FSC is misleading Canadians, say its key packaging customers

The Canadian branch of the Forest Stewardship Council (FSC) is trying to distance itself from a promotional video that has angered its Canadian packaging customers. But the video itself, with two demonstrably false claims in it, still remains accessible to the public on FSC Canada’s website.

When it launched the video last month, FSC Canada was proud to claim ownership, calling it “our” new video while baldly declaring that paper and paperboard packaging can be ‘’a product of deforestation or poor forestry practices.’’

The industry’s environmental council (PPEC) objected to this industry smear, laying out the facts in Canada and calling on FSC to remove any references to deforestation. FSC has not done that. But it has changed the wording of its website introduction to the video. It now reads: “Unfortunately, deforestation occurs in other parts of our world. It is important to check that the packaging you purchase does not contribute to deforestation.”

This is certainly an improvement on what was there before, but the video itself is unchanged and still available to the Canadian public. This is what’s wrong with it.

THE BIG DEFORESTATION LIE

First, there’s the big lie about deforestation. The video claims there’s a link between packaging and deforestation. But it doesn’t offer any evidence for this. All FSC Canada has come up with so far is two articles. One refers to the recent opening of a road in the Amazon. But the article doesn’t even mention packaging. The major cause of deforestation in Brazil is cattle ranching and agriculture, according to the World Wildlife Fund (WWF).

The second article supplied by FSC Canada doesn’t mention packaging either. This opinion piece is now 11 years old and quotes data that’s even older than that. And it’s not solely about deforestation, it’s about loss of forest cover, which includes forest lost through fire and insect infestations (which can be considerable). And again, there’s no mention of Canada.

So FSC Canada has provided absolutely no proof to date of its claimed linkage between packaging and deforestation. And it certainly won’t be able to do so for Canada. Because there is none. As we detailed in an earlier blog, Canada’s overall deforestation rate from all causes is extremely low, one of the lowest in the world at 0.01 per cent.

The specific rate for the Canadian forestry industry as a whole is a mere 0.0004% (mainly because of the creation of permanent access roads into the harvest areas), with packaging’s share of that a big fat zero. That’s because most of the boxes and cartons made by Canadian mills are 100% recycled content. The few freshly-cut trees that the industry uses for packaging are harvested from forests that are regrown afterwards. That’s the law in Canada. It stays as forest. It’s not deforestation. Packaging and forestry facts

FALSE IMAGE

And then there’s the false image that smears the whole industry. The video uses an image of a clear-cut to symbolise deforestation. Unfortunately for FSC, the major cause of deforestation in Canada is not the forest industry but rather the conversion of forest land to agriculture. FSC Canada knows this because it’s written on its website! So why not use an image of a deforested field of farmer’s hay or gently waving corn to illustrate the facts instead of unfairly smearing the forest and paper industries with the image of a clear-cut? All FSC is doing for a Canadian millennial watching this video is perpetuating a false image of forestry as the major cause of deforestation. It’s not. Dare we mention hypocrisy here? On the one hand, FSC is using the image of a clear-cut to symbolise nasty deforestation. Its other hand is stretched out for forest certification cheques from logging or forest companies that happen to use clear-cutting methods to harvest trees.

CANADA LEADS THE WORLD

Finally, the video makes a bald and unsubstantiated claim that paper and paperboard packaging can be a product of “poor forestry practices.” FSC doesn’t define what these “practices” might be but suggests you’ll be OK if you certify your packaging with FSC. Fair enough. This is a commercial. But what it doesn’t say to our poor confused Canadian millennial, is that Canada leads the world by far in the amount of forest independently certified as being sustainably managed. Almost 40% of the world’s entire certified forest is right here in Canada. That’s “poor forestry practices”? Packaging and certification
Not only that, every single mill member of PPEC (the Canadian industry’s environmental council), already has independent chain-of-custody certification for its operations in Canada. Some of them with FSC, some with its competitors the Sustainable Forestry Initiative (SFI) and the Canadian Standards Association or PEFC, some with two certifiers, some with all three federally-recognised certifying agencies.. That’s not poor forestry practices. That’s responsible sourcing writ large. In summary, the Canadian industry has been badly and unfairly smeared here. We can handle the truth, but the truth has not been told in this video. We are the good guys! We cause zero deforestation; have more forest certified as sustainably managed than anyone else in the world; every single mill member of PPEC has responsible (chain-of-custody) certification; we’re high in recycled content (mostly 100%); and our used packaging is the most widely recovered of all materials. FSC should be holding us up as a model for the rest of the world to aspire to. Not smearing us with lies and half-truths.

