When is recycled toilet paper not recycled? When it carries an FSC Recycled label

Hoarding of toilet paper started in early February 2020 in Hong Kong after consumers panicked themselves into believing that the coronavirus outbreak in China would disrupt supplies. Within days, toilet paper shelves were empty in the supermarkets. Social media helped fuel the hoarding, which quickly spread across the world from Sydney to London to Washington DC.

There was no actually shortage in terms of the pulp and paper industry’s ability to manufacture toilet paper. The industry ramped up production and watched its profits soar.

The shares price of Vinda International Holdings, a major Asian tissue products company, increased by 48% in the first months of 2020, as the South China Morning reported.

On 20 April 2020, the Forest Stewardship Council, ever sensitive to the wishes of the pulp and paper industry, put out a press release:

There is an increased demand for tissue and hygiene products on account of the COVID-19 pandemic situation. A significant amount of these products contains recycled paper using the FSC Mix and FSC Recycled labels. Companies are now beginning to see a shortage of recycled fibre to use in these products due to supply constraints and travel restrictions in many areas of the world arising out of the COVID-19 situation. FSC has issued a derogation (FSC-DER-2020-003) describing how companies can use virgin fibre for tissue and hygiene products carrying the FSC Recycled label.

The link from FSC’s press release to the derogation is no longer working, but the derogation is still available elsewhere on FSC’s website.

It states that,

Due to the logistical and practical difficulties that do not permit changing of packaging material at short notice, there are requests from organizations to allow substitution of recycled fibre with virgin fibre in products carrying the FSC Recycled label. This is expected to be a short-term measure till the COVID-19 situation improves and relevant supply chains and volumes can be re-established.

The Policy and Standards Unit at FSC will allow up to 50% virgin fibre to be used in products carrying the FSC Recycled label.

The derogation will remain in place until at least 30 June 2020. The FSC Recycled label is currently deceiving consumers, and is in effect completely meaningless.



  1. This derogation is valid until the end of June and it will be interesting to see if it is lifted then or extended. If the derogation of highly hazardous pesticides is anything to go by anything can, and will happen in the FSC.

    FSC maintain a list of highly hazardous chemicals. Included on this list, under the FSC Restricted List category is the pesticide Acetamiprid. The FSC has identified Acetamiprid as having “acute toxicity to mammals and birds”. FSC also maintain a list of approved derogations for the use of highly hazardous pesticides (FSC-PRO-30-001, 29.10.2019). No derogations have been granted for Acetamiprid use in any FSC certified forest anywhere in the world. Yet it is widely used in the UK and without doubt, many other countries with managed plantation forests. How do I know this? I’ve been planting sitka spruce and scots pine that have been pre-treated with Acetamiprid for the past two years. Some forest management companies apply two rounds annually of follow-up Acetamiprid treatment (via spraying) for two years after planting.

    It gets even worse. Acetamiprid’s predecessor was Cypermethrin. This insecticide was withdrawn from general forestry use in the UK after complaints from tree planters about the strong fumes released when sealed bags of treated trees were opened. Cypermethrin also appears on the FSC Restricted List and like Acetamiprid is classified as acutely toxic to mammals and birds. In spite of FSC identifying it as a highly hazardous chemical, it has approved derogations for Cypermethrin use in FSC certified forest in at least 11 countries. The largest number of derogations (11) have been in South Africa. All these derogations are valid for at least five years. In New Zealand the derogation is valid for 7 years.

    I have tried to ask FSC about the seeming contradictions in its hazardous chemicals policy but as anyone who has tried to get a response from them will know, they are highly secretive and non-transparent. A spokesperson for the FSC UK Pesticides Group did reply and explained that the FSC is no longer issuing derogations. The process aill be replaced by an Environmental and Social Risk Assessment from August this year.

    I’m not sure why nursery workers and tree planters should have any confidence in the FSC’s ability to protect them from hazardous chemicals. Anyone that is at all concerned about worker health and safety should be asking the FSC why they continue to allow these chemicals (and many others including glyphosate which is classified as a carcinogenic on the FSC register) to be used in certified forests.

  2. In delving into the reasons why the FSC permits the use without derogation of chemicals that it identifies as Highly Hazardous, acutely/chronically toxic to mammals and birds and in some cases, including glyphosate, carcinogenic, a shocking narrative emerges. This should worry any forestry or nursery worker that has been exposed to these highly hazardous chemicals whilst working on FSC certified sites.

    The FSC has a Pesticides Policy and maintains a List of Highly Hazardous Pesticides, FSC-STD-30-001. In November 2015 at a meeting in Finland the FSC International Board of Directors decided to suspend the need for derogations for new, active ingredients added to the updated List in February 2015. Based on recommendations from the FSC Working Group for Revision of the FSC Pesticides Policy, chemical ingredients were identified that did not require derogations.

