Paper Mills (U.S.) — NAICS 322120

An investor's primer. NAICS (North American Industry Classification System) code 322120 covers establishments that turn wood pulp or recovered fiber into paper — printing and writing grades, newsprint, base tissue, and kraft wrapping/bag paper. It deliberately excludes paperboard, the thick fiber used for boxes and cartons, which is a separate industry.

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1. Overview

A paper mill is a large, continuously running factory that converts pulp (cooked or ground wood fiber, plus recycled paper) into finished paper on machines that can be longer than a football field. This is heavy, capital-intensive process manufacturing: a single modern mill can cost well over $800 million to build, and pulp and paper is often cited as the most capital-intensive sector in U.S. manufacturing, spending on the order of $130,000 per employee per year on plant and equipment [17].

Why an investor should care: paper is a mature, cyclical commodity business in structural transition. The largest legacy grade — printing and writing paper, the stock in copier paper, books, magazines, and mail — is in a long secular decline as communication moves to screens [5][6]. Meanwhile fiber-based packaging is growing, but almost all of that growth sits in the neighboring paperboard industry (NAICS 322130), not in 322120. So the "paper is dying / boxes are booming" headline is real, but the two halves live in different NAICS codes — a distinction that matters when you pick where to put money.

Ways in:

• Public markets: a short list of listed producers, but very few are pure 322120 plays. The cleanest public proxy for printing/writing paper is Sylvamo; most other listed "paper" names (International Paper, Packaging Corporation of America, Clearwater Paper) are today mostly paperboard/packaging companies with only a slice of true paper-mill revenue.
• Private markets: the single largest U.S. maker of the flagship grade (uncoated freesheet) — Domtar — is privately held, as are specialty producer Pixelle and the paper operations of Georgia-Pacific (Koch Industries). Much of the industry's ownership is private, foreign, or held inside diversified conglomerates.

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2. What it is and how it's structured

Scope of NAICS 322120 (Paper Mills). Establishments primarily engaged in making paper from pulp — whether or not they also make the pulp on-site. The grades covered include:

• Uncoated freesheet (UFS) — copier/office paper, envelopes, forms, book paper. The industry's flagship printing-and-writing grade.
• Coated freesheet and coated/uncoated groundwood — magazine, catalog, and commercial-print papers.
• Newsprint — the low-cost groundwood paper newspapers are printed on.
• Tissue base stock, kraft wrapping paper, and bag/specialty papers.

A 2022 reclassification note. In the 2022 NAICS revision the two former codes — 322121 (Paper except Newsprint Mills) and 322122 (Newsprint Mills) — were merged into a single code, 322120, Paper Mills [1]. Older data series may still split them, creating a classification break that can make pre- and post-revision series appear comparable when they are not.

What it EXCLUDES (adjacent codes) — important, because these are where investors often mistakenly look:

• Paperboard Mills — NAICS 322130. Containerboard (linerboard and medium for corrugated boxes) and boxboard/cartonboard. This is where most U.S. fiber tonnage and most packaging growth actually sit.
• Pulp Mills (that don't make paper) — NAICS 322110.
• Corrugated & solid fiber boxes — NAICS 322211; folding cartons — 322212; other converted paper products (322220 series).
• Sanitary paper products — finished toilet tissue, towels, and napkins converted from paper — NAICS 322291. The base tissue paper-making can fall in 322120, but the branded consumer product does not.
• Photographic sensitized paper — 325992.

The production process. Operations begin with virgin wood fiber, recovered paper, or purchased pulp. Integrated mills mechanically or chemically separate cellulose fibers from wood; in the dominant chemical process, wood chips are cooked under pressure to dissolve lignin. Recycled-fiber mills repulp recovered paper and may screen, clean, and de-ink it. The fiber-and-water suspension is refined and mixed with chemicals and mineral fillers, distributed onto a moving screen, pressed, dried over heated cylinders, finished for surface and dimensional properties, and wound into parent rolls — the sheet leaving the dryer at about 5% moisture [19][20].

Ownership mix. Producers are large corporations: publicly listed U.S. companies, private-equity- and family-controlled private firms (Domtar/Paper Excellence, Pixelle), the paper arms of diversified private conglomerates (Georgia-Pacific under Koch), and U.S. mills owned by foreign groups (Bio Pappel of Mexico, Sofidel of Italy, Nine Dragons of China). There are essentially no small or "gig" operators — the minimum efficient scale is a nine-figure mill.

