OLR Research Report

September 20, 2001




By: Kevin E. McCarthy, Principal Analyst

You asked for arguments for and against requiring the use of chlorine-free paper. You also asked whether the Environmental Protection Agency (EPA) has provided any guidance on the subject and whether any states have adopted policies regarding such paper. This memo discusses copier (office) paper and related products. Many consumers have chosen to use unbleached paper for products such as paper towels and napkins.


Traditionally, office paper and related products were made from pulp that had been bleached with chlorine to whiten it. In this process, part of the chlorine was transformed into dioxins and related chlorine by-products. The pulp and paper industry has substantially reduced the production of these by-products by using chlorine dioxide, rather than elemental chlorine, for bleaching. However, the manufacturing processes generally used in the industry still produces the by-products.

Several environmental organizations have advocated the use of chlorine-free products to eliminate chlorine by-products in the pulp and paper industry. Pulp for such paper is bleached with hydrogen peroxide, ozone, or other materials rather than chlorine products. The paper is of similar quality, regardless of bleaching method. The principal argument for requiring the use of chlorine-free paper is that several of the by-products produced by chlorine bleaching are known to cause cancer and other medical problems and also harm the environment. The principal arguments against such a requirement are that such paper is not widely available in this country and costs somewhat more than conventional paper.

EPA has not issued any guidance on the issue of purchasing requirements. In 1998, it amended its regulations governing the pulp and paper industry. The new regulations require most mills to bleach pulp with chlorine dioxide rather than elemental chlorine. At that time, EPA rejected proposals from environmental groups to require use of hydrogen peroxide or ozone to produce paper.

Oregon and Vermont have executive orders that encourage the purchase of chlorine-free paper. Minnesota requires state and local agencies to purchase, when practicable, paper that has been bleached with little or no chlorine. Several other governmental entities have policies that encourage the purchase of chlorine-free paper.


Traditionally, the paper industry used chlorine gas to bleach pulp. (Bleaching is done to whiten the paper, which makes text on it easier to read.) The chlorine produces several by-products, including dioxins and furans. Recently, paper makers have begun using chlorine dioxide to bleach paper. The resulting product is called elemental chlorine-free (ECF).

A few paper makers (primarily in Europe) produce totally chlorine-free paper. This paper can be produced in two ways. Virgin fibers can be used to form a pulp that is bleached using hydrogen peroxide or ozone. Alternatively, recycled paper can be bleached using a process that does not use chlorine compounds. Any virgin pulp added to the recycled paper is bleached with hydrogen peroxide or ozone.


Arguments For

The primary argument for requiring the use of chlorine-free paper is that the chlorine bleaching process creates by-products that pose risks to human health and the environment. The use of chlorine to bleach pulp creates dioxins, furans, and related by-products. These by-products are toxic and cause cancer in humans. In addition, they are extremely toxic to aquatic life, according to EPA. The by-products are stored in the fat of animals and bioaccumulate. This means that the by-products ingested by small fish are concentrated in the larger fish that eat them and again in the people who eat the larger fish.

The use of chlorine dioxide, rather than elemental chlorine, to bleach pulp reduces the amount of by-products produced by 70% to 90%. However, dioxins are hazardous even in very small quantities, and it does not appear that there is a safe level of exposure to dioxins and related by-products. Several environmental organizations have argued that consumers (including governments) should buy totally chlorine-free rather than ECF products to avoid these risks. The Chlorine-Free Products Association Website ( describes their argument in greater detail.

Arguments Against

The primary arguments against requiring the use of chlorine-free paper are its limited availability and higher price. Very few mills in this country produce chlorine-free paper for office and publishing uses. As a result, the National Wildlife Federation (an advocate of chlorine–free paper) found that it had to go to a foreign supplier when it decided to publish its magazine on such paper. The federation made its decision in 1998 and there has been only a modest increase in the availability of chlorine-free paper on the American market since then.

The limited availability of chlorine-free paper means that it is somewhat more expensive than conventional paper. For example, the University of Vermont, which has a policy favoring the use of chlorine-free paper, identified two suppliers of such paper as of April 2001. The suppliers charged $31.70 and $31.80 per case for copier paper, compared to two other suppliers that supplied conventional paper for $28.20 and $29.25 per case. (The chlorine-free paper also had a higher recycled content than the conventional paper.) A university Website,, compares other attributes of the paper.

The pulp and paper industry argues that the move to ECF paper has substantially reduced production of dioxins and that the environmental benefits of ECF paper are comparable to those of chlorine-free paper. The industry's argument is laid out on the American Forest and Paper Association's Webpage,


EPA has focused on regulating discharges from the pulp and paper industry, rather than on purchasing mandates. In 1993, several environmental organizations sued the EPA, seeking to have it issue regulations that would bar the production of dioxins in the pulp making process. EPA subsequently entered into a consent decree with these organizations to use its best efforts to adopt regulations by June 1995, addressing the production of dioxins in pulp making.

In April 1998, EPA issued regulations on this topic (40 CFR 63, 261, and 430). In developing the regulations, EPA found that substituting chlorine dioxide for elemental chlorine was the best available technology that was economically achievable. It required pulp mills to switch to this process. EPA decided against requiring mills to use hydrogen peroxide or ozone to produce paper. It estimated that the capital cost of the regulation would be slightly less than $1 billion (1995 dollars). In contrast, it estimated that requiring use of hydrogen peroxide would cost about $3 billion and an ozone mandate would cost $5.6 billion. Similarly, EPA estimated that the annual operations and maintenance cost associated with the regulation was $113 million, compared to $660 million for hydrogen peroxide and $849 million for ozone. EPA estimated that the regulation would reduce dioxin production by about 70% and furan production by about 90%; requiring production of chlorine-free paper would totally eliminate these by-products.

In addition, EPA required oxygen delignification installed in new mills. The technology facilitates the use of hydrogen peroxide or ozone. The regulations established an incentive program to promote the production of chlorine-free pulp, and requested comments on the feasibility of producing such pulp.


Executive orders issued by the governors of Oregon and Vermont encourage the purchase of chlorine-free paper. Oregon Executive Order 98-07 requires that state purchasing policies reflect a preference for paper that has not been bleached with chlorine. Vermont Executive Order 06-94 requires the establishment of a state resource conservation and pollution prevention plan that includes practices and procedures to maximize the use of chlorine-free recycled paper with the highest post-consumer content feasible.

Minnesota law (Minn. Stat. 16B.122) requires that, whenever practicable, state and local agencies purchase recycled paper that is manufactured using little or no chlorine bleach or chlorine derivatives. This law appears to contemplate the purchase of elemental chlorine-free paper as an alternative to chlorine-free paper.

In addition to these state initiatives, several cities including Chicago, San Francisco, and Seattle have adopted ordinances encouraging the purchase of chlorine free paper. The University of Vermont, Evergreen State College (Washington), and several other colleges have similar policies.