The paper industry has actually been a pioneer of what we now call the “Circular economy” for years. Yet, due to widely-known regulations and cultural obstacles, waste material management is increasingly less straightforward, in particular, in terms of the “recycling cycle“. Paper mills continue to deal with no shortage of problems, even when it comes to the procurement of Paper for Recycling (such as recovered raw material). Misalignment between legislation and technical standards (such as, Italian Ministerial Decree 5 February 1998, and UNI EN 643 – the Italian edition of the EU standard – and its revisions) has left room for interpretation.
This, in addition to the fact that there is no specific End of Waste decree for paper and board waste, exposes companies to significant risks during the testing phase and during inspections performed as part of investigations by the authorities. Even incoming technological advances used to test Paper for Recycling (such as, Automated Bale Inspection Systems, like PTS’s Balemat and CTP’s NIR Moisture & Plastic Monitor) can cause problems, if not managed correctly, since they are considered capable of effectively differentiating between paper which is suitable for recycling, and types of material which are not (that is, waste), although we do not agree with this view. The sector must, in turn, “defend itself” with continuous explainations of its processes and papermaking jargon, defining the field of application and definitions within the applicable technical standards even more clearly and unequivocally, in order to reduce the room left for distorted, or even “dangerous” interpretations. Consequently, we believe additional efforts must be made to define procurement and “quality” control procedures. These efforts must be clear and they must be made collectively. Effective training tools are required for the staff involved in the procurement chain (from those in charge of purchasing, to those managing raw material acceptance, handling and quality control operations).
In light of the lack of clear regulations, only a collective approach, shared sector-wide, along with player awareness, can reduce the risks connected with the management of paper for recycling.
Recycling System and Reference Standards
Whether through industrial production cycles or end-users, the collection of paper and board for recycling is a key element of the environmental, social, and economic sustainability of the Italian paper industry. Thanks to input from COMIECO, Italy’s consortium for recovering corrugated fibreboard, which is made up of paper mills and converting companies, the collection rate across Italy has increased progressively, confirming improvements in paper recycling infrastructure. This growth has opened up new procurement sources for the industry, reducing the need to import, which is now limited to specific types of waste not available in sufficient quantities in Italy. Specifically, high rates of paper fibre recycling require larger quantities of fibre which can be sourced from countries where fibre produced from virgin material (i.e. well managed, sustainable forests) is still extensively used, such as North America.
It is worth noting that:
- Italy is currently the fourth country in Europe when it comes to recovered paper use, with a total of 4.89 million tonnes (ISTAT data for 2016 processed by Assocarta).
- In Italy, every year, an equivalent of 20 medium-sized landfills of waste material are avoided, thanks to paper recycling.
Despite the obvious contribution Italy’s paper sector and the whole industry have made to the environmental and socio-economic advantage of the country, there are still objective difficulties when it comes to achieving clear, extensive regulations which make recovered raw material management “safe”. In anticipation of the approval of the awaited “End of Waste Decree” on paper and board materials, the sector finds itself forced to “fight” against references which, while the paper mills know them well, continue to leave too much room for interpretation. And as we know, interpretation is ever the source of litigation.
These references are:
- a) Ministerial Decree 5 February 1998 – “Identification of non-hazardous waste subject to simplified recovery procedures as according to articles 31 and 33 of Legislative Decree 5 February 1997, n° 22” (updated with Ministerial Decree 5 April 2006).
- b) the sector technical standard UNI EN 6431 (latest edition 2014) – “Paper and board – European list of standard grades of paper and board for recycling”;
The definitions of foreign materials (known as “impurities” in the ministerial decree and “non-paper components” in UNI EN 643) and their relative reference limits (a maximum of 1% in the former, and a maximum of 0.25% to 3% in the latter, depending on paper grade) can lead to distorted interpretations if these documents do not provide explanations which consider the historic and technical-scientific evolution from 1998 to present. In addition to the specific grades of Paper for Recycling they have to comply to, respecting these limits means and has meant a material subject to recovery operations may no longer be classified as waste. It “turns into” a raw material, resulting in the “end of waste”.
These varying “limits” definitely do not help. There is no doubt that certain aspects need to be clearer.
Please refer to ASSOCARTA’s “Position Paper Assocarta – foreign materials in Paper for Recycling – July 2019”2 which provides a guided interpretation of some aspects which may be unclear for non-experts.
In short, Ministerial Decree 5 February 1998 (now 20 years old!) set an “impurity” limit, since recovered waste features had to comply with the UNI EN 643 standard which, at the time, listed just a few paper grades (compared to today’s 95 circa). It also indicated no limits for “non-paper components” at all. Incidently, we believe the Ministerial Decree did not indicate the edition of the standard so that it would conform with any future revisions.