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3. How big it is

U.S. federal statistics for NAICS 322120:

Concentration (2022 Economic Census) [3]: the four largest firms make 43.2% of revenue (CR4), the top eight 58.9%, the top twenty 82.2%, and the top fifty 98.1%; the Herfindahl-Hirschman Index (HHI) is 617 — statistically "unconcentrated" at the four-firm level, but the long tail is thin: a few dozen firms account for essentially the whole industry. Note that concentration varies sharply by grade: Sylvamo reports that the four largest North American uncoated-freesheet producers represent approximately 80% of that grade's capacity [7].

Undercount caveat — runs the other way here. Federal business statistics undercount industries dominated by tiny/individual operators or by government. Paper Mills is the opposite: a handful of large, well-tracked facilities, so the Census captures it cleanly. Two real caveats instead: (a) the receipts figure is from the 2022 Economic Census, and the industry has closed capacity since — a private estimate puts 2024 revenue near $34 billion but on a multi-year decline of roughly 5% a year [5]; and (b) because many mills sit inside companies whose primary business is paperboard or packaging, the true economic footprint of U.S. paper-making is split across several NAICS codes rather than undercounted.

For physical scale, the trade group AF&PA (American Forest & Paper Association) reports total U.S. paper and paperboard production of 66.3 million tons in 2025 (down 3.7%). Within the more relevant paper grades, printing-and-writing capacity fell 13.9% to 7.7 million tons — down from nearly 18 million tons in 2015 — while tissue production was approximately 7.8 million tons and packaging-paper production rose 1.7%. Printing-writing mills improved their operating rate to 82.8%, largely because capacity was removed faster than production declined [6]. The Federal Reserve's paper-except-newsprint production index stood at 59.34 in 2025 on a 2017-equals-100 basis, confirming that this is a long-running volume decline rather than a single weak year [21].

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4. The investable universe

Pure public plays in 322120 are scarce. Most listed "paper" companies have pivoted to paperboard/packaging; their true paper-mill exposure is a minority segment. Table figures are total-company scale (which spans multiple NAICS codes) unless noted.

Major private and other owners (often bigger in true paper than the public names):

• Domtar (owned by Paper Excellence; now includes legacy Resolute Forest Products) — the largest U.S. producer of uncoated freesheet; the group describes roughly 60 North American locations and more than 13,000 employees, though those totals include pulp, lumber, tissue, and other activities outside 322120 [11]. Has been curtailing paper capacity (e.g. idling a machine at Ashdown, AR) and converting some mills toward packaging.
• Georgia-Pacific (Koch Industries) — paper, tissue, and packaging; private.
• Pixelle Specialty Solutions (private equity) — specialty printing/writing and technical papers.
• Bio Pappel / McKinley Paper (Mexico), Nine Dragons / ND Paper (China), Sofidel (Italy, now owns the former Clearwater tissue mills) — foreign-owned U.S. capacity.
• Inland Empire Paper (Millwood, WA) — after NORPAC's 2025 exit, effectively the last U.S. newsprint mill [12].

Bottom line for stock-pickers: there is no large, clean, U.S.-listed "paper mill" pure play. Sylvamo is the nearest, with PCA's Paper segment a secondary read; the deepest paper (as opposed to paperboard) assets are private.

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5. How the money works

Paper is a commodity with brutal operating leverage. The economics are driven by three things:

1. Capacity utilization (the operating rate). Mills carry enormous fixed costs — depreciation, maintenance, and a crew that must run the machine around the clock. Those fixed charges are spread over tonnage, so profit is extremely sensitive to how full the mill runs. Industry analyses show fixed cost per tonne can roughly double when a mill drops from full capacity to ~50% [16], and reduced utilization can push total containerboard cost per ton up 8–9% [16]. Running at a high operating rate is the difference between making and losing money — which is why producers curtail capacity or idle machines rather than flood a weak market.

2. Input costs — fiber, energy, chemicals. Fiber (pulpwood and recovered paper) is the biggest single cost, ranging from roughly 25% to 70% of total cost depending on how vertically integrated the mill is; chemicals add another 8–25%, and energy is large on top of that [15]. Mills that make their own pulp on-site ("integrated") are insulated from swings in market-pulp prices; mills that buy pulp are exposed. Because pulp is globally traded, a U.S. mill's margin can move on Brazilian or Nordic pulp prices.

