China’s customs authorities have introduced new declaration requirements for imported recycled pulp, aiming to strengthen oversight and prevent environmental and health risks associated with low-quality or improperly processed imports.
On October 9, the General Administration of Customs (GAC) issued an announcement regarding the declaration requirements for imported recycled pulp. It stipulates that import consignees or their agents must indicate the production process of the recycled pulp in the remarks column of the customs declaration, and fill in either “dry method” or “wet method” according to the actual situation.
Since January 1, 2021, China has completely banned the import of solid waste in any form and prohibited the dumping, stacking, or disposal of foreign solid waste within its territory. The GAC said that the latest measure aims to regulate the declaration and management of imported recycled pulp and strengthen import supervision.
Xu Feng, Professor at the School of Materials Science and Technology at Beijing Forestry University, explained that proper waste paper pulp production requires purification processes such as deinking and screening in a liquid state, followed by concentration and steam treatment, and high-temperature drying to finally form the pulp, and pulp produced through these processes has a fiber content of over 91.5% (including 8% moisture), almost no impurities, and achieves sterilization during high-temperature drying, meeting hygiene standards.
Dry-milled pulp production, on the other hand, crushes waste paper raw materials into fragments using a grinder and directly packs them for import, skipping about 95% of the purification process. It carries plastic fragments, heavy metals, and other pollutants, essentially acting as disguised imports of “foreign garbage,” which pose serious environmental and health hazards. In the industry, it is even considered “more dangerous than waste paper.”
An Xingye, Associate Professor at the College of Light Industry, Tianjin University of Science and Technology, explained that “the dry method omits the use of water as a solvent, eliminating the crucial purification steps of hydraulic separation and washing. As a result, common contaminants in waste paper—such as plastic fragments, adhesives, microorganisms, and heavy metals like lead and cadmium—cannot be effectively removed. Without high-temperature steam treatment, the process also fails to achieve sterilization or disinfection.”
If these pollutants enter domestic production, they can become hidden hazards. Microbial contamination—such as coliform bacteria—may compromise the hygiene of food packaging and tissue paper; heavy metal residues can contaminate water treatment systems, leading to secondary pollution; and unremoved impurities may clog papermaking equipment or diminish the cleanliness and quality of finished paper products.
Industry experts said that the dry method essentially imports foreign solid waste in the guise of recycled pulp, posing huge environmental risks. Previously, import inspections for recycled pulp were insufficient, allowing dry-milled pulp to pass under the label of “recycled pulp.” Although there is a national standard for recycled pulp, it is a recommended standard rather than mandatory, with insufficient limits on biological or bacterial indicators for imported recycled pulp. In recent years, customs in many regions have seized solid waste imported under the name of recycled pulp and returned it.
China has made notable progress in curbing the inflow of “foreign garbage” in recent years and has emphasized the need to consolidate the results of its comprehensive waste import ban. To that end, customs authorities are required to refine declaration information, accurately identify risks in imported recycled pulp, and prevent non-compliant products from entering the country.
Regarding the impacts of the new regulation, experts said that the declaration process will increase some workload. Import companies need to accurately distinguish and indicate the production process, requiring them to improve internal procedures, conduct more detailed verification and record-keeping of the source and production process of imported recycled pulp, and strengthen verification of upstream suppliers to ensure that declaration information is true and accurate; otherwise, they may face customs penalties.
With the production method clarified, customs can carry out targeted inspections. Imported pulp produced using the dry method may become a key regulatory target, facing stricter inspection and testing, such as checking for impurities, microorganisms, and heavy metals, with significantly increased risks of rejection or penalties for non-compliant products.
Regarding the issue of leaving a “backdoor” for dry-milled pulp in the original national standard for recycled pulp, industry experts said it was primarily to address the shortage of papermaking fiber raw materials, as China’s domestic wood resources available for virgin pulp are limited, requiring large annual pulp imports. Dry-milled pulp, as a type of recycled pulp, can partially supplement papermaking fiber raw materials and alleviate raw material shortages, while also taking into account the developmental stage of the industry. At the time of standard formulation, some companies were already using dry method production, and excluding them outright could have caused significant impact on related companies and affected industry stability.
In addition, the limitations of the national standard for recycled pulp at that time included insufficient awareness of the hazards of dry-milled pulp and the fact that, as a recommended standard, it served more to guide industry development rather than enforce mandatory restrictions. Therefore, dry-milled pulp was not completely banned but was regulated through technical requirements. Subsequent practice, however, showed that these requirements were insufficient to prevent risks.
Industry experts noted that when the standard was formulated, some companies claimed that “dry method + electrostatic deinking + optical sorting” could reduce impurities to below 3%, and leaving a “backdoor” could encourage technological innovation. In practice, however, some dry-milled pulp companies cut back on downstream purification steps to save costs, leading to the backdoor being misused.
After the new regulation, some companies that rely on low-cost dry-milled pulp may face rising raw material costs and production adjustment pressures, needing to find alternative raw materials or upgrade processes. The industry may also experience short-term fluctuations in raw material supply, prompting companies to reassess their supply chains. In the long term, the import regulations on recycled pulp are conducive to the green transformation of the industry, forcing companies to eliminate low-quality dry-milled pulp and switch to high-quality recycled or virgin pulp, improving overall product quality in the industry.