Does the WWF Check Your Paper include all relevant environmental parameters?

No. The WWF Check Your Paper purposely focuses on a limited number of parameters that have major environmental impacts and that can be seen as ‘umbrella parameters’ or ‘signal indicators’. However, many other aspects are indirectly covered by parameters 28–29 Environmental Management Systems, which focuses on overall, continuous improvements made by the mill.

The CYP is designed as a user-friendly tool to capture the main impacts of pulp and paper making and estimate the environmental footprint. Adding more parameters would likely not significantly change the scoring of individual papers or provide much additional practical guidance for paper buyers.

How did WWF decide on which parameters to include in the WWF Check Your Paper method (the criteria behind the Check Your Paper scheme)?

WWF began the process by looking at over 20 parameters that are generally reported on by transparent paper companies. This set of parameters was then reduced to a more user-friendly subset by applying the following criteria:

  • The importance of each parameter in terms of the environmental impact, i.e. threat to human and/or ecosystem health and vitality
  • The significance of the paper industry’s contribution to the global environmental footprint for each parameter
  • Status as a ‘signal-parameter’ – i.e. whether the performance of one parameter is usually linked with performance in other parameters
  • Availability of reliable data for WWF to establish credible threshold performance values for rating
  • Parameters for which industry reduction is already driven by strong economic incentives were not selected.

The resulting shortlist addresses the main elements requiring particular focus. A number of other issues are indirectly addressed by recognising mills that have adopted ISO 14001 certification, part of parameters 28–29 (Environmental Managements Systems and Transparency).


Why FSC-certified virgin fibres can rate the same points as recycled fibres? Shouldn’t WWF promote firstly recycled fibre use and secondly virgin fibre use?

Both FSC-virgin fibre and post-recycled fibre are considered as preferred fibre sources by WWF.

WWF’s mission is to safeguard biodiversity as well as to reduce wasteful consumption. New virgin fibre will always be needed in paper production as each time fibre is recycled it loses quality and thus cannot be recycled indefinitely. The new fibres need to be from well-managed forests. By pushing for recycled paper without at the same time pushing for FSC-certified paper we might actually create a disincentive for fibres from well-managed forests (e.g. recycled fibres could come from converted rainforests). Since it will be easier in practice to get points for recycled fibre in CYP, CYP actually favours recycled fibres over certified virgin fibre.

For tissue products WWF is giving higher relative scores to post-consummer recycled fibres than to virgin fibre because these products are end of lifecycle products and cannot be recycled after their use. (Tissue papers can achieve a maximum of 30 points if they contain 100% FSC certified virgin fibres or preconsumer/agricultural fibres, and 40points if they contain 100% postconsumer recycled fibres)

Why is the parameter 21 – Virgin fibre of legal origin – so important?

Parameter 21 works as a ‘Gate-Keeping Parameter’ thus WWF will only allow legal virgin fibre sources to be posted on its CYP rating tool. Please refer to the disclaimer on legality under question 21.

Could you explain why only FSC-certified fibre qualify as credibly certified?

WWF has developed a methodology in collaboration with the World Bank the Forest Certification Assessment Guide (FCAG) to evaluate various certification schemes. These assessments as well as other evaluations demonstrate that, while there is considerable room for improvement in all schemes, FSC-certification best meets WWF’s values and key requirements of responsibility, transparency, international consistency and balanced multi-stakeholder governance. Thus, while WWF acknowledges that several schemes may contribute to improve forest management, the organisation will continue to focus its active efforts on improving the FSC -system, on adapting FSC-certification to different scales and national contexts, and on promoting the FSC-logo as an internationally recognised hallmark of responsible forest management.


What about nuclear energy? It is not renewable but doesn’t emit CO2?

Parameter 24 focuses on environmental impacts related to climate change. From an emissions perspective, nuclear power is a clean source of energy. However, WWF and most other NGOs do not see nuclear power as a solution mainly due to the security risks of the plants and storage of waste.

Doesn’t CYP put mills relying on fossil fuels and purchased power at a disadvantage?

Mills relying on energy from fossil sources will score lower on this parameter than mills that use renewable resources. While we recognise that there are limitations to what individual mills can do to change the production of grid electricity, this doesn’t change the fact that CYP needs to estimate the footprint related to such an important parameter. In some countries it is possible to buy ‘green’ electricity from the grid. Ultimately, mills need to invest in technology and increase their own use of renewable sources of energy.

Why is CO2 from transport emissions not included?

At the time of writing this manual, the lack of consistent data made it impossible to include emissions from transport as a parameter. As more data become available it may be possible to include emissions from transportation in future versions of the CYP.

For the paper sector as a whole, fossil CO2 emissions from transportation are still much lower than emissions from pulp and paper processing, even though there are examples of manufacturers that have had higher CO2 emissions from transport than from production units.

Why is energy efficiency not included as a parameter?

While WWF welcomes efforts to increase energy efficiency, the industry already has strong economic incentives to drive efficiency-related improvements. Energy efficiency was therefore not included as a CYP parameter. Instead, impact on climate change is addressed through the scoring of CO2 emissions in the parameter 24.

Why weren’t other greenhouse gases like methane addressed?

Methane emissions are indirectly included as they derive mainly from landfill addressed by the parameter 25 that contributes maximum one star in “Climate Performance” star-rating.

Why are SOX (sulfur oxide) not included?<7

SOX (mainly SO2) derives primarily from combustion of fossil fuels. Thus the measurement of CO2 fossil fuel emissions is considered an umbrella-parameter (even though different fossil fuels contain different amounts of sulfur and combustion give different amounts of SOX).