The decree is clearly directed at purchasing of secondary raw material originating from waste recovery. It is worht remembering that some paper mills directly perform paper and board waste recovery and, in this case, the material is accepted as waste and converted directly into normal paper and board products. Likewise, there may also be paper and board by-products on the market which may be used directly in papermaking processes.
The role of Paper Mills and the responsibilities of the players
Put briefly, Paper and Board are recycled within an industry that consists of:
- Collection Systems (Pre or Post-consumer)
- Sorting Facilities (where the paper and non-paper components are sorted and unwanted or prohibited materials removed. This is the recovery section of the industry)
- Paper Mills, where Paper for Recycling is recycled to produce new consumer goods
The sorting facilities supply the paper mills either directly or through sales agencies (just like other raw material suppliers).
The industry is heavily regulated by sector agreements and technical standards. The ANCI-CONAI Agreement, for example, provides specific conventions between the COMIECO consortium and municipalities for secondary raw material provision upstream of the collection. The materials are sorted in compliance with UNI EN 643, compressed into bales, or other compliant forms, and sent for recycling within the paper industry.
After processing, the sorting facilities, which recover the paper from the waste collection, assess whether the material complies with technical standard UNI EN 643 and then grade the materials (providing they comply with the standard) or put them through recovery once more/handle them as waste (if them do not comply).
Providing the sorting facilities grade the processed materials as compliant with standard UNI EN 643 after recovery, they leave the waste management chain officially and continue their journey to the paper mill as secondary raw material (end of waste).
Paper mills produre materials that leave the sorting facilities as compliant with standard UNI EN 643.
In other words, within the paper recovery chain described above, it is the recovery plant, which performs the temporary holding, sorting and elimination of unwanted materials and foreign materials, that is responsible for establishing the characteristics of the secondary raw material for the paper industry.
Paper Mill Screening
Once the raw material or Paper for Recycling reaches the paper mill, guaranteed as compliant with standard UNI EN 643, the obligations of the buying industry are the same as those for any raw material purchase: to check the documentation of the incoming load and perform an ordinary visual inspection of the actual (apparent) correspondence between that indicated in the documentation and that received.
All other checks that paper mills might decide to perform are typical “quality control” checks for received materials, just like those carried out for any raw material delivery.
And paper mills will perform their own checks on incoming supplies of Paper for Recycling to ensure compliance with trade agreements and the quality of the final product.
CEPI (Confederation of European Paper Industries) has produced several editions of guidelines on best practices for checks on paper for recycling.
Here is an outline of the checks proposed by the various CEPI guidelines “Best Practices for the Global Inspection of Recovered Paper” and “CEPI Paper for Recycling Quality Control Guidelines”3:
Fig.1 An outline of the checks the checks proposed by the various CEPI guidelines.
The main purpose of publishing these guidelines is to facilitate and lay the foundations for trade agreements between buyers and suppliers.
Specifically, “minimum requirement” inspections, defined as “First step: visual inspection (minimum requirement)”, are DOCUMENT and VISUAL inspections and may lead to three types of actions:
1) Load acceptance
2) Load rejection
3) Conditional acceptance depending on test result
In the third case, there is a further “Second step: advanced visual inspection and/or gravimetric method” which leads to further actions which, in the case of “Goods grading”, “Moisture”, “Unwanted material”, and “Other agreed specifications”, may lead to:
3 a) Load acceptance
3 b) Re-grading of the material (from one grade defined by UNI EN 643 to another)
3) Load rejection
“Packaging conditions” may lead to:
3 d) Acceptance with comments
In the event of the actions indicated at points 2, 3b, 3c and 3d, the supplier must be notified immediately and, if necessary, the load must be set aside for further joint checks.
To this regard, the different Italian and/or European (both pan-European or pertaining to individual states) trade associations of the players (buyers and suppliers) have issued a number of documents and guidelines to define inspection procedures and guide users in resolving issues regarding trade and disputes (e.g. ANCI-CONAI AGREEMENT 2014-2019 – Paper technical guide; Waste type inspection UNIRIMA, Assocarta, Assografici, COMIECO – rev. 5 of 04.06.2019).
As for sampling procedures, the UNI EN 17085 standard “Sampling procedures for paper and board for recycling” has also been available since June 20194.
