1. GPP Training toolkit 7.2. Copying and graphic paper
Module aims: To present the European Commission GPP criteria for Copying and Graphic Paper, introduce the key environmental impacts of the product group, the availability and verification of green alternatives, and also non-procurement strategies for reducing environmental impacts in daily operations.
This document forms part of the EU GPP Training Toolkit. The full toolkit can be found on the European Commission GPP website:

2. Module 7.2 – Copying and Graphic Paper
GPP Training Toolkit
Module 1: Introduction
Module 4: Needs Assessment
Module 2: Strategic Aspects of GPP
Module 5: Circular Procurement
Module 3: Legal Aspects of GPP
Module 6: Preliminary Market Consultation
Module 7: Operational
(Copying & Graphic Paper)
Module 7.2 – Copying and Graphic Paper

3. Environmental impacts
How do these products impact the environment?
Key life cycle environmental aspects:
Forest destruction and potential loss of biodiversity
Emissions to air and water during pulp and paper production
Energy and water consumption during production
Waste generation during production such as rejects and sludge
The most important environmental aspects of copying and graphic paper are related to pulp and paper production and are the following:
Industrial logging linked to the paper industry is responsible for the substitution of functioning ecosystems with fast-wood plantations which can lead to a loss of biodiversity, disruption of local water cycles, loss of soil productivity and increased risk of pests and diseases.
In pulping processes, sulphur compounds and nitrogen oxides are emitted to the air, and during pulp bleaching, chlorinated and organic compounds and nutrients are discharged to the wastewaters.
The production process of paper, especially when mainly based on virgin fibre is associated with high levels of water and energy consumption.
Pulp manufacture generates large quantities of solid waste, the most relevant of which are wood waste, pulp screening rejects and the sludge generated during wastewater treatment.
(*) The Global Forest Resources Assessment FAO. 2005
(**) Best Available Techniques (BAT) Reference Document for the Production of Pulp, Paper and Board, 2015
13 million ha per year of global loss of forested area(*)
m3/t of water and 5,000-10,700 kWh/t of energy used for the production of non-recyclable paper(**)
Module 7.2 – Copying and Graphic Paper

4. Module 7.2 – Copying and Graphic Paper
Scope
What is included in the EU GPP criteria?
Products included
Unprinted paper for writing, printing and copying (up to 170g/m2)
Products not included
Writing pads
Drawing books
Calendars
Manuals
Which products do these GPP criteria apply to?
EU GPP criteria covers procurement actions for the purchase of copying and graphic paper, which includes paper for writing, printing and copying purposes (up to 170g/m2) sold in sheets or reels.
Finished paper products (e.g., writing pads, drawing books, calendars, manuals, etc.) are not included.
Module 7.2 – Copying and Graphic Paper

5. Module 7.2 – Copying and Graphic Paper
Needs assessment
Choosing the right quality/quantity of paper
Assess your needs before tendering!
Key questions:
Is a new purchase necessary? (in terms of quantity and/or quality)
Is it compatible with the existing imaging equipment?
Would a service contract meet your printing needs/avoid environmental impacts more effectively? (see this case study as an example)
Responsible use of paper
Exchange documents electronically
Avoid unnecessary copies
Print using double-side and/or multi-page options
Use waste paper as scrap/note paper
Set up a paper recycling system in the office
Before starting the procurement process, it is crucial for a contracting authority to assess its actual needs in light of the potential environmental impact of the contract. A good needs assessment could result in significant environmental and economic costs savings.
The key questions are:
Is the quantity of the new paper being purchased necessary? (i.e. is it aligned with the current use, output and supplies of the printing devices?)
Is the purchase of reams paper based on 100% virgin fibre necessary? (i.e., is it possible to fulfil some/all of the printing needs of the public authority by using recycled paper?)
Is the new paper being purchased compatible with the existing imaging equipment? The producer should be asked by the contracting authority to provide a sample of the paper to be supplied to check if it generates any dust emissions during printing operations which can potentially damage the imaging equipment.
Would a service contract meet your printing needs more effectively? (e.g., the contracting authority could fulfil its printing needs by using a pay-per-copy model in which the supplier provides all equipment repairs, replacements and training rather than simply selling copy supplies).
Apart from carrying out a needs assessment, there are also some organisational and management aspects which can be taken into account by a contracting authority on top of the procurement process to reduce its environmental impacts and achieve sustainability goals beyond the purchasing process. In particular, paper consumption could be rationalized by informing the employees on the proper use habits to adopt when using paper for writing, printing and copying (staff education).
Best practices to reduce paper consumption are the following:
Documents should be mainly exchanged and disseminated in electronic format by using the or other telematic procedures.
The printing of unnecessary copies and documents which can be consulted on the screen should be avoided.
Documents should always be printed double-sided and/or using the multi-page printing option when possible.
The waste paper printed on one side should always be placed in a dedicated tray to be used as scrap/note paper.
A proper paper recycling system should be set up in the office to ensure the waste paper is recycled correctly.
Example –Purchasing copy, printing and scanning services in Zurich:
More information in: Module 4: Needs Assessment
Module 7.2 – Copying and Graphic Paper

