Pulp Mills (U.S.) — NAICS 32211

A Histometrics industry-group primer for public- and private-market investors

Short page — single-child pass-through. NAICS 32211 (a five-digit NAICS industry) contains exactly one six-digit child, 322110 Pulp Mills, and is economically identical to it. This page gives the level's own federal figures and orients you; for the full treatment — grades, company-by-company map, cost structure, regulation, and outlook — read the 322110 primer.

1. Overview

A pulp mill cooks, grinds, or bleaches wood (or recycled fiber) into pulp — the mat of cellulose fibers that becomes paper, cardboard, tissue, diapers, and even rayon clothing. This NAICS industry covers only the U.S. mills that make pulp for sale and do not also make paper or board on the same site — the "market pulp" business. Pulp is a global commodity priced in dollars per metric ton, and the U.S. is the single largest pulp-producing country in the world [1]. It sits upstream of packaging, hygiene products, and textiles, while its oldest customer — graphic (printing/writing) paper — is in structural decline.

2. What's inside — and why this level equals its one child

NAICS (the North American Industry Classification System) is a nested code: the five-digit industry 32211 rolls up its six-digit national industries. Here there is only one — 322110 Pulp Mills — so the group and the child are the same set of mills, the same firms, and the same statistics. There is nothing at 32211 that isn't at 322110; the extra digit adds no detail. Read 322110 for everything that matters [2].

The one distinction worth keeping in mind — because it governs how to read every number below — is the classification boundary: establishments that make pulp and paper are counted in NAICS 322120 (Paper Mills), and pulp and paperboard together in NAICS 322130 (Paperboard Mills) [2]. This industry captures only the pulp that is baled, dried, and shipped to someone else's paper machine.

3. How big it is (this level's rollup)

These are our ground-truth federal figures for NAICS 32211 — identical to 322110 because it is the sole child:

Concentration is high: the top 4 firms take 78.2% of revenue, the top 8 take 95.7%, and the top 20 reach 100% [4]. The Herfindahl-Hirschman Index (HHI, a standard concentration gauge where 2,500+ is "highly concentrated") sits at 2,005 — moderately-to-highly concentrated [4]. Pay runs well above the manufacturing average, reflecting skilled, unionized, 24/7 process-control work.

Undercount caveat — read before quoting these numbers. The $8.7 billion / 35-mill figure massively understates U.S. pulp production, not because of small or informal operators (there are none — the SBA size standard is a striking 1,050 employees) but because of the classification boundary above: most American pulp is made inside integrated mills that convert it straight into paper or board and are counted under 322120/322130 [2]. By physical output the U.S. made roughly 36 million metric tons of pulp for paper in 2024, the most of any country, and exported about 6.9 million tons against imports near 6.3 million [1][5]. Read this level as "the merchant pulp business," not "all U.S. pulp."

4. Investable universe (where the value sits)

Because the level is 322110, the investable map is identical — and thin: there is no U.S.-listed pure-play domestic market-pulp stock and no dedicated pulp ETF (exchange-traded fund). Value concentrates in a handful of names and, increasingly, in private hands:

• Public, closest to the pulp price: Mercer International (Nasdaq: MERC — market-NBSK, ~2.3M tons capacity, but mills in Germany/Canada); Rayonier Advanced Materials (NYSE: RYAM — U.S. dissolving/specialty cellulose, ~885k t/yr active system including Jesup, GA and Fernandina Beach, FL); Suzano (NYSE: SUZ — world's largest market-pulp producer with 13.4M tons nominal capacity, now with a U.S. mill at Pine Bluff, AR); Sappi (OTC: SPPJY — Cloquet, MN dissolving pulp, ~370k t/yr) [6][7][8][9].
• Adjacent / downstream: International Paper (NYSE: IP) exited merchant fluff pulp in Jan 2026 but retains a $190M preferred interest in the sold business; Sylvamo (NYSE: SLVM) is integrated freesheet; Clearwater Paper (NYSE: CLW) produces limited market pulp incidental to its paperboard business [10][11][12].
• Private owners of the biggest U.S. capacity: Georgia-Pacific (Koch Industries) operates four non-integrated wood-pulp mills and one cotton-linters pulp mill; Domtar (Paper Excellence) has approximately 3.2 million metric tons of North American capacity; and the former IP fluff business — seven pulp mills and two converting facilities across the U.S., Canada, and Poland — now sits with American Industrial Partners [10][13][14][15].

A common mix-up: Rayonier Advanced Materials (RYAM), a pulp maker, is not Rayonier Inc. (RYN), a timberland REIT (real estate investment trust). See the 322110 primer for the full company table and scale figures.

