OLR Research Report

April 26, 1999





By: Matthew Ranelli, Associate Attorney

You asked for information on “processed chlorine free” paper and its environmental merits relative to “elemental chlorine free” and totally chlorine free” paper in reducing the risk of exposure to chlorine and dioxin.


Paper manufactures have long used chlorine to bleach pulp when manufacturing office paper. Chlorine used in the manufacturing process produces a variety of chlorinated organic compounds (organochlorides) including dioxins (e.g. TCDD). Dioxin is a persistent pollutant that is acutely toxic to aquatic life and a possible human carcinogen that may also have harmful reproductive consequences.

Beginning in the early 1990's, some manufacturers, responding to concerns about the dangers of organochlorides, began developing alternatives to chlorine bleaching. Several mills began using oxygen or other chlorine-free processes to treat wood pulp. In some countries manufacturers have eliminated chlorine uses and reduced their costs (Environmental Science 5th ed., G. Tyler Miller, Jr., Wadsworth Publishing Company, 1995).

To market and distinguish the papers produced using various levels of chlorine the industry developed terms to describe the papers. The terms are not defined by statute or regulation. The Chlorine Free Products Association (CFPA) define the terms as follows:

1. “totally chlorine free” (TCF) paper is paper produced from virgin paper fibers that have not been bleached using chlorine or chlorine compounds;

2. “processed chlorine free” (PCF) paper with recycled content that may have originally been chlorine bleached, but was not re-bleached with chlorine compounds and any virgin content is totally chlorine free; and

3. “elementally chlorine free” (ECF) paper is paper produced without chlorine gas, but using other chlorine compounds for bleaching.

The CFPA is a nonprofit trade association that advocates chlorine free processing. CFPA developed logos for TCF and PCF and a voluntary certification program for companies that want to use CFPA's logos to market their products.


Totally chlorine free paper promotes the environmentally beneficial goal of reducing the unnecessary use of chlorine by removing it from the manufacturing process and the paper and water waste stream entirely. However, it does not promote another environmentally beneficial goal of increasing the use of recycled materials. TCF paper must be made entirely of virgin fibers; it cannot use recycled paper pulp because it contains chlorine (it is not feasible to collect post consumer wastepaper that is only TCF).

Processed chlorine free paper has the advantage of promoting both chlorine reduction and paper recycling. It has similar advantages as TCF paper in removing chlorine from the manufacturing process, but it does not remove it entirely from a facility's waste stream (in principle the level of chlorine could be substantially eliminated as PCF and TCF use increases). Unlike TCF paper, PCF paper may contain any amount of post consumer wastepaper so long as no chlorine is added to it or to the virgin fibers used.

The benefits of elemental chlorine free paper are less clear. To the extent that it enables manufacturers to use less chlorine or prevent accidental loss, leakage, or spillage of chlorine it may be beneficial. But it still involves the use of chlorine and produces organochloride by-products.

This report does not consider the quality or availability of PCF and TCF paper. According to CFPA, the papers meet the federal quality standards and are available from several manufacturers and distributors (see attached list).


Connecticut currently has a 10% price preference for goods made with recycled materials (CGS 4-59(c)) and requires state offices to use copy paper that satisfies the standards established by the federal EPA under a 1993 Executive Order (E.O. 12873) requiring federal agencies to buy environmentally preferable products (for more information see OLR Report 97-R-0122 and PA 97-124, attached).