ISO versus the FTC on Post Consumer Waste
By Vic Barkin on November 15th, 2010
Ever heard this one before? A print buyer sends the specs for a job specifying “recycled paper”.
We’re talking about recycled “content” here, which is simply any percentage of the paper made from fiber (paper) that has been diverted from a waste stream. This is further broken down into pre- and post-consumer waste components. Commonly, but not always, it’s only the post-consumer portion that’s reported on invoices or printed on the piece its self.
Now, especially since the FTC’s proposals for their new Green Guides have hit the streets, many potentially-effected entities are waiting for the storm concerning the definition of post-consumer waste. This may not seem like a big thing, but it is.
It’s more important than ever now to define “recycled content”. For instance, did you know that under the FTC’s current as well as their proposed guideline, a specific edition of printed matter, say a magazine issue, can be considered either pre-or post-consumer waste depending on where it lives when it’s recycled?
Post-consumer reclaimed/recycled/recovered waste/fiber (PCW or PCRF) definitions are going to become a touchy issue in the coming months. Once the FTC codifies their definition, it will become the de facto standard, and no matter which way the wind blows, the FTC will wind up continuing to put their definition at odds with the interests of others.
The current FTC Guides provide that marketers may make a recycled content claim from materials which have been reclaimed either during the manufacturing process (pre-consumer) or after consumer use (post-consumer). This sounds pretty straight-forward.
Furthermore, the FTC aligns their definition of PCW with that of the EPA’s: “Fiber such as paper, paperboard, and fibrous materials from retail stores, office buildings, homes, and so forth, after they have passed through their end-use as a consumer item; all paper, paperboard, and fibrous materials that enter and are collected from municipal solid waste.”
ISO 14021 however defines post-consumer as: “Material generated by households or by commercial, industrial and institutional facilities in their role as end-users of the product, which can no longer be used for its intended purpose. This includes returns of material from the distribution chain.” A definite difference of opinion.
When it comes to paper certification schemes, under current standards, both FSC and SFI subscribe to the FTC/EPA definitions (SFI actually requires alignment with the FTC rulings no matter what), however PEFC adheres to the ISO definition. That’s where the fun begins.
In response to the new FTC draft, many mills, recyclers and other groups have commented on the wisdom of the ISO definition noting that the FTC Guides should incorporate those definitions of post-consumer recycled content because competing definitions currently cause consumer confusion.
The reality can be summed up to intent. Is the intent that all material in its finished form has an equal recycled value no matter whether it has reached the end user/point of intended use or not? One can certainly argue that a publication which is remaindered (i.e.; never distributed) being exactly the same product as one that was read by the end-user, has exactly the same value in the recovery stream.
We don’t know as of yet which way the FTC will decide to go, but one thing is certain. Somebody’s not going to be happy. If the Guides are published as proposed, does it mean that merchants and printers need to watch all imports for the stated PCW content because they adhere to the ISO definition? Or will international mills have to adjust their PCW standards for exports to the US? It does present an interesting conundrum.
If FTC does adopt the ISO definition what happens to the FSC standards? Will they lower them to fit? Probably not, partially because of one interesting development; FSC released new trademark standards this past spring. The recycled mobius which used to convey the PCW content now conveys all recycled content. I find this a highly interesting development in conveying the message that reclaimed materials as a whole are equally valued.
As a final comment and case study, NewLeaf Reincarnation Matte was first released as a 50% pre and 50% post-consumer waste product (now 60% PCW). Under FSC standards both then and now, in order to use an FSC Recycled label there had to be at least 85% PCW, which meant that although 100% recycled, the FSC Mixed label with a 50% in the mobius had to be used for this product. Now under the new standard, though it’s still an FSC Mixed product, the mobius can state 100%. As Arte Johnson used to say, “Verrry Interesting…”