acceptability for consumers and to assist in saving fuel in

subsequent transport and distribution of products

• to reduce the content of hazardous substances and materials in the packaging material

and its components

• to design reusable or recoverable packaging.

4.3.2 Transport/distribution

Opportunities to minimise the overall carbon footprint of transport and distribution of the product from suppliers/distributors shall be sought. Initiatives to minimise the carbon 33 Technical Guidance Note IPPC S6.01 Technical Guidance for the Pulp & Paper Sector Version 2 Nov 2000 34 The Packaging and Packaging Waste Directive (94/62/EC)


22

footprint are constantly being developed and introduced. These currently include delivering outside rush hours, and monitoring fuel consumption, distances travelled, fuel efficiency and other items that indicate annual performance and CO2 emissions per unit transported.

4.4 Potential environmental benefits of virgin fibre vs recycled fibre

Tissue products may be made from recycled fibres or mixtures of recycled and virgin fibres or from virgin fibres. In order to produce recycled tissue paper, paper based on virgin fibre needs to be produced. Both types of paper are part of the same production chain. In fact, it is possible to recycle high-quality paper, such as graphic paper, several times for either the same graphic paper, or tissue paper, reducing the need for virgin fibre.

Both types of paper need to be purchased, as the amount of recycled paper cannot cover the total paper demand in Europe, and as there would not be recycled paper without having paper made from virgin fibres. Where virgin fibre is used this needs to stem from legally harvested woods and from sustainably managed forests. According to the BREF and other studies,35 production processes for paper based (totally or mainly) on post-consumer36 recovered paper fibres (recycled paper) use much less energy and water than those for paper based (totally or mainly) on virgin fibre:

• The water consumption for the production of recycled tissue paper is 8-25 m3/t (tissue with recycled fibre)37 between 10-15 m3/t for heavy weight products or lower quality grades made from virgin fibres and 15-25 m3/t for light weight products or high quality grades made from virgin fibres24.

• Energy consumption for the production of paper based (totally or mainly) on virgin fibre is 5,000-10,700 kWh/t, compared to a consumption for the production of recycled paper of 1,700-5,500 kWh/t. (source: http://ec.europa.eu/environment/gpp/pdf/toolkit/paper_GPP_background_report.pdf)

• The green house gas (GHG) emissions associated with pulp and paper production are closely tied to energy use. Three other important factors influence net GHG emissions from the fibre life cycle, namely: • The way, in which forests are managed, whether they are replanted after wood is

harvested for paper production. If trees are replanted, CO2 emissions can be considered GHG neutral

• The GHG intensity of the mix of fuels used to supply on-site process heat or cogenerated electricity to the pulp and paper mills

35 Quantitative impacts are estimated based on different studies and related to average figures for craft and paper based (totally or mainly) on post-consumer recovered paper fibres (recycled paper) (“Ökobilanzen für graphische Papiere”, UBA 2000, “Ökologischer Vergleich von Büropapieren in Abhängigkeit vom Faserrohstoff”, IFEU 2006 and “Integrated Pollution Prevention and Control (IPPC) Reference Document on Best Available Techniques in the Pulp and Paper Industry”, European Commission 2001.). 36 Post-consumer recycled fibres refers to paper that has been reprocessed. This may come from consumers, offices, printing houses, bookbinders, or similar. Broke (waste from the paper making process) is not classified as recycled fibre. 37 Technical Guidance Note IPPC S6.01 IPPC Technical Guidance for the Pulp and Paper Sector. Version 2, November 2000


23

• The GHG intensity of the mix of fuel used to generate electricity purchased

externally from the grid

Releases to water Indicative releases to water for an integrated virgin mechanical pulp and paper plant operating ‘best available technology ‘ (BAT), compared with a mill making de-inked paper from recycled fibre are shown below. This shows that for the most part the releases from the recycled fibre mill are the same or lower than the virgin based mill. Type BOD

(kg/Adt) COD (kg/Adt)

TSS (kg/Adt)

AOX (kg/ADt)

P (kg/ADt)

N (kg/Adt)

Source

Integrated mechanical pulp and paper plant (BAT)

0.2-0.5 2-5 0.2-5 0-0.01 0.004-0.01

0.04-0.1 EC 2001 (p38)

Recycled fibre processing – with deinking

0.05-0.02

2-4 0.1-0.3 0-0.005 0.005-0.01

0.05-0.1 EC 2001 (299)

Where: BOD – biological oxygen demand; COD – chemical oxygen demand; TSS – total suspended solids; P – phosphorous; N- nitogen


24

5 Cost considerations

Fibrous raw material costs have an impact on tissue paper prices. As indicated earlier, tissue grades are made from virgin fibre or recycled fibre. Both fibre sources are subject to price volatility and the fibre market has a history of price spikes, for example, there have been significant prices increases over the period June 2009 – May 2010. Bleached softwood kraft pulp (NBSK) rose by 73% over the period June 09 to May 1038 and sorted office waste rose 44% over the same period.39

Although the price increases for pulp and recycled fibre started to ease in late 2010, these significant increases forced tissue manufacturers to seek price increases in 2010.

In addition to fibre costs, tissue mills have very high energy usage in respect of electricity, gas and oil. These energy costs represent around 30% of the total cost of tissue manufacture and any increases in energy have a marked effect on overall manufacturing costs.

Improvements in recovered paper collection systems, together with investment in processing facilities at paper mills means that the costs for producing high quality tissue papers from recycled fibres have decreased in recent years. In the majority of cases, there is an economic incentive for manufacturers to use recycled fibre in their products. Thus, making tissue paper from recovered paper can be slightly cheaper than using virgin pulp. Since competition in the AfH tissue sector is intense, this cost saving is being passed on to the customer. Consequently, there is often a price premium for virgin pulp products over recycled ones.

However, certain technical attributes for recycled tissue products can lead to higher costs. In particular, the well-sorted, high-grade recovered paper needed to produce high quality recycled tissue products can command a price premium.

Indicative prices have been obtained for a range of products across the different product categories and examples of prices (March 2011) for a range of tissue products are given in Table 5.