FSC misleads Canadians, smears paper packaging

An open letter to Francois Dufresne, President and CEO of Forest Stewardship Council (Canada)

Dear Mr. Dufresne:

I recognize that FSC is in a three-way fight for market share in the forest and paper certification business, and that part of that fight is your recent launch of a new video plug for FSC aimed at the users of paper packaging.

Actually, as a commercial it’s not bad. Congratulations. Except for the big lie, or maybe I should say the totally misleading perception that the video leaves about paper packaging and deforestation. Because your slick commercial perpetuates a forestry myth, broadly smearing the Canadian packaging industry in the process.

The video begins well though. Some ”70% of consumers want the packaging of the products they buy to be sourced responsibly.” Couldn’t agree more. Wish it was higher. The good news is that every mill member of PPEC already has proof of responsible sourcing: independent third-party chain-of-custody certification as to where its fibre comes from, whether recycled or virgin.

But then comes the smear. “Paper, board and bioplastics can be a result of deforestation or poor forestry practices.” Can be? What does that mean? Could be? Or maybe, might not be? Which is it? And where’s the evidence, the examples, for this link you make between packaging and deforestation? Unfortunately, your video doesn’t provide any. Just smears everyone.

When you posted your commercial on Linked-In, I challenged you to provide specific examples of situations where trees used for packaging were harvested from forests that were not later regrown. Because that’s the law in Canada, as you know, Mr. Dufresne. Any provincial (crown) forest land that’s harvested must be successfully regenerated afterwards, either naturally or artificially (through tree planting or direct seeding).

A week went by with no answer, and then you posted the clip again. This time I pointed out (as if you didn’t already know) that the United Nations does not consider deforestation to have occurred when a forest is returned to forest. That is, when it remains as forest and is not converted to non-forest uses such as agriculture, oil and gas projects, hydro-electric development, residential subdivisions, and so on. (I’ve attached a link to a UN definition of deforestation for your benefit).

But you already know this. . You acknowledged this when you responded to my second Linked-In comment, and it’s posted on your website: : Deforestation, clearance or clearing is the removal of a forest or stand of trees where the land is thereafter converted to a non-forest use. (Underline added).

And how much of Canada’s forest land was converted to non-forest use in the latest data year? According to Natural Resources Canada, about 37,000 hectares or just 0.01 per cent. And how much of that conversion of forest land to non-forest land was the forest industry responsible for? Well, a smidge under 1400 hectares. Do the math. That means that the forest industry’s deforestation rate was a mere 0.0004 per cent.* Yes, that’s three zeroes and a four.

But that’s the total forest and paper industries combined (lumber, pulp, newsprint, everybody). What about packaging’s contribution? Well it may come as a surprise to you, Mr. Dufrense, but hardly any freshly-cut trees are used to make paper packaging in Canada at all. In fact, most boxes and cartons made by Canadian mills are 100% recycled content. So basically, they are not responsible for any deforestation. Nada. So why are you smearing the paper packaging industry in Canada and their customers with this deforestation BS? Why are you perpetuating this myth? It’s inaccurate, dishonest, and a smear on the whole Canadian industry.

Oh no, we meant global forests, you say, referring to an article (written over 10 years ago!) about the 10 countries with the worst deforestation rates in the world (not including Canada, of course). I’m sorry Mr. Dufresne, but that’s not good enough. You posted this as president and CEO of FSC Canada, and the video is proudly displayed on the FSC Canada website. People are entitled to assume you are talking about Canada. The buck stops with you.

If FSC Canada wants to have any credibility with the paper packaging industry and its customers, I would strongly suggest that you immediately remove any reference to deforestation in your commercial. And I will be among the first to commend you for your honesty.

