May 2025 WPC Industry Insights : simplebooklet.com

Table of ContentsWMC 2025 Wisconsin Business Friend of the Environment AwardsKonz Wood ProductsWatco Delivers Full-Service and Sustainable Supply Chain SolutionsWSI Launches Revitalized Brand Image and New WebsiteUpcoming EventsWPC Annual MeetingWPC Golf OutingEnvironmental UpdateWPC Environmental Conference2025 Fee Updates for WI Air Permits: What to ExpectPFAS Reporting: CY2024 TRI and TSCA Section 8(a)(7)Forestry & Transportation UpdateForestry & Transportation Committee Meeting Workforce Update Women’s Leadership SeminarWomen in Forest Products Scholarship Awards0406 - 07 08 - 09 10 - 11121314 - 1718 - 19 20 - 25 26 - 2728 - 29 30 -31 The Wisconsin Paper Council is the member-driven statewide trade association representing Wisconsin’s paper, pulp, packaging and forestry industries. The WPC strategically advocates on behalf of these industries to state and federal policymakers, achieving positive policy outcomes.Our team of professionals provides our diversemembership with accurate and timely informationessential to their success.The Council provides world-class educational forums and networking opportunities for our membership, as well as promotes the positive economic, environmental and social contributions of our industries throughout our state and nation.OFFICE:44 East Miin StreetSuite 404 - Madison, WI 53703Phone: 608-467-6025Website: www.wipaper.orgCall or Email: Shawn Brantmeier Email: brantmeier@wipaper.orgPhone: 608-733-1855ADVERTISING OPPORTUNITIES:

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Sta Roster Scott SuderPresidentAs President of the Wisconsin Paper Council, Scott directs all legislative, regulatory, media, political and member relations strategies. Scott is the primary representative for the statewide trade association in all internal and external matters. In this leadership role he supervises the entire WPC team.Shawn Brantmeier Director of OperationsShawn is responsible of the daily activities of the WPC oce and is a core member of our management team. Shawn works to implement innovative ideas and helps create and execute best practices for the organization. She is responsible for ensuring that the organization is managed and performing eciently and eectively.Mykaela is responsible for short and long-term research projects, regulatory and legislative document editing, managing membership tracking, and assisting with marketing and promotional development. Her role will help ensure that WPC information and materials are accurate and informative for WPC membership and stakeholders.Mykaela Chan Research and Development AnalystMAY 2025 | WISCONSIN PAPER COUNCILHERITAGE • SUSTAINABILITY • ADVOCACY03

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Dimension LumberCompany, based in Suring,Wisconsin, has more than 25years of experiencesupplying premium palletcut stock and customlumber. Using a modernscragg mill and locallysourced timber, DimensionLumber ensures a reliablesupply of dust-free lumberproducts year-round.Tower Pallet has providedhigh-quality palletsolutions across theMidwest for over half acentury. Operating from astate-of-the-art 25,000-square-foot automatedfacility, Tower Palletproduces large volumes ofdurable, customizedpallets, offering robustsupport for industrialshipping requirements.Konz Wood Products, Dimension Lumber Company, and Tower Pallet collectivelyrepresent decades of expertise in Wisconsin's wood manufacturing sector, eachproviding unique yet complementary services and products to industries across theregion.OUR CONNECTION TO THEWISCONSIN PAPER COUNCILKonz Wood Products, Dimension Lumber Company, and Tower Pallet collectivelyrepresent decades of expertise in Wisconsin's wood manufacturing sector, eachproviding unique yet complementary services and products to industries across theregion.Established in 1905, KonzWood Products is a fifth-generation company knownfor its extensivemanufacturing capabilities.KWP specializes in pallets,skids, shipping crates, andcustom packagingsolutions. The companyprides itself on maintaininghigh efficiency, a safeworkplace, and consistentinnovation.APPLETON LUMBER CO.ABOUT OUR COMPANIES

