Environmental Questionnaire

Climate change is a key environmental issue for the publishing sector, as the paper production process is energy-intensive and depends on heat, which is harder to decarbonize than electricity. Through the self-assessment Environmental Questionnaire, Mills and Printers can assess their environmental performance and share this information with Publishers. The Questionnaire covers the following topics:

Based on the site inputs, the system calculates intensity metrics such as energy intensity (MWh/tonne of paper produced for mills; MWh/tonne of paper used for printers), GHG intensity (tonnes Scope 1&2/tonne of paper produced for mills, tonnes Scope 1&2/tonne of paper used for printers), and water intensity (m3/tonne of paper produced for mills; m3/tonne of paper used for printers). These intensity metrics are then benchmarked against internal and external benchmarks, for example weighted averages from similar sites (internal) or the Transition Pathway Initiative’s [Paper Industry Pathways]( https://www.transitionpathwayinitiative.org/sectors/paper) (external). Publishers can use these intensity metrics to compare sites against each other, and also to calculate their own Scope 3 emissions from the production of the paper they have used in their books, as well as the printing of their books.

Each questionnaire is assigned a maturity level, based on a maturity ladder which ranks sites from Beginner through to Learning, Advanced, and Leading. This gives publishers and the site itself an idea of where they are in their journey to environmental leadership.

The Book Chain Project team sense-checks Environmental Questionnaires once they are submitted, to ensure that the data is as robust as possible. For example, outliers are questioned, and possible errors and omissions are highlighted to the site. Although it should be noted that this is not a formal verification; we do not ask to see evidence for the reported figures.

The Book Chain Project team also assists sites where requested in filling out the Environmental Questionnaire, including through providing guidance and support on how to calculate and report on specific metrics. The team also follows-up with sites after they have submitted an Environmental Questionnaire, to explain the maturity rating given and how the site can improve next year. This ensures that the Environmental Questionnaire is not just a reporting exercise, but is a tool to drive improvement in environmental management.

Water Risk Tool

Paper mills can be large water users and therefore water risks can be highly material, particularly for mills located in water stressed areas. Additionally, water used in the paper making process requires significant treatment to avoid polluting local water sources when it is discharged back to the environment. The water risk for each mill site is assessed based on the World Resources Institute’s Aqueduct Water Risk Atlas. Based on the site’s location, the current overall water risk and future water stress (absolute value and change from baseline) are shown. Current overall water risk is a composite score based on 13 indicators which measure a variety of water-related risks, including physical quantity risks, physical quality risks, and regulatory and reputational risks. Future water stress shows the expected future value of water stress in 2030, based on a pessimistic scenario as an absolute value and as a change from baseline. This provides publishers and mills with information on which sites should be prioritised for improving water use management and developing water stewardship approaches in the local watershed.

Code Of Conduct

We host the publishing industry Code of Conduct, which states the publishers’ commitments to their suppliers and what they expect from their suppliers in return. The Code articulates standards of labour practice and environmental performance. It is based on internationally-recognised standards, codes and laws, including the ILO Conventions, the UN Declaration for Human Rights and the ETI Basecode, and is updated regularly. We have developed a ‘Book Chain Project audit module’ which suppliers can use in conjunction with a SMETA audit to audit against both the Sedex methodology and the Book Chain Project requirements.

Human & Labour Rights Risk Assessment & Audit Sharing

Human and Labour Rights risks exist in every supply chain, but are highly localised, differing from country to country and sector to sector. The Labour and Environment Risk Assessment tool helps publishers adopt a risk-based approach to identify the countries at highest risk of poor labour and environmental practice. It uses publicly available metrics including, amongst others, the Global Rights Index (ITUC), Freedom in the World (Freedom House), the Human Development Index (UN), Rate of Unintentional Injuries (WHO), and the Environmental Performance Index (Yale). Publishers can use this tool to develop risk-based management of their supply base.

We would encourage publishers to prioritise higher-risk suppliers for regular auditing. Suppliers can use the Book Chain Project portal to share their results with multiple publishers, saving them the time and cost of duplicate audit visits. Suppliers can upload the following audit types to the system: Sedex SMETA, ICTI Ethical Toy Programme, BSCI Amfori, SA 8000 and WCA.

The Book Chain Project team reads every audit that is uploaded to the system, pulling out key information into a bespoke audit dashboard. The dashboard shows the total number of workers at the site, as well as the number of overseas migrant workers if stated in the audit. It will also list all audit findings, categorised into minor, major and critical findings based upon the applicable audit standard.

