What does the new regulation on imported recycled pulp mean for the papermaking industry?
On the evening of October 9, the General Administration of Customs issued an announcement regarding the declaration requirements for imported recycled pulp, stipulating that the recipient of imported goods or their agent, when declaring imported recycled pulp (commodity code 47062000), should indicate the production process used for recycled pulp in the remark column of the customs declaration form, filling in either "dry method" or "wet method" based on the actual situation. Since January 1, 2021, China has fully prohibited the import of solid waste in any form, and banned the dumping, stacking, or disposal of foreign solid waste within the country. The General Administration of Customs stated that this measure aims to standardize the declaration management of imported recycled pulp and strengthen import supervision. What is the difference between the "dry method" and the "wet method"? What does filling in "dry method" or "wet method" mean for companies importing recycled pulp? Can this measure effectively curb the entry of foreign pulp waste into China? What impact will the new regulations have on China's paper industry? When the national standard for "Recycled Pulp" was first formulated, why was there a loophole for dry-ground pulp? Professor Xu Feng from the College of Materials Science and Technology at Beijing Forestry University explained that proper waste paper pulp production requires purification processes such as de-slagging and screening under liquid conditions. This is followed by concentration and steam treatment (such as heat dispersion) and high-temperature drying to ultimately form waste paper pulp. Pulp produced through these processes can achieve a fiber content of over 91.5% (with 8% moisture), contains almost no impurities, and achieves sterilization during high-temperature drying, meeting hygiene standards. Dry-ground pulp production involves crushing waste paper raw materials into fragments with a crusher and directly packing them for import, omitting 95% of the purification process. It carries plastic fragments, heavy metals, and other pollutants, effectively making it a disguised import of "foreign garbage," posing serious environmental and health risks, and is even referred to in the industry as "foreign garbage more dangerous than waste paper." Associate Professor An Xingye from the College of Light Industry at Tianjin University of Science and Technology explained that the dry process does not use water as a solvent, which eliminates the opportunity to remove impurities through hydraulic classification and washing steps. Common pollutants in waste paper, such as plastic fragments, adhesives, microorganisms, and heavy metals (like lead and cadmium), cannot be effectively removed during the dry process. Without the high-temperature steam treatment step, sterilization cannot be achieved. Once these pollutants enter domestic production, they become "hidden bombs": microbial contamination (such as coliform bacteria) may threaten the sanitary safety of products like food packaging paper and toilet paper; residual heavy metals could contaminate water treatment systems, causing secondary pollution; and unpurified impurities may clog equipment during paper machine operations and even affect the cleanliness of finished paper.
Industry experts told Yicai Global reporters that the essence of the 'dry method' is crushing foreign solid waste, packaging it into recycled pulp for import, which poses significant environmental risks. Previously, inspections of recycled pulp during the import process were insufficient, and dry ground pulp often disguised itself under the name of 'recycled pulp.' Although there is already a national standard for 'Recycled Pulp,' this standard is recommended rather than mandatory, and its restrictions on biological and bacterial indicators for imported recycled pulp are insufficient. In recent years, customs authorities in multiple regions have seized solid waste imported under the guise of recycled pulp and returned it. Experts explained that in recent years, China's restrictions on the entry of 'foreign trash' have achieved significant results, and the state has clearly required to 'consolidate the results of the comprehensive waste ban reform.' In response, customs needs to refine declaration information to accurately identify risks associated with imported recycled pulp and prevent non-compliant products from entering the country.What impact does the new regulation have on companies importing recycled pulp? Experts stated that the declaration process will increase the workload to some extent, and import companies need to accurately distinguish and mark the production process. This requires companies to improve internal processes, conduct more detailed checks and records on the source and production process of imported recycled pulp, strengthen verification of upstream suppliers' information, and ensure that declaration information is true and accurate; otherwise, they may face customs penalties.Once the production process is clarified, customs can carry out targeted inspections. Imported pulp using the dry method may become a key regulatory focus, facing stricter tests, such as impurity, microbial, and heavy metal testing, with a significantly increased risk of product return or penalty if non-compliant. Experts said that this measure can significantly improve the targeting of supervision, preventing dry ground pulp from easily being imported under the vague name 'recycled pulp.' They also noted that relying solely on declaring the production process may not completely block the entry of dry ground pulp disguised as recycled pulp. If companies provide false declarations, supervision may fail, requiring supporting strict verification and penalty mechanisms. Additionally, enhanced source supervision, testing capacity, and violation punishment mechanisms are needed.Regarding the issue that the national standard for 'Recycled Pulp' left a 'back door' for dry ground pulp, industry experts said it was originally mainly to address the shortage of raw paper-making fibers, as China's wood resources for virgin pulp are limited, requiring large annual imports of pulp. Dry ground pulp, as a type of recycled pulp, can to some extent supplement raw paper-making fibers, alleviating raw material shortages while balancing industry development needs. At the time of setting the standard, some companies were already producing recycled pulp using the dry method, and excluding them directly could significantly impact those companies and affect industry stability. Moreover, there were limitations in the national standard for 'Recycled Pulp.' At that time, the hazards of dry ground pulp were not fully understood, and as a recommended standard, it mainly guided industry development rather than imposing mandatory restrictions. Therefore, dry ground pulp was not completely banned but regulated through technical requirements. However, subsequent practice has shown that these requirements were insufficient to prevent risk.Industry experts said that when the 'Recycled Pulp' national standard was established, some companies claimed that the 'dry method + electrostatic residue removal + optical sorting' could reduce impurities to below 3%, so leaving a 'loophole' was intended to encourage technological iteration. In reality, some dry ground pulp companies skipped the end-stage purification process to save costs, leading to misuse of the 'back door.' 'Although the Customs' General Administration announcement is brief, it marks the end of the dry pulp dividend era,' an expert told Yicai Global reporters. With the label 'dry method equals high risk,' dry ground pulp imports are expected to be curbed in the short term, but long-term effects depend on enforcement strength and supporting measures. After the new regulation is implemented, companies relying on low-cost dry ground pulp may face increased raw material costs and production adjustment pressures, needing to find alternative raw materials or upgrade processes. Meanwhile, there may be short-term fluctuations in raw material supply within the industry, prompting companies to reassess their supply chains. In the long term, the new import regulations for recycled pulp are conducive to the industry's green transformation, driving companies to eliminate low-quality dry ground pulp and switch to high-quality recycled pulp or virgin pulp, improving the overall product quality of the industry.'These improvements will significantly increase production costs. This in itself is a 'forcing mechanism,'" said An Xingye. Low-cost, low-quality dry ground pulp, unable to meet standards, will be eliminated, ultimately encouraging the paper industry to shift toward more environmentally friendly wet-process methods.