5. How the money works

Pulp owners earn the spread between a globally-set commodity price and their own cash cost per ton, times how many tons they run. Commodity pulp trades per air-dried metric ton (ADMT) against public benchmarks such as NBSK (Northern Bleached Softwood Kraft) and BEK (Bleached Eucalyptus Kraft); no single U.S. mill is a price-maker. The three big cash costs are wood fiber, energy, and chemicals — and kraft mills burn their own lignin waste ("black liquor") in recovery boilers, with more than 90% of cooking chemicals recovered and reused, making many of them net energy producers [16]. Profitability lives or dies on capacity utilization, and producers take deliberate "market downtime" when prices fall. Premium grades — fluff pulp (diaper cores) and dissolving pulp (rayon/viscose textiles) — earn structural premiums and are less violently cyclical. Full detail in 322110 §5.

6. Demand drivers

Hygiene/absorbent products (fluff pulp) — demographically driven and recession-resistant; packaging (softwood kraft), riding e-commerce and plastic-to-paper substitution; tissue (population-linked); textiles and specialty cellulose (dissolving pulp) [1]. The structural headwind is printing & writing paper, in permanent digital-substitution decline — U.S. P&W capacity fell 6.9% in 2024 to below 9 million tons [17]. China is the world's marginal pulp buyer and effectively sets the global price at the margin. See 322110 §6.

7. Regulation

Pulp mills are among the most heavily environmentally regulated U.S. manufacturers. The EPA Cluster Rule (1998) combined air and water standards for bleached kraft and sulfite mills — MACT (Maximum Achievable Control Technology) limits on the air side and a move off elemental-chlorine bleaching (to eliminate dioxin) on the water side [18][19]. Effluent is permitted under the Clean Water Act's NPDES program; the Clean Air Act adds Title V permits and TRS (total reduced sulfur, the "rotten-egg" kraft odor) controls [20]. Buyers demand FSC/SFI fiber-sourcing certification. Net effect: high environmental capex, long permitting, and a real barrier to new U.S. capacity — RYAM, for example, carries approximately $184 million of environmental liabilities associated with current and former sites [7]. Full detail in 322110 §7.

8. Consolidation

A concentrated global oligopoly (top-4 U.S. share 78.2%, HHI ~2,005) that is reshuffling in real time [4]: International Paper exited merchant fluff pulp; RYAM is shrinking commodity exposure to chase specialty cellulose; Brazil's Suzano pushed into the U.S. in 2024; and the crown-jewel U.S. fluff assets have moved to private owners (Koch, Paper Excellence, American Industrial Partners) [7][8][10]. Low-cost Brazilian eucalyptus keeps forcing capacity rationalization at higher-cost northern softwood mills. See 322110 §8.

9. Risks

Commodity price cyclicality / oversupply (the dominant risk, driven by new Brazilian and Chinese capacity); China demand concentration and trade/FX policy on an export-heavy business — RYAM reported that Chinese retaliatory tariffs on U.S. commodity fluff materially hurt operating income [7]; structural decline in graphic paper; input-cost inflation (wood, energy, chemicals, freight); capital intensity and aging assets; environmental/permitting liability; labor (68% of RYAM's workforce is unionized, and specialized maintenance skills are hard to replace) [7]; and leverage carried into cyclical troughs. Detailed in 322110 §9.

10. How to invest, and the outlook

Because 32211 is 322110, the playbook is the same. Public-market exposure runs through Mercer (MERC), RYAM, Suzano (SUZ), and Sappi (SPPJY), with timber REITs (Weyerhaeuser WY, Rayonier RYN) as an upstream fiber proxy; International Paper retains indirect exposure through its $190M preferred interest in the AIP-owned fluff business [11]. Private-market exposure is where the largest U.S. assets actually live — Georgia-Pacific (Koch), Domtar (Paper Excellence), and the former IP fluff business (American Industrial Partners) — reached through direct mill/timberland ownership or forest-products private-equity/credit vehicles.

Outlook. Near term, commodity pulp looks soft on oversupply, with producer downtime through 2025 and demand expected to catch up into 2026 [21]. Premium fluff and dissolving grades should stay more defensive; the clearest secular tailwind is plastics-to-paper packaging substitution, the clearest headwind is graphic-paper erosion, and the structural cap on the whole complex is low-cost Brazilian eucalyptus. For the full analysis, read the 322110 primer.

