Pulp Mills (U.S.) — NAICS 322110

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

1. Overview

A pulp mill takes wood (or recycled fiber) and cooks, grinds, or bleaches it into pulp — the mat of cellulose fibers that becomes paper, cardboard, tissue, diapers, and even rayon clothing. NAICS code 322110 covers the narrow slice of U.S. mills that make pulp for sale and do not also make paper or board on the same site. That distinction matters enormously for anyone sizing the industry, and we return to it below.

Why an investor should care: 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 three durable demand streams — packaging, hygiene products, and increasingly textiles — while its oldest customer, graphic paper, is in structural decline. That mix makes the sector cyclical but not dying, with pockets (fluff pulp for diapers, dissolving pulp for fabric) that command premium pricing.

Ways in differ by investor type. Public-market investors will find only a handful of listed pure-ish plays, and most of their mills sit outside the U.S.; broader exposure comes through integrated forest-products and timber names. Private investors face the opposite: the largest U.S. fluff-pulp capacity is now owned by Koch, an Indonesian-linked paper group, and a private-equity firm — the public market barely touches it. We map both routes in Section 10.

2. What it is and how it's structured

Scope. NAICS 322110 is pulp without paper- or board-making. Establishments that make both pulp and paper are classified in NAICS 322120 (Paper Mills); those that make pulp and paperboard together fall in NAICS 322130 (Paperboard Mills) [2]. So 322110 captures only the "market pulp" mills — the ones whose finished product is baled, dried pulp shipped to someone else's paper machine.

Process. The dominant virgin-wood technology is the kraft process: logs are debarked and chipped; chips are cooked under pressure in sodium hydroxide and sodium sulfide; the resulting fibers are washed, screened, and sometimes bleached; and market pulp is pressed, dried, and shipped in sheets or bales. Spent "black liquor" is concentrated and burned in a recovery furnace, providing steam and electricity while recovering inorganic cooking chemicals — more than 90% of kraft pulping chemicals are recovered and reused [3].

Pulp itself splits by process and grade:

• Chemical (kraft) pulp — the dominant method; wood chips are cooked in chemicals to dissolve away lignin, leaving strong cellulose fibers. Bleached kraft is the workhorse of the market. Benchmark grades: NBSK (Northern Bleached Softwood Kraft), SBSK (Southern Bleached Softwood Kraft), and BEK/BHK (Bleached Eucalyptus / Hardwood Kraft).
• Fluff pulp — a highly purified Southern-pine kraft, fluffed into the absorbent core of diapers, feminine-care, and incontinence products [4].
• Dissolving pulp (a.k.a. high-purity cellulose) — near-pure cellulose used to make viscose/rayon and lyocell fabric, plus cellulose acetate, ethers, filters, food additives, and pharma binders [5].
• Mechanical and recycled pulp — ground or de-inked fiber, generally lower value.

Ownership mix. This is a heavy-industry oligopoly, not a fragmented trade. Federal data count just 18 firms operating 35 establishments in the pure-play segment [6][7]. Owners are large corporations — some public, several private (Koch's Georgia-Pacific, Paper Excellence's Domtar) — plus foreign giants that sell into the U.S. There are essentially no small operators; the SBA (Small Business Administration) size standard is a striking 1,050 employees, reflecting how capital-intensive a single mill is [8].

3. How big it is

Our federal figures for the pure-play pulp-mill industry (NAICS 322110):

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

The undercount caveat — read this before quoting the numbers. The $8.7 billion / 35-mill figure massively understates U.S. pulp production, and not because of tiny or informal operators. It is a classification boundary: the great majority of American pulp is made inside integrated mills that turn it straight into paper or board on the same site — and those mills are counted under NAICS 322120 or 322130, not here [2]. Measured by physical output, the U.S. made roughly 36 million metric tons of pulp for paper in 2024, the most of any country [1], and exported about 6.9 million tons against imports near 6.3 million [9]. NAICS 322110 is best read as "the merchant pulp business," not "all U.S. pulp."

Two high-value niches within that merchant business:

• Dissolving pulp: U.S. output ~1.1 million tons in 2024, among the world's top three producers [5].
• Fluff pulp: the U.S. is the only net-exporting region on Earth, and three U.S.-headquartered companies (International Paper, Georgia-Pacific, Domtar) have historically accounted for roughly three-quarters of world fluff output [4][10].