Yours sincerely,

John Mullinder

Executive Director, PPEC

This letter first appeared on the PPEC website on April 8, 2020

 

Packaging stewards should be rewarded for using recycled content

Recycled content is central to the “Circular Economy” approach that Ontario and some other provinces say they want to adopt. It keeps raw materials flowing through the economy longer, reduces the pressure to extract more virgin materials from the earth, and delays their eventual disposal as waste. It’s something which governments say they want to encourage, and for which stewards of paper products and packaging should be rewarded.

The Canadian paper packaging industry has spent millions of dollars over the years investing in cleaning and screening machinery so that it can re-use and recycle recovered paper. Packaging mills in Southern Ontario led North America in recycling old boxboard for the first time back in the 1990s. Today, some 94% of Canadians can recycle it. And today, most of the corrugated boxes and boxboard cartons made in Ontario are continuously made from 100% recycled content, a circular achievement in and of itself.

The paper packaging industry gets no credit for this effort, while in the commercial marketplace it competes against mostly virgin packaging alternatives. We have suggested the province level the playing field by setting a target of 40% average recycled content for all packaging sold in Ontario by 2020 and an average of 70% within 10 years. This would place Ontario firmly on the path to the circular economy it says it wants, and create a more level playing field between materials at the same time.

An alternative to provincial regulation is a recycled content credit within the Blue Box funding formula itself. This is not a new suggestion. The producer responsibility organisation in Quebec, Éco Entreprises Québec, already has one. And while Stewardship Ontario does float the idea of a recycled content credit in the draft outline of the new Blue Box plan it is currently working on, its support seems rather tepid.

That’s because some Ontario stewards have objected to the concept in the past. Here are three historical objections, and our responses to them.

  1. That assessing recycled content is an administrative burden and costly to track and report.

We think this objection is way overstated. For paper materials we have independent third-party certifiers and chain-of-custody certifications as to where paper materials are coming from, whether from virgin or recycled sources, or a mix of the two. Chain-of-custody certification is an environmental metric supported by the global Consumer Goods Forum, of which most leading Canadian brands and retailers are members.

Making suppliers prove that they have internationally accepted chain-of-custody certification would seem to reduce the administrative burden on stewards and provide a good kick-start to the circular economy at the same time. It would also force other materials to develop chain-of-custody certification programs if they haven’t already done so.

Or stewards could use independently certified industry averages. PPEC has been tracking its members’ use of recycled content for over 25 years and it’s quite willing to open its books to a confidential third-party review. A sliding scale of recycled content usage would reward a lot more stewards and probably be more palatable and make any administration easier. Besides, won’t the new body Ontario has created to bring in the Circular Economy (the Resource Productivity and Recovery Authority) be monitoring this anyway?

  1. The funds to credit stewards using recycled content must come from other stewards (i.e. it is cross-substitution).

Well yes, it is. That’s why you do it, to encourage other stewards to be more circular, to reduce the overall environmental burden of the basket of goods that is the Blue Box, for the common benefit. This is the very same principle that’s supposed to apply to those materials that are recycled through the Blue Box versus the ones that are not. What’s the difference? It’s the same principle of rewarding preferred behaviour.

  1. Federal regulations limit the use of recycled content in food-contact packaging. Making recycled content a requirement would be unfair to those stewards.

First, federal regulations on food-contact packaging apply to all materials (i.e. it is material-neutral). Second, recycled content is not excluded. Food safety is the key issue and the onus is on the brand owner to guarantee food safety, whether through Health Canada “No Objection Letters” or through FDA approvals. It comes down to the material’s direct and indirect contact with the food and the element of risk to humans.

Is it unfair to single out “food” stewards?  No. They choose to be producers of foods and the safe delivery of food is part of that. Just as a producer of a washing machine or a microwave is “forced” to use a large package to have his or her product delivered. Or a perfume manufacturer with an elaborately designed stand-out boxboard carton. All choose of their own free will to be in those lines of business. That’s the game they’ve chosen to be in. Whether they can use recycled content or not in their delivery packaging is part and parcel of that original choice.

In summary, rewarding those who use recycled content is a good, fair, and effective way to achieve a circular economy and to level the playing field between “circular” and “non-circular” performers. Isn’t that what we’re supposed to be doing?

China doesn’t want the world’s garbage any more

And who can blame them? For years, the world has been shipping all sorts of waste to China for it to be sorted, made into new products, and shipped back to us. Low labour rates and lax environmental enforcement have benefited all parties to this commercial deal (even perhaps the Chinese workers, a job being better than no job).