38 FOEX Indices Ltd 39 www.letsrecycle.com


25

Table 5: Indicative prices for a range of tissue products40

Toilet Tissue € Unit Per sheet FibreBrand A Jumbo roll 2ply 250m 59.21 Pk 6 9.86 0.007 100% recycledBrand A Toilet tissue 2ply 260 sheets 186x125mm 61.49 Pk27 2.28 0.008 100% recycledBrand B Toilet tissue 2ply 260 sheets 186x125mm 61.45 Pk 36 1.7 0.007 100% recycledBrand B Toilet tissue 2ply 198 sheets 31.13 Pk 40 0.77 0.004 100% recycledBrand B Toilet tissue 2ply 320 sheets 40.44 Pk 36 1.13 0.002 100% recycledBrand A Toilet tissue 2ply 243 sheets 79.10 Pk 40 1.9 0.008Brand C Toilet tissue 59.16 Pk 40 1.48Brand D Toilet tissue 12.90 Pk 18 0.72

Toilet roll 2-ply 200 sheets 23.46 Pk 36 0.66 0.004 100% recycledToilet roll 2-ply 320 sheets 30.66 Pk 36 0.86 0.002 100% recycledToilet roll 2ply 410m roll 56.97 Pk 6 9.5 0.005 100% recycled

Brand E Toilet tissue 2ply 200 sheets 24.17 Pk 48 0.5 0.002 100% recycledBrand E Toilet tissue 2ply 320 sheets 25.82 Pk 36 0.72 0.002 100% recycled

Towels € Unit Per towelBrand E Centrefeed 2ply 150m roll 47.55 Pk 6 7.92 0.008 100% recycled

Hand towels 1 ply - 197 C fold towels - Green 59.04 Pk 15 3.93 0.02 100% recycledHand towels 1 ply - 197 C fold towels - White 71.38 Pk 15 4.75 0.025 50% recycled

Brand A Hand towels 3 ply 88 sheets interfold 315x215mm 135.49 Pk 30 4.52 0.018 75% recycled Brand A Hand towels 2 ply 116 sheets interfold 315x215mm 78.50 Pk 15 5.24 0.022 70% recycledBrand B Hand towels 1 ply 175 sheets M fold 206x315mm 109.19 Pk 25 4.37 0.025 60% recycledBrand B Hand towels 1 ply 180 sheets 318x217mm 71.87 Pk 15 4.79 0.027 70% recycled

Prices are extremely difficult to compare as many tissue products on the market do not indicate the nature of the fibres used and there are considerable variations in prices depending on discounts offered for quantity of orders. However the data obtained suggests that recycled papers can be sourced at a similar or lower price than their virgin equivalent in many cases. As expected unbranded tissue products made from 100% recycled fibre are the cheapest. With the towels, the influence of an increasing recycled content on price is more clearly seen and supports the view that the higher the content of recycled fibre the lower the cost of the product.

40 From Office Team Catalogue 2010


26

6 Public procurement needs

6.1 Typical procurement

Hygiene tissue products used in the AfH (away from home) sector are:

Products Formats

Washroom toilet tissue - Bulk pack cut and folded toilet tissue

- Maxi toilet tissue rolls (large rolls)

- Standard size toilet tissue rolls

Hand towels - Paper hand towel rolls

- Folded paper hand towels (C-fold, Z-fold)

Facial tissues - Boxed cut and folded facial tissues

Toilet tissue and hand towels/towelling are the main products used by public authorities. In the AfH market, many tissue producers also make dispensing equipment for their products. These developments have largely been in response to customer demands for ways to extend refill intervals, and reduce wastage, spillage and/or theft of tissue products (e.g. the development of cartridge and single folded-sheet dispensers in some toilet tissue and hand towel applications). As the dispenser size, shape and/or operation may be unique to a single tissue supplier/product, there can be difficulties when changing supplier. However, most tissue suppliers are likely to provide new dispensers when suppliers are changed.

Data on the consumption and spend on tissue products by the public sector in each of the EU countries is not readily available, however an estimation of likely consumption can be made based on employment numbers in the public sector and typical per capita consumption of tissue. Such an estimate indicates a likely consumption of approximately 400,000 tonnes which equates to 20% of the AfH market.

6.2 Purchasing requirements/demands

The key for any purchaser of tissue products is the cost (as discussed in Section 5) and end use performance. The most important end use criteria in this sector are:

• Strength/Wet Tensile Strength – Fibre length and pre-treatment with strengthening agents has an impact on the strength of the final tissue product, which may be a critical property in some applications.

• Softness/Feel – Fibre length and uniformity and also the production and drying method are important to achieve the required softness for facial tissues and premium toilet tissue.


27

• Absorbency – High levels of creping, thicker tissue and other production processes are required to make hand towels highly absorbent. As the uniformity and appearance is often less important, hand towel tissue may not even be deinked.

• Appearance – Colour and feel may be critical factors. White is the most popular colour.

The use of recovered paper grade tissue papers determines how well these factors are incorporated into the final tissue product and thus affects the possibility of using certain grades for certain applications.

Toilet tissue

A large number of AfH tissue manufacturers are using recovered paper for making toilet tissues. The vast majority of economy and own brand toilet rolls are generally made from 100% recycled fibre.

Premium quality toilet rolls with recycled fibre content are also available but are likely to be over-specified for public procurement needs.

Hand towels

Because of the low requirement for softness, the majority of folded hand towels on the market are already made from 100% recycled fibre - in fact in many cases the pulp may not be deinked, and the product dyed blue or green instead.

The premium end of the rolled hand towels sector is likely to be over-specified for public procurement needs. The majority of these products will be less than 75% recycled, and there are some 100% virgin rolled hand towels also on the market.

Facial tissues

Manufacturer ability to utilise high levels of recycled fibre in the facial tissue market is restricted by customer demands for softness. Consequently, it can be difficult to find good quality, high recycled content facial tissues.

Most AfH tissue products are bought directly from distributors (including some of the same ones that distribute printing and writing papers). The products are usually bulk-packaged and often tied to marketing specialized dispensers that encourage brand loyalty. Competition usually revolves around price, compatibility with dispensers, and ease of replenishment.

6.3 Recycled content of different tissue products

Some suppliers reflect different service level requirements in their AfH product ranges. Recycled content products are found across this differentiation, although in general higher recycled fibre can be found in the value and economy ranges.


28

While a large proportion of tissue products on the market in the AfH sector are made wholly or in part from recycled fibres, not all are labelled clearly. In part, this is due to a negative perception of recycled tissue products. Many manufacturer web sites contain information about the fibres used in making a certain brand of tissue paper. However, purchasers need to be aware that some brands differ in their fibre make-up depending on where they are sold.41 This is because of different market requirements in different countries and these regional differences make any quantification of the proportion of products containing recycled fibre virtually impossible.

.

41 Recycled content of European tissue brands – see http://wwf.panda.org/how_you_can_help/live_green/out_shopping/tissue_issues/tissue_brands/


29

7 Conclusions and summary The tissue sector is comparatively small in tonnage terms compared with other main paper and board grades. However, unlike many other grades, the tissue sector has continued to show overall growth year on year since 2005. The European market splits into the consumer (or domestic) sector and the AfH sector. The AfH sector accounts for around 30% of the overall market.

Typical hygiene tissue products used in the AfH sector are: toilet tissue; hands towels and facial tissues. Toilet tissue and hand towels/towelling are the main products used by public authorities. Data on the consumption and spend on tissue products by the public sector in each of the EU countries is not readily available, however estimates indicate a likely consumption of approximately 400,000 tonnes, which equates to 20% of the AfH market.

