Published in September 2014
Flushing away our forests
Toilet paper is arguably one of the most wasteful products that our western culture has made a necessity, with the average Briton flushing approximately 50 rolls of toilet paper down the loo each year.  As the majority of toilet paper is made from wood pulp, every wipe removes a little more woodland and its associated biodiversity from our planet. Worldwide, approximately 2,700 trees are either flushed down the toilet or end up on landfill every day, thanks to our global toilet paper habits. 
When walking down a supermarket’s toilet paper aisle, consumers’ cleansing preferences seem to have led to a wider range of ‘softer’, perfumed, moistened or quilted papers rather than a wider range of more ethical, unbleached and recycled toilet papers. In fact a growing preference for moist wipes, particularly within wealthier areas, is costing Thames Water approximately £12 million a year to remove sewage blockages partly caused by un-decomposed wet wipes. 
You’ll be hard pressed to find a toilet roll on sale that is not certified by the Forest Stewardship Council (FSC), a mark that ensures certain environmental and social standards are met. Although other certification schemes do exist, such as the Programme for Endorsement of Forest Certification (PEFC), the FSC mark dominates the toilet paper industry and is considered by the World Wildlife Fund to be the best of the bunch. 
However, the observed increase in FSC certification does not go hand-in-hand with more widespread sustainable forestry management practices, as discussed by Simon Counsell from the Rainforest Foundation, below.
Three FSC labels are found on toilet paper wrappings: ‘FSC mixed’, ‘FSC 100%’ and ‘FSC made with recycled materials’.
FSC MIx - The timber or fibre in the product is a mixture of some/all of the following: Timber or fibre from an FSC-certified forest; Reclaimed timber or fibre; Timber or fibre from other controlled sources. Need only contain 70% certified material.
FSC 100% - All the timber or fibre in the product comes from an FSC-certified forest.
FSC Recycled - All the timber or fibre in the product is reclaimed material. 15% can be pre-consumer waste.
The labels themselves are unclear, and the percentage of post- and pre-consumer waste used is not stated (with the exception of Ecoleaf toilet paper).
Only components considered ‘permanent’ or ‘essential’ for the function of the product are covered by the FSC mark. For example, the cardboard tube in the centre of a toilet roll does not have to comply with FSC certification as: “The cardboard roll is a method of dispensing or transporting the paper and can be separated from the product without compromising its function”.9
In addition, depending on which system the manufacturer uses, individual products don’t have to contain any FSC material at all, so long as the entire production volume of the product is 70% FSC.
Can we trust the Forest Stewardship Council?
Simon Counsell, Executive Director of the Rainforest Foundation, asks the question.
When I helped set up the Forest Stewardship Council (FSC) in the early 1990s, the aim was to try to establish an ‘eco-labelling’ scheme that would allow consumers to distinguish wood and paper products derived from sustainable and ethically acceptable sources, from those where forests were being destroyed. The indications were that very few products would qualify for a label in the short to medium term, because truly sustainable management of forests for wood was very much the exception rather than the rule.
Yet a mere (in forestry terms) 21 years after the FSC came into being, there are now tens of thousands of products carrying the FSC’s ‘Seal of Approval’. The ‘tree-tick’ logo can be seen everywhere from packets of toilet paper to Ikea furniture. Does this mean that there has been a miraculous improvement in how timber companies, and paper and furniture manufacturers, source their raw material? Are there really now hundreds of millions of acres of forests and woodlands worldwide under careful, sustainable, management?
Forestry practices not improving
Sadly, no. There is little hard evidence that forestry practices worldwide have significantly improved over the last two decades. Some marginal changes have been made by some FSC-certified companies in places such as Canada and Scandinavia (from where the UK obtains the vast majority of its imported wood).
For example, instead of completely clearing thousands of acres of forest, loggers might now clear-fell in smaller patches, perhaps leaving a few isolated trees standing. Damage to streams and rivers might have been cut, pollution and damage from heavy machinery reduced. But the basic nature of the companies’ practices has remained the same.
There are, at best, large question marks over whether such forestry operations are sustainable even in terms of being able to produce a continuing supply of wood, let alone whether they will be of any value as wildlife habitat, or useful for recreation and a source of important resources for local people.
