ISRI’s 2021 Summer Board of Directors and Committee Meetings began Tuesday, July 13, and ended Friday, July 16. Here are some highlights from the Paper Division meeting on Thursday, July 15.
The Paper Division meeting began with an international trade update from Adina Renee Adler, ISRI’s vice president of advocacy. Adler discussed Malaysia’s guidelines for the import of recycled commodities, which include recovered paper. Developed by SIRIM-QAS, a government-owned company, the guidelines are for pre- and post-shipment inspection of materials bound for Malaysia. Though most of the information available about the guidelines concerns metals, much of it applies to recycled paper, too. Only a manufacturer or a subsidiary of a manufacturer can make the imports; a third-party trader broker is not eligible. Volume is based on the quota of raw material required not to exceed maximum annual production. Importers must provide a bank guarantee based on the maximum shipping and incidental costs.
Adler explains that the guidelines are based on Malaysia’s Environmental Quality Act 1974, which relates to the prevention, abatement, and control of pollution, and enhancement of the environment. For paper, Malaysia will change the code it uses for the material standards from BS EN 643 2014 to MS EN (P) 643:2021. Importantly, there is zero tolerance for scheduled waste, under which plastics fall based on the 1974 law. While there’s still a ban on mixed paper, ISRI reminds members to ensure full compliance by eliminating plastics in paper grades prepared for export to Malaysia. There also is a new process to become a trusted shipper, but questions remain, including the cost, process, and the paperwork involved. ISRI will continue to track this issue.
Danielle Waterfield, ISRI’s chief policy officer, provided an update on the Extended Producer Responsibility (EPR) legislation recently passed by legislatures in Oregon and Maine. According to Maine’s law, the state Department of Environmental Protection (DEP) must commence a regulatory rulemaking by Dec. 1, 2023, to define what is “readily recyclable,” along with establishing the producer fee schedule, municipal reimbursements, program goals, and education and infrastructure investments. The DEP also needs to select and define the enforcement and oversight duties of an approved industry packaging stewardship organization (PSO). ISRI hopes to further develop relationships with regulators, along with DEP staff and offer the industry’s extensive expertise to help guide these determinations.
Like Maine, Oregon’s Department of Environmental Quality (DEQ) will determine what is recyclable. The agency is explicitly required to consult with and seek out guidance from a advisory board, which is defined in the legislation. Though the board does not have binding authority in law, the legislation strongly encourages the department and the Producer Responsibility Organization (PRO) to consider and include its recommendations. There are four slots on the board for organizations that represent recyclers.
David Wagger, Ph.D., ISRI’s chief scientist and director of environmental management, updated the division on issues surrounding a group of chemicals known as PFAS. Currently, 15 states have or are considering bills that address PFAS. Several measures would prohibit the sale of food packaging and certain other products that contain PFAS. Legislation in most of the proposed bills would only apply to food-grade paper packaging that has PFAS intentionally added.
For the most part, ISRI has seen that most legislation does not necessarily mention or specifically exclude the incidental presence of PFAS, such as through recycled feedstock materials. However, ISRI has seen universal bans introduced in the recent past by lawmakers unaware of the science and logistics of the subject. This issue could potentially affect any recycled paper provider if producers of food packaging sold in states with PFAS bans become concerned about their feedstock. ISRI is watching this issue carefully, and urges paper members in every state to engage with their regional chapters to educate state lawmakers on the subject.
Another way chemicals can affect commodity paper is with the Toxic Substances Control Act (TSCA). Earlier this year, the Environmental Protection Agency (EPA) issued a final risk evaluation concerning a chemical that’s used in some inks and colorants, pigment violet 29 (PV29). The EPA determined that recycling of materials containing PV29 poses potential unreasonable risk to human health through inhalation. The EPA is now required to write regulations to manage that risk, which could affect anyone who handles such materials, including paper used in commercial printing. Wagger notes ISRI is aware of the issue and plans to be involved in the process with the EPA as the agency develops new TSCA regulations.
The division meeting concluded with a request for proposals for the Paper Spotlight presentation at ISRI2022, which will be March 21-24 in Las Vegas. Contact Rebecca Turner, ISRI’s vice president of education and events, for more information. The deadline for Paper Spotlight submissions is Sept. 21. General educational session proposals can be submitted here on or before Tuesday, Aug. 3.
Image courtesy of ISRI.