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Watco Delivers Full-Service and Sustainable Supply Chain SolutionsHow do natural resource industries move their raw material and ﬁnished product throughout the Badger State and beyond? Our member Watco has a lot to do with that. They operate two short line railroads in Wisconsin: The Fox Valley & Lake Superior Rail System (FOXY) and Wisconsin & Southern Railroad (WSOR). In addition to rail, Watco oers full-service supply chain solutions throughout North America that include transloading and logistics services. In everything Watco does, the team is committed to valuing their customers and their people and safely improving every day.Watco Railroad Sales Director Brad Peot said, “It’s more than moving freight from point A to point B. It’s about partnering with our customers to help them succeed in their business by unlocking the value of rail tansportation. Watco executes this strategy on its railroads daily, and we continually work on identifying new opportunities to partner with customers.” FOXYAfter Watco started the FOXY in 2022, the team partnered with a large mineral processor and quickly began making enhancements on the railroad. The result was a multi-year agreement that included o-site storage, infrastructure improvements to allow for higher-gross-weight shipments, and an increase in rail switch service frequency to support more volume on rail. These changes have made operations more ecient for the customer. Similarly, a forest products customer now utilizes the FOXY to store surplus railcars. Before the FOXY took over operations, railcars were moved oine for storage, resulting in additional cost and longer lead times. Now, this customer has reduced costs and increased speed to market. There is more potential to serve the forest products industry in the Upper Midwest. Particularly when it comes to hauling raw ﬁber and providing value-added services. However, partnerships are needed with industry to make additional investments to fully take advantage of the eciencies and savings from utilizing rail transportation. Watco has done this on the WSOR and aims to replicate that success on the FOXY.WSOROver the last four decades, the WSOR has successfully positioned rail as a valuable short-distance transportation solution. Aggregates and grain account for two of the biggest increases in rail trac on this short line that support the economy of southern Wisconsin. Investments into customer facilities to load and unload rail, development of railcar block pricing, railcar ﬂeet expansions, and collaborations with rail transit commissions and the Wisconsin Department of Transportation on track improvements have helped grow this business over time, enabling bulk commodities to move across all lengths of haul. Short-haul trac has gone from being non-existent at startup to over 33% of the business today. While rail transport is generally most cost-eective for long-haul shipments, 74% of the country’s freight tonnage moves in a lane of 240 miles or less. A common misconception about rail is that it is not competitive when it comes to short-haul moves. However, if the volume in a lane is high and equipment can be cycled, this mode of transportation can be cost-eective and is a service short lines excel at providing.MAY 2025 | WISCONSIN PAPER COUNCILHERITAGE • SUSTAINABILITY • ADVOCACY08

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Commitment to Sustainability Watco is committed to doing business in an environmentally responsible way. Rail transportation is the most sustainable mode of land transportation, consuming 75 percent less energy compared to trucks. When a customer shifts freight from truck to rail, they can not only reduce transportation cost but also increase the sustainability of their supply chain. Watco’s railroads look to continually reduce their energy consumption by equipping locomotives with auxiliary power units (APU) on the FOXY and WSOR. With APUs, a locomotive engine does not have to idle in cold weather to prevent it from freezing up; thus reducing fuel usage, noise, and carbon emissions.Community EngagementWatco is actively engaged in our communities and industry trade organizations to advocate for wise land use planning and development. Preserving land use along rail corridors for industrial development is a primary concern of Watco’s as more industrial development in the region has a cascading eect in generating more commerce and opportunity for businesses and communities in our service territory.Learn MoreConnect with Watco Sales Director Brad Peot at bpeot@watco.com or (608) 445-3852. Keep up with Watco on LinkedIn, Facebook, Instagram, and X.MAY 2025 | WISCONSIN PAPER COUNCILHERITAGE • SUSTAINABILITY • ADVOCACY09

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APPLETON, WI, May 1, 2025 — WSI® (Warehouse Specialists, LLC®), an end-to-end logistics solution partner, released a new website alongside a refreshed brand image. The new website is set to provide a better user experience for current and prospective customers. The updates to the brand also create better alignment with KaseTM, WSI’s fulﬁllment company, serving ecommerce and omnichannel retailers.“WSI has grown signiﬁcantly since it was established almost 60 years ago,” says Paul Simmons, President of WSI. “This next phase in WSI’s evolution will help to provide better clarity on the capabilities we bring to the market and a better web experience.”WSI oers a robust menu of supply chain services with one of the largest rail-served logistics operations in the country, handling a range of products from consumer-packaged goods to industrial and hazardous materials. “With over thirteen million square feet of warehouse space and one of the largest rail accessible networks in the U.S., WSI is uniquely positioned to provide enormous value for the right customers,” says Jesse Jones, VP of Operations at WSI. “The new website will help businesses looking for a competitive edge through logistics excellence understand that WSI is that solution.”By adopting the new tagline “stored and delivered,” the brand aims to provide a simple yet clear message for those less familiar with the organization. “WSI, approaching its sixtieth birthday, has been providing supply chain and logistics operational excellence for a very long time,” says WSI’s CEO, Bob Schroeder. “Ensuring our name and services are visible to the market will be paramount for our continued success.”About WSI:WSI (Warehouse Specialists, LLC) is one of the largest privately held 3rd party logistics companies in the United States, with campuses in 10 states, including rail-accessible warehousing and secure hazardous material facilities. WSI’s commitment to safety, operational excellence, and eective communication is realized through people, process, and technology in perfect sync. Visit www.wsinc.com to learn more.About Kase:Kase, formerly known as ShippingTree and now a part of the WSI family of brands, is a premier provider of direct-to-consumer, retail, and omnichannel order fulﬁllment services. Our proprietary fulﬁllment technology platform was developed speciﬁcally with the needs of ecommerce merchants and omnichannel retailers in mind, providing real-time order tracking, order routing, inventory control, and parcel rate selection. Kase goes Beyond Fulﬁllment to deliver exceptional customer experiences, helping brands keep their promises with every order. Visit www.kase.com to learn more.Contact:WSIMariana ViethDirector of Marketing920-252-2735MAY 2025 | WISCONSIN PAPER COUNCILHERITAGE • SUSTAINABILITY • ADVOCACY10WSI® launches revitalized brand image and new websiteOne of the largest privately held U.S. logistics companies boasts a brand makeover

