Since January 1, 2021, China has completely banned the import of solid waste, including waste paper, which for many years had accounted for a large proportion of imports.
As a result, imported recycled pulp began to attract the attention of paper-making enterprises and overseas waste paper suppliers.
However, with increasing competition and rising production costs, problems have arisen. Some domestic paper companies, under the guise of importing recycled pulp, have skipped conventional pulping processes and instead directly shredded waste paper into fragments, packaged it, and brought it into the country—creating potential environmental risks.
Publicly available information shows that since 2021, there have been multiple cases nationwide in which customs inspections detected suspected solid waste being imported under the name of recycled pulp, leading to shipments being returned. Industry insiders have called for strengthened supervision of recycled pulp imports, raising standards for dry-method recycled pulp manufacturing, and enhancing guidance and support for paper companies establishing factories overseas.
Some Enterprises Producing Recycled Pulp Overseas
In mid-August, during an interview with a paper-making company, a reporter was shown three bags of recycled pulp samples. The first bag contained fibers with minimal damage and high integrity; the second bag consisted of waste paper fragments of varying shapes and sizes, mixed with plastic scraps and household garbage; the third bag was a sample returned by customs. “According to testing, the third sample contained excessive impurities and unidentified bacteria, making it impossible to change its true identity as ‘solid waste,’” said a staff member.
In recent years, imported waste paper has played a major role in China’s paper raw material structure, serving as the primary source of high-quality recycled fiber for domestic packaging paper producers. After the comprehensive ban on solid waste imports, this supply channel was cut off. As a result, some companies began preliminarily processing waste paper overseas into recycled pulp products for shipment back to China.
Public information shows that major paper enterprises such as Nine Dragons Paper (02689.HK), Shanying International (600567.SH), Sun Paper (002078.SZ), Lee & Man Paper (02314.HK), and Jingxing Paper (002067.SZ) have all invested in overseas recycled pulp projects. According to data from the China Paper Association, imports of waste paper pulp were 300,000 tons in 2018, but surged to 3.36 million tons in 2022—an elevenfold increase.
Depending on processing methods, recycled pulp can be categorized as roll pulp, wet pulp, dry-milled pulp, or recycled pulp boards. These types of pulp differ not only in appearance, but also in terms of capital investment, environmental impact, and the practical challenges faced by customs and inspection authorities in testing such imported products.
Roll pulp is processed using a paper machine, undergoing pressing, stretching, drying, and rewinding during papermaking, which causes fiber damage. Because it is produced through papermaking processes, its appearance is difficult to distinguish from finished paper products. Professional identification is required to determine whether it is raw material. Since customs authorities cannot easily differentiate it from imported finished paper, roll pulp was once subject to additional tariffs as if it were imported paper.
Recycled wet pulp is processed through the pulping stage of a papermaking production line, where waste paper is disintegrated, cleaned, and beaten. It is then mechanically dewatered into blocks with a moisture content of around 50%–60%. In form, recycled wet pulp resembles wood pulp wet sheets and is a common raw material for papermaking. However, because of its high moisture content, wet pulp carries high transportation costs. Compared with wood pulp wet sheets, paper companies are more sensitive to transportation costs for recycled wet pulp.
Dry-milled pulp, by contrast, is produced by directly crushing waste paper into fragments and then compressing it into bales. Compared with conventional pulping, this method omits almost the entire production process. Its low investment and quick returns have led some companies to take the risk of import rejection. Because the process lacks purification, high-temperature disinfection, sterilization, and drying, dry-milled pulp typically contains excessive impurities (especially plastic fragments and household waste) and fosters bacterial growth.
“A proper waste paper pulp production line converts waste paper from solid into liquid form (a suspension of fibers in water). In the liquid state, impurity removal, screening, and other purification steps are carried out. It is then thickened and treated with steam (such as thermal dispersion), and finally dried at high temperature to form recycled pulp boards”. After these processes, the recycled pulp boards achieve a fiber content of over 91.5% (with about 8% moisture), contain almost no impurities, and undergo sterilization during high-temperature drying—thus meeting hygiene standards. For this reason, the state allows such products to be imported.
“Three Major Problems” with Recycled Pulp
Industry insiders told that, in fact, China already has a national standard for recycled pulp. On November 27, 2023, the national standard Recycled Pulp (GB/T 43393-2023) was released, providing clear definitions, product classifications, technical requirements, testing methods, and inspection rules for recycled pulp.
An expert who participated in drafting the standard explained that the technical requirements were designed both to address the shortage of papermaking fiber raw materials and to serve as an entry “threshold” to prevent “foreign waste” from entering the country.
“The recycled pulp standard specifies requirements regarding radioactive contamination, hazardous waste, heavy metals, sensory deterioration, and physicochemical indicators. The physicochemical indicators include the content of undisintegrated fiber components, moisture, ash, coarse residue rate, and mechanical strength,” the expert said. “Paper-making enterprises should strictly design their production processes and develop equipment in line with the standard, ensuring recycled pulp fully meets the requirements to avoid being classified as solid waste.”
However, industry professionals pointed out that the standard is recommendatory, not mandatory. Companies may choose whether or not to comply. Moreover, the standard is clearly more applicable to the technical processing of domestically sourced waste paper recycled pulp, while lacking specific restrictions on biological, bacterial, and viral risks associated with imported recycled pulp.
In interviews, several paper company executives emphasized that beyond the standard itself, recycled pulp—particularly dry-milled recycled pulp—still faces three main challenges:
- Environmental safety and public health risks.
- High energy consumption.
- Product quality concerns.