So why is the FSC’s seal of approval now so prevalent?
When interviewed by Ethical Consumer magazine about this in 2008, I described how the companies involved in carrying out the assessments of logging companies for the FSC were engaged in a “race to the bottom” of certification standards.
The 30 or so companies charged with carrying out the on-the-ground assessment of compliance with FSC’s standards, compete with each other for business. They are paid directly by the logging companies, with fees running to tens or hundreds of thousands of dollars. The certifiers know that they are likely to gain more business in the future if they are lenient with their clients, turn a blind eye to problems, postpone any sanctions for many years, and issue an FSC certificate rather than deny one.
The FSC and a linked organisation are supposed to oversee the certification companies and ensure they are following the rules, and genuinely assessing the loggers for compliance with the FSC’s, mostly sensible, ‘checklists’ of sustainability. But they have consistently failed to do so, and in fact the FSC is almost powerless to really control the certification companies, which carry on with impunity in issuing certificates to non-compliant timber companies. Some of the largest certification companies have repeatedly fallen foul of the FSC’s requirements – issuing sustainability certificates to companies involved in wrecking critical wildlife habitats, or engaged in illegal logging, for example – yet remain within the FSC system.
Always read the small print
Meanwhile, the ‘small print’ on FSC’s product labels – of which there are three different kinds – needs ever-closer inspection. Product lines carrying the ‘FSC Mix’ logo may contain only 70 per cent of certified material, and any individual product may contain no certified material at all. The ‘FSC Recycled’ logo means that the product contains only recycled material, although up to 15% of it could be ‘pre-consumer’ waste, which some campaigners say should not really qualify as ‘recycled’ at all.
What this all means is that consumers are probably often being misled into thinking that the FSC logo guarantees that products are from an ‘environmentally acceptable, socially beneficial and economically sustainable’ source. For toilet paper specifically, products labelled ‘100% post-consumer waste’ would seem preferable to perhaps those labelled ‘FSC Recycled’. Buying products labelled ‘FSC 100% or ‘FSC Mix’ might be contributing unnecessarily to the destruction of the world’s forests.
By choosing to use recycled paper over virgin pulp you “require 28-70 per cent less energy than that required to make virgin paper... and for every tonne of paper used for recycling, [you save] at least 30,000 litres of water, 3,000-4,000 kWh of electricity and up to 95 per cent of air pollutants”. However, you can only recycle paper 4-6 times before the fibres become too short or weak. Virgin fibres are therefore always going to be required. 
This realisation has lead to the exploration and use of alternative plant fibres. Bamboo, cotton, hemp, wheat and sugar cane are just some of the materials being used. For example, Kimberly-Clark’s Andrex Eco contains 10% bamboo fibres. Although these fibres may limit the direct use of timber for paper production, they may still be linked to the deforestation and clearing of areas for agricultural production, unsustainable agricultural practices, land grabs and other human rights and workers’ rights abuses unless they are certified Organic and/or Fairtrade.
The unknown substances...
In July 2014 we conducted a shop survey and reviewed the information presented on toilet paper packages. We didn’t find much ‘ingredients’ information. The chemicals used to process, bleach and perfume toilet papers were not disclosed despite a growing number of reports of toilet papers, particularly perfumed varieties, causing allergic reactions.
Ingredient lists posted on sensitive skin blogs highlighted the use of parabens and ingredients derived from petroleum, such as Poly (Ethylene Oxide), within perfumed loo rolls.  According to the Campaign for Safe Cosmetics, parabens have been linked to endocrine disruption, developmental and reproductive toxicity, allergies and immunotoxicity.  Poly (Ethylene Oxide) has been linked to skin irritations. 
When reviewing a company’s paper sourcing practices, Ethical Consumer looks beyond FSC certification and assesses a company’s broader timber and paper sourcing policies and practices.