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NCASI Technical Update:Jayme Coyle, Ph.D., Senior Research Scientist for NCASI, provided an in-depth technical update on PFAS for attendees. The Wisconsin Paper Council and NCASI conducted their spring environmental conference on May 7th at Miron Construction in Neenah. The all day, in-person event provided attendees with the latest information on state and federal issues relevant to the papermaking industry. DNR Presentations:The conference began with updates from the Department of Natural Resources air and water permitting experts. Kristin Hart, DNR Field Operations Director for the Air Division, provided the group with an update on pending and future air regulation. Following Kristin’s presentation, Tim Ryan, DNR Field Operations Director for the Wastewater Division, presented on permitting and regulatory developments for water related issues. WPC - NCASI Environmental Conference RecapENVIRONMENTAL UPDATE The May 7th Event Featured State and Federal Policy Updates, In-Depth Technical Presentations, Expert Legal Analysis, a Roundtable Environmental Management Discussion and Networking Opportunities

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AF&PA Presentation:Paul Noe, Vice President for Public Policy for AF&PA, reported on numerous federal developments impacting the papermaking industry, including EUDR, EPA legal and regulatory issues, federal legislative initiatives and insight into relevant court matters aecting our industry. Michael Best Presentation: Todd Palmer, Esq., partner with Michael Best Law Firm, provided the group with an expert legal perspective on current environmental litigation and enforcement on both the state and federal levels. Todd’s update and analysis provided attendees with valuable insight into current environmental enforcement trends and litigation strategies impacting our industry.Trinity Consultants Presentation: Harrison Rae, Senior Consultant with Trinity Consultants, provided an update on 40 CFR 84 (Phasedown of Hydroﬂuorocarbons). Harrison provided valuable insight into environmental requirements, trends and protocol for this rule which impacts many of our paper mills. Roundtable Discussion: The environmental conference wrapped up with an interactive roundtable discussion on practical strategies in environmental management. The panel included environmental managers from various paper mills as well as industry consultants. Topics covered included insights on environmental compliance strategies, best practices in identifying and managing risk, state and federal environmental trend forecasts and industry “war stories” on permitting, compliance and enforcement issues.

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The Wisconsin Department of Natural Resources (WDNR) has proposed revisions to its air permit fee structure, anticipated to take eect mid-2025. The proposed changes will impact businesses applying for construction permits. Additionally, the fees for Title V operating permits are expected to increase. These updates are intended to better align permitting fees with the actual cost of regulatory oversight and compliance enforcement.The adjustments are part of a broader eort by the WDNR to maintain program eciency, support increased stang needs, and meet evolving federal environmental requirements. This article outlines the proposed changes and discusses what regulated entities in Wisconsin should consider as they prepare for implementation.Construction Permit Fee UpdatesBusinesses constructing or modifying emission units will be aected by the updated construction permit fees. Under the proposal the Initial Application Fee will be increased from $7,500 to $15,000, due at the time of application submittal. The Additional Construction Permit Fees, which are billable upon Final Permit Decision, are also increased. Overall, construction permit fees are expected to almost double. These changes reﬂect the growing complexity of permit reviews and the increasing demand for resources to ensure compliance with air quality standards. WDNR intends to add additional permit writers with the revenue generated from these increased fees, which are expected to take eect in Summer 2025.Title V Operating Permit Fee RevisionsThe current Title V operating permit fees are based on the fee structure below:Base Fees (Annual):• <10 tons: $900• 10–25 tons: $1,200• 25–50 tons: $1,600• 50–80 tons: $2,300• 80 tons: $3,000• “Per-Ton” Emission Fee: A $35.71/ton charge for each ton of billable pollutant emitted, up to 5,000 tons per pollutant. Facilities emitting fewer than ﬁve tons total are exempt from the per-ton fee.Additionally, Governor Evers’ biennial budget proposal (Senate Bill 45) includes an increase in the “per-ton” emission fee to $63.69 per ton of emissions. Note: The Legislature’s Joint Committee on Finance is currently crafting their own biennial budget which likely will not include this proposed fee increase. MAY 2025 | WISCONSIN PAPER COUNCILHERITAGE • SUSTAINABILITY • ADVOCACY182025 Fee Updates for WI Air Permits: What to ExpectOverview of Proposed Air Permit Fee IncreasesIn collaboration with Trinity ConsultantsENVIRONMENTAL UPDATE

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Why the Change?WDNR perspective: The WDNR has proposed these air permit fee revisions in response to several growing needs within the air permitting program. Rising administrative and stang costs have made it increasingly dicult to maintain timely permit processing and eective compliance monitoring under the existing fee structure. Additionally, the WDNR has emphasized the need to invest in more robust air quality analysis and regulatory enforcement, particularly as federal standards evolve. Inﬂation, which has not been adequately accounted for in previous fee adjustments, also played a signiﬁcant role in prompting this update. By aligning fees with the actual costs of oversight, the WDNR aims to ensure Wisconsin’s continued compliance with the Clean Air Act while sustaining a well-functioning permitting system.Wisconsin Paper Council perspective: The Wisconsin Paper Council continues to advocate for reasonable policy changes such as streamlining permitting requirements and providing a more reasonable agency sta time review structure in order to mitigate these substantial fee increases. Additionally, the WPC opposes creating automatic inﬂationary adjustments for these fee increases. What Businesses Should Consider Doing:Businesses should begin preparing now for these potential fee changes. Companies are encouraged to review the proposed fee schedule closely and assess how these changes may impact ongoing or future projects. It is advisable to incorporate the revised costs into operational budgets and permitting timelines to avoid unforeseen delays. Submitting applications early may also help facilities avoid backlogs as the rule changes approach implementation. Proactive engagement will be key to navigating the transition smoothly and maintaining regulatory compliance.