The technical evolution in paper mill screening
Industry efficiency has always been one of the primary objectives for COMIECO, Italy’s consortium for the recovery and recycling of packaging made from corrugated fibreboard. Their efforts have meant recycling objectives set by the law for the management of this type of waste were achieved well in advance, with over 80% recycled and 90% recovered. Since raw material quality is fundamental for paper mills (to the ends of achieving quality end products and producing less waste), many of them willingly participated in the initiative promoted by COMIECO to install Automated Bale Inspection systems intended to provide increasingly tighter quality controls for the paper coming from recovery facilities.
This technology has a coring tool 3 cm in diameter that can penetrate up to 70 cm circa into the bale of Paper for Recycling. A sensor system measures the moisture (the number one parameter to trade ends to avoid “buying water”) and other parameters (plastic, lignin and ash) to give an overall assessment of the paper’s compliance with the specified grades. (There are certain limits, though, but we will discuss these shortly.)
It should be emphasised that Automated Bale Inspection systems aim to check the Paper for Recycling grade trend as a whole for trade purposes. In order to guarantee the reliability of the data provided by its sensors, they must be compared with a significant number of samples using direct methods (e.g. weighing in laboratory). Any assessment of supply quality involves long-term observation of the same type of material.
Sampling of a single bale of paper and board for recycling is performed randomly, and according to probability, on specific quantities of small samples. Considering the small sample quantity examined, the test gives better results for characteristics which tend to be more homogeneous throughout the bale, for example, moisture.
The UNI EN 17085:2019 standard “Sampling procedures for paper and board for recycling” defines the type of sampling performed with Automated Bale Inspection systems as micro-sampling (please refer to point 3.5 and relative Note). Samples taken with Automated Bale Inspection systems are compared with “core drill” weights of between 200 and 300 grams circa. According to the Note at the same point 3.5 “A micro-sample is typically less than 500 and may be used to measure moisture“.
The standard goes on to specify, at point 5.2, the size of macro-samples as 150 kilograms, which may be lowered to an acceptable minimum of between 30 and 100 kilograms, in relation to the recovered paper grade, exclusively on the agreement of both parties.
At point 6.1, the standard specifies that “Paper and board are generally inhomogeneous materials, implying numerous challenges in terms of sampling for small-scale laboratory testing. Due to the restrictions that this places on subsequent analyses, micro-sampling is considered necessary exclusively for certain parameters where migration within the sample may occur (that is, moisture content)”. So while this sampling method may be used to some extent for parameters distributed uniformly within the bale, it is most certainly not feasible for parameters, such as plastic, which may be distributed inhomogeneously or may even be components of the material analysed. Other automatic methods are used to determine plastic. Sampling is performed by drilling through multiple layers of the bale and repeated at different points, with a statistical average determined from the IR spectra of the samples taken.
In its note dated 31 May 2019 (Prot. ACC-162687/2019-DMI/dmi), COMIECO stated that according to experiment results (on the possibility of using automatic testing tools for waste quality in comparison to the parameters indicated in UNI EN 643), the “moisture” parameter data proves reliable and may be used for trade checks in agreement with suppliers and to guarantee data reliability. As for the “plastic” parameter, COMIECO concludes that, due to the limited sample quantity (and the material’s heterogeneity), along with the sensor’s technological limitations, which make it unable to distinguish plastic foreign bodies in the paper product, this technology cannot currently be used to grade the quality of the material analysed.
So, with the exception of the moisture parameter, this technology cannot directly compare the specific results obtained with the limits indicated in UNI EN 643:2014. Automated Bale Inspection systems are unable to distinguish between non-paper components (as defined and regulated in UNI EN 643:2014, for example, plastic) and other recovered paper and board components (for example, plastic material from the “little window” on a spaghetti box or plastic film coupled with paper) as specified in the UNI EN 643:2014 definition.
Of course, in addition to the desired grade of paper raw material, paper mills endeavour to have less waste (waste disposal issues), and thus testing for the overall tendency of plastic quantity, whether component or foreign, certainly remains of interest.
Let me explain what happened during an inspection in a paper mill where some issues emerged regarding the matter of checks on the secondary raw material purchased.
Basically, based on the Automated Bale Inspection systems data analysed, it was hypothesised that the company had somehow willingly accepted materials which did not comply with UNI EN 643 and, was thus, considered waste. Incidently, the system had observed an average trend of “plastic” values coherent with the grades bought and “peaks” in the individual tests, as would normally be the case, due to the technological limits indicated in the COMIECO5 note, so, of course, we believe this interpretation to be wrong.
By assessing the test results – which, nonetheless, are merely statistics relating to the average grade of the overall material received, but do not provide elements which either affirm or deny whether they had been wrongly graded by the individual supplier sorting facility (by the way, I will come to the representativeness of the individual core drill and lack of coherence between testing and data required according to UNI EN 643 later) – we obtain an average value of 1.57% of total plastic present. This figure, however, includes the so-called “plastic component” which does not lie within the percentage limit indicated by the UNI EN 643 standard.