Tissue paper products for AfH applications are made predominantly from 100% recovered fibre. However, the use of recycled fibre will influence key end use performance characteristics of the final tissue product. This means that for some tissue products the fibre source may need to be a mixture of recycled fibre and virgin fibre. For some products, the fibre content may be 100% virgin fibre.

Prices of tissue products are extremely difficult to compare as many products on the market do not indicate the nature of the fibres used and there are considerable variations in prices depending on discounts offered for quantity of orders. However it is apparent that recycled papers can be sourced at a similar or lower price than their virgin equivalent in many cases. As expected unbranded tissue products made from 100% recycled fibre are the cheapest.

A range of factors throughout the tissue manufacturing and distribution supply chain will impact on GPP considerations. The dominant factor is the fibre used and although tissue products under consideration are, as mentioned before, made predominantly from 100% recycled fibre, some are not. Therefore the GPP criteria proposed will need to cover tissue products based on a) recycled fibres; b) based on mixtures of recycled fibre and fibres from legally and sustainably harvested wood.; and c)based on fibres coming from legally and sustainably harvested wood.

In addition to fibre factors other issues that need to be considered are:

• Energy and water consumption during production - in general the pulp and paper industry is a heavy user of energy and water. The consumption levels vary depending on the grade/type of tissue paper produced

• Emissions to air and water during pulp and paper production – these have been steadily reduced – but reduction of discharges of eutrophic or toxic substances into water still remains a priority

• Hazardous chemical substances – a large number of chemicals are used for process and product enhancements – some can have negative effects on health and the environment


30

• Waste generation – systems need to be in place for the effective handling of waste and

residual products arising from production

• Packaging – this shall not be made from chlorine based plastics and shall follow the principals established in the packaging and packaging waste directive

• Transport/distribution – methods used for delivery and distribution of the tissue products shall be monitored and the carbon footprint related to transport assessed.


31

8 Existing ecolabels and other information sources

8.1 EU Ecolabel and other ecolabels There is a number of Type I42 ecolabels for tissue paper such as the EU Ecolabel, Nordic Swan, Blue Angel, and others. The major aspects of these are compared in Annex 1. In the European market, the most usual ones are the Blue Angel for 100% post-consumer recovered paper fibres (recycled paper); and the EU Ecolabel and Nordic Swan for both recycled paper and paper based (totally or mainly) on virgin fibre. The recommended criteria are based on these ecolabels.

Because the production of recycled paper and paper based on virgin fibre is different, the criteria of the various ecolabels are not the same. As highlighted in Section 2, the production of paper based on virgin fibre is characterised by higher water and energy consumption and emissions to air and water. The EU and Nordic Swan ecolabel criteria focus on these aspects, as well as on the use of chemical products. On the other hand, the Blue Angel criteria for paper based on post-consumer recovered paper fibres concentrate on the use of chemical products in pulp and paper manufacture and on technical performance. Annex 1 presents a comparison of the criteria of these three ecolabels.

Apart from these ecolabels, tissue paper can also be marked with the logos of the FSC or PEFC sustainable forest management systems. These, depending on what they state, can certify that paper is made of 100% recycled fibres or that it contains a minimum percentage of certified sustainable wood fibres. However they do not deal with any other environmental aspects relating to paper production.

• EU Ecolabel - EC: Commission Decision of 9 July 2009 establishing the ecological criteria for the award of the Community Eco-label for tissue paper (notified under document number C(2009) 4596) http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=CELEX:32009D0568(01):EN:NOT

• Blue Angel criteria. Basic Criteria for Award of the Environmental Label for Sanitary Paper Products made from Recycled Paper RAL-UZ5: http://www.blauer-engel.de/en/products_brands/search_products/produkttyp.php?id=459

• Nordic Swan criteria. Ecolabelling of tissue : http://www.svanen.se/en/Svanenmarka/Kriterier/Criteria/?productGroupID=47001

• Other ecolabels http://ec.europa.eu/environment/ecolabel/useful_links/other_ecolabels_en.htm

42 The International Standards Organization (ISO) has categorised the different kind of product labels on the market. “Type 1” labels are those where the underlying criteria are set by an independent body and which are monitored by a certification and auditing process. As such they are a highly transparent, reliable and independent information source for procurers.


32

8.2 GPP Guidance on tissue Although there has not been an EU GPP before, a number of countries have developed criteria for national GPP of Tissue/Toilet Paper. These have been reviewed and compared as part of a larger study that assessed and Compared of National Green and Sustainable Public Procurement Criteria and Underlying Schemes in 10 EU states.43

Austria44 45

The scope of the criteria Austria adopted in 2006 is partially from the “OkoKauf Vienna” and partially from the Austrian Ecolabel. In turn these were based on studying 24 pulp mills and 23 tissue paper mills, taking into consideration the emissions and energy use. A number of key core criteria are set in Austrian for the tissue paper product group. These focus on the following: • Paper shall be made of 100% recycled fibres. • Packaging must consist of paper, cardboard, cards or polyethylene (PE) or polypropylene (PP) film. • Requirements relating to wet strength and elongation. • Dry tear strength. In addition there is a set of advanced criteria, which include the following requirements: • Chemical restrictions o Use of substances that are classified as very toxic, toxic, carcinogenic or mutagenic are limited to 0.1% (R23, R24, R25, R26, R27, R28, R39, R40, R45, R46, R48, R49, R50, R50/53, R51/53, R59, R60, R61, R62, R62). o Chlorine bleach shall not be used for bleaching pulp. o EDTA and optical brighteners shall not be used, neither shall azo dyes that may cleave a particular range of amines. o Use of dyes is limited to kitchen towels, and shall not contain mercury, lead, cadmium or chromium. o Antimicrobials shall not be detectable in the final product (other than paper towels). • Emissions from production phase are established, including chemical oxygen demand (COD), sulphur emissions and CO2. • Raw material: only recycled paper shall be used. • Packaging: any packaging used shall be free of halogenated organic compounds, composites shall not be used, and collection and recycling schemes shall be utilised. Belgium46 The emphasis of the Belgian criteria for toilet and tissue paper is sustainable raw materials, chemical content and packaging. As with other product groups developed by Belgium, this area has a basic set of criteria and an advanced set of criteria, both of which have various levels of criteria to enable extension of the requirements where desired. These requirements are summarised below. The basic criteria include the following technical specifications: • Raw materials: virgin fibres must not originate from forestry environments with a large need for protection for biological and/or social reasons.