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IntroductionPer- and polyﬂuoroalkyl substances (PFAS) have emerged over the past decade as a chemical of concern throughout industry, with a speciﬁc concern for pulp & paper mills in North America, due to historic use, the ability to persist, and background concentration in the environment. These chemicals are a grouped family of synthetic organoﬂuorine chemical compounds, with almost 15,000 species listed in the United States Environmental Protection Agency (USEPA) CompTox Chemicals Dashboard, with nearly seven million listed in the NationalInstitute of Health’s (NIH) National Library of Medicine maintained database, PubChem. The deﬁnition of PFAS varies from agency to agency, however, the most generic deﬁnition of PFAS is any chemical that has multiple ﬂuorine atoms attached to an alkyl chain, speciﬁcally following the formula of CnF2n+1, these substances will also typically have a functional group attached to the compound, e.g., a carboxyl group. The perﬂuoroalkyl varieties are deﬁned as aliphatic substances where all of the hydrogen atoms bonded to carbon atoms are replaced by ﬂuorine atoms, except those hydrogen atoms where substitution would modify the nature of the functional group present. Polyﬂuoroalkyl varies are deﬁned as aliphatic substances where all of the hydrogen atoms attached to at least one (but not all) carbon atoms have been replaced by ﬂuorine atoms. PFAS can be further broken down into two categories, short- and long-chain PFAS. Short-chain PFAS are those that contain six or fewer carbon atoms, while long-chain PFAS contain seven or more carbon atoms. Research has shown that long-chain PFAS are likely to persist longer in the environment or bioaccumulate, while short-chain PFAS may not bioaccumulate but are much more soluble in water than the long-chain PFAS species. Due to their prevalence in commerce and nature as long-chain species, perﬂuorooctanoic acid (PFOA) and perﬂuorooctane sulfonic acid (PFOS) are the two most commonly discussed PFAS species, see Figures 1 and 2 below for the chemical structure of PFOA and PFOS. MAY 2025 | WISCONSIN PAPER COUNCILHERITAGE • SUSTAINABILITY • ADVOCACY20Figure 1. PFOA StructureFigure 2. PFOS StructurePFAS Reporting: CY2024 TRI and TSCA Section 8(a)(7)In collaboration with Trinity ConsultantsENVIRONMENTAL UPDATE

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Toxic Release Inventory ReportingThe National Defense Authorization Act (NDAA) for ﬁscal year 2020, issued December 20, 2019, introduced new PFAS requirements under Title LXXIII, the PFAS Act of 2019. These requirements cover a number of topics, including Toxic Release Inventory (TRI) reporting under Subtitle B – PFAS Release Disclosure. PFAS to be included in TRI are listed in Section 7321(b)(1)(A)-(I), see table below for complete listing. Table 1. NDAA Section 7321 Included PFASProactive engagement will be key to navigating the transition smoothly and maintaining regulatory compliance. TRI reporting is required for facilities that meet all of the following criteria: • The facility is in a covered North American Industrial Classiﬁcation System (NAICS) Code(s) or is a federal facility, • Has the full-time equivalent (FTE) of ten employees (20,000 hours per year), • manufactures, processes, or otherwise uses (MPOU) Section 313 chemicals, and chemical speciﬁc thresholds for MPOU are exceeded. Chemical Name CAS #Perﬂuorooctanoic acid (PFOA) 335-67-1PFOA Salts 3825-26-1, 355-95-5, 68141-02-6Perﬂuorooctane sulfonic acid (PFOS) 1763-23-1PFOS Salts2795-39-3, 29457-72-5, 56773-42-3, 29081-56-9, 70225-14-8Hexaﬂuoroproylene oxide dimer acid (GenX) 13252-13-6GenX Ammonium Salt 62037-80-3Perﬂuorononanoic acid (PFNA) 375-95-1Perﬂuorohexanesulfonic acid (PFHxS) 355-46-4Any TSCA Section 8(1)(b) PFAS Varies, see 40 CFR Part 721.9582 or 721.10536MAY 2025 | WISCONSIN PAPER COUNCILHERITAGE • SUSTAINABILITY • ADVOCACY21