4. The investable universe

Pure-play, U.S.-listed market-pulp stocks are scarce, and ownership of the biggest U.S. fluff capacity has recently moved into private hands. The practical map:

Publicly traded

Private and other major owners

• Georgia-Pacific (owned by Koch Industries) — operates four non-integrated wood-pulp mills and one cotton-linters pulp mill in the southeastern U.S., producing fluff, paper-grade, and specialty cellulose; private [10][19][20].
• Domtar (owned by the Paper Excellence group, linked to Indonesia's Widjaja family) — U.S. and Canadian pulp mills with approximately 3.2 million metric tons of annual capacity across softwood, hardwood, and fluff grades; taken private in 2021 [10][21][22].
• American Industrial Partners (private equity) — now owns the former International Paper Global Cellulose Fibers business (seven pulp mills and two converting facilities across the U.S., Canada, and Poland), a leading global fluff-pulp producer, as of January 2026 [11][12].
• Foreign majors selling into the U.S. market: Bracell/Royal Golden Eagle (RGE), CMPC (Chile), Klabin (Brazil).

A note to avoid a common mix-up: Rayonier Advanced Materials (RYAM) — a pulp maker — is not the same company as Rayonier Inc. (RYN), a timberland REIT; RYAM was spun off in 2014. Likewise, Weyerhaeuser (WY) exited pulp in 2016 (sold to International Paper) and is now a pure timber REIT — a fiber supplier, not a pulp producer.

5. How the money works

Pulp owners make money on the spread between a globally-set commodity price and their own cash cost per ton — and on how many tons they can run.

• Price. Commodity pulp trades per air-dried metric ton (ADMT) against public benchmarks (NBSK, BEK). In 2025, U.S. NBSK list prices ran roughly $1,535–$1,570/ton and U.S. BEK around $1,530/ton, though these gross list prices carry large discounts and the net price to China — the marginal buyer — swings far lower [23][24]. Prices are set globally; no single U.S. mill is a price-maker.
• Cost position. The three big cash costs are wood fiber, energy, and chemicals — together roughly 45% of per-ton cost of sales for cellulose specialties, with freight, depreciation, labor, and maintenance making up the balance [15]. Winners own cheap fiber (Southern pine, Brazilian eucalyptus) or long-term supply contracts. Critically, kraft mills burn their own lignin waste ("black liquor") in recovery boilers, so many are net energy producers and even sell surplus green power — RYAM reports that nearly 80% of its 2024 energy consumption came from renewable process biomass [15].
• Volume and the operating rate. Mills are enormous fixed-cost machines; profitability lives or dies on capacity utilization. When prices fall, producers take deliberate "market downtime" to prop up prices rather than flood an oversupplied market — Suzano, for example, announced its 2026 output would run ~3.5% below nominal capacity because marginal production did not offer adequate returns [14].
• Cyclicality. This is a classic price cycle business. New low-cost supply (mostly Brazil) and Chinese demand set the tempo; U.S. Gulf/South mills are mid-cost, so they earn fat margins at the top of the cycle and get squeezed at the bottom. International Paper's former Global Cellulose Fibers segment illustrates the swing: it earned $106 million operating profit on $3.2B of sales in 2022, then posted operating losses of $92 million (2023) and $226 million (2024) as prices and mix deteriorated [25].
• The premium grades. Fluff and dissolving pulp earn structural premiums over commodity kraft and are less violently cyclical — which is exactly why RYAM is pivoting toward specialty cellulose and biomaterials and away from commodity tons [15].
• Byproducts. Tall oil, turpentine, lignin derivatives, and surplus electricity add high-margin revenue.

Energy intensity. Pulp mills are among the most energy-intensive manufacturers. EIA's 2022 Manufacturing Energy Consumption Survey reported energy use for NAICS 322110 of 38,021 million Btu per employee and 40.4 thousand Btu per dollar of shipments — roughly seven times the broader Paper Manufacturing average [26].

