The Recycled Material Standard (RMS) is a third-party chain of custody certification standard developed to help advance the use of recycled materials. By establishing a comprehensive network of certified participants, RMS promotes transparency, consistency and accuracy of claims while supporting broader adoption of recycled materials.
The RMS Paper Module was developed with input from stakeholders across the paper value chain, including paper manufacturers, recyclers, converters, brands, certification bodies, and other relevant organizations, following the process described in the RMS Standard Development and Maintenance Policy. Industry engagement is an essential component of the module development process and helps ensure the standard reflects operational realities, aligns with market expectations, and supports credible recycled material claims.
RMS Paper Module Public Comment Process
The RMS Paper Module and RMS Paper Material Classification were made available for public comment from December 10, 2025 through February 28, 2026. Respondents were asked to respond to several multiple-choice questions and given the opportunity to comment on all sections of the documents.
The survey received feedback from individuals representing a cross section of supply chain stakeholders including trade associations, paper companies, and consumer products companies. Some respondents provided additional written comments.
Every comment received was reviewed by GreenBlue staff, and where warranted, changes were made to the standard before presenting a final version to the Technical Development Committee (TDC) for a vote. The TDC voted to approve the RMS Paper Module and Material Classification, which are now available for participant implementation. None of the comments or resulting revisions to the standard were significant enough to warrant a second public comment period.
Public Comment Themes
A few common themes emerged across the submitted comments, highlighting key areas of stakeholder interest and concern. These themes are summarized below and describe areas where further clarification or revision of the module were either warranted or rejected. In addition to the key topics outlined below, we received editorial comments, requests for clarification, and support for the use of examples throughout the standard to illustrate requirements.
Terms and Definitions
Some commenters suggested that we consider using “recycled fiber” as an umbrella term and avoid the differentiation between post-consumer and post-industrial fiber. Concern was also expressed that by including a hierarchy of claims, the RMS conveys a preference for post-consumer materials. This topic was vetted during the original development of the RMS Framework and with the Technical Development Committee that supported the Paper Module. In both cases, there was clear consensus to maintain the ability to support the hierarchy and allow claims by status. Participants also have the option to make a non-differentiated claim of “recycled content” or “recycled fiber” without indicating post-consumer or post-industrial status.
One stakeholder suggested that “The definition of “paperboard” could be clarified using existing ISO standards, such as defining paperboard as having a grammage greater than 250 g/m².” A prior draft of the standard had included reference to both caliper and basis weight to differentiate between paper and paperboard, but the TDC agreed that this was not required. Participants are free to use their own judgement when classifying a substrate as either paper or paperboard. This distinction is not material for defining the amount or status of recycled material.
We received some comments in support of using ISO terms and definitions in some circumstances, and in other cases were asked not to use ISO terms. GreenBlue staff and the TDC often referred to ISO documentation (and other standards) through the development of the Module. Generally speaking, we have adopted ISO terms (such as “controlled blending”) to harmonize with current best practices. Our definitions of recycled content, post-industrial (pre-consumer) material, and post-consumer material align with those in ISO 14021, though we have added nuance to reflect the specific ways that post-industrial materials are generated and accounted for within the paper sector. We rejected consideration of some ISO terms but did so with support of the consensus process. For example, unlike ISO 22095, the RMS does not treat rolling average as type of mass balance chain of custody method, but a distinct approach that supports its own claim type indicating the physical presence of certified material (as detailed further below).
Methodology for Calculations
The Paper Module allows calculations to be made based on either the mass of the fiber in paper or the total mass (including fillers and coatings). The Module also enables the use of several chain-of-custody methods including controlled blending, rolling average, and mass balance. While several comments suggested unfamiliarity with the mass balance approach, survey responses and comments supported all three methods for use in the paper sector.
Commenters supported the use of different approaches for different material sectors. For example, stakeholders supported the use of proportional allocation when using mass balance for paper, whereas in the plastics sector we reached consensus to allow non-proportional allocation for chemical recycling (while treating fuel as a loss).
There were comments regarding the source of default fiber composition factors for different categories of paper. The module stipulates that actual composition data is preferred, and there was no opposition to the concept of using these factors nor were other factors proposed. Therefore, no changes to the default factors have been made.
It was noted that while the standard requires accounting for losses, none of the examples included illustrated this requirement. We introduced an example in section 4.3.2 to reflect accounting for losses in a tissue converting facility.
Some comments expressed concern related to consumer facing claims, especially related to the use of the mass balance method; however, claims are covered under the RMS Label and Trademark Guidelines and were out of scope for this review. The RMS program does not allow for a consumer facing “content” claim when using mass balance.
Paper Module in the Context of Other RMS Standards
We received several comments that were out of scope for the Paper Module but relevant to other RMS standard documents, including the Framework or Label and Trademark Guidelines. For example, the current Framework and Label and Trademark Guidelines only include examples related to plastics because we did not yet have a Paper Module. Relevant comments on those documents which will be kept in mind for future revisions of those elements of the RMS program. The Paper Module requirements should be interpreted in the context of other applicable standard documents, including the Framework and, when labels are used, the Label and Trademark Guidelines.
Emerging Legislation for Packaging
We received conflicting observations about the role that the RMS Paper Module may play in relation to Extended Producer Responsibility (EPR) for packaging. For example, some comments suggested that the RMS material classifications should be organized for consistency with EPR material categories, and one commenter suggested “The RMS must be in alignment with EPR”.
The RMS was designed as a voluntary standard, and GreenBlue has not attempted to develop the RMS to support any specific legislation. EPR for packaging is evolving in the US on a state-by-state basis, and there are significant variations among the approaches. For example, only California and Oregon have introduced the concepts of Responsible End Markets, and rules for implementation are still being developed.
As a voluntary program, it will be up to individual participants if they choose to use RMS to support certain aspects of their compliance with EPR or recycled content mandates.
Material Classifications
There was some confusion regarding the reference to ReMA’s ISRI Specifications (formerly known as ISRI Scrap Specification Circular) within the standard. We have deleted the reference to the ReMA ISRI Specifications. The RMS Material Classifications are intended only for use within the RMS chain of custody program, e.g. for defining product groups and identifying which materials support RMS claims.
Claim Syntax
Commenters were asked whether the standard should require a unique claim syntax code for claims based on a rolling average. The majority of respondents felt that a rolling average claim is distinctly different from a claim based on controlled blending, and supported a distinct claim syntax. While the RMS Framework as published in 2021 treats claims based on rolling average as equivalent to claims based on batch-level controlled blending or segregation, we agreed that it was important to differentiate a rolling average claim that could reflect a variable physical presence of certified material in an output product, especially given the classification of rolling average control systems within ISO 22095 and emerging legislation recognizing recycled material claims based on specific chain of custody models. Accordingly, a new claim syntax for claims based on rolling average has been added to Section 5.