43 http://ec.europa.eu/environment/gpp/pdf/Criteria%20and%20Underlying%20Schemes.pdf 44 http://www.nachhaltigebeschaffung.at/node/122 45 http://www.nachhaltigebeschaffung.at/node/124 46http://www.gidsvoorduurzameaankopen.be/sites/default/files/file/20090306_PUB_DOfiche_papieren%20doekjes_uitgebreid_EN.pdf


33

• Chemical restrictions: Chlorine gas shall not be used for bleaching. In addition when awarding the contract, there are a number of additional environmental criteria that can be considered: • Raw materials: virgin fibres must originate from forests that are sustainably managed. Alternatively the fibres used can be 100% recovered paper in the following categories: o Toilet paper must consist of low, medium and special recovered paper grades. o Crepe paper towels must be made of low to medium, kraft-containing and special recovered paper grades. o All other sanitary paper products must consist of at least 60% of low to medium, kraft containing and special recovered paper grades. The advanced criteria, as well as requiring the above also places further restrictions on the use of chemicals. Additional technical specifications are included as follows: • Chemical restrictions: Optical brighteners and dyes must not bleed and no azo dyes or pigments that may release a specified list of amines are permitted. In addition limits are placed on the levels of glyoxal, formaldehyde and chloro-organic substances as well as microorganism growth restrictors used on dry tissue. The following additional environmental criteria are also included in the advanced criteria: Chemical restrictions: • No optical brighteners; no dyes based on heavy metals, aluminium or copper; dyes do not contain phthalates; heavy metal impurities must be below a total content of 100ppm with further restrictions placed on specific metals. • Paper napkins and kitchen crepes must demonstrate high level (5) of colour fastness. • Use of substances classified as environmentally hazardous must be no higher than 2%. • An extensive list of chemical products has restrictions applied ranging from not being deliberately added to the product (APEOs), not be used at all (including EDTA), or to having certain levels which must not be exceeded in use or in the final product (formaldehyde). Many of these will fall into the specific R-phrase categories that are banned: R40, R43, R45, R46, R49, R60, R61, R62, R63, and R68. Complete verification of all requirements is confirmed by award of the Blue Angel, Nordic Swan or EU Ecolabels, while FSC and PEFC certificates confirm raw material compliance. Once again, an alternative is for suitable evidence from a recognised body to be made available instead. Denmark47 The Danish have both a Background Document and an Environmental Guide for this product group that was published in 2005. The Background Document introduces and defines kitchen and toilet paper. It considers the tissue market in Denmark, the life cycle of tissue, the environmental and health impacts of its manufacture as well as the energy consumption. It finally makes recommendations on the selection of the product as well as the use of the product. The Environmental Guide contains the specifics of the criteria requirements as well as suggested questions to ask the supplier covering ecolabelling, product information (weight, proportion of recycled fibres), material information (sourced from sustainable forests , use of bleach, type of bleach) and information about the manufacturer such as whether they have ISO 14001 or EMAS. The key criteria requirements are: • Select products labelled with the EU or Nordic Swan Ecolabels.

47 http://www.miljoevejledninger.dk/vejledninger/personlighygiejne/koekkenogtoiletpapir


34

• Choose low gram weight and sufficient absorbency. • Raw material: Choose tissue paper made from recycled fibres – the recycled fibres content shall be maximised as far as possible. With additional suggestions including: • Raw material: where virgin fibre is used, ensure it is from sustainably managed forests. • Chemical restrictions: use of chlorine containing bleach is not recommended, and ideally unbleached paper shall be used. • Manufacturing conditions: select a manufacturer with an EMAS in place. Verification can be confirmed by using products that have been awarded the Nordic Swan or EU Ecolabel. Finland48 Finland has established a range of criteria that are split into three groups. • The sustainable raw materials criterion requires that at least 15% of raw materials used in production are taken from sustainable forest management produced timber or shall use completely recycled fibre. • The second area of criteria focuses on chemical content: the fibres or tissue paper products must not contain set levels of formaldehyde, glyoxal and PCB (polychlorinated biphenyl). In addition chlorine gas shall not be used as a bleaching agent; however, this requirement does not apply to recycled fibres made during the previous cycle bleaching. Finally in relation to chemical content, a limit of 0.05 kg / tonne of paper is set for the level of organic chlorine compound that may be used in bleaching (specialty products may not exceed 0.25 kg / tonne of paper product). • The final area of the criteria focuses on packaging, taking into account the product packaging and transportation. The Finnish criteria also stipulate that packaging shall not be made of chlorine-containing plastics and where a combination of packaging material are used, they shall be recyclable. Packaging shall be optimised to ensure efficient transportation, and therefore reduce emissions resulting from transportation. Verification guidance is provided against each criterion, and this product group refers to the Blue Angel, the Nordic Swan or the EU Ecolabel or equivalent, together with FSC, SFI and PEFC systems or manufacturers statement relating to bleaching. Various testing methods are cited for verification of recycled fibre content. Germany49 The German information covers toilet paper, paper towels, paper hankies, paper serviettes and cleaning and household wipes. For all of these products the information is the same, and refers the user to the Blue Angel requirements for this product group. The criteria are chemical specific and quite detailed. The tendering recommendations for sanitary papers include: • Only additives listed in the XXXVI recommendation of the Federal Institute for Risk Assessment may be used • Chemical restrictions: glyoxal may not be used in the manufacturing process • No colourants, surface refinements, additives or coatings with specific R-phrases or classified as carcinogenic, mutagenic or teratogenic may be used. • Restrictions are placed on the use of azo colourants and metals in colourants. • Restrictions are placed on the levels of formaldehyde and pentachlorophenol in the final 48http://www.hymonet.com/hymonet/tuotteet_ja_palvelut/pehmopaperi/ 49http://www.umweltbundesamt.de/produktee/beschaffung/doks/tendering_recommendation_for_sanitary_papers.pdf


35

product. • Chlorine and other bleach may not be used in the manufacturing process. • Sanitary papers must meet the legal requirements of the Foodstuffs and Consumer Goods Law. • The paper fibres must consist 100% of recovered paper. • Chelating agents that are biologically hard to biodegrade must not be used e.g. EDTA, DTPA. • Crêpe toilet papers must be made exclusively from recovered paper of the ordinary, medium or special grades (Groups 1, 2 and 5). • Crêpe paper tissues must be made exclusively of recovered paper of the ordinary, medium or kraft and special paper grades (Groups 1, 2, 4 and 5). • All other sanitary papers must consist of at least 60% recovered paper of the ordinary, medium or kraft and special paper grades (Groups 1, 2, 4 and 5 – with the exception of the individual kinds 4.01 and 4.07). Priority shall be given to single-ply crepe papers that are easy to produce instead of multi-ply tissue products that require intensive processing. Germany recommends that products meet the requirements of the Blue Angel Ecolabel. Sweden50 The criteria in Sweden cover soft paper, printer and copy paper, wrapping and envelopes all as one Product Category. For the purposes of comparing tissue and toilet criteria for different countries, the soft paper in the Swedish criteria is particularly relevant. The scope of the Swedish paper products criteria defines soft paper as including; toilet paper, household paper, paper towels, handkerchiefs, serviettes, underlay paper, examining table paper, wash cloths and paper covers. The criteria are split into three sections; mandatory supplier requirements, mandatory requirements on the goods and award criteria. The mandatory supplier requirements focus on packaging to ensure producer responsibility and design requirements for packaging are met. The mandatory criteria for goods state the following: • Pulp used in the paper products shall be bleached without chlorine gas. • AOX release to the environmental receptor e.g. lake or river, is limited. • Limits relating to the annual release of COD, phosphorus, sulphur and nitrogen oxides from the manufacturing of the product. Guidance on the calculation of the release values is provided in a separate attachment to the criteria document. • Legislative requirements relating to general product safety shall be met. • Products conform to all legislation relevant to the product. The award criteria requirements are as follows: • State the carbon dioxide release from non-renewable sources, including the release from electricity production whether or not this takes place at the production site. • The principles for calculating this release are provided in a separate attachment to the criteria document. • The principle for this award criterion is the lower the value the better. Specific verification guidance is given as a section of the product group document. This gives detailed verification guidance for each requirement and makes reference to the REPA registry and/or Swedish Glass Recycling or other in house system for product responsibility, EN standards, third party verification and ISO or EMAS systems.

