Three Real Boundaries of Packaging "Water Footprint": Papermaking / Printer Production / Recycling and Repulping — Which Three Accounts Should a Printer Calculate First When Brands Request Data
💡 💡 At a Glance
Water footprint is often treated as a substitute for carbon footprint, but packaging water consumption has three mutually incompatible scopes. Three real boundaries must be distinguished. First, upstream papermaking accounts for the overwhelming majority of water use, generally one to two orders of magnitude above printing, but it does not appear on the printer's books. The printer should obtain paper mill water-consumption data and identify its source rather than estimate and submit a figure. Deliverables should classify material data sources into three categories: client-provided, mill-provided, and unavailable with the impact explained. This table itself forms an auditable evidence chain. Second, the printer's own water use is concentrated in four areas: offset press washing and dampening, which declines substantially with water-based, UV, or EB inks; plate making and cleaning; auxiliary die-cutting, laminating, and gluing processes; and plant operations and landscaping. Reported figures should separate total water withdrawal by scope and state the reporting period and boundary. Including or excluding dormitories and canteens can change the figure by more than tenfold. Wastewater discharge should be documented as an independent compliance item. Third, recycling and repulping is the most frequently overlooked stage. Pulping, deinking, and purification are water-intensive, so using recycled paper does not necessarily save water. The environmental benefits of recycled paper lie in raw-material substitution and waste diversion, not reduced water consumption. Recycling rate must identify the stage to which it applies before inclusion in a report. The first three accounts a printer should calculate are actual plant water withdrawal broken down by boundary, unit product water consumption allocated using two drivers so the client can select the appropriate methodology, and a boundary table showing data item, responsible party, and status.
In September 2026, a client specializing in organic skincare sent us a questionnaire.
One section asked: "Supplier annual water consumption (cubic meters)."
The client added: "We need this for our impact report, using 2025 data, and it must be auditable."
We have answered this question many times, and the answer changes each time because our plant is a special case within the industry: we are a printing plant and do not manufacture paper, but we use water-based inks.
If we simply report our own meter readings, the number is so small that the client may face audit questions such as, "Your water consumption is this low. Did you leave something out?" If we estimate using an industry average, the result would not reflect our actual plant.
This issue eventually became a long-term task for our plant and a useful way to explain water footprint to clients: The printer cannot provide the entire data set the client wants to report. It can provide one segment, and without clearly defining that segment's boundary, presenting it would be misleading.
The First Boundary: Upstream Papermaking Accounts for Most Water Use, but It Is Not on the Printer's Books
First, consider the water-consumption structure of the packaging industry.
For most packaging, the overwhelming majority of water consumption does not occur during printing. It occurs further upstream, particularly in pulp production for chemical pulp and some mechanical pulp, paperboard manufacturing, and certain coating and laminating processes.
For paper packaging specifically, a rough but reliable scale is: water consumption during package printing is typically only one-hundredth to one-tenth of the level used in pulp and paper production. This ratio varies substantially by paper grade and production process, but the overall direction remains stable.
This means two things.
First, if a client tries to reduce packaging water footprint by asking the printer for data, it has approached the wrong party. The variables that can actually be changed include grammage, the use or absence of liners, and whether laminating is required. These are determined at the order-structure level, not through the printer's production parameters.
Second, the printer's proper role is to obtain upstream data and identify its source, not estimate a value and submit it.
A client asked: "What is the water consumption of the paper you use?"
We replied: "That information is held by the paper mill. We know this paper's grammage, origin, and pulp type, but the mill holds the water-consumption data. We can request it from the mill or help you verify the corresponding entry in your LCA data for this paper.
One practical detail is worth highlighting. Our client deliverables include a table listing every material used in the order and the source of its upstream data, divided into three categories: client-provided data with version and year noted, mill-provided data with report title noted, and unavailable data left explicitly blank with the impact explained. When the client uses this table to complete its report, it becomes an auditable evidence chain showing that we understand the boundaries of the data rather than inventing a figure.