The calibration period of the technology was not considered in all this (the stabilisation of the trend is visible after the first two months of testing).
Fig.2 Processed Automated Bale Inspection Systems data Plastic parameter % in relation, although not correlatable, to certain limits indicated for the “non-paper components” in UNI EN 643:2014
So, in addition to the fact that the “plastic” results provided by Automated Bale Inspection systems cannot be compared with the limits set by UNI EN 643 when it comes to non-paper components, there is no actual legal obligation to check whether that declared by the sorting facilities as compliant according to the UNI EN 643 standard is actually correct (furthermore, attributing the buyer of the Paper for Recycling that “dual” responsibility could create disincentive to buy paper for recycling, going against industry efficacy).
We believe that paper mills most certainly have an obligation to be “diligent” when buying from licensed suppliers, and at market prices, however, they cannot take on the role of testing and be held responsible for the successful outcome of the sorting facilities’ actions.
Company procedures and training
In order to improve the procurement of Paper for Recycling and prevent problems, we advise paper mills implement procedures which provide for, not just quality controls, but also:
- Formal accreditation of suppliers (license to supply paper for recycling, permits, check business purpose, possible COMIECO registration, certifications, etc.)
- Clear, detailed purchase order issuing (what we want to purchase, references to UNI EN 643 and other reference standards)
- Any requests for a Declaration of conformity for the Paper for Recycling (End of waste), as according to article 184-ter, paragraph 3 of Legislative Decree 152/06 and as amended, provided by the supplier in the form of a self-certificate, as according to article 47 and 38 of Presidential Decree 28 December 2000, n° 445 (as indicated in the Guidelines for the application of the End of Waste regulations as according to article 184-ter, paragraph 3-ter of Legislative Decree 152/2006″ – Resolution of the Italian Council for Environmental Protection. Session of 06/02/2020. Doc. n° 62/20 Guidelines of the same council 23/20). This declaration should be traceable to supplied lots.
- For purchases from outside of the EU, there must be proof that the grade purchased (possibly regulated by other standards) corresponds with those indicated by UNI EN 643. (It may thus be useful for sector associations involved to share code transposition tables to these ends).
- Where possible, the supplier should have an “identification” system for the recovered paper supplied, in order to guarantee traceability of the lots purchased to the relative suppliers and to the documentation they provide (e.g. permits, conformity statements, analysis, etc.), in the event of disputes or inspections carried out by the authorities. Otherwise, an internal identification system should be combined with a traceability system.
- Management methods should be defined in the event of nonconformities (material re-grading to other standard grades) and also for when other parameters have been exceeded, such as, moisture and non-paper materials. In the latter case, if the material is not downgraded to another standard grade, it may be graded as WASTE and should be handled as such, considering certain difficulties: the producer would not be considered the paper mill, which, however, would detain the waste, in the event they had unloaded the goods while awaiting an explanation from the supplier. These aspects should be defined clearly when the contract is being drawn up to avoid management issues.
The staff dealing with purchases and those who manage acceptance, handling and testing operational phases should be appropriately trained on the contents that the paper mill’s outgoing documentation must include, checking of documents which are required for goods acceptance, visual inspections, and analytical and instrumental testing, obtaining any photographic evidence and archiving all documentation.
The legislative framework surrounding Paper for Recycling must be adjusted to the current needs of the paper industry, with standardised definitions and limits. Paper mills don’t have to be the weak link in the system. Paper mills produce goods and guarantee the longevity of the recycling industry.
Paper mills should be sharing their experiences collectively in order to bolster the sector’s approach and define procedures which can be applied consistently by companies.
Once procedures and instructions have been defined, and collective agreements have been made on the competence set necessary for the workers on the front-line and the possible gap to be filled, specific training activities must be provided for. The awareness of all operators becomes fundamental to guarantee paper mill productive continuity.
Paolo Peruzzi, Paper Market Director – firstname.lastname@example.org Ecol Studio S.p.A. Lucca
 UNI EN 643:2014 “Carta e cartone – Lista europea delle qualità unificate di carta e cartone da riciclare” (Paper and board – European list of recovered paper and board standard grades)
 Position Paper Assocarta – Foreign matters in recovered paper – July 2019
 CEPI Paper for Recycling Quality Control Guidelines – November 2016
 UNI EN 17085:2019 “Procedure di campionamento di carta e cartone da riciclare” (Sampling procedures for recovered paper and board)
 COMIECO – note dated 31 May 2019 (Prot. ACC-162687/2019-DMI/dmi)