50 http://www.msr.se/en/green_procurement/criteria/Office/Paper-products/


36

United Kingdom51 The UK criteria are brief and focus on the recycled content of the products, requiring 100% recycled content and this includes only genuine recycled fibre (i.e. no ‘mill broke’), as defined by the National Association of Paper Merchants. No specific verification guidance is given. The current guidance indicates that best practice is now the ecological criteria of the EU Ecolabel for ‘tissue paper100’ – or an equivalent standard. The applicable sections of the EU Ecolabel documents are listed as: emissions to water and air; energy use; hazardous chemical substances; and waste management (as applied to paper production and not general management practices).

8.3 Other Information sources

8.3.1 Websites from the European commission • http://ec.europa.eu/environment/gpp/index_en.htm

• http://ec.europa.eu/environment/forests/flegt.htm

8.3.2 Studies and other information sources

• FSC (Forest Stewardship Council): http://www.fsc.org/en/ • FSC chain of custody standard for companies supplying and manufacturing FSC-certified

products.FSC-STD-40-004(version1-0): http://fsccontrolledwood.org/Documents/FSC_STD_40_004_V1_0_EN_CoC_for_Suppliers_and_Manufacturers.pdf

• FSC on-product labelling requirements. FSC-STD-40-201 (version 2.0): http://www.fsc.org/fileadmin/webdata/public/document_center/international_FSC_policies/guidance_documents/FSC_GUI_40_201_V1_0_Guidance_on_implementation.pdf

• PEFC (Programme for the Endorsement of Forest Certification): http://www.pefc.org

• PEFC Chain of Custody of Forest Based Products – Requirements: http://www.pefc.org/standards/technical-documentation/pefc-international-standards-2010/item/673

• PEFC Logo Use Rules. http://www.pefc.org/standards/technical-documentation/pefc-international-standards-2010/item/674

• CSA (Canadian Standards Association): http://www.csa-international.org

• UK timber procurement website: http://www.cpet.org.uk/uk-government-timber-procurement-policy; http://www.defra.gov.uk/rural/forestry/procurement.htm; http://www.illegallogging.info/uploads/DefinitionoflegalandsustainableFourthEdition.pdf

• Danish Environment Ministry timber procurement website: http://www.skovognatur.dk/Emne/Skov/Miljoe/Indkoeb/ See also http://www.illegallogging.info/approach.php?a_id=95

• Dutch Environment Ministry: http://www.vrom.nl/pagina.html?id=23992

• Study on costs/benefits of Green public procurement in Europe, Öko-Institut & ICLEI 2007, available at: http://ec.europa.eu/environment/gpp/index_en.htm

• Guide to Sustainable Procurement of Wood and Paper based Products - http://www.actionsustainability.com/documents/downloads/Timber%20and%20paper%20Procurement.pdf

• Integrated Pollution Prevention and Control (IPPC) - Reference Document on Best Available Techniques in the Pulp and Paper Industry (BREF report): http://eippcb.jrc.es/reference/

51 http://www.defra.gov.uk/sustainable/government/advice/public/buying/products/paper/spec/paper.htm


37

• Comparison GPP analysis http://ec.europa.eu/environment/gpp/studies_en.htm


38

9 Proposal for the EU GPP criteria A range of factors throughout the tissue manufacturing and distribution supply chain will impact on GPP considerations. Table 6 summarises the main environmental impacts related to tissue paper as previously described in Section 4 and indicates the focus of measures to address these impacts.

Table 6: Key environmental impacts for tissue paper

Impact GPP Approach

Forest destruction and potential loss of biodiversity

Energy and water consumption during production

Emissions to air and water during pulp and paper production

Hazardous chemicals used during production

Waste generation

Excessive packaging

Transport and distribution

Procurement of paper based on postconsumer recovered paper fibres (recycled paper) or paper from legally and sustainably harvested wood

Procurement of paper produced through processes with low energy and water consumption

Avoidance of certain substances in tissue production and bleaching

Good environmental management practices

Avoiding the excessive use of packaging materials and reducing the content of hazardous substances and materials in the packaging material

Use of environmentally friendly transport for delivery of products

The consequences of these key impacts and the issues and factors referred to in existing standards and ecolabels , as reviewed in Section 8, are taken into consideration in the proposed GPP criteria. The major issue is the fibre source. As already discussed, tissue paper products for AfH applications will be made predominantly from 100% recycled fibre. However, the use of recycled fibre will influence, as discussed in Section 6, key end use performance characteristics of the final tissue product. This means that for some tissue


39

products the fibre source may need to be a mixture of recycled fibre and virgin fibre. In other cases, some products, notably facial tissue, the fibre content may be 100% virgin fibre.

For these reasons the criteria proposed cover tissue products based on a) recycled fibres; b) based on fibres coming from legally and sustainably harvested wood; and c) based on mixtures of recycled fibre and fibres from legally and sustainably harvested wood.

