FSC® certification (along with PEFC Certification, a scheme much more common globally than in the US) is a critical component of building a long-term future in which our paper packaging can be net neutral (or even net positive!) for the planet. That said, our research has shown that FSC® certification cannot be relied upon as a crutch or a panacea and has had some negative consequences for our primary forests that should be acknowledged. Brands that want to truly pave the way to building a greener future can use FSC® certified paper, but we believe they should do so only as a stepping stone as they innovate towards recycled or next-generation fibers.

There are three critical points to recognize regarding FSC-certified wood fibers.

1. FSC® certified forests are still deforested.

A study by Resources For the Future compared 64 FSC® certified forest units in Mexico with non-certified ones and found no difference in deforestation rates. Another study found that FSC® certified forests in the Indonesian part of Borneo had slightly lower deforestation rates than non-certified timber in the same area. This same study found that these certified forests had more “holes'' in the canopy (or more significant degradation) created by small clearings within the forests. According to Mongabay, a few other studies have found only minor reductions in deforestation rates in certified forests. According to a Yale Environment 360 article, one 2016 meta-analysis of scientific studies found that FSC® certification in the tropics has reduced degradation and improved labor and environmental conditions in the affected forest, while other rigorously designed studies looking at overall deforestation indicate that FSC® certification has had little or no effect.

2. There is a lot of fraud and illegal wood being sold under Chain of Custody FSC® certification.

According to the same Yale Environment 360 article, “many logging companies appeared to obtain an FSC® certification for management practices on one forest, and then use it to cast a halo over their far more extensive dealings in forests elsewhere, with little regard for sustainability or even legality.” In 2014, Greenpeace called out FSC® for allowing certified loggers to ravage the Dvinsky Forest in Russia, highlighting the fact that FSC® can only go so far to protect forests when companies are so motivated to pursue logging efforts in old-growth regions to meet continually increasing demand for wood pulp.

3. Even if FSC® certification was perfect (and it is not), there isn’t enough FSC® certified forest product, given our current use of virgin wood.

About 10 percent of the world's pulp supply is FSC® certified, according to Liza Murphy of FSC®. As of September 2017, about 198 million hectares of forests are FSC® certified, mainly in Europe and North America. However, wood in countries home to our critical Tropical Forests (across Asia, Africa, and Latin America) is far less likely to be FSC® certified and accounts for just 16 percent of FSC® certified forestry.

The logging, pulp, and paper industries have controlled the narrative that “trees as packaging” is universally good for the planet. They have created a perception that because trees are renewable and paper is curbside recyclable, the material is “virtuous” and does not need to be improved.

This is untrue, and we believe it has been - in part - a deliberate attempt to stifle innovation and progress with respect to non-tree inputs, including agricultural waste, grasses, hemp, and more. As with all things related to sustainability, we cannot rely on a monopolistic, single source for our inputs into any material or energy source. This approach will continually deplete our natural resources faster than we can replenish them. Instead, we need a diversified mix of sustainable inputs to create the paper and fibers humans use.

There are many articles out there arguing that cutting down trees to make paper is good for our planet. They claim that because trees can be replanted, logging is a net neutral (or even net positive) step for the planet. Unfortunately, because of how heavily our world relies on trees now - for lumber, paper, and many fabrics - these trees can't be produced in net neutral ways. Inevitably, trees must be cut down in intact forests. These gorgeous, adult trees are typically replaced by single species (over time, destroying our forests' critical and beautiful biodiversity).

Alternatively, many trees come from monocrop tree plantations, in which trees are not sequestering the level of carbon, supporting the level of diversity, or supporting the water cycle in the way intact or even second-growth forests can. In some instances, natural lands (including carbon-rich regions such as prairie lands) are converted into monocrop tree plantations.

Most of these articles are written by industry groups created by or funded by paper companies. These industry groups are the ones most vocally objecting to policies being put forth to help increase the use of recycled content, improve our recycling infrastructure, and put broader bans on single-use grocery bags rather than simply banning plastic grocery bags. Some of these articles even equate FSC® certified and recycled paper as equally good for the environment.