6. Module 7.2 – Copying and Graphic Paper
Overview
EU GPP Copying and Graphic Paper approach
Procurement of paper based on post-consumer recovered paper fibres (recycled paper) or paper based on legally and/or sustainably harvested virgin fibre
Procurement of paper produced through process characterised by low energy consumption and emissions
Avoidance of certain substances in paper production and bleaching 
Module 7.2 – Copying and Graphic Paper

7. Module 7.2 – Copying and Graphic Paper
EU GPP Criteria
Copying and Graphic Paper (2008)
Examples:
Technical specifications (TS)
Purchase of 100% recycled paper which is at least Elementary Chlorine Free (Recycled paper example)
Purchase of paper based on fibre stemming from legal sources and at least Elementary Chlorine Free (Paper based on virgin fibre example)
Award criteria (AC) – extra points are awarded for paper for which a certain percentage of virgin fibre is certified as stemming form sustainable sources (Paper based on virgin fibre example)
Since the production of recycled paper and paper based on virgin fibre is different, different sets of criteria are proposed for each of the two types of paper.
EU GPP criteria are divided into:
Technical specifications – used to set minimum requirements that must be met by all tenders. Must relate to the characteristics of the work, supply or service being purchased
Recycled paper example – the paper to be supplied must be made from 100% recovered paper fibres, which is at least Elementary Chlorine Free (ECF).
Paper based on virgin fibre example – the paper must be made from virgin fibre coming from legally harvested sources and at least Elementary Chlorine Free (ECF).
Award criteria – used to stimulate additional environmental performance, but are not mandatory
Paper based on virgin fibre example – additional points will be awarded in proportion to the amount of virgin wood fibres for pulp production coming from forests that are verified as being sustainably managed.
For each set of criteria there are two levels of ambition:
Core – designed to allow easy application of GPP, focussing on the key area(s) of environmental performance of a product and aimed at keeping administrative costs for companies to a minimum.
Comprehensive – take into account more aspects or higher levels of environmental performance, for use by authorities that want to go further in supporting environmental and innovation goals.
(Example: the comprehensive criteria for both types of paper recommend to refer to the full set of criteria from either EU Ecolabel, Nordic Swan or Blue Angel)
EU GPP Criteria for Copying and Graphic Paper:
For full criteria see:
EU GPP Criteria for Copying and Graphic Paper
Module 7.2 – Copying and Graphic Paper