One of the first warning signs of impending change occurred in 2013 when China launched “Operation Green Fence” to limit imports of scrap materials. Unscrupulous people were sending more garbage than resources. This was followed by the more recent “National Sword” crackdown on smuggling operations. Then last week, China shocked the global recycling industry with the announcement of a scrap import ban effective the end of this year.

“To protect China’s environmental interests and the people’s health, we urgently adjust the imported solid wastes list, and forbid the import of solid wastes that are highly polluted” read China’s filing of intent with the World Trade Organisation. Details were scarce beyond general statements about multiple plastics, mixed paper, textiles, and other materials. But the impact of the announcement itself has been significant.

The Institute of Scrap Recycling Industries (ISRI) called the new move potentially “devastating” and “catastrophic” for the US recycling industry. The Bureau of International Recycling (BIR) labelled the new policy as “serious” and wants more time before it comes into effect.

For Canadians involved in the international recovered paper trade, the challenge is that no one yet fully understands exactly what will be banned. The wording that is being used is “unsorted paper” and “mixed plastics.” If this is taken literally then most of the Canadian paper fibre currently being exported to China will not be impacted. The Green by Nature consortium that handles British Columbia’s Blue Box materials, for example, sorts all residential paper and does not ship single stream (or mixed) unsorted material to the republic.

Al Metauro on world's garbage going to China“If this is not acceptable,” says consortium partner Al Metauro, CEO of Cascades Recovery, “then we will have a challenge. The challenge will not be on the curbside fibre but rather on the demand for old corrugated containers (OCC). The Chinese mills rely on imports and with no curbside fibre they will need an alternative. On the other hand, the Chinese government could also ban imports of OCC considering some of the poor quality being shipped.”

Metauro says a ban on “mixed plastics” will impact material recovery facility (MRF) operators that are not sorting their plastic, glass and metal recyclables (the container stream). This will be a bigger challenge in the US, he says, where many program operators are currently shipping commingled single stream material direct to China. In British Columbia, by contrast, all residential plastics are sorted and consumed locally.

Paper, paper, everywhere, and not a scrap to waste

Every Tuesday night I come face-to-face with the twin issues of consumption and “sustainable materials management” or the latest buzzword favoured by governments, the “circular economy.” For Tuesday night is Recycling Night.

From the bathroom and bedroom, I gather toilet rolls and tissue, envelopes and writing paper. From the kitchen and dining room, I grab the box of recyclables holding newspapers, cartons, cans, jars, and bottles; the special food scraps bag (made of compostable paper, of course) that’s stored under the sink; and the small “garbage” bag of other stuff. Then I head for the big carts parked in the garage before wheeling the appropriate ones (this week, recycling and organics) out to the curb for the morning pick-up. All told, it takes me maybe five or ten minutes. And I feel good about it, doing my little bit for the circular economy.

What I have learned from this exercise is that education and convenience are key. It is very true, as someone has said, that waste diversion is all about a flick of the wrist, that crucial moment when the householder decides whether something goes into the recycling or into the garbage. If garbage is easier, that’s where it goes, and generally, that’s where it stays.

I have a special interest in enhancing the recovery of paper, and Ontario’s Blue Box system is doing very well in this regard with almost three-quarters of it being sent on for recyclingBut far too much paper is still slipping through the cracks: mainly old boxboard (such as cereal and shoe boxes) and printing and writing paper.

If most (say 85%) of that perfectly recyclable but dumped paper were instead captured and sent for recycling, provincial Blue Box paper recovery would jump to an amazing 96%, and the Ontario Blue Box overall from its current 64% to a very impressive 78 per cent. Folks, this is actually achievable, if only we set our minds to it!

It’s not as if there are no steady markets for the various paper materials. There are. In fact, the packaging mills of Southern Ontario led North America in pioneering the recovery of old boxboard back in the 1990s. We have gone from boxboard not being collected at all to virtually all Canadians (94%) being able to recycle it in the space of 20 years. An impressive achievement.

No, the issue is not markets, as some government people will tell you, it is capture. We are not physically getting enough paper material out of the home because it’s too easy for householders to flick the wrist. So how do we get them to flick in the right direction?