Energy intensity is unusually high because large amounts of water must be removed and the sheet thermally dried. The EIA reports that NAICS 322120 consumed 475 trillion BTU of fuel in 2022, including 16.2 billion kilowatt-hours of net electricity, 181 billion cubic feet of natural gas, and 214 trillion BTU classified as other fuels — much of which reflects biomass and mill by-products [23]. PCA's International Falls mill used about 11 million MMBtu in 2025, with approximately 74% supplied by mill-generated biogenic fuels and 26% by purchased natural gas [9].

3. Price and the cycle. Paper prices are set by supply-demand balance and move in cycles. Owners make money by (a) keeping utilization high, (b) sitting low on the industry cost curve (cheap fiber, cheap power, modern machines), and (c) matching supply to demand — often by permanently closing or converting weak mills. The key numbers investors watch: operating/utilization rate, price per ton by grade, cash cost per ton, and pulp prices. Volumes are reported in tons; a large machine makes 300,000+ tons a year.

Reading a producer's results, the levers are volume (tons shipped), realized price/mix, input-cost pass-through, and downtime. Unlike retail or banking, there is no same-store-sales or net-interest-margin frame — this is a tons-times-price-minus-cash-cost business where the swing factor is the operating rate.

Segment margins. No defensible industrywide margin exists, but public segments illustrate the range. Sylvamo's North American segment generated $263 million of operating profit on $1.75 billion of 2025 sales, a derived margin of approximately 15%; lower volume and higher energy and chemical costs reduced profit year over year [7]. PCA's paper segment generated $130 million of operating income on $615 million of sales, approximately 21%, but it consists of a single, competitively positioned mill and is not representative of the full industry [9].

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6. What drives demand

Demand is grade-specific and diverging:

• Printing & writing paper — structural decline. Digital substitution (email, e-billing, online media, screens over print) shrinks copier paper, magazine, catalog, and newsprint volumes year after year. North American UFS shipments fell 9.6% in 2025 [9]. U.S. printing-writing capacity fell to 7.7 million tons in 2025, down 13.9% in a single year [6]. Newsprint is the extreme case — North American newsprint output fell to ~1.66 million tons in 2025, and the U.S. is down to essentially one operating newsprint mill [12].
• Tissue — stable, growing share. Tied to population, hygiene, and away-from-home consumption; recession-resistant. Tissue has grown from 7.2% to 11.3% of total U.S. paper/paperboard capacity since 2000 [6], with production near 7.8 million tons in 2025.
• Kraft, bag, and specialty papers — mixed, with pockets of growth. Paper bags and food-service papers benefit from plastic-substitution and e-commerce, but the big packaging tailwind mostly accrues to paperboard (322130), outside this code.

Recycling is both a demand source and an input-market issue. The U.S. paper recovery rate was between 60% and 64% in 2024, representing roughly 46 million tons recovered [24]. High-quality graphic and tissue grades may still require substantial virgin fiber, while recovered-fiber quality can deteriorate as less printing paper enters the collection stream.

Macro drivers: office activity and mail volumes (printing/writing), consumer spending and demographics (tissue), advertising and publishing (coated/newsprint), and — for the whole complex — the pulp price cycle, energy prices, and the U.S. dollar (a strong dollar invites imports and hurts exporters).

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7. Regulation

Paper mills are heavily environmentally regulated because pulping and bleaching discharge to air and water:

• The "Cluster Rule" (1997–98). The U.S. EPA (Environmental Protection Agency) issued an integrated air-and-water package for pulp and paper. On the water side, Effluent Guidelines at 40 CFR Part 430 (Clean Water Act) limit dioxin, AOX (adsorbable organic halides), and chlorinated compounds via NPDES (National Pollutant Discharge Elimination System) permits; the guidelines distinguish kraft, sulfite, mechanical, secondary-fiber, purchased-pulp, and other processes [13]. On the air side, NESHAP/MACT standards (National Emission Standards for Hazardous Air Pollutants / Maximum Achievable Control Technology, Clean Air Act) — MACT I, II, and III — cap hazardous air pollutants from pulping, chemical recovery, and papermaking, requiring controls on vents and condensates including collection, incineration, scrubbing, or biological treatment depending on the process [13].
• Boiler and combustion rules, air permits (Title V), and greenhouse-gas reporting add ongoing compliance cost; mills burn biomass and fossil fuel for steam and power.
• Chemical and safety oversight (OSHA), plus state-level water and air permits. The broader paper-manufacturing sector recorded a total recordable injury-and-illness rate of 2.4 cases per 100 full-time workers in 2024 [25].