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The 10 or more FTE employee threshold for TRI reporting only accounts for employees that worked for the facility, and includes operational sta, administrative sta, dedicated sales sta, company drivers, contractors, and o-site direct corporate support. This threshold does not include contract drivers or any contractors performing intermittent service functions, such as janitorial services. All part-time and full-time employee hours are required to be aggregated to determine if the facility exceeds the 20,000-hour threshold. Pulp and Paper facilities generally fall into the 32 NAICS codes and exceed the 10 FTE threshold, thus are required to perform threshold screening for the MPOU thresholds. There are currently 799 individually listed chemicals and 33 chemical categories covered by TRI reporting listed in 40 CFR Part 372.65, of which 196 are PFAS chemicals for RY2024. As part of the MPOU threshold screening, facilities will be required to determine if a TRI listed chemical is manufactured, processed, or otherwise used at the facility in excess of the thresholds set for any speciﬁc chemical. The deﬁnitions for manufacture, process, or otherwise use are listed in 40 CFR 372.3, importantly deﬁning manufacture as “produce, prepare, import, or compound a toxic chemical,” and also applies to any TRI chemicals that are “produced, coincidentally during the manufacture, processing, use, or disposal of another chemical or mixture of chemicals.” See Table 2 below for covered NAICS codes. Table 2. NAICS Coverage for TRI ReportingMAY 2025 | WISCONSIN PAPER COUNCILHERITAGE • SUSTAINABILITY • ADVOCACY22Industry Type NAICS CodeMining 212Utilities 221Manufacturing 31-33All other miscellaneous manufacturing 1119, 1131, 2111, 4883, 5417, 8114Merchant Wholesalers, Non-durable goods 424Wholesale Electronic Markets and Agents Brokers425Publishing 511, 512, 519Hazardous Waste 562Federal Facilities NAENVIRONMENTAL UPDATE

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For the majority of non-PFAS chemicals, the manufacture or process thresholds are set at 25,000 pounds per 40 CFR 372.25(a), and the otherwise use threshold is set at 10,000 pounds per 40 CFR 372.25(b). In addition to the 25,000/10,000-pound MPOU thresholds, the EPA has issued a list of chemicals of special concern per 40 CFR 372.28, each of which has thresholds lower than 25,000/10,000 pounds. PFAS are included in this list and are subject to a lower 100-pound MPOU threshold. PFAS chemicals are not listed as a chemical category, rather Table 1 to Paragraph (a)(1) in 40 CFR 372.28 references individually listed PFAS listed in 40 CFR 372.65(d) & (e). As these chemicals are listed individually, the 100-pound threshold applies to each chemical listed in 40 CFR 372.65(d) & (e), thus the MPOU values for each individual PFAS chemical are not aggregated in the same manner that chemical categories are aggregated against a listed MPOU threshold. Updates by the EPA to TRI requirements were published in the Federal Register on October 31, 2023, including per- and polyﬂuoroalkyl substances in the list of chemicals of special concern. With the listing of PFAS as chemicals of special concern, the de minimis exemption is removed, and the TRI reports for the chemical can no longer be ﬁled as a streamlined Form A. The de minimis exemption is included in 40 CFR 372.38(a) and allows facilities to exclude the quantity of chemicals in a mixture if it is present below 1%, or 0.1% if the chemical is a carcinogen, as deﬁned in 40 CFR 372.38(a)(1)(i)-(iii). The removal of the de minimis exemption for PFAS chemicals requires all mixtures with PFAS that were previously considered exempt from reporting to be included in threshold determinations and compared to the 100-pound threshold for MPOU. For the ﬁrst year of PFAS reporting in TRI, EPA only received 89 reports for PFAS. With the removal of the de minimis exemption for PFAS, EPA expects this number to increase for RY2024 by an additional 623 to 2,015 Form R reports. This is because PFAS are routinely found in mixtures below the previously accepted de minimis level. Streamlined Form A reporting is codiﬁed at 40 CFR 372.27. A chemical can be subject to a 1 million pound MPOU threshold and Form A reporting if the chemical has an annual reportable amount not exceeding 500 pounds for the combined total quantities released at the facility, disposed within the facility, treated at the facility (as represented by amounts destroyed or converted by treatment processes), recovered at the facility as a result of recycle operations, combusted for the purpose of energy recovery at the facility, and amounts transferred from the facility to o-site locations for the purpose of recycle, energy recovery, treatment, and/or disposal. With the designation of PFAS as Chemicals of Special Concern, a Form A is no longer an option. Pulp and paper facilities are likely to encounter PFAS in chemical additives for paper machines, wastewater treatment system residuals, activities stemming from the use of recycled ﬁber, and in aqueous ﬁlm forming foam (AFFF) ﬁreﬁghting systems. Prior to 2024, Safety Data Sheets (SDS) would not necessarily have included PFAS in a mixture below the de minimis concentration. With the removal of the de minimis exemption for PFAS, facilities must ensure that suppliers provide accurate SDS that list low concentrations of PFAS. Targeted outreach to suppliers is prudent if facilities suspect that PFAS could be present. PFAS may also be present in incoming water to a facility. A study from March 2024 by the Minnesota Pollution Control Agency (MPCA) showed that PFAS background concentrations in groundwater are between 1.85-166 ng/L and in precipitation up to 0.61 ng/L. PFAS has historically been used in paper coatings for waterprooﬁng, which are likely to be recycled into old corrugated containers (OCC), which is then processed at recycled ﬁber facilities as a virgin ﬁber alternative. Any incoming PFAS that is not incidentally included in the ﬁnal product would be removed either from the ﬁber during the pulping process or during paper making as wastewater, which could then settle in on-site wastewater ponds, be removed in routine sludge removal operations, or be discharged to a publicly owned treatment works (POTW) or to a water body. If sludge is removed from a wastewater treatment system, it is generally incinerated in a boiler for energy recovery or used as beneﬁcial material on agricultural ﬁelds. Releases to the environment or on-site and o-site facilities would need to be quantiﬁed in sections 5 through 8 of the Form R report if the MPOU threshold is exceeded. Industry Type NAICS CodeMining 212Utilities 221Manufacturing 31-33All other miscellaneous manufacturing 1119, 1131, 2111, 4883, 5417, 8114Merchant Wholesalers, Non-durable goods 424Wholesale Electronic Markets and Agents Brokers425Publishing 511, 512, 519Hazardous Waste 562Federal Facilities NAMAY 2025 | WISCONSIN PAPER COUNCILHERITAGE • SUSTAINABILITY • ADVOCACY23