Education is key. We drool over British Columbia’s new Blue Box program where there is a standard list of materials accepted province-wide. Imagine that! One consistent recycling message across the whole province. Wouldn’t that be great! Remove the confusion. Save money on promotion. Increase the capture rate.

But we also need to engineer the Blue Box system for greater convenience. Municipalities and their service providers have been very creative in this respect: encouraging recycling by charging for garbage bags or bins and by limiting the number of garbage bags allowed at the curb and/or the frequency of garbage pick-up. Restrict the “garbage opportunity” and encourage recycling. Great stuff. And we do recognize that multi-residential apartments represent a special problem. It’s a lot easier to dump something down a garbage chute than to separate the recyclables and carry them in the elevator to a downstairs recycling bin.

But somehow we have to educate Canadians that most paper materials are perfectly recyclable; that there are long-standing and sustainable markets for them; that most boxes and cartons made in Canada, for example, are already 100% recycled content, and that the industry needs this household paper as feedstock to make new packaging; that this ongoing recycling activity provides local jobs and taxes; and that paper recovery is a great example of the circular economy and the goal of zero waste that we all hopefully aspire to, and is in our collective best interests.

Provincial governments have a key role to play too, in getting more paper out of the waste stream. For years, governments have been telling the packaging industry to reduce, re-use, and recycle. And it’s been doing that. But guess what, the provinces can do something too, something that industry can’t. They can introduce disposal bans on materials headed to landfill.

How about it? It’s not as if it hasn’t been done before. Nova Scotia and PEI have had disposal bans on paper materials for years. Wouldn’t a disposal ban send a great message to everyone that paper doesn’t belong in landfill; that it’s a valuable feedstock; that banning it from the dump would reduce the greenhouse gases released to the atmosphere and mitigate climate change? Isn’t that what we’re all supposed to be doing?

The English novelist Charles Dickens once described politics as the art of scurrying nowhere in a violent hurry. We wish some governments (OK, Ontario in particular) would scurry somewhere fast (hint: disposal bans) in more of a hurry! At the moment the province is not even considering disposal bans on paper until “2019 and beyond.” Which just happens to be safely past the next scheduled elections. Shame on them! Hurry hard!

Household paper that shouldn’t be in the garbage

(the 26% that doesn’t make it to the Blue Box)

Ban Old Boxes

 

Fewer newspapers but more boxes in the home

There’s just something about paper! Thirteen years of data on what ends up in Ontario homes tells us that Canadians, or at least those who live in Ontario, cannot or do not want to shuck their paper habit, despite all those urgent exhortations to do so. The paper-less home ain’t happening. Well, not yet anyway.Paper Generation Ontario 2015

Newspapers, corrugated boxes, boxboard cartons, and printing and writing paper are still the major paper items ending up in Ontario households, a PPEC analysis of residential generation since 2003 reveals. Paper materials today represent some 65% of the dry recyclables in the home, the same as they did back in 2003.

While there has been an 11% drop in overall generation of paper products over the period, some of this can be attributed to the light-weighting of paper and boxes (everything being measured by weight). But most of that lost tonnage has been on the newspaper side in losses to digital competition. It’s more than just newspapers, though. Printed papers overall are down by 26% collectively.

The biggest hit by far has been taken by the publisher members of the Canadian Newspaper Association and the Ontario Community Newspaper Association (down 35%), but magazines and catalogues (down 31%) and telephone books especially (down 70%), have been savaged too.

On the paper packaging side, however, everything except laminated paper is on the up. Corrugated boxes, likely buoyed by the development of e-commerce, and boxboard cartons are both up between 20 and 22%, and the minor grades, gable top and aseptic cartons, have made significant gains too.

Generation Specific Household Paper Types

The tables outline the generation changes over the 13-year period. The good news, of course, is that most of that paper packaging is made from 100% recycled content material that is widely recycled back into new packaging, an already existing local circular economy.

Packaging is the villain again (sigh)

There is no doubt that some goods are over-packaged and that more can be done to reduce the amount of paper, glass, metal and plastic packaging that ends up in consumers’ homes. But blaming packaging all the time is only part of the story. To put it bluntly, we in the so-called developed world eat, drink and buy far too much stuff.

Consumption is the real issue, not the packaging that delivers it. As consumers, however, we find it difficult to limit what we purchase. It’s so much easier to point the finger at the packaging that’s left behind.