SOX are also indirectly included in the parameters 28–29, which address the Environmental Managements Systems (EMS) of a mill. Any EMS certified mill will monitor SOX and must continuously improve their performance.

To keep the CYP simple and user-friendly WWF applied a range of criteria on all environmental parameters and SOX did not come out among the top environmental impact parameters.

Why are NOX (nitrogen oxide) not included?

NOX contributes both to the formation of ground-level ozone (harmful in contrast to atmospheric ozone) and to acidification. However, we decided against including NOX emission (at least for now) for the following main reasons:

  • Although important, we didn’t consider the environmental impacts of NOX on par with the other ‘majors’. Thus including NOX would have made it necessary to include another level of weighting, increasing the complexity (and subjectivity) of the tool and diluting the weight of the other parameters.
  • While including NOX may have given a somewhat better estimate of the ‘real, total’ impact, it would not really change the ranking between different papers very much, and thus hardly contribute to CYP’s usefulness as guidance.
  • It would place more of what’s estimated outside the immediate influence of the mills and weaken the instrument as a driver of change.

Does the CYP scheme include emissions from non-integrated pulp mills?

Yes. The CYP requires that emissions from market pulp processing are reported.

Can the score on fossil CO2 emissions be improved by accounting for sequestration through plantations or acquiring carbon credits?

No – currently the rating doesn’t consider any emission compensation through e.g. forest planting or by buying carbon credits; fossil CO2 emissions are emissions.

There are a number of voluntary offset standards in place but the decision that a buyer may make to choose one system over another is not governed by regulation. Voluntary forest offsets typically have expectations of co-benefits attached to them, such as preserving or restoring degraded ecosystems or providing community benefits. The majority of forestry schemes in the voluntary carbon market focus on afforestation and reforestation, i.e. tree planting, while initiatives to reduce emissions from deforestation and degradation are on the rise.

There are many concerns with offsetting. The quality of these offsets is ultimately based on the extent to which they result in actions that are additional to what would have occurred in the absence of the offset and are permanent in their impact.

WWF believes that forest carbon offsetting, if used appropriately, could play an important and perhaps crucial part in a global strategy to reduce carbon emissions and contribute to sustainable development – helping to catalyse the global transition to a low-carbon economy whilst improving the lives of people in the developing world. That said, WWF recognises the importance of reducing emissions from primary sources and views offsets (be they from forest or non-forest activities) from a purely climate mitigation perspective as a ‘second-best alternative’, to be employed after all reasonable efforts have been made by investors to reduce their primary emissions.

Why is waste to landfill included as a parameter?

Much of the organic materials directed to landfill decompose in the absence of oxygen, releasing large amounts of methane – a very powerful greenhouse gas.

Has the impact of fillers and coatings in the paper been included?

WWF has not included the impact of fillers and coatings in this version of the CYP scheme, mainly due to lack of consistent data and impact assessments. This will mean that paper with high proportions of fillers will get a proportionally better rate than papers using less fillers. However, a heavily-coated paper can also result in a higher level of waste to landfill, covered in the parameter 25. As data become available it may be possible to address impacts related to fillers and coatings in future versions of the CYP.

Why is Elemental Chlorine Free (ECF) processes not considered on par with Totally Chlorine Free (TCF)?

AOX (Absorbable Organic Halogens) are potentially hazardous compounds created during bleaching with chlorine based chemicals. The highest levels derive from the use of elemental chlorine. ECF processes are generally much better but differ widely in performance. The CYP scheme therefore focuses at the real emission levels of AOX rather than the type of process involved.

Why is water consumption not included?

WWF recognises that water use in paper mills is significant and encourages efforts by mills to reduce consumption. However, the importance of water consumption varies much depending on the location of the mill. Consequently, the CYP concentrates on pollutants in mill effluents rather than on water consumption. There are already economically motivated efforts by mills to reduce water consumption.

Why are other commonly reported pollutants such as Phosphorous and Total Suspended Solids (TSS) not included?

To keep the CYP simple and user-friendly, WWF applied a range of criteria on all environmental parameters and TSS did not come out among the top parameters chosen by WWF. Furthermore, there is a very high correlation between TSS and COD, so the latter acts as an umbrella parameter in this case. However, these pollutants are indirectly addressed by the parameters 27–28, which address Environmental Management Systems.

Why measure COD and not BOD (biological oxygen demand)?

COD is a more inclusive measurement than BOD as it addresses a wider range of polluting organic material than does BOD. However, there is conversion factor between COD and BOD and these can be used to rate by the CYP.

Why are the parameters 27–28 on Environmental Management Systems so important?

An Environmental Management System is a well-established systematic approach to continuous improvement across all parameters. It acts as an ‘umbrella parameter’ that addresses emissions of a number of compounds not specifically included elsewhere in the CYP. This Parameter also addresses the highly important issue of transparency.


Will providing data for the Check Your Paper scheme be too expensive for mills?

WWF has reviewed company reporting of environmental issues since 2002. The most responsible mills already publish their environmental performance at the mill level. There is already a clear trend for more extensive and open reporting from European manufacturers, and over 60% of mills in Europe are ISO 14001 and/or EMAS certified. In addition, those producers participating in the Paper Profiles scheme are already publishing data on their paper grades. Much of this published data is already third-party verified. Therefore, expense should not be a valid excuse for the mills.

Can a technically same product appear at the CYP listing several times with different product names?

Yes. In some cases, the paper producer has a brand name for its product different from the brand name merchants or paper distributors use from the very same product. Since paper merchants and other distributors are not always able to name publicly the manufacturer of the product they sell, the product needs to be rated again when using a different brand name. This guarantees confidentiality between companies, and helps to make the CYP tool useful both for paper merchants and other distributors and buyers.