Suppliers can add their responses to each audit finding, demonstrating how they are closing each non-compliance. They are also able to upload evidence to prove this. Corrective Action Plans (CAPs) can be tagged to each audit uploaded, so publishers are able to review both at the same time.

Labour Questionnaire

There is both a gap and an increasing need to share data on labour standards in the supply chain, particularly bearing in mind increasing regulation around Human Rights due diligence. We are responding to this through a Labour Questionnaire which Mills and Printers can fill out to self-assess their labour performance and share that information with Publishers. The Questionnaire covers the following topics:

The Book Chain Project team sense-checks all questionnaires once they are submitted, to ensure data robustness and catch any obvious errors or outliers. Although it should be noted that this is not a formal verification; we do not ask to see evidence for the reported figures. The questionnaire is designed to minimise the burden on suppliers and mills when it comes to filling out data for multiple publishers, as well as help publishers understand their key risk areas and potential mitigation when responding to human rights due diligence legislation.

Each questionnaire is assigned a maturity level, based on a maturity ladder which ranks sites from Beginner through to Learning, Advanced, and Leading. This gives publishers and the site itself an idea of where they are in their labour standards management. Each supplier and mill submitting a questionnaire is given 1:1 support by a person on the Book Chain Project admin team, including guidance on how the site can improve in their next submission, to drive improvement.

Special Projects

As well as our standard database work, we also address specific hot-spot issues through what we term ‘special projects’. This to drive improvements throughout global print supply chains, focusing on specific high-risk areas for the publishing industry, diving into the detail in collaboration with publishers and suppliers to address certain challenges.

In the past, we have run special projects focusing on the following (including links where resources have been made public):

1. Social insurance in China, developing a report on protecting employees and employers in China’s print sector, followed up in 2022 with targeted guidance for both publishers and employees to better understand the social insurance scheme and it’s importance to human rights due diligence.
2. Health & Safety at Chinese print sites, developing a Factory Health and Safety guidebook and training videos
3. Responsible recruitment in Malaysia and Italy, two key sourcing countries with well-known country risks surrounding the use of labour providers (such as overseas migrant workers getting charged recruitment fees in their home countries). These projects culminated in the Book Chain project developing a responsible recruitment audit module add-on to SMETA audits in collaboration with SGS. This add-on gives auditors extra time to focus on recruitment-related paperwork, interviews with workers and understanding migrant worker recruitment pathways, to help uncover potential issues. We have also published responsible recruitment guidance
4. Best practice guidance on modern slavery statements for publishers.

Design For Sustainability

Circularity refers to a new economic model, where materials get re-used over and over again in a circular way. This is the opposite of the “take – make – waste” model that prevails today. Choices made during the design of a book can determine that book’s recyclability at the end of its life, but also its impact on the health of workers in the supply chain, as well as on the environment.

Design Guide

We created a Design Guide to help publisher design teams make informed decisions about the materials and/or processes they are using. The design guide contains a traffic light-style assessment of 28 finishes, inks & dyes, adhesives, foiling, papers, binding, and materials and processes across their environmental impact, recyclability, and health and safety/labour impact. It also contains emission factors for some of these materials.

Plastics Guide

We have also specifically looked at where and how plastic is used in the book supply chain. Our Plastics Guide summarises the current state of play on plastics, looks at some of the common misconceptions, charts new developments in this area, and presents good practice from other sectors.

Forest Source Risk Assessment & Grading System

Publishers’ main interface with nature is through the paper they use for their books, and the tree fibres that go into those papers. Our Forest Sourcing tool collects and analyses the origins of tree fibres used in paper and board, helping publishers identify responsible forest sources for their books. The tool collects information on the pulp supplier; the tree species, country and (optionally) district of origin of the tree fibres within each pulp, and information on certification credentials. We hold data on over thousands of paper and board brands from hundreds of paper mills around the world. This information is collected directly from paper makers, to hold manufacturers accountable and safeguard data quality and completeness.

We define a Forest Source as a combination of a tree species and its location of origin (country and optionally district). One paper brand is usually made up of multiple Forest Sources.

The Forest Source is screened against three risk tools, which are all updated either annually or biannually and use robust, third-party data from organisations such as Transparency International, the United Nations Food & Agricultural Organization, the World Resources Institute, and the International Union for the Conservation of Nature. All of these tools are freely available to download, and more information about them can be found through the links below.

Based on this screening, the forest source is then given a grade between and , following this logic:

With each forest source graded, we then distil these grades into a single grade for the whole paper, usually the lowest common denominator across the forest sources:

The Forest Source data collection and grading are repeated on an annual basis to ensure any changes in a mill’s sourcing are reflected in the assessment.