6. What drives demand

• Hygiene / absorbent products (fluff pulp): diapers, incontinence, and feminine-care goods. Demographically driven (aging populations, emerging-market income growth) and recession-resistant — the sector's most defensive demand pool [4].
• Packaging (softwood kraft): containerboard and cartonboard need long, strong softwood fibers. E-commerce and the substitution of paper for plastic are secular tailwinds.
• Tissue: steady, population-linked demand and the largest single use of softwood pulp.
• Textiles (dissolving pulp): viscose/rayon and lyocell as substitutes for cotton and polyester; boosted by "sustainable fashion" narratives [5][17].
• Specialty cellulose: acetate (filters), ethers (construction, food), pharma and food additives — high-value, less cyclical [15].
• Printing & writing paper: a structural headwind — digital substitution keeps shrinking graphic-paper demand. AF&PA reported that U.S. printing-and-writing capacity fell 6.9% in 2024 to below 9 million tons, while total paper-and-paperboard capacity declined 2.0% to 78.1 million tons; tissue's share of capacity has risen from 7.2% (2000) to 11.3% (2024) [27].
• China: the world's marginal pulp buyer. Chinese paper, board, and viscose demand effectively sets the global price at the margin.

Wood supply. USDA found that the South produced 52.9 million cords of pulpwood in 2023, down from 56.0 million cords in 2022; roundwood supplied 72% of the total, and 70 mills drew wood from the region's 13 states (those counts include integrated mills, not merely 322110) [28].

7. Regulation

Pulp mills are among the most heavily environmentally regulated manufacturers in the U.S.

• The EPA "Cluster Rule" (1998). A landmark rule that combined air and water standards for bleached kraft and sulfite mills into one package. On the air side it set MACT (Maximum Achievable Control Technology) standards — MACT I/III for pulping areas and MACT II for chemical-recovery — cutting air-toxic emissions sharply; on the water side it drove mills off elemental chlorine bleaching to eliminate dioxin [29][30].
• Clean Water Act. Effluent is permitted under NPDES (National Pollutant Discharge Elimination System); pulp/paper mills are among the largest industrial water users and dischargers. RYAM states that more than 90% of its water withdrawals are treated and returned to the environment [15][31].
• Clean Air Act. Title V operating permits, boiler standards, greenhouse-gas reporting (including recovery furnaces and lime kilns under 40 CFR Part 98 Subpart AA), and controls on TRS (total reduced sulfur) — the "rotten-egg" odor characteristic of kraft mills [32][33].
• Fiber sourcing. Not government-mandated but commercially decisive: buyers demand FSC (Forest Stewardship Council) or SFI (Sustainable Forestry Initiative) chain-of-custody certification, and deforestation scrutiny falls hardest on globally-sourced producers.
• Trade. As an export-heavy industry, pulp is exposed to tariffs, anti-dumping actions, and currency policy.

The practical effect: high environmental capital spending, long permitting timelines, and a real barrier to building new capacity in the U.S. At December 31, 2025, RYAM carried approximately $184 million of environmental liabilities associated with current and former pulp, paper, sawmill, and wood-treatment sites — illustrative of company-level exposure [15].

8. Competitive dynamics and consolidation

The industry is a concentrated global oligopoly (top-4 U.S. share 78%, HHI ~2,005) [7], and it is consolidating and reshuffling in real time:

• Portfolio surgery at the top. International Paper exited merchant fluff pulp entirely, selling its Global Cellulose Fibers business to private equity to concentrate on packaging [11]. RYAM is shrinking commodity exposure — it indefinitely suspended high-purity operations at its Temiscaming (Quebec) complex — to chase specialty cellulose and biomaterials [15].
• New entrants and geography shifts. Brazil's Suzano, already the world's largest market-pulp producer on cheap eucalyptus, pushed into the U.S. with the 2024 Pine Bluff acquisition [13].
• The low-cost fiber threat. Fast-growing Brazilian eucalyptus keeps expanding the low end of the global cost curve, structurally pressuring higher-cost northern softwood mills and forcing capacity rationalization — closures and conversions of NBSK/SBSK lines.
• Private capital moving in. The biggest U.S. fluff capacity now sits with Koch, Paper Excellence, and American Industrial Partners — a marked shift of the crown-jewel assets away from public markets.