Practical effect: environmental compliance is a structural cost and a barrier to entry — you cannot cheaply stand up a new bleached kraft mill in the U.S. — and it disadvantages older mills that need capital to stay compliant, accelerating closures.

Trade policy is the other regulatory swing factor: antidumping and countervailing duties on imported paper (and past newsprint tariffs), plus 2024–25 tariff actions on Chinese and Asian paper and board, can reshape prices and import volumes quickly [18].

Labor: many mills are unionized, largely under the United Steelworkers (USW) — formally the United Steel, Paper and Forestry union — which bargains multi-mill "pattern" agreements [26]. Labor is a smaller cost than fiber and energy but is operationally critical; mills need experienced operators, electricians, mechanics, engineers, and environmental staff, often in rural locations with aging workforces.

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8. Competitive dynamics and consolidation

This is a consolidating, capacity-rationalizing industry:

• Portfolio surgery. The dominant corporate move of the last few years is to exit declining paper and concentrate on packaging/paperboard: International Paper spun off its uncoated freesheet as Sylvamo (2021) then bought DS Smith to double down on boxes (2025) [7][8]; Clearwater sold its tissue business to become a paperboard pure-play (2024) [10]; Domtar is converting paper machines toward containerboard [11].
• Supply discipline. Because profitability hinges on the operating rate, producers respond to falling demand by permanently closing or idling machines rather than price-warring — the healthiest thing that can happen to a declining grade's margins is a competitor's mill shutting down.
• Cost-curve competition. Winners own cheap fiber, cheap power, and scale-efficient machines. Integrated (own-pulp) mills beat non-integrated ones through pulp-price cycles.
• Foreign and private capital are active buyers of U.S. paper assets (Paper Excellence/Domtar, Sofidel, Bio Pappel, ND Paper, private equity in Pixelle), often acquiring assets the public majors are shedding.

The barriers to entry (capital, permits, fiber supply, scale) are high, so competition is among a fixed roster of incumbents rationalizing a shrinking pie in graphic grades and a stable one in tissue.

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9. Risks

• Secular demand decline in printing/writing and newsprint — the core of 322120 — with no floor yet visible for graphic grades [5][6].
• Cyclicality and operating leverage: a demand dip that lowers the operating rate hits margins hard [16]; the same leverage cuts the other way in upturns.
• Input-cost volatility: pulp, energy, chemicals, and freight can compress margins faster than prices can be raised, especially at non-integrated mills [15]. Weather, wildfire, sawmill activity, and competing biomass uses influence virgin-fiber supply; collection rates, export demand, and contamination affect recovered-paper prices.
• Capital intensity and stranded assets: mills cost hundreds of millions and are hard to repurpose; a mill on the wrong grade can become a write-off. Conversions to packaging are expensive and not always feasible.
• Environmental/regulatory cost and liability: compliance capital, permits, and remediation; tightening air/water and greenhouse-gas rules [13].
• Trade exposure: import competition (a strong dollar and low-cost foreign capacity) and tariff whipsaw both ways [18].
• Customer concentration: distribution consolidation can create significant mill-level exposure even when end demand is diffuse (e.g., PCA's largest paper customer = 58% of paper-segment sales) [9].
• Concentration and thin float: with the best paper assets private, public investors have few clean vehicles and are often buying a packaging company with a paper tail.

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10. How to invest and the outlook

Public-market routes.

• Sylvamo (SLVM) is the closest thing to a listed paper-mill pure play — a printing/writing producer that has run for cash: strong free cash flow, debt reduction, and shareholder returns [7]. The thesis is a "cash cow in a declining industry" — buy the cash generation cheaply, accept the secular fade. Its foreign operations, currencies, market pulp, and regional cost positions matter as much as the U.S. cycle. (Tickers, valuations, and yields belong to your own diligence.)
• PKG gives paper exposure inside a well-run containerboard company (paper = ~7% of sales); IP is now essentially a global packaging bet with minimal true paper; Clearwater (CLW) is now paperboard. Suzano (SUZ) and Billerud offer foreign-listed pulp-and-paper exposure. For tissue, the liquid proxies are consumer-staples names (KMB, PG) rather than paper-mill stocks, though branded converting and consumer marketing dominate their economics, making them poor proxies for mill margins.
• There is no dedicated U.S. paper-mill ETF; broad materials or forest-products funds only touch the space indirectly.