    The updated List identified 389 separate, active ingredients. Of these, 255 or 66% were exempted from the requirement for a derogation. Chemicals that I’ve personally used in FSC certified UK forests, acetamiprid and glyphosate are on the exemption list. Astonishingly, glyphosate was not listed as highly hazardous by the FSC until 2019 yet it is widely recognised to be carcinogenic. Is this important? You bet. Four years ago I was treated for bladder cancer and it came back last year. The only known causes of bladder cancer are smoking and exposure to industrial chemicals. I haven’t smoked for 30 years and it therefore seems quite likely my cancer was caused by exposure to forestry chemicals.

    The serious question the FSC must answer is, having identified chemicals as highly hazardous to mammal and bird health, what evidence did it use back in 2015 to authorise exemptions from derogation? A quick search of scientific literature reveals a large body of evidence as to the human health risks posed by the two chemicals I’ve been using and probably many more on the derogation exempt list. Much of this research was carried out before 2015 when the FSC revised the derogation requirements.

    It seems to me that in so blatantly neglecting to consider the human health implications of using these chemicals, the FSC has shown itself to be morally bankrupt and to have complete contempt for often very low paid tree nursery and forestry workers worldwide.

    I would urge anyone who has had to use a chemical on the highly hazardous list in an FSC certified forest to take it up with their parliamentary representative, forestry safety organisation or any other body that has an interest in ensuring the health and welfare of forestry workers. I certainly will be. Also there may be sufficient grounds to bring legal actions against the FSC and FSC certificate holders for knowingly endangering the health of forestry workers.

  3. A family member gave us a case of toilet paper purchased on Amazon (Commercial). Each roll is wrapped in (tissue) paper and has a label which includes an FSC Mix label. Since beginning to use the toilet paper I have had irritation and itching and needed to use cortisone cream. I realized the connection with beginning to use the toilet paper and stopped using it this morning and started using another brand. Within hours I could feel the difference. Is this an allergic reaction to something in the toilet paper? In reading through the provided information above and references to toxic chemicals I am highly concerned about any of our family members using the toilet paper. Any info would be greatly appreciated.

  4. @Jane – Thanks for this comment. I have no idea is the short answer. The chemicals described in the comments above are used in FSC forestry operations. I don’t know whether any residues remain in the finished paper products. Paper production itself is an extremely polluting process that can also involve the use of toxic chemicals.

    I’d suggest talking to your doctor about your reaction to the toilet paper. And contacting FSC – and/or the manufacturers of the toilet paper – to tell them about it.

  5. I can’t comment on chemicals in FSC certified toilet tissue other than to say that converting wood fibre into pulp and paper must involve the use of some chemicals. Maybe some brands contain chemicals that are more suitable for sensitive skins?

    What I can do is provide an update on my earlier comments concerning the FSC’s policy on highly hazardous chemicals (HHCs) and the health implications for forestry and nursery workers exposed to these chemicals.

    My local MP has managed to table several questions in the UK parliament relating to forest worker’s exposure to three chemicals the FSC identifies as highly hazardous to humans – glyphosate, acetamiprid and cypermethrin. The Secretary of State for Environment, Food and Rural Affair’s response gives no reassurances to any UK forestry worker regularly exposed to these chemicals. The UK government is committed to a 25 year programme to phase out the use of chemicals. So, forestry workers will have to wait a further 25 years before they are free of exposure to known carcinogens and other HHCs?

    I asked the FSC if they are satisfied with this timetable. Their answer gave me no reason to think they disagree with the UK government’s timeline for phasing out HHCs in the UK. In other words the FSC is completely ignoring the growing, published research evidence on the harmful effects on humans of exposure to these chemicals and has nothing to say to people like me who suspect their cancers may have been caused by exposure to glyphosate, acetamiprid and cypermethrin. Amongst all of the FSC’s many failings, this surely ranks as one of the most callous and egregious. To knowingly put at risk the health of a group of poorly paid and under-represented workers suggests a level of cruelty and cowardice that sits uneasily with the FSC’s self-proclaimed public persona of a caring and concerned organisation. FSC policy makers and forest managers are not the ones exposed to these chemicals yet they are taking decisions they must know could affect the health of people like me.

    My MP is continuing her dialogue with the Secretary of State in the hope of persuading the UK goverment that people’s health and lives will be put at risk as a result of the 25-year delay. If you are a UK consumer you might want to consider that a product made from wood fibre originating in a UK forest may come at the cost of the health of someone like me who has waged a 6-year battle against bladder cancer.

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