9. Risks

• Commodity price cyclicality / oversupply. New Brazilian and Chinese capacity can swamp demand and crater prices; this is the dominant risk [23][34].
• China demand concentration and trade policy. A single marginal buyer setting global prices, plus tariff and FX exposure on an export-driven business. RYAM generated $273 million of 2025 sales to China, including $234 million of U.S.-manufactured products, and reported that Chinese retaliatory tariffs on U.S. commodity fluff materially hurt operating income [15].
• Structural decline in graphic paper. A permanent headwind for freesheet-linked pulp demand.
• Input-cost inflation. Wood, energy, chemicals, and freight all hit margins directly. Wood economics are intensely local — haul distance, species mix, sawmill-residue availability, weather, and competition from nearby mills all matter [28].
• Capital intensity and aging assets. Mills cost billions and demand heavy sustaining and environmental capex; mis-timed expansions destroy value.
• Environmental and permitting liability. Cluster Rule compliance, water/air permits, and ESG scrutiny (emissions, deforestation) are ongoing costs and reputational risks.
• Leverage. Several pulp producers carry high debt into a cyclical trough — a recurring source of equity risk.
• Labor. At year-end 2025, 68% of RYAM's ~2,325 employees were unionized. Retiring experienced workers, remote mill locations, and shortages of qualified personnel add operational risk; a strike or loss of specialized maintenance capability can halt the entire continuous process [15].

10. How to invest, and the outlook

Public-market routes. There is no U.S.-listed pure-play domestic market-pulp stock and no dedicated pulp ETF. The nearest options, in rough order of "purity":

• Mercer International (MERC) — the closest listed pure-play on the market-NBSK price, though its mills are in Germany and Canada, so it tracks the global softwood benchmark more than the U.S. industry specifically.
• Rayonier Advanced Materials (RYAM) — the way to play U.S. dissolving / specialty cellulose.
• Suzano (SUZ) and Sappi (SPPJY) — global pulp leaders (eucalyptus; dissolving) with growing U.S. footprints.
• International Paper (IP) and Sylvamo (SLVM) — now packaging- and freesheet-focused respectively, i.e. downstream of pulp rather than pure pulp plays. IP retains financial (but not operating) exposure via its $190M preferred interest in the AIP-owned fluff business [12].
• Upstream fiber exposure via timber REITs — Weyerhaeuser (WY), Rayonier (RYN) — which supply the wood rather than make the pulp.

Private-market routes. This is where the largest U.S. pulp assets actually live: Georgia-Pacific (Koch), Domtar (Paper Excellence), and the former IP fluff business now under American Industrial Partners. Private and family-office capital dominates, and access comes through direct mill/asset ownership, timberland investment (the fiber base), or private-equity and private-credit vehicles in forest products. The $1.5 billion AIP purchase is a useful recent transaction marker, though it included multinational assets, converting facilities, and preferred consideration and should not be treated as a simple U.S. mill valuation multiple [11][12].

Outlook (forward-looking judgment). Near term, commodity pulp looks soft on oversupply: 2025 saw ongoing producer downtime, with demand growth expected to catch up to supply and tighten the market into 2026 [34]. The premium grades — fluff and dissolving — should stay more defensive, anchored by hygiene demographics and textile substitution. The clearest secular tailwind is plastics-to-paper substitution in packaging; the clearest secular headwind is the continued erosion of graphic paper. And the structural cap on the whole complex remains low-cost Brazilian eucalyptus, which limits how much higher-cost U.S. and northern mills can earn over a full cycle. Net: a cyclical, capital-heavy, consolidating industry where the durable money increasingly favors the specialty niches and the lowest-cost fiber — and where the most direct U.S. exposure is, ironically, mostly private.