Private-market routes. The deepest paper assets change hands privately — through private equity (Pixelle-type specialty platforms), strategic/foreign buyers of divested mills, and control positions in names like Domtar. Individual investors can rarely access these directly; the realistic private angles are timberland/fiber supply, mill real estate, or PE fund exposure. Returns often depend on buying below replacement cost, securing economical fiber and energy, improving reliability, and having a credible product-conversion or capacity-rationalization thesis. Environmental liabilities, pension obligations, deferred maintenance, and the capital required to restart or repurpose a machine must be underwritten as core purchase-price items.

Near-term outlook (forward-looking judgment). The base case is continued structural decline in graphic paper, stable tissue, and margin driven by supply discipline rather than demand growth. Expect more mill closures and paper-to-packaging conversions; the survivors should be low-cost, integrated, and disciplined about the operating rate. Packaging-linked demand (e-commerce, plastic substitution) is a tailwind for the broader fiber complex but mostly benefits paperboard (322130), not 322120 [18]. Pulp-price cycles and tariff policy are the main swing factors into 2026 [18]. The investable proposition here is cash return and rationalization, not growth: owners make money by running full, sitting low on the cost curve, closing what doesn't earn, and returning the cash.

Common analytical errors to avoid: (1) describing this as the cardboard-box industry — containerboard, boxboard, and stand-alone box converting are outside NAICS 322120; (2) applying the ~80% four-producer UFS concentration figure to all paper mills — that is grade-specific, not industrywide; (3) treating "paperless" as a uniform thesis — printing and newsprint are contracting rapidly while tissue and some specialty grades have different demand curves.