The Second Boundary: The Printer's Own Water Use and the Areas It Can Actually Control
The second boundary is one the printer can explain fully: how much water its own plant uses and where it is used.
A printing plant uses water primarily in four areas, with very different consumption levels.
First, offset press washing and dampening. This is the main water-use point in conventional solvent-based offset printing. Press-washing water, fountain solution, and equipment-cleaning water are included here. Water-based ink processes, including UV and EB inks, substantially reduce water consumption in this area because wash-water systems are unnecessary.
Second, plate making and cleaning. Conventional chemical plate making and cleaning require water. CTP digital plate making has already reduced water consumption considerably in this stage.
Third, auxiliary processes for die cutting, laminating, and carton gluing. Examples include diluting adhesives, as many water-based adhesives require dilution, and cleaning equipment. These are intermittent water uses with relatively low volumes but high frequency.
Fourth, daily plant operations and landscaping. These include the canteen, restrooms, and irrigation. This category often represents a substantial share of total plant water consumption, yet it is something printers rarely want to mention to clients, although clients will find it if they investigate.
When clients ask for annual water consumption, we use the following scope: total water withdrawal, based on meter readings or water-supplier settlement statements, equals production-process water use plus plant residential and auxiliary water use, with the reporting period and organizational boundary stated, including whether rented dormitories and canteens are covered.
This scope matters because figures reported by different printers may differ by more than tenfold. The difference is not caused by production processes but by inconsistent statistical boundaries. Some plants report only production meters, while others report the total meter for the entire industrial park. A figure with a clearly documented boundary can withstand audit questions; one without a defined boundary will eventually have to be corrected.
Another issue clients frequently raise is: where does the water go after it has been used? This leads to wastewater treatment and discharge, which is a separate technical discipline. Our approach is to document wastewater discharge as an independent compliance item in the delivery materials, including the applicable discharge standard, monitoring indicators, and the latest test results, rather than blurring it into the water-consumption figures.
The Third Boundary: The Recycling and Repulping Stage Is the Most Frequently Overlooked Part of the Chain
The third boundary is the stage most likely to be omitted from a water footprint and the one that best demonstrates the meaning of the life cycle: water consumption during recycling and repulping.
The recycling route for paper packaging is collection, sorting, pulping, deinking, purification, papermaking, and finished paper production. On a scale basis, water consumption during this process can approach or even exceed the water used in original pulp production because deinking and purification are inherently water-intensive stages.
This leads to a counterintuitive but entirely valid conclusion: using recycled paper does not necessarily mean saving water. If only the papermaking stage is considered, recycled paper may use less water than virgin paper. However, when deinking and purification are included, the gap narrows substantially, and in some cases the recycled route may have higher total water consumption.
A client asked: "If we switch to recycled paper, will it be more environmentally friendly?"
We replied: "That is the right question, but the answer is not what you might expect. The main environmental benefits of switching to recycled paper come from replacing virgin raw materials, thereby avoiding the harvesting of virgin forests, and diverting waste from other disposal routes. They do not come from reduced water consumption. The source of the recovered paper also matters. If the recycling stream contains large quantities of impurities that are difficult to deink, chemical consumption and water consumption during deinking will both increase."
The practical implication for clients is: recycling rate should not be reported as a standalone metric. We have seen brands state a packaging recycling rate of 85% in their impact reports without specifying which stage the figure covers, such as post-consumer recycling or production-waste reuse, or explaining the actual processing route after collection. When brands ask us to verify the figure, we cannot, because it falls outside our boundary. We can provide our accurately measured production-waste reuse rate and evidence of whether the packaging from a given order is recyclable under a specified recycling route.