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Toxic Substances Control Act Lookback Reporting:The Toxic Substances Control Act (TSCA) is codiﬁed in 40 CFR Chapter I Subchapter R, and provides EPA with authority to require reporting, record-keeping and testing requirements, and restrictions relating to chemical substances and/or mixtures. The NDAA authorization for 2020 requires a 12-year lookback for TSCA codiﬁed at TSCA Section 8(a)(7) requiring reporting for any facility who manufactured any per- or polyﬂuoroalkyl substances between January 1, 2011, and December 31, 2022. The reporting period was extended by the EPA on May 12, 2025 (see 90 FR 20236) from July 11, 2025 – January 11, 2026, to April 13, 2026 – October 13, 2026. TSCA deﬁnes manufacture as “ to import into the customs territory of the United States…, produce, or manufacture for commercial purposes.” The rule does not give a discrete list of PFAS compounds, rather it gives a molecular structural deﬁnition of PFAS. This structural deﬁnition is codiﬁed at 40 CFR 705.3, deﬁned as any substance or mixture containing a chemical substance that structurally contains at least one of the following three sub-structures:• R-(CF2)-CF(R’)R”, where both the CF2 and CF moieties are saturated carbons• R-CF2OCF2-R’, where R and R’ can either be F, O, or saturated carbons• CF3C(CF3)R’R’, where R’ and R” can either be F or saturated carbonsThe EPA has published a list of chemicals subject to TSCA Section 8(a)(7) as an excel spreadsheet which is available on the EPA TSCA Section 8(a)(7) Reporting and Recordkeeping Requirements for Perﬂuoroalkyl and Polyﬂuoroalkyl Substances website as the Public List of TSCA PFAS for 8(a)(7) Rule (xlsx). The list contains 1,224 identiﬁed PFAS that are subject to the reporting, a small fraction of the 13,054 (as of April 24, 2024) chemicals listed as PFAS in the CompTox list: PFAS | Toxic Substances Control Act Reporting and Recordkeeping Requirements for Perﬂuoroalkyl and Polyﬂuoroalkyl Substances: Section 8(a)(7) Rule List of Chemicals with the list acronym of PFAS8a7. As of the ﬁnal rule posting for TSCA Section 8(a)(7), EPA states that only 770 PFAS are on the active TSCA inventory, i.e., those active in U.S. commerce. The rule deﬁnes PFAS using a structural deﬁnition. While EPA and other databases provide lists of included PFAS, these lists are not exhaustive, and other compounds may be reportable. Facilities may need to use chemistry knowledge to make a judgement of whether a compound meets the PFAS structural deﬁnition or not. Reporting under TSCA Section 8(a)(7) is required only for facilities that manufactured (including imported) any PFAS for a commercial purpose in any year since January 1, 2011, including coincidental manufacture of PFAS as byproducts or impurities. The rule does not include any facilities that only processed, distributed in commerce, used, and/or disposed of PFAS, and does not include facilities that processed PFAS that were received domestically. The EPA further deﬁnes manufacturing for commercial purposes to include the import, production, or manufacturing of a chemical substance or mixture containing a chemical substance with the purpose of obtaining an immediate or eventual commercial advantage, including but not limited to the manufacture of chemical substances or mixtures for commercial distribution, including test marketing, or for use by the manufacturer itself as an intermediate or for product research and development (R&D). This deﬁnition speciﬁcally excludes non-commercial R&D activities such as scientiﬁc experimentation, research, or analysis conducted by academic, government, or independent not-for-proﬁt research organizations, unless the activity is for eventual commercial purposes. The report will be submitted via the SCPP: Submissions for Chemical Safety and Pesticide Programs service tool in the EPA Central Data Exchange (CDX) web-application, similar to the CDR submissions. MAY 2025 | WISCONSIN PAPER COUNCILHERITAGE • SUSTAINABILITY • ADVOCACY24ENVIRONMENTAL UPDATE