---

Sources

1. Statista, "Pulp for paper — production by country 2024," 2025. https://www.statista.com/statistics/1333386/pulp-for-paper-production-by-country/
2. U.S. Census Bureau, "2022 NAICS Definition — 322110 Pulp Mills (and adjacencies 322120/322130)," 2022. https://www.census.gov/naics/?input=322110&year=2022&details=322110
3. U.S. Census Bureau, "County Business Patterns (NAICS 322110): establishments, employment, payroll," 2023. https://www.census.gov/programs-surveys/cbp.html
4. U.S. Census Bureau, "2022 Economic Census — Concentration by Largest Firms (NAICS 322110): firms, receipts, CR4/CR8, HHI," 2022. https://www.census.gov/programs-surveys/economic-census.html
5. Statista, "United States pulp and paper industry — statistics & facts," 2025. https://www.statista.com/topics/5268/us-pulp-and-paper-industry/
6. Mercer International, "Q4 2024 Press Release / Form 10-K (~$2.04B revenue; ~2.3M ADMT capacity)," 2025. https://mercerint.com/wp-content/uploads/Q4-2024-Press-Release-Final.pdf
7. Rayonier Advanced Materials, "2025 Form 10-K (~$1.6B revenue; Jesup 600k t/yr, Fernandina 155k t/yr; 885k t/yr total system; environmental liabilities; China exposure; unionization)," 2026. https://www.sec.gov/Archives/edgar/data/1597672/000159767226000010/ryam-20251231.htm
8. Cleary Gottlieb, "Suzano Completes Acquisition of Pine Bluff Paper Mill from Pactiv Evergreen ($110M)," 2024. https://www.clearygottlieb.com/news-and-insights/news-listing/suzano-completes-acquisition-of-pine-bluff-paper-mill-and-waynesville-extrusion-facility-from-pactiv-evergreen
9. Sappi, "Cloquet Mill — dissolving wood pulp (Verve; ~370k t/yr)," 2024. https://www.sappi.com/en-us/about-us/locations/mills/cloquet-mill
10. American Industrial Partners, "AIP Completes Acquisition of International Paper's Global Cellulose Fibers Business ($1.5B; 7 mills + 2 converting facilities)," Jan 2026. https://www.prnewswire.com/news-releases/american-industrial-partners-completes-acquisition-of-international-papers-global-cellulose-fibers-business-302669253.html
11. International Paper, "Completes Sale of Global Cellulose Fibers Business (incl. $190M preferred interest)," Jan 2026. https://www.prnewswire.com/news-releases/international-paper-completes-sale-of-global-cellulose-fibers-business-to-american-industrial-partners-aip-302669231.html
12. Clearwater Paper, "2025 Form 10-K (limited market pulp; primarily paperboard)," 2026. https://www.sec.gov/Archives/edgar/data/1441236/000144123626000007/clw-20251231.htm
13. Georgia-Pacific, "GP Cellulose Operations (4 wood-pulp mills + 1 cotton-linters mill)," 2025. https://www.gp.com/product-overview/gp-cellulose/
14. Domtar, "Pulp Business (~3.2M MT North American capacity)," 2025. https://www.domtar.com/pulp/
15. ICIJ, "Owner of Canada's largest pulp and paper company (Paper Excellence / Domtar)," 2023. https://www.icij.org/investigations/deforestation-inc/owner-of-canadas-largest-pulp-and-paper-company-to-take-over-controversial-asian-conglomerate/
16. American Forest & Paper Association, "How Wood Chips Become Paper (kraft recovery >90%)," 2026. https://www.afandpa.org/news/2026/how-wood-chips-become-paper
17. American Forest & Paper Association, "2024 Capacity Survey (P&W −6.9%; total capacity −2.0% to 78.1M tons)," 2025. https://www.afandpa.org/news/2025/afpa-details-us-paper-production-and-capacity-trends
18. U.S. EPA, "Pulp and Paper Production MACT I & III — National Emission Standards," 2024. https://www.epa.gov/stationary-sources-air-pollution/pulp-and-paper-production-mact-i-iii-national-emissions-standards
19. U.S. EPA, "Kraft, Soda, Sulfite and Stand-Alone Semichemical Pulp Mills — MACT II (Cluster Rule)," 2024. https://www.epa.gov/stationary-sources-air-pollution/kraft-soda-sulfite-and-stand-alone-semichemical-pulp-mills-mact-ii
20. U.S. EPA, "Pulp, Paper and Paperboard Effluent Guidelines (Clean Water Act / NPDES)," 2024. https://www.epa.gov/eg/pulp-paper-and-paperboard-effluent-guidelines
21. Fastmarkets, "Market sentiment showing signs of recovery: Global pulp outlook — 2025 preview," 2025. https://www.fastmarkets.com/insights/market-signs-recovery-global-pulp-outlook-2025/