This piece does not intend to discredit every data point shared by industry groups! Likewise, we do not want to discredit the many ecological advancements that pulping and paper milling operations have made over the past few decades. These include using wood chips from logged trees as a source of energy, closed-loop water usage, and releasing water back to the environment. These are wonderful breakthroughs worth celebrating.

LCA tools are imperfect and based on several assumptions - which are sometimes hidden from the end user.

Everyone wants to quantify aspects of this environmental crisis - including us at EcoEnclose. We want exact and agreed-upon numbers about how much carbon can be emitted into the atmosphere, how much carbon a product emits, or how to compare the eco-impact of two options exactly.

Unfortunately, agreed-upon calculations are not feasible because each one relies on numerous assumptions, studies, and analyses. Moreover, each of these pieces is contested and (even when they are agreed upon) changes with new information.

With this in mind, we believe it is essential for any LCA user to understand the fundamental assumptions that go into the calculations they receive. Users can then put their data in context, make informed decisions about which LCA is suitable for them, and use the output to make truly beneficial decisions for the planet.

Indeed, several popular packaging LCA software is available today - Trayak and Sphera being two notable examples - will output results indicating that virgin paper emits less carbon than recycled paper.

This is due to two crucial assumptions they are making:

1. Logging is a net carbon-neutral operation, and no carbon losses are associated with cutting down trees.
2. Wood chips and black liquor from these logged trees are waste products of the input so that they can be applied as a carbon-negative energy source. This means these LCAs are making the pulping process of virgin trees energy “negative” but treat the repulping process of recycled paper as energy-consuming.

We believe these assumptions go against basic common sense. We are not surprised that the vast majority of environmentally-focused scientists also disagree with these assumptions and approaches, with their (far more analytically derived) concerns outlined in a variety of statements and articles, including these:

• Meeting GHG reduction targets requires accounting for all forest sector emissions
• Letter from scientists to the EU parliament regarding forest biomass

There are a variety of LCAs that do not make these two assumptions. Nevertheless, we have chosen to use the Environmental Paper Network for two reasons.

1. It is free and accessible to all, meaning that any brand we work with can analyze us for verification.
2. They have published every assumption that goes into their analysis, rather than keeping these assumptions hidden - which all paid LCA software systems do.

The EPN does not assume logging is a carbon-neutral activity. Instead, they factor in the analyzed impact of cutting down a long-standing tree - an approach most climate scientists believe is essential to achieving emissions goals.

Like all LCAs, EPN has to make various assumptions to attempt to quantify paper production's impact ideally. It is also imperfect. However, after evaluating the assumptions and motivations of EPN versus Trayak and Sphera, EcoEnclose has chosen to use EPN as our preferred LCA system for paper.

We also recognize that their detailed assumptions can also be contested. With this in mind, we don’t treat EPN’s results as gospel. Instead, we review its results and process them as critical inputs into a broader decision-making process.

Step 1: Trees are logged. Trees can be logged from natural forests or tree plantations. Natural forests can include old or second-growth forests, typically including a wide range of tree species, plant species, and animal species. They can be tremendous biodiversity, carbon sequestration, and water retention hotspots. Tree plantations are purely planted for commercial reasons. They consist of vast swaths of land in which one or two species of trees are planted to minimize future logging costs and species protection issues. Up to 300 trees are planted per acre, and chemicals are often applied to reduce the natural growth of native flora and fauna that might interfere with the rapid growth of trees. In addition, tree plantations tend to be evenly aged, posing higher fire risks than natural forests.

Trees can be logged in several different methods:

• Clearcutting: A designated area is fully cut down, destroying the entire ecosystem in an area and releasing a tremendous amount of carbon into the environment rapidly.
• Shelterwood: In this method, trees of a similar age and size are removed, allowing mature trees to support the growth of saplings.
• Selective Cutting: Trees of a specific size, age, or quality are cut.