Accordingly, the printer can provide two reliable data points for this stage: first, the proportion of production waste reused within our plant. Printing trim and waste plates can generally be returned to the mill for papermaking, and our own records allow us to provide accurate figures; second, the level of mono-material construction for the packaging in the order. This directly determines whether the package is sorted as paper or classified as mixed material after entering the recycling system. We discussed this assessment separately in another article and will not expand on it here.
Which Three Accounts Should a Printer Calculate First When a Brand Requests Data?
Bringing these three boundaries together leads to three practical accounts.
Account 1: Actual water withdrawal at the printer's own plant, broken down by reporting boundary. The figure should not be estimated or copied from an industry average. It should come from meter readings or water-supplier settlement statements and correspond to a clearly defined reporting period, normally one year, and a clear organizational boundary, including whether dormitories, canteens, and rented auxiliary facilities are included. Production and non-production water use should be listed separately if the difference is substantial. This is the account the printer can calculate most reliably and is also the only one it can improve proactively.
Account 2: Unit water consumption for the product, allocated by order. What brands usually want to know is not how much water the printer uses annually, but how much water is consumed by their packaging order. To calculate this, annual or monthly total water withdrawal should be allocated to products using an appropriate driver. The selected allocation driver should be clearly explained to the client, whether it is printing hours, paper consumption, or order quantity, because different drivers can produce unit water consumption figures that differ by two or three times.
Our approach is to provide results based on two drivers and allow the client to select the appropriate one, because the client ultimately enters the figure into an externally disclosed table and the allocation method must align with its reporting methodology. Providing two figures with each methodology identified is more credible and more resistant to audit scrutiny than providing a single number.
Account 3: A clear division showing which data the printer can provide and which must come from the client or upstream supplier. This responsibility table should accompany the quotation and delivery documents. Its format is simple: one item per row, with columns for the data item, responsible party, and status. The responsible parties are printer, client, paper mill, or third party, and the statuses are available, request from paper mill, or unavailable.
Clients often say: "I thought you could provide everything."
We reply: "For water footprint, most of the paper packaging data lies with the mill. For the recycling stage, we can provide the production-waste reuse rate. To obtain a complete data set, you need to obtain the paper's water-consumption data from upstream suppliers. We can help you request it from the mill, but two to three weeks' notice is required."
One Sentence for Clients
The most important message we want to convey about water footprint is: "It is not a substitute for carbon footprint. It is a separate accounting scope, and the greatest risk arises when figures from different stages are combined.
Taking one plant's water-consumption figure, entering it in a report, and adding it directly to upstream paper mill water consumption to calculate a package's water footprint forcibly merges two incompatible boundaries. The professional approach is to have each stage report separately and then reconcile the figures within a single life cycle model.
Accordingly, we always deliver a figure with clearly defined boundaries rather than an isolated number. When clients use the data in reports, face audits, or respond to consumer questions, they can identify who provided each entry, the methodology used, and the applicable boundary. This is far more important than the number itself.
We also frequently advise clients: "If your questionnaire contains only one field to complete, first clarify whether it requires factory water use or product water consumption, because the calculation methods differ substantially."
Further Reading
- How Is Packaging Carbon Footprint Calculated? Practical Calculations for 3 Types of Packaging Under ISO 14067 — Carbon and water are separate accounts, but their boundary logic is the same
- 3 Real Data Boundaries for the Carbon Footprint of Package Printing: Scope 1 / 2 / 3 and the Challenges Facing Small Printers — Where printers struggle when clients request upstream data
- Recycled Paper vs Virgin Paper for Packaging: A Real Cost Comparison Across 3 Brand Positioning Strategies — The real benefits of the recycled route do not come from reduced water consumption
- Mono-Material Packaging Design: Why Brands Are Pursuing a Single Material — The factor determining how a package is classified after entering the recycling system
FAQ
Can a printer submit a standalone figure for "annual water consumption"? Why might auditors question it?