For example, a recent anonymous letter to the editor of Solid Waste & Recycling magazine outlines the increase in convenience packaging of produce (plastic bags for peppers, a bundle of herbs in a plastic case, fresh grapes in a plastic bag with grab-and-go handles). The writer complains that the increased packaging waste from this new convenient shopping trend means higher costs for municipalities dealing with it down the line. A reasonable argument.

It’s when the letter writer rather loosely broadens the attack to packaging in general that we get concerned. “Our waste streams are clogged with unnecessary packaging at every turn,” he/she writes, “and most of it is neither recyclable nor compostable.”

Now hang on a minute there! If you are talking about convenience packaging of fresh produce (the peppers, herbs and grapes above) then you might have a point, although we suspect there will be debate over exactly what “necessary” means.

But when you broaden the issue to all packaging, you are lumping all packaging together in the same boat. Setting aside the argument over what might be deemed necessary or unnecessary, packaging is definitely not “clogging” our waste streams “at every turn.” In the most comprehensive national survey of packaging ever done in Canada, packaging represented only 13% of total solid waste. Significant, but not exactly “clogging.”

Consumption is the issue not the packagingThis survey was conducted by Statistics Canada for the Canadian Council of Ministers for the Environment (CCME) and is admittedly now some 20 years old, but there’s no obvious reason why the percentage would not be hugely different if measured today. Some people (including the Ontario Ministry of Environment and Climate Change) claim a higher percentage, but that’s because they change the denominator, they use a much narrower definition of solid waste.

It’s the claim that “most of it is neither recyclable nor compostable” that really gets us going though. Again, if the writer is talking about specific convenience packaging for produce, he/she might have a case. But by far  most packaging used in Canada is able to be recycled (recyclable). And a fair chunk of it (mostly paper-based) is compostable. Whether it is actually being recycled and composted is an issue for another day, and an argument for better and more current national data.

 

The reports of paper’s death are greatly exaggerated

We frequently hear and see comments about paper “dying” or being supplanted by other materials. It’s not happening, or at least not happening in the way many people think.

While the weight of paper entering Ontario homes, for example, fell by 8% between 2003 and 2014,(( PPEC analysis of Stewardship Ontario Blue Box data for 2003 and 2014. PPEC analyses on the generation, recycling, net costs, and EPR fees for all materials across Canada are available to members upon request.))  at least part of the reason is the continuous light-weighting of paper products that’s gone on over the years: newspapers and magazines with narrower pages, fewer flaps and layers of packaging, and a tighter fit between packaging and product. The introduction of lighter, high-performance board or micro-flutes has also displaced what some boxboard or paperboard used to do. Who could have predicted, for example, that a fast-food hamburger would one day be delivered in a lightweight corrugated box! Check out that distinctive corrugated ripple in the packaging next time you visit one of the chains.

Measuring generation by weight, of course, doesn’t give a complete picture of what’s going on in the marketplace, where volume and sales units rule. But it can be a useful indicator of changing market forces. Printed paper (especially newspapers), for example, has taken a severe hit from its electronic competitors. The weight of newspapers ending up in Ontario homes fell by 21% over the period, magazines and catalogs by 25%, telephone directories by a whopping 47% and “Other Printed Paper” by seven percent. This is the demise part of the paper story we mostly hear about.
Packaging exceeds newsprint in Ontario for the first time
But at the same time as printed paper generation declined by 20%, the use of paper packaging increased by 16%, basically offsetting any major changes to paper’s overall share. In fact, for the first time in Ontario, more paper packaging (corrugated and boxboard) ended up in the home than newsprint. So paper products, whether printed or packaging, still represent two-thirds of the dry recyclables in Ontario households by weight.

The two main household packaging types (boxboard/paperboard and corrugated) are up 27% and 9% respectively, with the small market gable top and aseptic containers also making significant gains (up 24% and 118 percent).

When you put these two changes together (newsprint down and paper packaging up), we pretty much have the status quo, although the trend line within the paper group seems to be clear. And as e-commerce distribution ramps up in Canada, more and more paper packaging (mostly corrugated) is expected to end up in the home. The good news is that most of it is 100% recycled content already, with almost all of it (98%) being collected for further recycling.