Step 2: Once the logs are cut and removed from the plantation or forest, they are shipped to their next destination. Here, logs are stripped from the logs, and this waste product is used, often to generate electricity. The debarked logs are then chipped.

Step 3: These woodchips undergo chemical or mechanical pulping, where the lignin breaks down to produce pulp or lap. At this stage, a tremendous amount of heat is often applied to “dehydrate” the wet lap. This process is required if the lap is being shipped far distances (to minimize the weight and volume of what is being shipped).

Step 4: The lap is either rehydrated (or not, if it remained wet lap), and is then meshed, screened, and dried, across a massive wire section, allowing the material to take the shape of large sheets of paper.

Step 5: Chemicals are applied to the dried paper to improve properties as needed (i.e., turning the paper white, dying the paper another color, increasing water absorption, increasing water phobic properties, adjusting printing properties, etc.)

Step 6: Paper is pressed to remove 50% of the water content, then heated and dried. At this stage, it is ready to be converted into its final form - printing paper, corrugated cardboard, paperboard, toilet paper, etc.

As described above, we use the EPN’s life cycle analysis, which calculates virgin linerboard paper as having 3.8x the carbon impact of recycled linerboard.

This means - if you were to make your packaging decision on a pure carbon basis - recycled paper would have to be almost four times as heavy as the virgin paper you are switching to for the net carbon impact of these solutions to be equivalent.

Some point to transportation, saying that the thinner virgin paper will require fewer trucks for freight. In LCAs we conduct using Trayak and Sphera software, transportation accounts for less than 3% of the carbon footprint of our packaging; so, even if thinner paper makes transportation more efficient, it is unlikely to result in enough carbon savings to account for the massive benefit of using recycled paper.

So, even from a pure carbon emissions perspective, downgauging is unlikely to make virgin paper as eco-friendly as recycled paper.

Additionally, this idea that carbon emissions of the paper itself also misses much of the point!

This type of analysis does not account for the water usage, ocean acidification, and pollution caused by virgin paper, or the massive impact of deforestation on carbon emissions, water health, and biodiversity.

Primary forests cannot simply be replanted. We have to ensure trees don’t get cut down there in the first place. Primary, intact forests are a vast, beautiful, and powerful interconnected network of species - from algae to earthworms to mushrooms to caribou.

Unfortunately the logging, paper, and pulp industries have taught us to see trees as quantifiable commodities. One tree (regardless of what it is, where it is and how it exists in its environment) equals a set amount of carbon and value. Because this logic is pervasive, logging companies have claimed “sustainability” (and even received FSC® certification) by planting a tree every time they cut down a tree.

This doesn’t make sense on many levels.

Companies are typically replanting just a single species of tree when they log into diverse primary forests, which dismantles the critical network of species that coexist and are essential to a forest’s ability to thrive and capture carbon. As this network is upended, the ability for newly planted trees (and long-standing trees) to thrive diminishes. This manufactured approach also makes forests more susceptible to pests and wildfires, which are increasingly becoming major contributors to climate change and deforestation.

Lastly, on a pure carbon basis, cut-down old-growth trees have more carbon sequestered than a newly planted tree can hope to capture in 40 years. “Responsible logging” in intact boreal, tropical, and rainforests should be kept to an absolute minimum, allowing these regions to regenerate and thrive.

Because the demand for virgin wood products is still rising, we continue to experience rapid loss of primary forests.

Again, an estimated 12 million hectares of forestland are lost annually.

While the most significant drivers of this are land use changes for agriculture, the rising demand for paper packaging is undoubtedly having an important impact.

Canada’s boreal forest is the world’s largest intact forest but has the third highest rate of primary forest loss in the world due to skyrocketing demand for paper products (and is unfortunately also used as a major source for toilet paper). Loss of tropical primary forests also persists. The three most recent years with available data (2016, 2017, and 2018) experienced the three highest rates of primary tropical forest loss since the turn of the century.