Data on the effectiveness of sanitary pest-control treatment for imported waste paper at a certain port showed alarming results. According to GB 15979-2002 testing standards on 12 untreated waste paper samples, the maximum total bacterial count reached 150,000 per gram; the maximum total fungal count reached 28,000 per gram; Escherichia coli tested positive in 5 cases, Staphylococcus aureus in 3 cases, and Pseudomonas aeruginosa in 1 case. In addition, the imported waste paper contained 19 species of disease vectors and 43 species of plant pests.
In January 2022, under the supervision of Jiaxing Customs, a branch of Hangzhou Customs, one company’s 5 batches of substandard recycled pulp—about 1,900 tons in total—were returned overseas by ship. This marked the first batch of prohibited solid waste returned from the Hangzhou Customs district in 2022. In 2021, Hangzhou Customs had repeatedly detected suspected solid waste disguised as recycled pulp.
The paper-making industry is known for its high energy consumption, heavy pollution, and large carbon emissions. Experts explained that wet-process recycled pulp follows traditional pulping procedures, requiring companies to invest heavily in overseas plants, equipment, and operations—meaning energy use, pollutants, and carbon emissions are largely generated abroad. By contrast, dry-milled recycled pulp involves only rudimentary processing overseas, and therefore must undergo further treatment and processing after importation into China. This leads to significant additional energy consumption, carbon emissions, and environmental pollution domestically.
Furthermore, recycled pulp produced through dry-milling suffers from severe fiber damage and reduced strength, resulting in a waste of high-quality fiber. One paper company reported that after purchasing small quantities of dry-milled recycled pulp, they found that compared with wet-process pulp boards, the dry-milled pulp had 20% more fine fibers, 10% shorter fiber length, and 15% lower fiber yield. In addition, dry pulp contained 0.5%–1% contaminants such as adhesive tapes, hot-melt glue, and plastics, which stuck to paper-making screens and equipment, causing a 20% increase in paper breakages. The quality of paper products also deteriorated, with dust spots and impurities on finished panels rising by more than 15%, leading to more customer complaints.
Calls to Raise Standards and Strengthen Supervision
Interviews revealed that in March 2023, the Zhejiang Paper Industry Association submitted a proposal to the Ministry of Ecology and Environment titled “Recommendation on Excluding Dry-Process Treatment from the National Standard for Recycled Pulp” (hereinafter referred to as the “Recommendation”), urging the state to prohibit the import of recycled pulp produced through dry-milling processes.
The Recommendation pointed out that dry-process recycled pulp is essentially just shredded foreign waste paper, which still contains impurities, plastic waste, household garbage, viruses, and bacteria that have not been treated. Allowing the import of dry-milled recycled pulp would be tantamount to allowing the disguised import of waste paper and “foreign garbage.”
“But such calls have not had much effect. Some companies are still trying to push shipments through,” said one insider.
Cao Chunyu, Chairman of the China Technical Association of Paper Industry, previously stated that many companies have made good use of overseas waste paper resources with positive results. However, numerous issues remain unresolved, such as standards for imported recycled pulp, quality control, and conflicts with environmental protection—problems that require further clarification through policy.
According to the China Paper Industry 2024 Annual Report recently released by the China Paper Association, the country’s total pulp consumption in 2024 reached 124.15 million tons, up 4.34% year-on-year. Of this, pulp imports totaled 34.35 million tons. After excluding non-paper pulp and non-wood pulp, actual imports of wood pulp amounted to 25.44 million tons.
Many experts and industry insiders told reporters that China should raise the standards for imported dry-processed recycled pulp. They recommended that the State Administration for Market Regulation, together with the Standardization Administration of China and the General Administration of Customs, conduct thorough evaluations of the quality, environmental, safety, technical, and ecological requirements of dry-processed recycled pulp imports, and establish a mandatory national standard for “Imported Recycled Pulp” to drive technological improvement.
Expert Recommendations on Strengthening Supervision and Industry Support
Experts have suggested that customs authorities nationwide should inspect and test all goods declared under the name of recycled pulp, assessing their quality, safety, and environmental performance. If the majority of dry-processed recycled pulp fails to meet import requirements, they recommend prohibiting its import or designating it as a statutory inspection commodity. Imported recycled pulp should undergo strict inspection at ports, and non-compliant shipments should be returned.
For producers or exporters repeatedly found to supply substandard recycled pulp, experts proposed adding them to a blacklist, restricting their import eligibility, and imposing penalties in accordance with laws and regulations. They also recommended establishing an information-sharing mechanism and improving the risk prevention and control system to promptly detect and address cases of inferior recycled pulp imports. Furthermore, for exporting countries with repeated instances of non-compliant recycled pulp, China should require stricter supervision of such products to ensure that their quality and environmental performance meet Chinese import standards.
Experts also called for stronger guidance and support for paper-making enterprises building factories overseas. They suggested that the Ministry of Industry and Information Technology, together with the National Development and Reform Commission, the Ministry of Ecology and Environment, and the State Administration for Market Regulation, guide Chinese enterprises investing in overseas recycled pulp projects to enhance technological innovation, develop new pulp and paper-making technologies, and improve product quality—thereby ensuring the safety and stability of industrial and supply chains.
At the same time, they recommended greater policy support for the domestic pulp and paper industry. Enterprises that strictly comply with relevant requirements should receive preferential treatment, while those seeking to upgrade production processes but lacking capital or technical capacity should be provided with assistance. For paper companies investing in overseas recycled pulp projects, tariff reductions and other incentives could be offered to encourage their development.
At the Ministry of Ecology and Environment’s recent 2025 Solid Waste and Chemical Management Conference, Minister Huang Runqiu emphasized that local environmental authorities must consolidate and expand the achievements of the comprehensive ban on “foreign garbage” imports, and, together with relevant departments, continue to strengthen related work.