For the purposes of these criteria legally harvested wood is defined in the EU Timber Regulation of 2010 as “harvested in accordance with the applicable legislation in force in the country of harvest” covering the following matters:

• Rights to harvest timber within legally gazetted boundaries

• Payments for harvest rights and timber including duties related to timber harvesting

• Timber harvesting, including environmental and forest legislation including forest management and biodiversity conservation, where directly related to timber harvesting

• Third parties’ legal rights concerning use and tenure that are affected by timber harvesting

• Trade and customs, in so far as the forest sector is concerned

Sustainably harvested sources are defined as harvested from forest which also has certification from a third party scheme such as FSC or PEFC. The certification verifies compliance with applicable managerial, environmental and social legislation via a reputable risk assessment procedure.

a) Recycled paper (based on recycled fibres) The Core criteria propose the purchase of paper made from 100% recycled paper fibres, consisting of recycled fibres from both post consumer and pre-consumer fibres. Depending on their end use source, these fibres will consist of low, medium, kraft containing and special waste paper grades. All bleached papers are processed using at minimum an Elementary Chlorine Free (ECF) bleaching process. The paper must be purchased from suppliers that have a Type 1 ecolabel. The Comprehensive criteria also stipulate the purchase of paper from suppliers with a Type 1 ecolabel and that the paper is made from 100% recycled paper fibres that include both post-consumer recycled fibres and pre-consumer recycled fibres from paper mills with a minimum of 90% post-consumer recycled fibres. Furthermore, all bleached papers are processed using a Totally Chlorine Free (TCF) bleaching process. b) Paper made from virgin fibres coming from legally and sustainably harvested

wood The Core criteria propose that at least 50% of the virgin fibres will originate from sustainably managed forests certified by independent third party schemes. All bleached papers are processed using at minimum an Elementary Chlorine Free (ECF) bleaching process. The paper must be purchased from suppliers that have a Type 1 ecolabel.


40

The Comprehensive criteria demands that at least 75% or more of the virgin fibres shall originate from sustainably managed forests certified by independent third party schemes. Again the paper must be purchased from suppliers that have a type 1 ecolabel. Additionally, all bleached papers must be processed using a Totally Chlorine Free (TCF) bleaching process c) Paper made from a mixture of recycled fibre and from virgin fibres coming from legally and sustainably harvested wood Irrespective of the ratio of recycled to virgin fibres in tissue products made from a mixture of both, each type of fibre used must meet the Core or Comprehensive criteria applicable for their particular category. The ratio of recycled fibre to virgin fibre in the product shall be stated. .


41

9.1 Verification issues

Verification of the GPP core and comprehensive criteria can be made through the use of appropriate certification of product and supplier attributes. In Europe, many paper companies have sought to reduce their environmental impacts by establishing environmental management systems in their factories and certifying their products with one or several ecolabels. In addition, fibre use may be accredited through one or more of the forest accreditation schemes, e.g. FSC or PEFC for example. In such cases, only chain of custody certification is relevant to products, as forest management certification pertains only to forest management. Many manufacturers’ web sites contain information on which accreditations they hold.

The ecolabel certification will normally be based on the one hand the product specific criteria and, on the other hand, the assessment or verification methods aimed at checking compliance with these criteria. The supporting documents may consist of declarations by the producer or by the supplier, technical and/or product safety sheets; calculation formulas, laboratory tests results, etc. Where criteria are based on ecolabels, the easiest way to prove compliance will be through the possession of the relevant ecolabel. Contracting authorities shall ask for copies of all relevant accreditations relevant to the proposed product purchase from the selected bidders. If the relevant tissue paper product is not ecolabelled or has no forest accreditation (where appropriate), the contracting authority needs to allow bidders to present other supporting documents as means of proof.


42

10 Relevant European legislation and policies In general terms, there is little European legislation that relates directly to paper as such. However, there are several regulations that affect the sector (the following list is not exhaustive): • Timber-Regulation (EU) No.995/2010 of the European parliament and of the Council of

20 October 2010 laying down the obligations of operators who place timber and timber products on the market. http://ec.europa.eu/environment/forests/timber_regulation.htm

• The Integrated Prevention and Pollution Control (IPPC) legislation 2008.

Directive 2008/1/EC of the European Parliament and the Council of 15 January 2008 concerning integrated pollution prevention and control. See also http://europa.eu/legislation_summaries/environment/waste_management/l28045_en.htm

• The Large Combustion Plant Directive 2001/80/EC of the European Parliament and of the Council of 23 October 2001 on the limitation of emissions of certain pollutants into the air from large combustion plants. See also http://ec.europa.eu/environment/air/pollutants/stationary/lcp.htm, or the Waste Incineration

Directive 2000/76/EC that regulate air emissions - Directive 2000/76/EC of the European Parliament and of the Council of 4 December 2000 on the incineration of waste. See also http://ec.europa.eu/environment/air/pollutants/stationary/wid.htm

• Directive 2003/87/EC of the European Parliament and of the Council of 13 October 2003 establishing a scheme for greenhouse gas emission allowance trading within the Community and amending Council Directive 96/61/EC (Text with EEA relevance). See also http://www.europeanenergyforum.eu/archives/european-union/eu-general-topic-file/eu-environment/third-energy-package-climate-action-and-renewable-energy/amending-directive-2003-87-ec-so-as-to-improve-and-extend-the-greenhouse-gas-emission-allowance-trading-system-of-the-community

• The Water Framework Directive 2000/60/EC of the European Parliament and of the Council of 23 October 2000 establishing a framework for Community action in the field of water policy. See also http://ec.europa.eu/environment/water/water-framework/index_en.html

• Directive 2002/61/EC of the European Parliament and of the Council of 19 July 2002 amending for the nineteenth time Council Directive 76/769/EEC relating to restrictions on the marketing and use of certain dangerous substances and preparations (azocolourants). See also http://ec.europa.eu/enterprise/sectors/chemicals/documents/reach/archives/market-restrictions/amendments_en.htm

• Commission Regulation (EC) No 1451/2007 concerning the placing of biocidal products on the market which repeals Regulation (EC) No 2032/2003. Most of the operational provisions of Regulation (EC) 2032/2003 remain essentially the same, save for minor adaptations (changes in numbering; adaptation of references to other Articles or Annexes; etc.). - http://ec.europa.eu/environment/biocides/regulation.htm


43

• The REACH regulation for the approval of new chemicals - Regulation (EC) No 1907/2006 of the European Parliament and of the Council of 18 December 2006 concerning the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH). See also http://ec.europa.eu/environment/chemicals/reach/reach_intro.htm

• Council Directive 75/442/CEE of 15 July 1975 on waste and its amendments - Directive 2006/12/EC of the European Parliament and of the Council of 5 April 2006 - http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2006:114:0009:0021:EN:PDF

This legislation is the key relevant legislation for pulp and paper factories in Europe. In addition to these, it is necessary to mention the FLEGT (Forest Law Enforcement Governance and Trade) action plan adopted by the EU in 2003. The Action Plan outlines a series of measures to address illegal logging both in the countries concerned and within the EU as a timber importer. As mentioned before, in relation to procurement the Plan has defined a timber licensing system to guarantee the legality of certain imported timber products. In order to obtain the license, Voluntary Partnership Agreements (VPAs) have to be signed between timber-producing countries and the EU. Timber products, which have been legally produced in VPA partner countries, will be licensed with a FLEGT license for the legality of production by a third-party, and only licensed products from these partner countries will be allowed access to the EU52 53.

