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Consultation on proposed new criteria for grease-proof paper

11 May 2023  –  30 June 2023

Nordic Ecolabelling gives you the opportunity to comment on the proposal for new criteria for Grease-proof paper. The Nordic Swan Ecolabel is assessed from a life cycle perspective and places high demands on the environment and health.

Your comments are important and will be considered by the national ecolabelling boards and the Nordic Ecolabelling Board. 

Please find the proposed criteria for download further down on this page.

We look forward to your comments, which should be sent to Nordic Ecolabelling no later than 30 June 2023.

Nordic Swan Ecolabel grease-proof paper

A Nordic Swan Ecolabel on grease-proof paper signifies that the product meets strict environmental requirements. This means that the paper has minimal environmental impact throughout its lifecycle.

Nordic Swan Ecolabel grease-proof paper: 

  • Is manufactured in a climate and energy efficient way, with reduced energy consumption and reduced emissions of greenhouse gases. Fossil oil and coal are excluded in production.
  • Meets strict requirements concerning chemicals that are hazardous to health and harmful to the environment. Among others, fluorine and chromium compounds are strictly forbidden.
  • Is made of 100% traceable fibres from controlled sources. At least 70% of the fibres must come from certified forests.
  • Meets strict requirements for emissions to air and water during manufacturing.

What has been changed?

  • Both references values for fuel (2500 kWh/ADt) and electricity (1400 kWh/ADt) in the paper mill have been tightened (O5).
  • Regarding requirements for greenhouse gases (O6-O7), there is a new requirement on fossil fuels banning the use of fossil oil and coal in production of process heat (O6). Use of natural gas is, however, still allowed. The limit value set on the emissions of greenhouse gases is 700 kg/ADt encompassing fuels and electricity used for production of process heat in the mill.
  • The requirement for emissions to water and air has been tightened (O8), both reference values for specific emissions but also the individual score calculation (from 1.5 to 1.3).
  • Regarding silicone treatment of paper: dodecamethylcyclohexasiloxane, D6, (CAS 540-97-6) has been introduced in the requirement O10. Impurities of D4, D5 and D6 in the commercial product must be at concentrations below 400 ppm (0.04% by weight, 400 mg/kg emulsion). The limit value is applied to each substance separately. The sum of D4, D5 and D6 must not exceed a limit value of 1000 ppm in the chemical product.
  • There is a new requirement for colourants and printing inks (O11), colourants used shall follow BfR's recommendation XXXVI. including subsequent subdocuments or EuPia’s guidelines and Swiss Ordinance Annex 10.
  • Greaseproof paper marketed in contact with food (O12) must comply with both BfR's recommendation XXXVI. Paper and board for food contact, April 2021 or more recent versions including subsequent subdocuments and Cepi's Food Contact Guidelines for the Compliance of Paper & Board Materials and Articles, 2019 or more recent versions.
  • The requirement for functional properties of the product applicable within the industry (O13). At a minimum, the following test shall be declared depending on the product type:
    • All kinds of greaseproof paper: Oil and Grease Resistance (OGR)
    • Baking and cooking paper: Water absorptiveness “Cobb value” and “Non-stick performance”
    • Wrapping paper for hot foods: Water vapour moisture (WVM)
  • There are new requirements for packaging (O14–O17): sales packaging made of paper and board, must consist of at minimum 70% certified fibres or 70% recycled material or combination of these (O14). The content of recycled material in plastic packaging must be at minimum 35%. In addition, sales packaging must be made from mono-materials (plastics), be recyclable and information on how to sort the packaging must be specified on the packaging (O17).
  • Regarding labelling (O17), Information about how to sort and recycle the product after use must be in line with existing recycling possibilities in each specific country where the product is sold. This means g. that paper cannot be labelled as compostable if industrial composting is not an option in the country in question.
  • Release paper has been removed from the product group.

The requirements for paper products are gathered in a so-called modular system, where the Basic Module and the Chemical Module include the general requirements for pulp and paper production, including forestry. The Basic Module and the Chemical Module were revised to a generation 3 in 2020. Revision of these modules also affects grease-proof paper in this revision.

Major changes in the Basic Module, generation 3:

  • Regarding the requirement for fibre raw material (O7), the required amount of certified fibres has increased from 30% to 70% in the paper.
  • Reference values for pulps regarding energy (Appendix 4) and emissions to water/air (Appendix 5), have been tightened. Calculation of the energy score for the paper has been changed.

Major changes in the Chemical Module, generation 3:

  • Requirement O1 for classification of production chemicals has been expanded with further hazard class and hazard statement H412.
  • There is a new requirement for prohibited substances (O2), such as substances on the Candidate list shall not be ingoing substances in chemical products used in the production of pulp and paper. Subsequently, some former requirements are removed, such as the requirement concerning residual monomers, as these are now included in the new requirement.
  • The definition of ingoing substances and impurities in chemical products has been updated, the limit for impurities in the chemical product is 1000 ppm (0.1 w-%).

We ask for input on the proposal as a whole and specifically on the following

  • The energy requirement (O5) and the limit value set on the emissions of greenhouse gases (700 kg/ADt) in O7 in the Criteria for Grease-proof Paper. If you have comments on these levels, please explain your objections by specifying which kind of fuel you use, and why you therefore consider the suggested limits to be a problem.
  • The requirement for functional properties of the product (O13). If you have comments on the suggested tests, please explain your objections by specifying what kind of test you use, and why you consider the suggested tests to be a problem.

Documents for download

Who can provide input?

All people, companies and institutions who are interested in taking part in the development work of Nordic Ecolabelling criteria for Grease-proof paper can provide us with their opinions and comments. We would appreciate if you kindly distribute information about this review to whom it may concern.

How can comments be sent in?

Your input is most valuable to our criteria development. We prefer to receive your answers via mail for each country.

For further questions, please contact our product specialists


Ann Strömberg
E-mail: ann.stromberg@svanen.se or remiss@svanen.se


Kristian Kruse
E-mail: kk@svanemerket.no or post@svanemerket.no


Jakob Wegener Waidtløw
E-mail: jwa@ecolabel.dk or hoeringssvar@ecolabel.dk


Anna Sahlman
E-mail: anna.sahlman@ecolabel.fi or joutsen@ecolabel.fi

Please write Finnish comments on this answer sheet: https://link.webropolsurveys.com/S/C7153744A9001FA9

What happens next?

When the consultation period is complete, the answers will be compiled and evaluated. For this reason, a new revised proposal for criteria will be submitted to the national ecolabelling boards and committees. On this basis, the Nordic Ecolabelling Board will then decide on new criteria.

Part of the decision document is the summary of all hearing responses together with answers from Nordic Ecolabelling. The summary will be public and available on the Nordic Swan Ecolabel web page in connection with the publication of the new criteria.

We look forward to receiving your comments no later than 30 June 2023.