We rate companies out of ten for covering the following ten topics considered by us to be essential for a robust policy:
- A timber sourcing policy that covers all timber and timber-derived products
- The exclusion of illegal timber or that sourced from unknown sources
- A discussion on how a company implements its policy
- Clear targets for sourcing timber from sustainably-managed sources
- A discussion of a good minimum standard
- Preference given to certified sources
- A discussion about tropical hardwoods (THW) and the percentage of THW sourced that are FSC certified
- Involvement with a multi-stakeholder initiative or bridging programme such as the World Wildlife Fund – Global Forest Trade Network
- Use of reclaimed or recycled materials
- A high total percentage (50%+) of FSC certified materials sourced
Companies who covered six or more of the above in their policy were considered to have a good timber sourcing policy. In the report this included: Kimberly-Clark, the Co-operative Group, SCA, M&S, Sainsbury’s and the John Lewis Partnership.
Those who covered three to five topics received a middle rating. In this report this included: Essential Trading, Suma, Sofidel SPA and Morrisons.
Those who provided no information, or covered two or less issues, were considered to have a long way to go before they could claim to be reducing their contribution to deforestation. Companies who received this worst rating included: Traidcraft Foundation, Tesco, Aldi and Wal-Mart stores.
The toilet paper market is dominated by three large corporations: Kimberly-Clark, Svenska Cellulosa Aktiebolaget (SCA) and Sofidel SPA. The rest of the market is comprised of supermarket and home-ware retailer’s own brand toilet papers.
Out of the three paper giants, Kimberly-Clark remains the market leader and owns a range of well known brands including Andrex, Kleenex and Huggies. Previously Kimberly-Clark received criticism for cutting down ancient woodlands and poor social practices, and was the target of Greenpeace’s Kleercut campaign. With the release of a new fibre procurement policy, the Kleercut campaign achieved its goal and came to a close in 2009. Since this campaign success, Kimberly-Clark appears to have cleaned up its environmental behaviour. The company received our best rating for its environmental policy and timber procurement policy, and no environmental criticisms of the company could be found.
However in terms of social and political practices the company still has a way to go. Kimberly-Clark is a member of several corporate lobby groups, has key operations within several oppressive regimes and the company still conducts tests on animals ‘where necessary’.
Svenska Cellulosa Aktiebolaget (SCA), is Europe’s largest private forest owner, which it manages according to Forest Stewardship Council guidelines. Similar to other corporations covered within this report, SCA and Sofidel SPA sell a number of items containing cotton that was not certified as organic. Companies who failed to present cotton sourcing policies lost marks under the genetic engineering, workers’ rights, and pollution & toxics sub-categories. This was due to the prevalence of GM cotton worldwide, the widespread use of pesticides within the cotton industry, and the prevalence of cotton sourced from Uzbekistan (a country whose cotton industry is linked to forced child labour and human rights violations).
Two of the three toilet paper Best Buys are owned by co-operatives (Suma and Essential Trading), who are striving to sell environmental and socially responsible products. Suma, the trading name of Triangle Wholefoods Collective, was named ‘2014 Cooperative of the year’ at Co-operative UK’s AGM in June.
Suma and Traidcraft both failed to receive Ethical Consumer’s best ratings for environmental reporting and timber sourcing policies as little information on either was provided. However both organisations, in addition to Essential Trading, were deemed to be progressive in their social practices and their stances on animal testing, animal welfare and the sourcing of GM products.
An alarming recent news headline revealed the use of slave labour within the prawn supply chains of Wal-Mart, Tesco, Aldi, ASDA, Morrisons and the Co-operative.  The Guardian conducted a six month investigation that stated ‘the world’s largest prawn farmer, the Thailand-based Charoen Pokphand (CP) Foods, bought fishmeal from some suppliers that own, operate or buy from fishing boats manned with slaves’.
John Lewis, owner of the Waitrose chain, gave Palestinian solidarity activists a reason to cheer after it stopped stocking SodaStream products early in July 2014.
All websites viewed in July 2014
2 Noelle Robbins, June 2010, Flushing Forests, WorldWatch Magazine, http://s.coop/1uy8r
3 William Cook, October 2012, Too posh for loo-paper, Daily Mail, http://s.coop/1uy8s
9 FSC Directive on Chain of Custody Certification, Updated Feb 2013, http://s.coop/1uygf
10 Paul Thomas, May 2008, Behind the label: Recycled Toilet Tissue, Ecologist, http://s.coop/1uy8u
12 Christian Wolmar, March 2009, Let’s wipe out toilet paper, The Guardian, http://s.coop/1uy8z