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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. American Forest & Paper Association, "How Wood Chips Become Paper (kraft recovery >90%)," 2026. https://www.afandpa.org/news/2026/how-wood-chips-become-paper
4. Fact.MR, "Fluff Pulp Market Size and Share — Industry Statistics," 2024. https://www.factmr.com/report/1615/fluff-pulp-market
5. IndexBox, "U.S. Dissolving-Grade Wood Pulp Market — production ~1.1M tons 2024," 2026. https://www.indexbox.io/store/usa-dissolving-wood-pulp-market-analysis-forecast-size-trends-and-insights/
6. U.S. Census Bureau, "County Business Patterns (NAICS 322110): establishments, employment, payroll," 2023. https://www.census.gov/programs-surveys/cbp.html
7. 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
8. U.S. Small Business Administration, "Table of Size Standards (NAICS 322110 = 1,050 employees)," 2023. https://www.sba.gov/document/support-table-size-standards
9. Statista, "United States pulp and paper industry — statistics & facts," 2025. https://www.statista.com/topics/5268/us-pulp-and-paper-industry/
10. Nonwovens Industry, "Fluff Pulp Market Faces Year of Transition (U.S. as sole net exporter; IP/GP/Domtar share)," 2022. https://www.nonwovens-industry.com/issues/2022-05-01/view_features/fluff-pulp-market-faces-year-of-transition/
11. 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
12. 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
13. 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
14. Suzano, "2025 Form 20-F (13.44M tons capacity; 2026 output ~3.5% below nominal)," 2026. https://www.sec.gov/Archives/edgar/data/909327/000090932726000045/suz-20251231.htm
15. Rayonier Advanced Materials, "2025 Form 10-K (~$1.6B revenue; Jesup 600k t/yr, Fernandina 155k t/yr; 885k t/yr total system; 80% renewable energy; cost structure; environmental liabilities; China exposure; unionization)," 2026. https://www.sec.gov/Archives/edgar/data/1597672/000159767226000010/ryam-20251231.htm
16. 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
17. Sappi, "Cloquet Mill — dissolving wood pulp (Verve; ~370k t/yr)," 2024. https://www.sappi.com/en-us/about-us/locations/mills/cloquet-mill
18. Clearwater Paper, "2025 Form 10-K (limited market pulp; primarily paperboard)," 2026. https://www.sec.gov/Archives/edgar/data/1441236/000144123626000007/clw-20251231.htm
19. Georgia-Pacific, "About Us (Koch ownership)," 2025. https://www.gp.com/about-us/
20. Georgia-Pacific, "GP Cellulose Operations (4 wood-pulp mills + 1 cotton-linters mill)," 2025. https://www.gp.com/product-overview/gp-cellulose/
21. Domtar, "Who Owns Domtar (Jackson Wijaya / Paper Excellence)," 2023. https://www.domtar.com/who-owns-domtar-jackson-wijaya/
22. Domtar, "Pulp Business (~3.2M MT North American capacity)," 2025. https://www.domtar.com/pulp/
23. Fastmarkets, "US NBSK prices decline amid oversupply (US list ~$1,535–1,570/tonne 2025)," 2025. https://www.fastmarkets.com/insights/pulp-market-prices-oversupply-us-bleached-kraft-pulp-downtime-producer-inventories-rise/
24. Fastmarkets, "US NBSK flat as SBSK posts decline; BHK edges up (US BEK ~$1,530/tonne)," 2025. https://www.fastmarkets.com/insights/us-nbsk-flat-as-sbsk-posts-decline-on-higher-supply-bhk-edges-up-5-per-tonne/
25. International Paper, "2024 Form 10-K (GCF segment: $3.2B/2022, $2.9B/2023, $2.8B/2024; operating profit/loss by year)," 2025. https://www.sec.gov/Archives/edgar/data/51434/000005143425000013/ip-20241231.htm
26. U.S. Energy Information Administration, "2022 MECS Table 6.3 — Energy Intensity (322110: 38,021M Btu/employee; 40.4k Btu/$ shipments)," 2024. https://www.eia.gov/consumption/manufacturing/data/2022/pdf/Table6_3.pdf
27. American Forest & Paper Association, "2024 Capacity Survey (paper+board +3.2%; total capacity −2.0% to 78.1M tons; P&W −6.9%; tissue 11.3% share)," 2025. https://www.afandpa.org/news/2025/afpa-details-us-paper-production-and-capacity-trends
28. USDA Forest Service, "Southern Pulpwood Production, 2023 (52.9M cords; 70 mills)," 2024. https://research.fs.usda.gov/treesearch/69287
29. 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
30. 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
31. 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
32. U.S. EPA, "Kraft Pulp Mills — New Source Performance Standards (NSPS) 40 CFR 60," 2024. https://www.epa.gov/stationary-sources-air-pollution/kraft-pulp-mills-new-source-performance-standards-nsps-40-cfr-60
33. U.S. EPA, "Subpart AA — Pulp and Paper Manufacturing (GHG Reporting)," 2024. https://www.epa.gov/ghgreporting/subpart-aa-information-sheet
34. 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/