Recycled Content Certification

The use of recycled content in manufacturing is an important strategy to reduce carbon emissions and should be encouraged for all products and packaging. Verus allows manufacturers to obtain affordable third-party certification of recycled content for any product. Verus utilizes a combination of ISO 14021 standards, EPA and FTC guidelines to establish a protocol. Pre-consumer and post-consumer designations are evaluated and indicated on customized symbols. Recycled content is expressed quantitatively as a percentage. Total proportion of recycled materials is considered by mass for the product and or product packaging.  

Verus can also calculate the reduction of environmental impact that results from using recycled content through a Life Cycle Assessment.

PRE- and POST-recycled content percentages can be combined in a total amount. However, most customers demand that content is broken-out into different percentages as follows.

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PRE-Consumer Content

PRE-consumer recycled content is defined as materials that are diverted from the manufacturing waste stream and used to make a new product. Normally, the materials are purchased from companies that collect discarded waste from other manufacturers. To qualify, the materials must be considered a waste product and not normally reused by industry within the original manufacturing process. Paper product scraps that must be re pulped can be considered PRE-consumer content.

POST-Consumer Content

POST-consumer recycled content is designated as materials used in manufacturing that are diverted from the consumer waste stream.

Bringing Clarity to Recycled Content Certification

If your company is in the paper-making business chances are good that you sell products with recycled content. Whether you manage a mill or handle the marketing for your company, it is important to understand all of the rules behind recycled content labeling.

The first symbol for recycled content, the Mobius Loop, was created by Gary Anderson in 1970. Now the symbol helps to describe a number of specific product content claims including post-consumer and pre-consumer waste. Over the years standards and guides were created to help define these marketing claims.

Standards and guides are generally beneficial as they encourage transparency and help to level the playing field among competitors. Problems arise when room is left for interpretation. Due to differences in the standards it is difficult to find consistency without having a knowledgeable third party involved. Currently, there are two major standards and two guides that cover the use of recycled content in paper products in some form or fashion:

1. ISO 14021,
2. ASTM International D5663,
3. Federal Trade Commission (“FTC Guide”), and the
4. EPA Comprehensive Procurement Guidelines.

Each has their strengths and weaknesses.

The ISO standard benefits from international acceptance. The language is fairly straightforward and easy to comprehend, especially regarding symbol usage. ISO briefly qualifies “pre” and “post” consumer waste without much detail. Unfortunately, ISO standards conflict with the EPA and FTC guidelines regarding classification of “material returned from the distribution chain” as post-consumer waste.

The ASTM International standard does a very good job of covering details specific to packaging paper and paperboard. They focus on measurement procedures and include an example of how yield factors effect calculations. Strangely, the ASTM standard leaves out “pre” and “post” consumer definitions.

The FTC guide touches on the differences between pre and post-consumer waste, but spends more time clarifying marketing. Many of the examples are worth exploring, as they are specific to, or can be applied to the paper industry:

FTC Example 1 speaks to the fact that “spilled raw material and scraps left over from the ‘original’ manufacturing process,” should not be counted as recycled material. “Original” is a key word to the paper industry as it refers to the pulping process, and should not be confused with scraps from a finished product. Although the FTC does not clearly define how to classify these scraps, the EPA does (read on).

FTC Example 6 refers to a laminated product, where one of the layers contains recycled content but the others do not. The example states, “one of the three layers of this package is made of recycled plastic.” This is not unlike combining fibers with recycled content and coatings made from virgin materials. Although it is possible that a coating may be interpreted as “minor” or “incidental,” it also can make up 35% of the content—something to watch out for.

FTC Example 9 should be of particular interest to large manufacturers that make paper with 100% virgin and recycled content on the same line. Example 9 allows claimants to express recycled content percentages for a single product, but does not allow several different products from the same line to be included in the “weighted average of recycled materials.” Ironically, limiting the calculation to an individual product may discourage the use of recycled content and does not fully credit the paper industry for more cost-effective and sustainable practices.

Although the EPA Comprehensive Procurement Guidelines on paper products acts as a buying guide for federal agencies, the EPA clarifies the FTC guidelines regarding the classification of scrap or mill broke from manufacturing. Mill broke can not be considered “recovered” or recycled fiber, however, it is defined as “any paper waste generated in a paper mill prior to completion of the papermaking process.” Recovered fiber is also known as pre consumer or post industrial. Finally, the EPA differs from ISO Standards, claiming materials that are returned before they are used by a consumer are considered pre-consumer waste.

Properly defining recycled content for your products can be very confusing especially if you run a large, vertically-integrated operation. Before you set your recycled content designations in stone, be sure to read through all the standards and guidelines very carefully. If you decide to take this task on yourself make sure your substantiation documents can be accessed electronically—this will save you a lot of effort if you are ever challenged or you decide to secure third-party certification of your recycled content.

FTC, Part 260 – Guides For the Use of Environmental Marketing Claims  (260.7 e. Recycled Content)