UPM requires all its suppliers to be fully compliant with the requirements of the local chemicals regulation e.g. European Community REACH (Registration, Evaluation, Authorization and Restriction of Chemicals) and CLP (Classification, Labelling and Packaging) regulations.


We pre-evaluate all chemicals prior to making a purchasing decision. For the pre-evaluation we collect chemical compliance information and documents. For pulp and paper mill production chemicals we use Pulp & Paper Industry Harmonized Questionnaire to collect the information.

The P&P Industry Harmonized Questionnaire is a comprehensive data set of chemicals. It has been developed in co-operations of several chemicals suppliers and paper companies. To learn more of the P&P-Harmonized Questionnaire and the IT tool P&P Value Chain Information system (P&P -VIS) developed to support chemicals information exchange pls. visit CEPI web page

UPM RSL 2020

To enhance product stewardship and ensure that UPM products meet our high sustainability standards, UPM has launched the Restricted Chemical Substance List (UPM RSL) in 2010. The most recent update, UPM RSL 2020, is a request to provide chemicals information.  It is built on the P&P Industry Harmonized Questionnaire. In addition, we have few company specific questions. The scope of the P&P Harmonized Questionnaire and the UPM RSL 2020 is the same: Chemical additives and raw materials (excluding pulps) that are used in pulp and paper production or in water or effluent treatment.

 The following documents must be provided to UPM mill procurement contact and cc: productstewardship(at) using email or P&P-VIS tool.

All chemicals

  1. The latest Material Safety Data Sheet (MSDS) that fulfils the local chemicals regulation in the official language of a receiving UPM unit to the address  . The accompanying email must also include information detailing which UPM unit(s) have received the chemical. (UPM Raflatac units, Blandin paper mill in US, Fray Bentos pulp in Uruguay, UPM saw mills, Chudovo plywood mill in Russia and Otepää plywood mill in Estonia: Pls. contact mill procurement for SDS delivery address)
  2. Deliveries in EU countries and when applicable: Extended safety data sheets with exposure scenarios

Pulp and paper mills chemical additives and raw materials (excluding pulps) that are used in production or in water or effluent treatment.

Suppliers are requested to fill in the Pulp&Paper Industry Harmonized Questionnaire and reply to UPM RSL questions. The Harmonized Questionnaire includes following sections:

  • Ecolabel declaration/information (e.g. EU Ecolabel, Nordic Ecolabel, German Blue Angel)
  • Food contact material compliance (e.g. EC 1935/2004, BfR XXXVI, FDA CFR 21, Part 176)
  • EU Biocides Regulation 528/2012
  • Pulp and Paper Industry List of Declarable Substances (PIDSL) including e.g. the following regulations:


European Chemicals Agency’s list of chemicals of very high concern (SVHC)

Substances that are classified carcinogenic, mutagenic or toxic for reproduction (CMR) in the Annex VI of the CLP regulation

Elements or organic contaminants that are restricted in the EU harmonized toy standard EN 71-3, EN 71-9

Substances included in the California Proposition 65

  • Additional requirements e.g. animal based content, genetically modified organisms


UPM restricted chemical substances list

Pulp&Paper Industry Harmonized Questionnaire v.2.0.1

UPM RSL 2020 additional requests

Ecolabels and other UPM requirements for chemicals

EU Ecolabel Requirements

The EU Ecolabel defines further criteria for UPM graphic papers, tissue paper and tissue products production processes, covering:

  • emissions to air and water;
  • energy use;
  • fibres: conserving resources, sustainable forest management;
  • chemicals: restricted hazardous substances and mixtures;
  • waste management;
  • fitness for use.

Suppliers delivering process and functional chemicals to UPM mills that manufacture Ecolabelled copy or graphic paper or newsprint paper must provide a warranty complying with the EU Ecolabel criteria for graphic paper and the EU Ecolabel criteria for tissue paper and tissue products (2019/70/EU); Chemicals are at criterion 4 – Restricted hazardous substances and mixtures) together with the latest updated MSDS to the Competent Body/ Kirsi Auranmaa (kirsi.auranmaa(at) and to  
UPM Responsibility/(productstewardship(at)

All chemical suppliers are required to send minimum SVHC compliance declaration / statement.

Links to the Declaration documents below:

EU Ecolabel Graphic paper, tissue paper and tissue products (2019/70/EU)  
Combined Declaration  – Combined declaration for all types of chemicals Declaration 6 – Lotions
Declaration 1– SVHCs for chemicals for which there is no specific declaration  
Declaration 2 – Coating, cleaning, defoamers and dispersants  
Declaration 3 – De-inking chemicals  
Declaration 4 – Biocides  
Declaration 5 - Dyes  

Pulp needs to fulfill Tissue Criteria requirements.

More instructions regarding EU Ecolabel criteria


Nordic Ecolabel (Swan) Requirements

Nordic Ecolabelling defines environmental requirements concerning the origin of the raw wood material, air and water emissions, use of energy as well as the chemicals used in the production of the pulp and paper. Products are reviewed from a life-cycle perspective, from sourcing through to waste.

The Basic Module contains general requirements concerning forestry management, emissions, energy use and waste disposal regarding pulp and paper production. The Forestry Requirements contain information about the requirements for raw materials deriving from forestry operations.

The Chemical Module contains general requirements regarding the use of chemicals in the manufacture of pulp and paper. Suppliers must fulfill Nordic Ecolabelling (Swan) chemical criteria when supplying process chemicals to UPM Jämsänkoski, Kaipola, Kaukas, Kymi, Nordland, Plattling and Rauma mills as well as Fray Bentos, Kaukas, Kymi and Pietarsaari pulp mills. In practice, suppliers have to add requested information into the My Swan account tool, developed by Nordic Ecolabel. The My Swan Account is a database for chemicals used by Nordic Ecolabelled pulp, paper and printing companies.

Specific instructions for chemical suppliers about Nordic Ecolabel