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…”

Clearly, many companies are taking sustainability seriously and looking for ways to do business in more environmentally responsible ways. More and more manufacturers and business partners are offering programs and solutions to help them do just that. And in most cases, those programs and initiatives are launched in good faith.

That said, as the sustainability movement gathers steam, the risk of “green-washing” is always a concern. So it’s important to invest due diligence in making sure the products you buy and the programs you subscribe to are legitimately green. When evaluating sustainability claims, the same principle applies to “going green” that applies to commerce in general – buyer beware. It’s important to look beyond the hype, to steer clear of unsubstantiated claims and demand credible proof of sustainability from prospective technology partners.

Want to be sure a potential partner really is green? Challenge them to demonstrate truly green manufacturing processes. How are they heating and cooling their production facilities? How do they deal with waste? Is sustainability designed into the products? Do the printers support recycled papers? Are they energy-efficient – or better still – ENERGY STAR certified? Do they emit ozone – and if so, how much? What about heat and noise? Has the technology partner taken steps to reduce the use of toxic materials? Because if there are no toxic materials in the device, there won’t be any toxins entering landfills. Are the products manufactured using bio-friendly or recycled materials? Does the vendor offer any programs to help you achieve your goals of becoming carbon-neutral? Or programs to keep products from landfills?

These are all key considerations if you want to make an informed and responsible purchasing decision. By all means, choose a partner that reduces, recycles and re-uses materials. Ask if they have sustainable processes for handling waste and emissions and transporting materials. And ask for evidence that sustainability is being incorporated into strategic planning cycles. A prospective partner may not satisfy every criterion, but it’s safe to say that if they meet several, you’re in good hands.

For example, Océ has a dedicated Asset Recovery Facility and has implemented programs to keep products from entering the waste stream prematurely. Through remanufacturing policies, Océ sent only six percent of industrial waste to landfills and reused or recycled 89 percent. Océ has also developed an online eco-calculator and launched the Eco-Start program, which gives customers a huge head start in achieving carbon-neutral operation by planting trees to offset new products’ energy emissions for a year.

Beyond ensuring that the production device you’re considering buying is manufactured in a environmentally responsible manner and built to reduce environmental impact, there are things print providers can do right now to make a difference. These include:

• Reduce, re-use, recycle & promote two-sided printing within your organization
• Whenever possible, use recycled papers
• Understand the chain of custody associated with paper and use virgin fiber sourced from well-managed/sustainable forests or pulp farms
  (FSC-certified or Sustainable Forestry Initiative certified)  
• Only engage with vendors and partners who can demonstrate that they maintain green business practices.
• Explore ways to become more carbon-neutral and request an energy audit to calculate your carbon footprint
• Look for vendors who offer programs that offset carbon or energy emissions produced by their production devices.
• Determine if you’re compliant with regulatory agency guidelines
• Promote two-sided printing
• Discuss “green” and digital print-on-demand options with your customers

And don’t forget to track, report, market, promote and publicize your green efforts.

On August 20, 2009 the first provisions of the CARD Act go into effect. By this date, card issuers must have made the changes necessary to ensure that:

• - Cardholders have a minimum of 21 days to pay their bill;
• - Cardholders receive 45 days’ advance notice of significant changes to their card agreements;
• - Notice is provided that cardholders have a right to opt out of significant changes in their account terms, including interest rate and fee increases, as long as they are not more than 60 days overdue on their payments.

These provisions will have significant benefits to cardholders and will require extensive systems and programming changes for card issuers, but they pale in comparison to what’s in store for 2010.  By next year, the CARD Act will fundamentally change the way credit card issuers advertise, market, and bill credit cards. The majority of these changes will need to be in place in little more than 6 months, only 9 months from passage of the law. Tick. Tick. Tick.

 Beginning in February 2010, the CARD Act entails changes that impact what card issuers can charge, who they can charge and how and when those terms are disclosed. The overarching theme is “Plain Language and Plain Sight” and affects the layout of every solicitation, application, notice, and periodic statement delivered to consumers. The Federal Reserve has been tasked with providing model disclosures, which are to be updated regularly, based on government-sponsored reviews of the market, empirical research and direct consumer testing.

In addition to disclosing terms, card issuers are required to provide information to consumers on the consequences of their financial decisions such as how long it would take to pay off the existing balance, and the total interest cost if the consumer paid only the minimum due each month. In addition, all terms and contracts must be made available online for easy comparison and monitoring.

 What’s at stake for card issuers and banks? An estimated 15 billion in annual revenue from late fees alone, the cost of retrofitting existing contracts and communications while issuing new (more profitable) products and the cost of lobbying against additional reforms likely to be imposed on the lending industry.

What’s at stake for service providers? Potentially a one-time opportunity to help your customers gain efficiencies by introducing them to new marketing techniques such as transpromo and relevant personalization that can make all of their documents more efficient and effective.

Card issuers are challenged to analyze, redesign and reprogram each of their marketing and customer communications over the next 6 months. Are you ready to help? Tick. Tick. Tick.

 (Stay tuned for the next post covering changes to individual communications mandated by the CARD Act of 2009)