The issue is usually not the size of the number but the lack of a clearly stated reporting boundary. The same plant can report figures differing by more than tenfold depending on whether it reports only the production meter or the total industrial-park meter. Whether dormitories, canteens, and rented auxiliary facilities are included directly determines the scope of the figure. Auditors typically ask which water-use points are covered, which reporting period applies, and whether the figure can be reconciled to the water-withdrawal settlement statement. Our standard practice is to use meter readings or water-supplier settlement statements, list production-process water use separately from plant residential and auxiliary water use, state the reporting period and boundary, and document wastewater discharge separately as an independent compliance item rather than mixing it into water consumption.
What is the relationship between water footprint and carbon footprint? Is it correct for a brand to stop calculating carbon and switch to water footprint?
No. They are separate accounting scopes rather than substitutes. Water footprint measures freshwater withdrawal and consumption, while carbon footprint measures greenhouse gas emissions. The drivers of the two metrics for the same package differ substantially. For example, replacing virgin paper with recycled paper provides raw-material substitution and waste-diversion benefits, primarily at the raw-material and waste stages. For water consumption, however, deinking and purification are water-intensive, so the difference between recycled and virgin routes may be much smaller than expected. The correct approach is to have each stage report its own data and then reconcile the figures in a single life cycle model, rather than adding one plant's figure to upstream figures to produce a product water footprint.
Is it compliant for a printer to provide upstream paper mill data together with its own data?
It may be included in the deliverable, but the source, report title, and version year must be identified. A printer is not the paper mill, and the mill's water-consumption data should be issued by the mill. A sound division of responsibility is for the printer to request the data, allowing two to three weeks' notice, and to match each item in the materials list to its data source in a table. If the client already has LCA data, the printer can help identify the corresponding entry for that paper. A printer must never estimate an upstream value independently and submit it to the client for use in an external report, because that would present an estimate as data.
Does using recycled paper actually reduce packaging water consumption?
It should not be assessed based on intuition alone. If only the papermaking stage is considered, recycled paper may use less water than virgin paper. However, once pulping, deinking, and purification in the recycling chain are included, the gap narrows substantially, and total water consumption may even be higher along the recycled route in some cases. The main environmental benefits of recycled paper come from replacing virgin raw materials, thereby avoiding the harvesting of virgin forests, and diverting waste from other disposal routes, not from reducing water consumption. When evaluating a recycled option, the source and impurity content of the recovered paper must also be considered, because difficult-to-deink impurities can significantly increase chemical consumption and water use during deinking.
If a brand requests a packaging recycling rate, can the printer verify it?
Not directly. A recycling rate reflects data from the post-consumer recycling system and falls outside the printer's boundary. The printer can provide two accurately measured related data points: first, the proportion of production waste reused within the plant, since printing trim and waste plates can generally be returned to the mill for papermaking and are documented in the printer's own records; and second, the level of mono-material construction for the packaging in the order, which directly determines whether it is sorted as paper or classified as mixed material in the recycling system. When a brand reports a recycling rate, it should specify the relevant stage, such as post-consumer recycling or production-waste reuse, and the actual processing route after collection. Otherwise, a percentage without a stated methodology is likely to attract questions during verification.
A client questionnaire has only one field for "supplier annual water consumption." Should the printer simply enter a number?
Two questions should be clarified before entering the figure. First, does it require factory water use or product-order water consumption? The calculation methods differ substantially. Second, does the questionnaire accept a response accompanied by a methodology statement covering the data source, reporting period, and coverage boundary? Our practice is to include a methodology statement with the figure, identifying whether the source is a meter reading or settlement statement, the reporting period, whether residential and auxiliary water use is included, and the breakdown between production-process and non-production water use. For unit product water consumption, we provide results based on two allocation drivers, such as printing hours, paper consumption, or order quantity, and identify the methodology for each so the client can select the option aligned with its reporting methodology. Delivering a figure with clearly defined boundaries gives clients support when facing audits or consumer questions.
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