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Sources

1. U.S. Census Bureau. "NAICS 322120 — Paper Mills (2022)." census.gov. https://www.census.gov/naics/?input=322120&year=2022&details=322120; consolidation of 322121/322122 per Ask Kodiak NAICS guide, https://naics.askkodiak.com/naics/2022/322120
2. U.S. Census Bureau. "County Business Patterns, 2023" (establishments, employment, annual payroll for NAICS 322120). https://www.census.gov/programs-surveys/cbp.html
3. U.S. Census Bureau. "2022 Economic Census — Concentration & Selected Statistics, NAICS 322120" (receipts, firms, CR4/CR8/CR20/CR50, HHI). https://www.census.gov/programs-surveys/economic-census.html
4. U.S. Small Business Administration. "Table of Size Standards, 2023" (NAICS 322120 = 1,250 employees). https://www.sba.gov/document/support-table-size-standards
5. IBISWorld. "Paper Mills in the US — Industry Report (2024)." https://www.ibisworld.com/united-states/industry/paper-mills/406/
6. American Forest & Paper Association. "AF&PA Releases 66th Annual Paper Industry Capacity and Fiber Consumption Survey" (2025/2026; 66.3M tons production, printing-writing 7.7M tons −13.9%, tissue ~7.8M tons, 82.8% operating rate). https://www.afandpa.org/news/2026/afpa-releases-66th-annual-paper-industry-capacity-and-fiber-consumption-survey
7. Sylvamo Corporation. "2025 Form 10-K" (North American segment: $1.754B sales, $263M operating profit; 975,000 short tons owned UFS capacity; ~80% four-firm UFS concentration). https://www.sec.gov/Archives/edgar/data/1856485/000185648526000008/syl-20251231.htm; 2024 results: https://www.businesswire.com/news/home/20250212793495/en/
8. PaperAge / International Paper. "International Paper Completes Acquisition of DS Smith," 2025 (~$18.6B 2024 revenue; ~90% fiber-based packaging; ~$514M synergies). https://www.paperage.com/2025news/02-03-2025international-paper-conpletes-acquisition-of-ds-smith-updated.html
9. Packaging Corporation of America. "2025 Form 10-K" (~$8.989B net sales; Paper segment $615.4M sales / $129.6M operating income; ~500,000 tons International Falls capacity; largest paper customer 58% of segment; 11M MMBtu energy use, 74% biogenic). https://ir.packagingcorp.com/static-files/35c034f5-fc65-478a-a558-ccfec48ce671
10. Packaging Dive. "Clearwater closes $1B sale of tissue business to Sofidel," 2024. https://www.packagingdive.com/news/clearwater-sell-tissue-business-sofidel-paperboard/721956/
11. Domtar. "Who Owns Domtar" (Paper Excellence ownership; ~60 North American locations, 13,000+ employees). https://www.domtar.com/who-owns-domtar-jackson-wijaya/; Wikipedia, https://en.wikipedia.org/wiki/Domtar
12. Recycling Today. "NORPAC to exit U.S. newsprint market," 2025, and EMGE, "North American Newsprint Market: Capacity, Closures and 2026 Outlook." https://www.recyclingtoday.com/news/norpac-to-exit-united-states-newsprint-market/; https://www.emge.com/news/north-american-newsprint-market-capacity-closures-and-2026-outlook
13. U.S. EPA. "Pulp, Paper and Paperboard Effluent Guidelines (40 CFR Part 430)" and "Pulp and Paper Production (MACT I & III) NESHAP" (the Cluster Rule). https://www.epa.gov/eg/pulp-paper-and-paperboard-effluent-guidelines; https://www.epa.gov/stationary-sources-air-pollution/pulp-and-paper-production-mact-i-iii-national-emissions-standards
14. McKinsey & Company. "Resetting cost competitiveness in pulp and paper packaging" (fiber 25–70% of cost; chemicals 8–25%). https://www.mckinsey.com/industries/packaging-and-paper/our-insights/resetting-cost-competitiveness-in-pulp-and-paper-packaging
15. McKinsey & Company. "Resetting cost competitiveness in pulp and paper packaging" (fiber 25–70% of cost; chemicals 8–25%). https://www.mckinsey.com/industries/packaging-and-paper/our-insights/resetting-cost-competitiveness-in-pulp-and-paper-packaging
16. Fastmarkets. "The cost of mill downtime: how low operating rates impact mill costs and profitability." https://www.fastmarkets.com/insights/how-low-operating-rates-impact-mill-costs-and-profitability/
17. U.S. Department of Energy. "Energy and Environmental Profile of the U.S. Pulp and Paper Industry" (capital intensity; mill construction cost). https://www.energy.gov/sites/prod/files/2013/11/f4/pulppaper_profile.pdf
18. Coface. "Paper: Sector risk analysis and economic outlook," and Fastmarkets 2026 pulp-and-paper projections (packaging demand, tariffs, pulp cycle). https://www.coface.com/news-economy-and-insights/business-risk-dashboard/sector-risk-files/paper
19. U.S. EPA. "Papermaking Process Overview." https://archive.epa.gov/wastes/conserve/materials/paper/web/html/papermaking.html
20. American Forest & Paper Association. "How Is Paper Made Today?" (production process; ~5% moisture at dryer exit). https://www.afandpa.org/news/2025/how-paper-made-today
21. Federal Reserve Bank of St. Louis. "Industrial Production: Paper except Newsprint (IPN32212PA)." FRED. https://fred.stlouisfed.org/series/IPN32212PA
22. Billerud. "Annual Report 2025" (North American mills; graphic paper 70% of NA product mix). https://www.billerud.com/globalassets/cision/documents/2026/20260401-billerud-publishes-annual-report-2025-en-0-5335990.pdf
23. U.S. Energy Information Administration. "2022 Manufacturing Energy Consumption Survey (MECS), Table 3.1" (NAICS 322120: 475 trillion BTU fuel, 16.2B kWh electricity, 181B cu ft natural gas). https://www.eia.gov/consumption/manufacturing/data/2022/pdf/Table3_1.pdf
24. American Forest & Paper Association. "Recycling Statistics" (60–64% U.S. paper recovery rate in 2024; ~46M tons). https://www.afandpa.org/priorities/recycling
25. U.S. Bureau of Labor Statistics. "Industries at a Glance: Paper Manufacturing (NAICS 322)" (2.4 TRIR per 100 FTE, 2024). https://www.bls.gov/iag/tgs/iag322.htm
26. United Steelworkers. "Paper Bargaining — 2025 Officers' Report." https://usw.org/2025-officers-report/paper-bargaining/