After China Banned Waste-Paper Imports, Why Does Recycled Pulp Need New Rules?

2025 · RECOVERED-FIBRE SNAPSHOT

12,891 × 10,000 tonnes of total pulp consumption · 6,948 × 10,000 tonnes of recycled-pulp consumption · 372 × 10,000 tonnes of imported recycled pulp

Sources: China Paper Association, 2025 Annual Report on China's Paper Industry; unit: 10,000 tonnes; recycled pulp accounted for 54% of total pulp consumption.

01 · THE OLD ROUTE

The Import Ban Closed the Old Route, but Fibre Demand Did Not Disappear

Announcement No. 53 of 2020 makes clear that, from 1 January 2021, China prohibits the import of solid waste in any form. Recovered paper can no longer enter China under the identity of solid waste; the word “recycled” does not relax that boundary.

Recovered fibre remains an important feedstock for China's paper industry. In 2025, recycled-pulp consumption reached 6,948 × 10,000 tonnes (69.48 million tonnes), or 54% of total pulp consumption; imported recycled pulp accounted for 372 × 10,000 tonnes (3.72 million tonnes). China's domestic collection and recycling system determines the overall supply base, while imported recycled pulp remains a smaller but still industrially meaningful supplementary channel.

The change is not simply a matter of moving one processing step offshore. If a shipment is to enter China as recycled pulp, the overseas producer must first perform sufficient processing—and assume sufficient quality responsibility—to support that product identity.

Sources: Announcement on Matters Concerning the Comprehensive Ban on the Import of Solid Waste, issued by the Ministry of Ecology and Environment and other authorities; annual statistics from the China Paper Association.

CORE FINDING

The new national standard raises the threshold not for using the name “recycled pulp,” but for proving that the material has undergone genuine resource-recovery processing.

02 · DECLARATION AND INSPECTION

Processing Alone Does Not Make It Recycled Pulp

The six-agency Announcement No. 200 of 2025 specifies that overseas feedstock used to produce recycled pulp for import must consist of separately collected recovered paper, paperboard and paper products, and that the imported product must comply with GB/T 43393. Recovered-paper fragments that have undergone only simple sorting, cutting or baling remain solid waste prohibited from import.

GACC Announcement No. 195 of 2025 requires importers declaring recycled pulp to state “dry process” or “wet process” in the remarks field of the customs declaration, according to the actual production process. This is a declaration and regulatory-identification requirement; it does not make either process inherently compliant or non-compliant.

Announcement No. 200 also authorises Customs to conduct solid-waste identification on imported recycled pulp suspected of being solid waste. Material identified as solid waste must be returned in accordance with the law. Where metal, plastic, glass or other impurities exceed the announcement's 0.50% limit, official interpretations state that the shipment may be returned or destroyed.

Sources: GACC and other agencies, Announcement No. 200 of 2025; GACC Announcement No. 195 of 2025; official government interpretations.

KEY DISTINCTION

GB/T 43393—2026 is a voluntary product standard. It does not, on its own, determine whether a shipment will clear customs; product standards, customs inspection and solid-waste identification address different questions.

03 · PRODUCT IDENTITY

The New Standard Provides a Technical Foundation for the Product, Not a Standalone Customs-Clearance Licence

GB/T 43393—2023 was issued and implemented on 27 November 2023. The national standards platform shows that the 2026 edition was issued on 31 March 2026, will take effect on 1 October, and will replace the 2023 edition in full. The revision project was assigned on 31 October 2025 with a six-month project cycle.

The published scope of the revision covers terms and definitions, product classification, requirements, inspection rules, marking, packaging, transport, storage, quality documentation and test methods, while excluding recovered-paper fragments obtained only through simple cutting and baling. The central question is not whether the material “looks like pulp,” but whether it can be defined, tested, delivered and held accountable as a product.

SN/T 5939—2025, Rules for Inspection of Imported Recycled Pulp, is already in force. The product standard supplies the technical benchmark; Customs' sensory checks, key-indicator testing and any necessary solid-waste identification for a specific batch form part of import supervision.

Sources: National standards platform: GB/T 43393—2026; Recycled Pulp revision project; SN/T 5939—2025.

04 · FOUR EVIDENTIARY GATES

What Really Matters Is Passing Four Evidentiary Gates

Raw-material gate | Where did the feedstock come from, and can its separately collected and recovered status be demonstrated?

Processing gate | Do the declared process, batch records, warehousing records and shipping documents correspond?

Product gate | Are key indicators and non-fibrous impurities controlled, and can the material withstand batch inspection?

Accountability gate | Do the source, processing, testing, quality documents and customs-declaration information align? When a dispute arises, the party able to reconstruct this chain is the party with genuine control over the supply chain.

Statistical note: All three figures are from the China Paper Association's 2025 annual statistics. The 3.72 million tonnes account for about 5.4% of recycled-pulp consumption—not 5.4% of China's total recovered-fibre supply.

05 · SUPPLY-CHAIN VALUE

3.72 Million Tonnes Is Not the Main Volume Driver, but It Can Still Shape a Supply Chain

The 3.72 million tonnes represented approximately 5.4% of recycled-pulp consumption in 2025. It is not the mainstay of China's recovered-fibre supply; the domestic collection and recycling system still determines the overall supply base.

Procurement competition, however, is not determined by national totals alone. For a specific paper grade, region and furnish design, a stable and verifiable overseas source can influence sourcing options, raw-material volatility, mill furnish strategy and supply security. It cannot replace the domestic recovery system, but it can be an important variable at the margin.

The National Development and Reform Commission and other authorities have called for stronger supervision of imported recycled pulp, while encouraging Chinese recycling enterprises to expand overseas and build an integrated domestic-and-international resource-circulation system. This is not a “reopening” of recovered-paper imports; it places cross-border secondary resources within two boundaries: zero solid-waste imports and verifiable resource use.

Sources: National Development and Reform Commission and other authorities, Action Plan for Promoting the Application of Recycled Materials; annual statistics from the China Paper Association.

Four Checks for Procurement and Pulping Teams

1. Audit the raw material. Can the supplier document the separately collected feedstock source and exclude unsuitable materials?

2. Audit the process. Does the dry- or wet-process declaration match actual production, warehousing, shipment and batch records?

3. Audit the product. Do key tests, impurity controls and quality documents form a closed evidentiary loop that can withstand exception tracing?

4. Audit the paper-machine application. What, exactly, does the fibre improve: furnish design, finished-paper performance, broke rate, fibre cost, or inventory and working-capital requirements? The first three checks correspond to regulatory concerns; the last is the mill's own operating decision.

Keep the two ledgers separate. The import-compliance ledger answers “Can it enter China?”; the paper-machine application ledger answers “Is it worth importing, and what will it contribute?” Passing customs inspection does not automatically mean that the pulp is suitable for a particular grade's furnish. Mills must still assess runnability, paper performance and cost per tonne.

The import ban defines what may not enter; standards and regulation must define what qualifies to enter as an industrial resource.

The Next Contest Will Not Be Fought on the Paper Machine Alone

GB/T 43393—2026 is not a licence that allows recovered paper to cross borders under a different name, nor should it be understood as a “closed-door order” against compliant recycled pulp. Together with customs declarations, inspection and solid-waste identification, it raises the evidentiary standard for product identity.

The companies that can connect source, processing, product and evidence into a stable supply chain will be better positioned to convert recovered fibre into lasting cost, delivery and circular-value advantages.