Dye Reduction Guidelines for Pulp Mills

Summary#

The federal Minister of the Environment, Steven Guilbeault, has issued the amended Guidelines for the Reduction of Dyes Released from Pulp and Paper Mills under the Canadian Environmental Protection Act, 1999. Published as final on March 16, 2024 and noted in the Canada Gazette on April 6, 2024, the Guidelines set retention, treatment, containment, monitoring and reporting expectations for certain dyes used in pulp and paper mills.

What it does#

The Guidelines for the Reduction of Dyes Released from Pulp and Paper Mills tell mills how to limit dye releases. Key points:

• Which dyes are covered:

  • MAPBAP acetate
  • Malachite Green
  • Basic Violet 3
  • Basic Violet 4
  • Basic Blue 7

• Retention and treatment targets:

  • Minimum dye retention on the final paper product: 90% for MAPBAP acetate; 95% for the other four dyes.
  • Solids removal by the primary wastewater treatment system: 75%.

• Containment and handling:

  • Mills must have a containment plan for dye storage, handling and disposal.
  • Secondary containment capacity must be at least 110% of a single tank’s volume, or 100% of the largest tank plus 10% of the combined capacity of other tanks.

• Notifications, monitoring and records:

  • Operators must inform the Minister in writing of plans to implement the Guidelines within six months in certain situations (timing differs by dye; see below).
  • Mills should measure conformity annually and record any incidental releases.
  • Records must be kept for five years.

• Reporting to the government:

  • For Malachite Green, Basic Violet 3, Basic Violet 4, and Basic Blue 7, the first conformity report is due three years after final publication of the 2024 amended Guidelines; thereafter annual reports are required only if standards were not met or incidental releases occurred.
  • The report schedule is different for MAPBAP acetate (the Guidelines say this requirement is not applicable for MAPBAP acetate).

• Helpful methods included:

  • The Guidelines include a laboratory method to measure dye retention on fibres and a formula for calculating solids removal efficiency.

Who's affected#

• Primary: operators and owners of pulp and paper mills that use any of the listed dyes.
• Secondary: suppliers of dye-containing products to mills, and the companies that manage mill wastewater and treatment systems.
• Local communities and downstream water users may notice changes in mill practices or monitoring, but the document does not set out new penalties or direct actions for the public.

If it’s unclear whether a specific mill uses one of the named dyes, the Guidelines require operators to check and notify the government if they do.

Why it matters#

• Environmental protection: the Guidelines aim to reduce coloured dye released into rivers and lakes, which can affect water quality and how aquatic life and people use the water.
• Practical impact on mills: some mills may need to change dye supplies, improve primary treatment, add containment, or test for dye retention. That can mean operational or cost adjustments.
• Complementary to existing rules: these Guidelines are meant to work alongside the Pulp and Paper Effluent Regulations (PPER) under the Fisheries Act, not replace them. Local conditions could still require stricter limits.
• Transparency and oversight: the monitoring, record-keeping and reporting requirements increase information available to the government about dye use and releases.