52 Article 4, paragraph 1 of the Council Regulation (EC) No 2173/2005 of 20 December 2005 on the establishment of a FLEGT licensing scheme for imports of timber into the European Community. See http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2005:347:0001:0006:EN:PDF 53 This system is similar in effect to other systems already in place in several international agreements, including, amongst others, the Convention on International Trade in Endangered Species (CITES) and the Kimberley Process on conflict diamonds, which feature licence or permit systems, and tracking mechanisms, designed to exclude particular categories of products from international markets. The regulation to implement the FLEGT licensing system was adopted by the EU Council in December 2005; further details will be agreed during 2007. The licensing system is built up through a series of bilateral agreements with major timber-producing and -exporting partner countries .See http://www.katoombagroup.org/~foresttr/documents/files/doc_1021.pdf


44

11 Annex I – Comparison of ecolabel criteria

General area - Fibres

EU Ecolabel criteria Nordic Swan criteria Blue Angel criteria

At least 50% of virgin wood fibres shall be proven to come from sustainably managed certified forests

The remaining virgin wood fibres shall come from forests that are managed so as to implement the principles and measures aimed at ensuring sustainable forest management.

The origin of all virgin fibres used shall be indicated.

The fibre raw material in the paper may be recycled or virgin.

Virgin fibre must come from certified forest operations and not from protected forest environments*. The pulp manufacturer must document the origin of the fibre. The paper manufacturer must ensure that fibre raw materials (wood) do not come from forestry environments with a large need for protection for biological and/or social reasons. Annually at least;

1. 20% of the fibre raw material in the paper must come from certified forestry operations

2. at least 75% of the fibre raw material in the paper must come from recycled fibre, woodshavings or sawdust, or

3. a combination of 1 and 2. If the fibre raw material in the paper consists of less than 75% recycled fibre wood shavings or sawdust, the proportion of fibre raw material from sustainable forestry must be calculated as follows.

Requirements as to the proportion of certified fibre raw material in the paper (Y) Y(%) 20 – 0.267x

100% post-consumer recovered paper only. The following product/waste paper grades are specified • Toilet crepes – grades 1,2 and 5 • Crepes paper towels – grades 1,2,

4 and 5 • Other sanitary products – at least

60% grades 1, 2, 4 and 5 Note: Waste paper grades 4.01 (New shavings of corrugated board; New shavings of corrugated board with covers made of kraftliner or testliners, and 4.07 (Unused kraft papers; shavings and other kraft paper and boards, unused, natural coloured - must not be used


45

Where x = the proportion of recycled fibre, woodshavings or sawdust

*In some cases, Nordic Ecolabel allows fibre from forests which have not been certified to an approved standard providing credible documentation is provided which demonstrates a sustainable forestry operation and fulfills the same level of requirements


46

Emissions to water and air


CO2

CO2 emissions shall not exceed 1,500 kg/Adt

Detailed calculation showing compliance required

Pulp manufacturer must calculate CO2 emissions on the basis of the quantity of fuel used to meet heat requirements. Emissions of CO2 deriving from the combustion of fossil fuels must not exceed threshold CO2 values set for each pulp type.

Not specified

Emissions to air of suphur (S), nitrous oxides (NOx) chemical oxygen demand (COD) and phosphorous in water (expressed as PCOD, PS, PP and PNOx) from the production of pulp and paper54

PCOD, PS, PP or PNOx ≤ 1.5 points

PTotal (=PCOD+PS+PP+PNOx) ≤ 4.0 points

PCOD, PS, PP or PNOx ≤ 1.5 points

PTotal (=PCOD+PS+PP+PNOx) ≤ 4.0 points

Not specified

54 The calculation of PCOD (as well as PS, PP and PNOX) are made in the following way. For each pulp ‘I’ used the related measured COD emissions (CODpulp I expressed as kg/ADt) shall be weighted according to the proportion of each pulp used (pulp I with respect to ADt tissue paper). The weighted COD emission for the pulps is then added to the measured COD emission from the paper production to five a total COD emission, COD total. The weighted COD reference value for the pulp production shall be calculated in the same manner, as the sum of the weighted reference values for each pulp used, and then added to the reference value (reference values for tissue are provided) for the paper production to give a total COD reference value (COD reftotal). PCOD is derived as follows:


47

Emissions to water and air

EU Ecolabel criteria

Nordic Swan criteria Blue Angel criteria

AOX

The weighted average value of AOX released from the production of pulps used in the eco-labelled tissue product must not exceed 0.12 kg/ADt. AOX emissions from each individual pulp used in the paper must not exceed 0.25kg/ADt

AOX emissions into water must not exceed 0.05 kg/ADt AOX (special tissue products such as handkerchiefs) must not exceed 0.25k/ADt AOX emissions from each individual pulp must not exceed 0.40 kg/tonne The weighted average value of AOX released from pulps must not exceed 0.25kg/tonne paper

Not specified

Chelating agents

Not specified Pulp manufacturers need to specify the quantity of EDTA and DTPA as kg/tones used per 90% tonne and emissions of DTPA/EDTA to the recipient environment (does not apply to pulp mills using <1.0kg DTPA/EDTA per 90% tonne pulp

Waste paper treatment shall be carried out without poorly biodegradable chelating agents, such as EDTA and DTPA.

Chlorate

Not specified Chlorate emissions from chemical pulp production must be measured twice per year Measurements not necessary if

• The pulp mill does not produce chlorine dioxide

• The effluent water from the production of chlorine dioxide undergoes chlorate reduction

Not specified


48

Energy and fuel use EU Ecolabel criteria

Nordic Swan criteria

Blue Angel criteria

2,200 kWh/t

Applicants are required to calculate all electricity used in the pulp and tissue paper production stages. The electricity calculation does not include electricity used in transporting raw materials, converting, packaging, or waste water treatment and air cleaning.

Energy use requirements are imposed on both pulp and paper manufacturers in terms of limitations on the use of energy in the

form of fuel and electricity. The principle is that an energy score for pulp and paper production is calculated on the basis of reference energy use

together with the manufacturer’s

information on total energy consumption per tonne pulp/paper. Tables specifying fuel use and electricity used by each manufacturing stage are

provided.

Not specified


49

Hazardous Chemical substances


Chlorine

Chlorine gas is not permitted as a pulp bleaching method

Chlorine gas is not permitted as a pulp bleaching method

Compulsory - Total chlorine free (TCF) only. Chlorine gas and halogenated bleaching agents are not allowed

APEOs

Banned – APEO’s must not be added to:

-cleaning chemicals

-Foam inhibitors

-dispersants

-coatings

Banned – APEO’s must not be deliberately added to production chemicals and products. Signed declarations required from suppliers of the following: -cleaning agents and dispersants -de-inking chemicals -coating chemicals -foam inhibitors and defoamers.

Not specified

Surfactants in deinking formulations for recycled fibres

Where surfactants use ≥100g/ADt – each surfactant must be biodegradable to OECD 301-A-F or equiv. ISO std.