Even if your brand is sourcing all of your virgin paper from FSC® certified wood that comes from well-run plantations, you are still contributing to the growing demand for virgin wood that (1) inevitably puts pressure on primary forests and (2) supports a future world in which the vast majority of our fibers come from trees derived from either forests or monocrop tree plantations. This is particularly important to recognize as more and more brands leap paper instead of plastic.

Suppose you are building a brand that is truly dedicated to a more sustainable future and to operating your business in a way that is net neutral or even net positive long-term. In that case, it is essential that you - as an industry leader in sustainability - find ways to use recycled content and build demand for the right next-generation and thoughtfully selected and well managed on-purpose crops (such as bamboo, hemp, and miscanthus).

Paper can only be recycled a finite number of times, so yes - it is true that any world with recycled paper must rely on a source for virgin paper. However, this mentality can breed laziness, something we (the collective community of eco-conscious brands) cannot afford.

If all brands that have set sustainability goals and consider themselves eco leaders defaulted to this argument, companies would collectively (1) put undue pressure on virgin tree fiber and primary forests, and (2) neglect two critical steps of moving the paper industry to a far more sustainable and diversified future. When brands that have made authentic commitments to sustainability recognize how important it is to innovate beyond virgin tree fiber (even FSC® certified virgin tree fiber), it will help drive:

• Critical improvements to paper recycling including increasing paper recycling rates and extending the number of times that recyclers can recycle paper before it is no longer usable.
• The introduction of next-generation agricultural waste and other non-tree fibers into our paper stream.

While paper products are recycled at higher rates, there is undoubtedly much more we can do across the US and the world to make drastic improvements.

We need to increase the amount of paper that is recycled.

In 2018, about 65% of paper was recycled. While this is undoubtedly a high number (especially when compared to plastic and glass!), that still leaves us with 35% of paper, which is unrecycled. Over 21 million tons of paper were used and not recycled in 2018! Paper based items account for 25% of the volume in the landfill! Every time paper is landfilled instead of recycled, it represents a missed opportunity to create recycled (rather than virgin) paper and produces landfill methane (which, in the US, is the third largest contributor to greenhouse gas emissions). As the supply of recycled paper becomes more limited (causing it to be more expensive), the fact that our country is discarding this much paper is particularly frustrating!

We need to improve the paper recycling infrastructure.

Paper fiber lengths get shorter each time they are recycled, which is one primary reason why recyclers can only recycle paper a limited amount of times - currently about 5-10 times - before it reaches the end of its useful life. In reality, most paper is not recycled this often (because a third of paper ends up not getting recycled, most virgin paper may only be recycled one or two times before being discarded). But, as we fix this (per the above point), we’ll also want to improve our recycling infrastructure to help make the recycled paper stronger and more usable across many applications. Examples of infrastructure improvements include:

• More precise sorting at the MRF to maximize the value of each bale sold
• De-inking and screening technology advancements to make recycled paper pulp more usable for various printing and packaging use cases.
• Expanded acceptance of non-white paper for printing and packaging. Even as our paper usage is increasing, our use of white copy paper has decreased significantly. Unfortunately, this means recycled white paper is increasingly difficult to come by. In many cases, the need for white paper is simply a brand requirement, not a functionality requirement.

Most paper packaging solutions we offer are made with 100% recycled content.

That said, we offer two solutions - Glassine Bags and GreenWrap - that are made with virgin fibers from certified sustainable trees that do not come from intact forests. As described above, we recognize that while getting to 100% recycled content and incorporating next-generation fibers is ideal, it is not always feasible. GreenWrap and glassine bags both currently require virgin fibers due to their tensile strength and fiber length requirements. That said, we are actively working to introduce recycled content and/or next-generation fibers into these product lines.

Additionally, we offer 100% recycled alternatives to both products - 100% Recycled Kraft Bag & Seal and a variety of 100% recycled void fill options. While the alternatives we offer are not the same and do not have all of the same functional specifications, we hope they help enable some brands to choose recycled.