Forest Source data is double-checked for a sample of brands (based on risk) each year through microscopic fibre analysis. A sample from the paper maker is sent to a third-party testing house who provide a detailed report of the pulp types and tree species in the sample. In addition, we spot check papers throughout the year using samples sourced from printers and from finished books.

Mill Assessment Framework

As the buyers of timber and pulp, mills constantly make decisions on which forests to source from and therefore indirectly on how well those forests are managed. While there are many resources and frameworks available to help companies strengthen their responsible sourcing of timber and pulp, in our experience these are not yet regularly integrated in mills’ sourcing strategies and policies, which are often reliant on certification.

The Book Chain Project team visits a number of mills each year, to build a stronger relationship with key mill partners; get an insight into their operations; and develop a deeper understanding of their sourcing policies, due diligence system, supply chain engagement, objectives and targets. Our visits are guided by our Mill Assessment Framework, which is based on the Accountability Framework launched by the Accountability Framework initiative, a coalition of environmental Non-Governmental Organisations (NGOs), in 2019.

After each visit, a report is drawn up and agreed with the mill, scoring the mill across seven steps:

1. Right people, right conversation: are we able to speak directly with those who manage responsible sourcing? Are they willing to share examples of resources, systems and databases?
2. Capability and resourcing: to what extent does the mill know the country origin and associated risks of its sources, choose suppliers based on sustainability considerations, and engage in long-term supplier relationships? How well are the relevant staff members trained and equipped?
3. Supply chain assessment and management: how does the mill manage for responsible fibre sourcing, including through information collection, risk assessment, certification, and other control mechanisms?
4. Supplier engagement: how are sourcing requirements communicated to suppliers and how are suppliers supported to meet those criteria?
5. Ambition and commitment: how well-defined and rigorous are the mill’s responsible sourcing objectives, targets, and tracking and reporting processes?
6. Water use and wastewater treatment: is the mill conserving water and protecting sensitive water supply areas? Is it adequately managing wastewater and sludge to minimise pollution?
7. Human resource management: how does the mill manage its human resources, through policies, processes and workforce engagement?

In our report, we provide mills with suggested next steps to improve on gaps we have identified and associated timelines. We also provide links to public resources from reputable third parties where we think these would be helpful. Our team stays in contact with the mills after the assessment, to understand whether they have implemented the suggested improvements.

We have assessed over 30 mills since the launch of the Mill Assessment Framework in 2018, and assess a further five or so each year. Through this process, we hope to help mills develop more robust sourcing policies, due diligence systems, and support them engage with their pulp and/or timber suppliers to drive improvement across the value chain. We also learn about current practice and use these insights to develop events, guidance documents and tools, to support build capacity.

Component & Chemical Screening

There is an increasing focus on chemical safety as more information comes to light regarding the impact of the chemicals that we have added to the environment in the last 50-100 years on the health of humans, animals and the wider environment. Books have many component parts, from paper and board to ink, adhesives and varnish. And in more complex examples they include cover mounts like toys, embedded audio units with speakers and batteries, and textured inserts in sensory books for children.

Chemical safety laws place more stringent reporting requirements on companies with regards to the chemicals that can be used in products. The EU Toy Safety Directive, for example, requires publishers to compile full chemical substance lists – a Bill of Materials – for their books where laws apply, for example in products destined for use by children.

Our portal allows print suppliers to submit exact chemical breakdowns of each book component. We screen these chemicals against lists of international safety legislation, allowing publishers to quickly flag and substitute any that are of concern and possibly gauge the volumes of each chemical.

Lists are under constant review to monitor changes and prepare for new additions.

We monitor legislation in seven jurisdictions:

1. Australia and New Zealand: Safety of Toys – Migration of certain elements
2. Canada: Canada Consumer Product Safety Act (CCPSA)
3. European Union: REACH, Toy Safety Directive, and CMR substances
4. Japan: Chemical Substances Control Law
5. South Korea: The Special Act on Children Product Safety
6. United Kingdom: REACH, Persistent Organic Pollutants (POPs)
7. United States: Consumer Product Safety Improvement Act, and all State-specific legislation e.g. California - Proposition 65

We also maintain a precautionary list of chemicals that are not yet included in any of the legislations but are of interest, for example due to focus from Non-Governmental Organisations. The precautionary list currently includes the SIN list developed by the non-profit ChemSec, and the Zero Discharge of Hazardous Chemicals (ZDHC) Manufacturing Restricted Substances List.