Where surfactants are use ≤ 100g/ADt – each surfactant must be biodegradable (OECD 301 A-F) or ultimately biodegradable (OECD 302 A-C)

Where surfactants use ≥100g/ADt – each surfactant must be biodegradable to OECD 301-A-F or equiv. ISO std. Where surfactants are use ≤ 100g/ADt – each surfactant must be biodegradable (OECD 301 A-F) or ultimately biodegradable (OECD 302 A-C)

Not specified

Biocides

Are not potentially bio-accumulative.

Are not potentially bio-accumulative.

Only those substances may be used as biocides in the manufacture of products which are listed as so-called ‘existing substances in Annex II to Commission Regulation (EC) No 2032/2003

Residual monomers

Not specified Polymer products (coating chemicals, retention agents and wet strength agents*) may contain a maximum of 100ppm residual monomers (calculated on the dry matter content of the product) classified as environmentally harmful with risk phrase R50,+R53, R51+R53 or R52+R53 or classified as harmful to health with risk phrases

Not specified


50

R45, R46, R60 or R61.

700ppm limit set for acrylamide in coating chemicals and retention aids

*Epichlorohydrin is regarded as a residual monomer in this requirement

Foam inhibitors / defoamers

Not specified Risk Phrases R50+R53, R51+R53 or R52+R53 need to be absent from constituent substances that have a foam inhibiting or foam retarding effect

Not specified

Wet strength agents

Must not contain more than 0.7% of the chloro-organic substances, epichlorohydrin, 1, 3-dichloro-2-propanol and 3-monochloro-1, 2-propanediol (MCPD), calculated as the sum of the three components and related to the dry content of the wet strength agent.

Wet strength agents which contain glyoxal must not be used

Maximum of 0.01% chloro-organic compounds (e.g. epichlorohydrin, dichloroisopropanol, and chloropropanediol) classified as environmentally harmful or harmful to health in accordance with EC Directive 67/548/EEC, is allowed

Products shall be manufactured without wet strength or dry strength agents. Glyoxal containing auxillaries shall not be used.

Softeners, lotions, fragrances and additives of natural origin

Constituent substances must not contain Risk Phrases R42, R43, R45, R46, R50, R51, R52 or R53.

Fragrances must comply with the Code of Practice of the International Fragrance Association

Perfumes or other scents must not be actively be added to the paper product

Not specified

Slimicides and anti-microbics

Tissue product must exert no growth retardance of microorganisms according to test method EN1104



Formaldehyde

≤1mg/dm2 to test method EN 1541

≤1mg/dm2 to test method EN 1541

≤0.5mg/dm2 to test method EN1541


51

Glyoxal

≤1.5 mg/dm2 to test method DIN 54603

≤1.5 mg/dm2 to test method DIN 54603

Limit not specified. Products are required to be manufactured without glyoxal-containing auxiliaries

PCP

≤2mg/kg to test method EN ISO 15320

Not specified ≤0.15mg/kg to test method EN ISO 15320

PCB

Not specified ≤2mg/kg to test method EN ISO 15318

Not specified

Bisphenol A

Not specified Not specified Determined once per year to test method EN 645

Auxiliary chemicals

Not specified Auxiliary chemicals used on Yankee cylinders must contain no more than 0.05% by weight low-molecular organic compounds based on the dry matter content of auxiliary chemical

No colorants, surface finishing agents, auxiliaries and coating materials may be used with the following Risk Phrases, R40, R43, R45, R46, R49, R60, R61, R62, R63 and R68 or which according to the current version of TRGS 905 are classified as carcinogenic, mutagenic or reprotoxic substances.

Dyes and optical brighteners

No bleeding according to test method EN 648, latest edition, level 4-5

No bleeding according to test method EN 648, latest edition, level 4-5

No optical brighteners shall be used.

• Paper napkins and kitchen crepes – level 5 must be reached to test method DIN 646.

Kitchen towels and serviettes – migration of optical brighteners – stage 5 to test method DIN 648

Dyes and inks

Dyes and inks must not be based on cadmium or manganese

Azo dyes or pigments which release amines listed in Directive 2002/61/EEC are not to be used

Dyes classified as environmentally harmful in accordance with EU Directive 99/45/EC shall not be used Dyes for printing and dyeing shall contain a maximum of 2% of weight of substances classified as environmentally hazardous in accordance with EU Directive 67/548/EEC. Does not include dyestuffs that

Dyes and pigments containing mercury, lead, cadmium or hexa-valent chromium compounds must not be used Azo dyes or pigments which release amines listed in Directive 2002/61/EEC are not to be used


52

are fixed to fibres >98% and which do not appear on the Products Register (Sweden), List of undesired substances (Denmark), and the Environmental Authorities’ Warning List (Norway) Dye stuffs or pigments in dyes must not be based on aluminium or copper, with the exception of copper in phthalocyanine. Impurities of Pb, Hg, Cr and Cd in dyes must not exceed 100ppm Limit values applied in the case of individual substances in direct dyes – Pb 100ppm, Hg 4ppm, Cd 20ppm and Cr 100ppm Limit values applied in the case of individual substances in pigment dyes: Pb 100ppm, Hg 25ppm, Cd 50ppm and Cr 100ppm. Phthalates shall not be present

Azo dyes or pigments which release amines listed in Directive 2002/61/EEC are not to be used

Adhesives

Not specified Adhesives used in production, conversion and packaging shall not contain APEO’s, phthalates, halogenated solvents or ethylene glycol ethers classified as harmful to health in accordance with EU Directive 67/548/EEC with the risk phrases R60 or R61

Not specified

Product function / physical properties

Not specified Absorbtivity – at 5g water/g paper measured for 30 seconds according to test method ENV 126-8 Strength of paper longitudinally and over the perforation = ≥2 to test method EN 12625-4:1999 Toilet paper wet strength – no strength when wet (wet tensile strength ≤10% in machine direction

Not specified


53

Packaging

Not specified Packaging must not be made from chlorine-based plastics Combination packaging must be recyclable Adhesives used in packaging shall not contain APEO’s, phthalates, halogenated solvents or ethylene glycol ethers classified as harmful to health in accordance with EU Directive 67/548/EEC with the risk phrases R60 or R61

Not specified

Waste management

Documented system needed for handling waste and residual products arising from production plants.

Documented system need to account for both pulp and paper manufacturers:

• How sorting at source is carried out

• What fractions are sorted

• How individual fractions are disposed of

• Annual quantities of each waste fraction

Not specified

Fitness for use

Note confirming the product is fit for purpose

Not specified Not specified

Consumer information

Eco-label shall include the following text:

• uses sustainable fibre

• low water and air pollution

• low greenhouse has emissions and electricity use

Not specified Not specified

Draft Technical Background Report on Tissue Paper

Documents

Transcript of Draft Technical Background Report on Tissue Paper