What is the purpose and where can I find the ZDHC MMCF Guidelines V2.2?
The ZDHC MMCF Guidelines V2.2 delivers unified requirements for discharged wastewater quality, air emissions, and chemical recovery for manufacturing facilities producing man-made cellulosic fibres.
The complete set includes:
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ZDHC MMCF Responsible Fibre Production Guidelines V2.2
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ZDHC MMCF Wastewater Guidelines V2.2
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MMCF Air Emissions Guidelines V2.2
The current version of the ZDHC MMCF Guidelines V.2.2 Published in August 2023, can be found here https://downloads.roadmaptozero.com/fibres/mmcf-guidelines
With this set of documents, ZDHC appeals to its Committed Community and the entire MMCF industry to improve the quality of discharged industrial wastewater and production-related air emissions. ZDHC expects also to support the transition of the production of MMCF towards a circular approach by proposing recovery rates for substances such as sulphur, sodium sulphate, N-Methylmorpholine N-oxide (NMMO), ammonia, copper and acetone.
Are the ZDHC MMCF Guidelines only applicable to MMCF manufacturers?
Yes, ZDHC MMCF Guidelines V2.2 applies to MMCF manufacturers only.
Why are MMCF treated differently within the ZDHC approach?
Sustainable chemicals management of fibre production processes requires an approach beyond simply restricting the chemicals used with an MRSL. We can achieve the most impact by collaboratively setting guidance around good sustainable chemicals management and setting limits for wastewater, sludge, and air emissions during fibre production. ZDHC continues to promote researching MMCF production processes using less hazardous chemicals.
Why has ZDHC included Man Made Cellulosic Fibres (MMCF) in its program?
Fibres are an important part of the value chain. Therefore it’s a logical next step for ZDHC Roadmap to Zero Programme to include fibre production processes and their raw materials. MMCFs are produced from cellulose sources using hazardous chemicals. Within the production process of MMCF, particularly where that’s not an integrated (closed-loop) process, chemicals react with the cellulose. This creates by-products, which can be released into the air, water and soil.
What is the scope of the ZDHC MMCF Guidelines V2.2
MMCF Guidelines V2.2 covers outputs proceeding with the dissolving of the pulp to fibre and filament production of MMCF fibres:
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Viscose staple fibres (VSF)
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Modal staple fibres
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Viscose filament yarn (VFY)
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Lyocell
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Cuprammonium rayon (cupro)
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Cellulose acetate (acetate)
This document doesn't cover the environmental impact of dissolved pulp processing.
What are the changes from the ZDHC MMCF Guidelines V2.1 to the ZDHC MMCF Guidelines V2.2?
The below details the changes, split out into the relevant chapters, made in the MMCF Guidelines V2.2
Chapter 1: Responsible Fibre Production Guidelines
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Revision to the Progressive limit value for copper and ammonia recovery for cupro fibre
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Revision to the raw material consumption value for acetone for acetate fibre
Chapter 2: MMCF Wastewater Guidelines
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Alignment of wastewater test methods for some parameters to the ZDHC Wastewater Guidelines V2.1
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APEO wastewater limit value changed from Foundational/ Progressive/Aspirational categories into a single reporting limit of 5 ug/litre
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Removal of sum of hydrocarbon parameter
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Requirements for sludge changed to: MMCF manufacturing facilities should meet local legal regulations. If no such regulation exists, facilities to refer and implement ZDHC requirements for sludge disposal and testing as mentioned under ZDHC Wastewater Guidelines V2.1 and ZDHC Sludge Reference Document V1.0
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Addition of a table mentioning wastewater discharge types, sample locations and test parameters for MMCF facilities
Chapter 3: MMCF Air Emission Guidelines
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Addition of acetone air emission limit values at Foundational/ Progressive/ Aspirational level for acetate fibre manufacture
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Revision of ambient air emissions limit value for CS2, H2S and NH3 from Foundational/ Progressive/Aspirational to a single reporting limit.