8. Module 7.2 – Copying and Graphic Paper
Verification
Checking compliance with GPP criteria for copying and graphic paper
What to ask for?
When?
Test reports
Technical dossier
Ecolabels
Certificates of chain of custody
Wood origin tracing systems
FLEGT licence
Sample of the product
Compliance with GPP criteria for copying and graphic paper needs to be assessed at the time of selection of best offer
An additional check should be carried out at first delivery to ensure correspondence of supplied products with product samples
Verification systems are product-specific, include different requirements and may consist in the submission of existing documentation that the supplier has at their disposal and of specific documentation to be produced to prove compliance with an environmental requirement.
In the case of copying and graphic paper, both types of documentation need to be asked for to ensure compliance with the EU GPP criteria. Suppliers should also be asked to provide the contracting authority with a sample of the product for the purpose of conducting quality tests to check the compatibility of the offered paper with the existing office imaging equipment.
Each criterion has its corresponding verification that must always be included in the tender documentation.
The compliance with the GPP criteria always needs to be verified during the evaluation and selection stage. An additional check should be carried out at first delivery to ensure correspondence of supplied products with the product samples, thus the compatibility of the supplied recycled paper with the office equipment.
Tenderers should always be allowed to provide verification based on the supplied product holding the EU Ecolabel or another relevant Type I Ecolabel I (according to ISO 14024) fulfilling the same specified requirements.
Note: in the case of copying and graphic paper, the wood tracing system demonstrating the legal origin of wood can be a voluntary system certified by a 3rd party, often as part of ISO 9001:2008 and/or ISO 14001:2004 or EMAS management system.
To guarantee that wood is legally harvested, the EU has also established a licensing system in the framework of its Forest Law Enforcement, Governance and Trade (FLEGT) Action Plan designed to identify the legality of the production of imported products, the FLEGT license. In order to obtain the license, Voluntary Partnership Agreements (VPAs) have to be signed between timber-producing countries and the EU. Timber products, which have been legally produced in VPA partner countries, will be licensed with a FLEGT license for the legality of production by a third-party, and only licensed products from these partner countries will be allowed access to the EU. At present the only country that has started issuing FLEGT licenses is Indonesia. Therefore, if the wood used stems from this country the FLEGT license is another possible means of proof to asked to check the legality of production.
EU GPP Criteria for Copying and Graphic Paper:
For full verification instructions see:
EU GPP Criteria for Copying and Graphic Paper
Module 7.2 – Copying and Graphic Paper

9. Module 7.2 – Copying and Graphic Paper
Market Availability
How to identify sustainable products
EU GPP criteria are based on:
EU Ecolabel and Nordic Swan (recycled paper and paper based on virgin fibre)
Water and energy consumption/emissions to air and water
Blue Angel (recycled paper)
Use of chemical products
Other relevant labels: FSC and PEFC
Ecolabels are not all the same!
Some ecolabels are more valuable than others – procurers should choose “Type I” ecolabels (i.e., verified by a third party and awarded on the basis of life cycle impacts)
See Module 3 (Legal) for more on ecolabels
The best way to check the market availability of “green” options is to start from the availability of certified products.
The GPP Criteria for copying and graphic paper are based on the most common Type I ecolabels for office paper available in the European market, which are:
European Ecolabel and Nordic Swan for both recycled paper and paper based (totally or mainly) on virgin fibre. The criteria of these two ecolabels are mainly focused on water and energy consumption, and emissions to air and water
Blue Angel for the paper based on 100% post-consumer recovered paper fibres (recycled paper). The criteria of this ecolabel mainly address the technical performance and the use of chemical products in pulp and paper manufacture.
Full comparison of the criteria of these three ecolabels can be found in the Technical Background report for Copying and Graphic Paper:
Apart from these ecolabels, office paper can also be marked with the logos of the FSC or PEFC sustainable forest management systems. These, depending on what they state, can certify that paper is made of 100% recycled fibres or that it contains a minimum percentage of certified sustainable wood fibres. However, they do not deal with any other environmental aspects relating to paper production.
In addition market availability of “green” paper can also be checked by using other relevant “Type I ecolabels”, which ensure equivalent standards and performances foreseen by the EU Ecolabel, Nordic Swan and Blue Angel, such as: Milieukeur, Good Green Buy, Czech Ecolabel, Hungarian Ecolabel, Austrian Umweltzeichen.
For full comparison of the three ecolabels: Technical Background report
Module 7.2 – Copying and Graphic Paper