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One key TSCA CDR reporting exemption not included in Section 8(a)(7) is the article exemption. Articles are deﬁned as “a manufactured item which is formed to a speciﬁc shape or design during manufacture, which has end use function(s) dependent in whole or in part upon its shape or design during end use, and which has either no change of chemical composition during its end use or only those changes of composition which have no commercial purpose separate from that of the article, and that result from a chemical reaction which occurs upon end use of other chemical substances, mixtures, or articles; except that ﬂuids and particles are not considered articles regardless of shape or design.” The exclusion of this exemption is not ﬁnal however, as the USEPA Administrator issued a news release on PFAS actions. Included was a statement to “implement Section 8(a)(7) to smartly collect necessary information, as Congress envisioned and consistent with TSCA, without overburdening small businesses and article importers.” Until the USEPA clariﬁes its stance on article exemption, mills are advised to determine what articles imported could contain PFAS, as this is likely not an issue that mills have undertaken in the past, especially as previously imported articles with PFAS under the de minimis would not have included PFAS concentrations on an SDS. Articles that could reasonably contain PFAS would be dryer felts, machine wires, specialty seals and gaskets, etc.An on-demand recording of the Trinity Consultants presented TSCA Lookback Reporting webinar can be found at the Trinity Consultants training catalog. The webinar can be found at https://www.trinityconsultants.com/training/160104/EPA-TSCA-Rule-Targets-PFAS-Consumer-Goods-Importers-and-Industrial-Manufacturers-with-Retroactive-Reporting-RequirementConclusion:The regulatory landscape for PFAS reporting is ever changing and places an increased reporting burden on facilities. Continued compliance relies on facilities having an awareness and understanding of reporting requirements, with an emphasis on starting these reports early. The time required to obtain PFAS data that has not been previously required due to de minimis limits or exclusions from reporting can be a limiting factor for meeting reporting deadlines. Facilities are not recommended to perform blanket requests on all chemicals or vendors, rather use reasonable judgment to determine which chemicals or inputs could potentially contain PFAS chemicals. Using a targeted approach and EPA or trade group guidance on PFAS data including calculations, exemptions, estimations, background concentrations, and reporting requirements is key to successfully complying with existing and future PFAS regulations. This newsletter was prepared in partnership with Trinity Consultants, see the Trinity Consultants website for more information.MAY 2025 | WISCONSIN PAPER COUNCILHERITAGE • SUSTAINABILITY • ADVOCACY25

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The Wisconsin Paper Council’s Forestry and Transportation Committee recently held a productive, well-attended meeting, reinforcing the importance of strong industry partnerships and focused policy advocacy in support of Wisconsin’s forest products sector.The session began with opening remarks from the Forestry Committee Chair Troy Delaet of Domtar Nekoosa alongside Jim Hoppe of Packaging Corporation of America (PCA) and Henry Schienebeck of the Great Lakes Timber Professionals Association (GLTPA). The Chair, who revisited a past discussion on forest certiﬁcation, highlighted the importance of maintaining engagement with the DNR as it begins a certiﬁcation study examining the necessity and eectiveness of forest certiﬁcation in Wisconsin. The conversation brought out the need for a more nuanced understanding of timber sale constraints and encouraged continued feedback from counties and landowners.Other comments reiterated the importance of certiﬁcation to our consuming mills. Timber sales may include restrictions that some attribute to certification, many of these issues may actually stem from social factors—such as proximity to campgrounds, endangered species, and recreational land use.Regional forestry issues were further explored, including federal efforts to delist the northern long-eared bat, regulatory changes aimed at easing timber operations, and instability in landowner grant programs. Transportation infrastructure concerns were also noted—particularly the need for additional multi-axle truck routes and the impact of recent storm damage in Michigan, which has drawn resources away from Wisconsin.Following the opening discussions, key industry and policy representatives provided updates. Jim Hoppe of PCA discussed current Council on Forestry initiatives. Scott Suder of the Wisconsin Paper Council reviewed recent state and federal policy developments. Chris Grawien, from Congressman Wied’s office, offered a federal legislative perspective on issues affecting Wisconsin and the forest products sector. Finally, Brad Peot of the Fox Valley & Lake Superior Rail System gave an update on the Wisconsin Shortline Rail Modernization Act.An update on the current efforts of the Wisconsin Council on Forestry covered legislative activity, including the foreign land ownership bill, Representative Mursau’s forestry budget motions, and funding for a Strategic Plan and Road Map. Also reported on cross-agency collaboration, staffing shortages within the State Forestry Division, growing wildfire risk, and challenges such as red pine and oak reforestation and invasive species management.FORESTRY & TRANSPORTATION UPDATEMeeting Brings Together Industry Leaders to Discuss Priorities and CollaborationMAY 2025 | WISCONSIN PAPER COUNCILHERITAGE • SUSTAINABILITY • ADVOCACY26