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Separate tables have been added for air emissions by mass balance calculation and ambient air emissions by direct testing.
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CS2 & H2S ambient air emission limits are referred from the World Health Organization, Air Quality Guidelines for Europe. 2nd Edition, 2000.
Why are wastewater parameters as load-based values mentioned separately in addition to concentration-based wastewater parameters?
To understand the environmental impact and efficiency of water usage in the production of man-made cellulosic fibre (MMCF), it is necessary to measure some important wastewater parameters in terms of load-based values1 rather than only concentration-based values2. For this, the pollutant concentration needs to be linked with the wastewater flow rate in the fibre or filament manufacturing process.
In the MMCF Guidelines V2.2, Table 11- Wastewater parameters to be assessed in load per tonne of fibre or filament (pg no. 28-29) outlines the norms to be achieved for COD, BOD and Zn parameters in terms of load per tonne of fibre production at Foundational, Progressive and Aspirational levels for the different MMCF types.
The load per tonne is calculated by simply multiplying the concentration in mg per litre with the water flow rate in cubic metres per day.
Note: The month of determining the water flow rate should be the same as the month in which the wastewater testing has been done and the pollutant concentration has been measured
1Load-based values: Gramme per tonne of fibre produced
2Concentration-based values: mg per litre of discharged wastewater
Why are modal staple fibres included in the scope of MMCF V2.2 but not listed in Appendix A Table 1.A Conventional Parameters Limit Values and Test Methods?
Table 1. A for modal staple fibre production is only applicable for sites with a mixed production of viscose and modal fibres. It does not apply to facilities with the production of modal without viscose production. Therefore the same parameters and limits for viscose staple fibre (VSF) are applicable to modal+ viscose staple fibre production facilities.
How does MMCF connect with Canopy?
ZDHC are very proud to be working closely with Canopy to push for a more sustainable chemical management in MMCF’s supply chain production. This, along with the new ZDHC MMCF Guidelines V2.2 release in 2023, has led to ZDHC reviewing and updating the chemical management criteria, which will be released in Canopy’s Hot Button Report (2023 Edition).
Following the ZDHC MMCF Implementation Approach Guidelines V2.2, the updated chemical management criteria focuses solely on viscose and modal staple fibres, which means points will be awarded according to volume production that have reached Progressive level by manufacturer. Given that testing and sampling results can only be ascertained at the end of each year, the results from the chemical management criteria will be based on the preceding year’s results of the Hot Button Report. This means, for example, the points awarded in the Hot Button Report (2024 Edition),
This means that manufacturers can obtain full points in all of the chemical management criteria if all of their viscose and modal facilities achieve the Progressive level in 2023 in each area according to the ZDHC MMCF Guidelines V2.2.
How to Access the MMCF Module?
The MMCF Module can be accessed on the ZDHC Supplier Platform. ZDHC Supplier Platform -
ZDHC acknowledges that the EU BAT BREF 2007, used in the Changing Market’s VSF sustainable chemical management target setting, was a good starting point to determine the MMCF producers’ goals for 2023. Since ZDHC’s release of the MMCF Guidelines V1.0 to V2.2, we believe we have created a global implementation roadmap for the MMCF industry’s sustainable chemical management. Within this roadmap MMCF producers are guided towards standards set by the EU BAT BREF’s best-available techniques. While the ZDHC MMCF Guidelines provides clear progress milestones, identified in consultation with MMCF producers from different regions.
In addition, one needs to understand the purpose of the publications. The EU BAT BREF serves as a reference document to issue operating permits for industrial installations that have potential of significant pollution in the EU region. Whereas the ZDHC MMCF Guidelines specifically targets the global MMCF industry’s chemical management. This is why some ZDHC MMCF Guidelines limits and parameters may not align exactly with the EU BAT BREF.
ZDHC believes it is important to take into account all MMCF producers’ chemical management journeys, wherever they may be, whilst also setting ambitious targets for everyone to reach.