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Francisco Pinto Balsemão
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  < back to issues: environmental issues




European Recycling Forum Working Group D - Regulation: position paper from the European Publishers Council (EPC)


National Differences

The European Union has a mixture of natural forests and "urban forest" areas. Nordic countries are rich in forest resources and to a large extent their economies are dependent on these resources. They have developed sound forest management policies and it makes ecological and economical sense that they should not be tied by legislation on minimum recycled content for paper.

Other western European countries that do not possess these forests are rich in "urban forests". Over the years, industry has taken advantage of the high volume of waste paper in more populated areas and invested in newsprint mills, with the capacity of making highly recycled paper. As technology advances, so has the ability and capacity of most of these mills to produce good quality products with a high proportion of recycled waste content.

A geographical balance is thereby achieved. It is acknowledged however, that in some places, the level of waste paper going into landfill is not acceptable. The most sensible way for the authorities to deal with the problem is at national level, with a long-term strategy, based on the Best Environmental Practical Option.

The American Experience

The report by EU Consulting (sponsored by DG3) on the experience of statutory regimes in the United States is evidence that statutory regimes do not work. It must be pointed out that there is no federal legislation on the issue. Mandatory measures were taken by 13 US States between 1990 and 1994. The report states that the "US is now swinging away from legislation on this issue and towards commitments to minimum achievable targets".

The reason for this move was that market pressures eventually made the measures unworkable.

The report also says that the legislation encouraged increased recoveries of waste paper. However some of this waste had to be dumped or incinerated, because it had no home to go to.

Paper Industry's Investigation

The report by Jaakko Poyry, worldwide paper industry experts, which was sponsored by CEPI recommends that there should be no mandatory recycled content for the paper industry. The authors of the report say that the problems resulting from such legislation would be enormous. According to their findings, the measures would: (i) be a disadvantage to Europe and an advantage to the US; (ii) have uneven impacts on the European countries; (iii) have disturbing impacts on every sector of the paper industry; (iv) be a special disadvantage to small and medium-sized Central European mills that rely heavily on recovered paper; (v) have an impact on the paper industry's clients.

As the paper industry's clients, it is this latter claim that most concerns the European publishers. Among other things, the authors say, "a poorer quality of product (linked to very high recovery rates) does not meet the requirements of either the markets or the equipment". They add that if clients cannot get what they need in Europe, they will go elsewhere (North America, South America, and Southeast Asia).

National Voluntary Agreements

There is clear evidence that voluntary agreements at national level do work. The experience in Germany, involving the whole paper chain shows that all parties can work together to produce a solution which works to the benefit of the environment.

The experience in the UK, with regard to newsprint is working well. A first recycling target was met ahead of schedule, and a second one is being discussed with the Government.

Legal Implications

Proposals for minimum content legislation would need to comply with WTO rules and competition rules within the EC Treaty. Therefore, before such legislation is drafted, careful consideration should be given to its compliance with these rules. In particular, with regard to the WTO the legislators would clearly have to avoid any dispute being brought by a WTO member country, if the latter felt that its rights were being infringed. At European level, DG1V would have to give clearance. It would have to balance the anti-competitive elements against the environmental benefits. It is our view that the path towards minimum content legislation has not been adequately tested.


23 August 2023


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