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During the government relations portion of the meeting, a comprehensive update was provided on both federaland state policy matters aecting the forest products industry. At the federal level, the discussion included tradenegotiations with the UK and China, the future of Trump-era tax policies, and provisions in the budgetreconciliation bill favorable to the industry. Additional topics included concerns about PFAS regulations, EPAair standards, and the potential negative impact of postal rate increases on paper-based industries. Updates alsoaddressed SNAP work requirements for able-bodied adults in the Farm Bill, ongoing infrastructure legislation,and Medicaid reforms. Concerns were raised about the forest products sector’s perceived unequal treatmentcompared to other agricultural industries. On the state side, updates highlighted pending redistricting eorts,upcoming Supreme Court decisions that could impact legislative authority, Extended Producer Responsibility (EPR)discussions, and energy policy issues such as the Right of First Refusal (ROFR) bill. WPC also rearmed itssupport for modernization eorts at the Rothschild Dam.The meeting wrapped up with the proposed Wisconsin Shortline Rail Modernization Act, a legislative eort aimedat oering tax credits to support infrastructure improvements for shortline rail systems, including sidings and spurs.These investments could be utilized by industrial users such as paper mills.After the meeting, the committee toured Ahlstrom’s facility, where attendees had the opportunity to see operationsﬁrsthand and observe the innovative practices supporting the company’s sustainability and production goals.The Wisconsin Paper Council extends sincere thanks to all participants for their valuable contributions, and toAhlstrom for graciously hosting the Forestry & Transportation Committee Meeting. WPC remains committedto advancing Wisconsin’s forest products industry through strategic advocacy, strong partnerships, and theexpertise of dedicated committee members.MAY 2025 | WISCONSIN PAPER COUNCILHERITAGE • SUSTAINABILITY • ADVOCACY27Pictured from left to right: Troy Delaet, Domtar; Dan Kalupa, Bulkley Dunton; Joe Kies, Domtar; Brad Peot, FoxValley & Lake Superior Rail System; Larry Krueger, Krueger Lumber; Travis Zydzik, Ahlstrom; Henry Schienebeck,GLTPA; Brad Mischler, Ahlstrom; Shawn Brantmeier, WPC

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Women in Forest ProductsLeadership SeminarWORKFORCE UPDATESeminar held at Mid-State Technical College to promote developing leadership skills forwomen in the forest products industry.On May 22nd, the Wisconsin Paper Council in coordination with Mid-State Technical College hosted a Women inForest Products Leadership Seminar. The seminar intended to impart and grow leadership skills within the femalepopulation of the forest products industry. It created a space for industry professionals – and those interested inthe industry – to network, mentor, and build skills that can aid their growth in a male-dominated workplace.Keynote speaker Gina Glover, owner of GinaConnects LLC, engaged the attendees in a networking workshop,“The 5th Question.” The purpose of this workshop was to teach attendees the valuable skill of pushing past thesmall talk and forming meaningful connections when networking.After the keynote, the Schreiber Institute’s Executive Director, Pa Lee Moua, Ph.D., provided early access to theInstitute’s most recent study the “2025 Leadership Horizons Survey”. This survey received 550 respondentsfrom men and women to determine the leadership landscape in Wisconsin. These insights gave attendees aperspective on what concerns leadership have, and what concerns employees have about the leadership in theircompanies.Lee Steigerwaldt, CEO, President, and owner of Steigerwaldt Land Services, Inc., presented the lunch program“Lessons in Communication and Leadership”. Headquartered in the Midwest, Steigerwaldt was established in 1957and is a third generation and family-owned natural resources and real estate consulting company. Lee shared theleadership lessons she’s learned as CEO of her company and how her company has encouraged leadership skillsin their own employees.The seminar also featured a panel of industry professionals and leaders. Lee Steigerwaldt, Jacquelyn Beaulieu,Environmental Manager at Georgia-Paciﬁc, and Kelly Guay, Plant Manager at Ahlstrom all provided valuable insighton their experiences in the industry.At the end of the event, four attendees went home with a membership to the Schreiber Institute for Women’sLeadership and another membership for a friend or colleague. With this membership, the attendees will continuetheir skills development and have access to educational and networking opportunities through the Institute.Thank you to the Schreiber Institute for sponsoring two of these memberships.The Wisconsin Paper Council would like to thank its co-host Mid-State Technical College for their continuedsupport through the planning and execution of this event. Thank you as well to our sponsors at WisconsinDepartment of Natural Resources and TAPPI for making this event a success!MAY 2025 | WISCONSIN PAPER COUNCILHERITAGE • SUSTAINABILITY • ADVOCACY28

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Women in Forest Products Scholarship AwardsWORKFORCE UPDATEThe second cycle of the Women in Forest Products Scholarship has concluded and two women were chosen as recipients this year. Each recipient will receive $1,000 toward their education. The Women in Forest Products Scholarship Fund provides ﬁnancial support to female graduating seniors in Wisconsin who are pursuing a career in the forest products industry or a related ﬁeld, as well as develops women currently in the forest products ﬁeld as future leaders. The Wisconsin Paper Council (WPC) founded the scholarship in coordination with Ahlstrom, a ﬁber-based specialty materials company with mills in Wisconsin. Ahlstrom provided $20,000 seed money to the fund.Isabelle Tibbits received the 2025 High School Scholarship. Isabelle plans to attend college at the University of Wisconsin Green Bay, and major in environmental science to protect and improve the health of the environment and the community.MAY 2025 | WISCONSIN PAPER COUNCILHERITAGE • SUSTAINABILITY • ADVOCACY30“Thank you for this scholarship & your support of my educational goals!” – Isabelle Tibbits

May 2025 WPC Industry Insights

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