10. Module 7.2 – Copying and Graphic Paper
Using Ecolabels in GPP
Adding further criteria to your tender
As well as verification, Type I ecolabels can be a source of additional criteria
Some ecolabel criteria – but not all – can be used in a tender.
For example, EU Ecolabel:
Criterion 4(a): the product shall not contain substances that have been identified according to the procedure described in Article 59(1) of Regulation (EC) No 1907/2006 of the European Parliament and of the Council and included in the Candidate List for Substances of Very High Concern in concentrations greater than 0,10 % (weight by weight)
Criterion 5: All pulp and paper production sites shall have a system for the handling of waste arising from the production process and a waste management […]
Depending on an authority’s needs and priorities, a procurer may wish to develop their own or add additional criteria to a call for tender.
Type I ecolabels can be a good place to find additional, verifiable criteria.
However it is also necessary to be aware, that all selection criteria, technical specifications, award criteria and contract clauses must be linked to the subject-matter (LtSM) of the contract
This is important for GPP, as it limits the ability to look at the overall practices of a bidding company
Definition of the LtSM requirement: “[criteria which] relate to the works, supplies or services to be provided under that contract in any respect and at any stage of their life cycle, including factors involved in:
(a) the specific process of production, provision or trading of those works, supplies or services; or
(b) a specific process for another stage of their life cycle, even where such factors do not form part of their material substance.” (Art. 67)
See Module 3 (legal) for more on LtSM.
The EU Ecolabel criteria for Graphic Paper can be found at:
The EU Ecolabel for graphic paper and criteria can be found in – Commission Decision 2019/70 - Annex 1
Module 7.2 – Copying and Graphic Paper

11. Relevant EU legislation
Regulation affecting the paper production sector
Industrial Emissions Directive 2010/75/EU - Integrated Pollution Prevention and Control (IPPC)
Best Available Techniques (BAT) Reference Document for the Production of Pulp, Paper and Board
The Water Framework Directive 2000/60/EC22 for emissions to water
REACH Regulation (EC) No 1907/2009
More information in:
Best Available Techniques (BAT) Reference Document
Key aspects of the implementation of the Water Framework Directive
REACH Candidate List for SVHCs
There are several examples of EU legislation relevant for the paper production sector. The inclusion of EU GPP criteria in the procurement process ensures compliance with (and application of) the environmental provisions included in the following relevant sectoral EU directives and regulations:
Industrial Emissions Directive 2010/75/EU - Integrated Pollution Prevention and Control (IPPC)
Best Available Techniques (BAT) Reference Document for the Production of Pulp, Paper and Board: ised_BREF_2015.pdf
The Water Framework Directive 2000/60/EC22 for emissions to water: pation/notes_en.htm
REACH Regulation (EC) No 1907/2009: high-concern-identification-explained
Module 7.2 – Copying and Graphic Paper

12. Case studies
Purchasing copy, printing and scanning services in Zurich
(Municipality of Zurich, Switzerland)
Joint procurement of 100% recycled copying paper
(Municipality of Erlangen, Germany)
Paper purchasing for Lombardy local governments
(Lombardy Region, Italy)
GPP Helpdesk For further support on GPP, contact the EU’s free Helpdesk
Purchasing copy, printing and scanning services in Zurich (Municipality of Zurich, Switzerland):
Joint procurement of 100% recycled copying paper (Municipality of Erlangen, Germany):
Paper purchasing for Lombardy local governments (Lombardy Region, Italy):
Toolkit developed for the European Commission by ICLEI - Local Governments for Sustainability
Module Author: Ecosistemi
Owner, Editor: European Commission, DG Environment, 2019
Photos: courtesy of Pixabay.com under Creative Commons CCO
Disclaimer: This toolkit is an indicative document of the Commission services and cannot be considered binding to this institution in any way. Neither the European Commission nor any person acting on behalf of the Commission is responsible for the use that might be made of the information in this document.
Module 7.2 – Copying and Graphic Paper