Preparing for Ballot Paper Shortages in 2022 and 2024

Background

The unpredictability of supply chains and election administration has created a perfect storm for the 2022 midterm elections. Election officials are facing an uphill battle preparing for November, between longer lead times for orders, increased costs, uncertainty about voter behavior, and an ever-changing terrain of legislation and litigation. 

Supply Chain Disruptions, Paper Shortages: “Nothing short of a nightmare” 

The U.S. paper production industry has been declining for years. In a 2017 report, IBISWorld asserted that “The Paper Mills industry is in the decline stage of its life cycle” and forecasted an annualized 3.1% decrease in the industry’s contribution to the economy. The market size of paper mills in the U.S. fell 36.5%  from 2012 to 2020 as a result of increased competition with foreign markets and decreasing demand for paper.  

As demand for goods and services skyrocketed during the pandemic, many of the remaining paper mills—both domestically and globally—shifted their focus to producing cardboard boxes and other shipping materials with higher profit margins than conventional paper goods. With heightened demand at home and abroad, international trade wars, and costly and unreliable shipping, many of the countries the U.S. used to import paper materials from are now retaining materials for their own populations.  

This volatility has caused an unexpected uptick in the market size of domestic paper mills since 2020, but less overall availability of paper for industries outside of delivery and transportation.  

Paper shortages are further compounded by rising costs, labor shortages, and delivery delays. Damani Coates, CEO of a printing shop that specializes in book printing, started experiencing shortages in early 2021. What began with a shortage of select products has now spread to “every type” of paper finish, he explained in a Printing Impressions article. Coates had to rethink his business strategy, moving away from “just-in-time inventory approaches” to “purchasing what you can, when you can.” Facing consistent shortages and 20% or higher price increases, he described the state of paper supply chains as “nothing short of a nightmare.” 

When faced with shortages, private companies can pivot by taking a more aggressive approach to ordering and directing customers to alternative paper types. Election officials rarely have that luxury. While ballot envelopes and other nonballot collateral can be printed on alternative paper weights and types, ballots themselves need to meet certain specifications to be processed correctly by ballot tabulators.  

Electoral Landscape

During this volatile period in the global print industry, American election administration also underwent a seismic transformation.  

2020 launched an era of frequent and often late-in-the-game changes to state voting rules. The National Conference of State Legislatures has tracked nearly 2,000 election-related bills in the 2022 legislative session alone, 165 of which have been enacted across 39 states. Regardless of the laws’ contents, making significant changes during a federal election year risks voter confusion and administrative mistakes. Furthermore, given long lead times for orders, legislative or court-mandated changes that happen close to an election will have the biggest impact on officials’ ability to respond to the paper shortage. With limited materials, most jurisdictions won’t be able to reprint orders after they’ve been placed. If a statutory or rules change requires adjustments to ballot materials, jurisdictions may not be able to obtain new materials in time for the election. 

Additionally, between shifting pandemic realities, the deepening of election misinformation, and new voting rules and regulations, it’s not clear which voting methods voters will favor most in upcoming elections. Convenience voting options are far from new, but there is uncertainty about whether the high rate of mail voting seen in 2020 will continue. The incessant false information campaign to sow doubt into convenience voting options may drive some voters back toward in-person Election Day voting options, making it difficult to anticipate voters’ behavior in November.  

When faced with this uncertainty, election officials will have to build additional error margins into their preparations for early, mail, and in-person voting. For many, that will mean ordering additional materials to accommodate demand for each method, particularly in states that use differently labeled ballots for in-person early and Election Day voting. For states that use the same ballots for both early and Election Day voting, each voting site will likely still need additional materials due to uncertainty about in-person turnout. For mail voting, election officials will not only need more paper ballots but also additional ballot envelopes, secrecy envelopes, and instructional materials. This, too, will drive up paper orders and cause greater potential for disruption in the voting process. 

Looking Ahead 

Uncertainties about voter behavior and supply chain disruptions have converged to create a uniquely challenging situation for the 2022 midterm elections. Yet while the midterms are on the forefront of national consciousness, supply chain disruptions won’t dissipate after November. The decline in U.S. paper mills combined with economic volatility and price uncertainty means that supply issues are likely to persist into at least the near future. The recommendations of this report strive both to prepare election officials for the midterm elections and encourage state and federal lawmakers to take a proactive approach to addressing paper shortages in the long term. 

Supply and Storage of Ballot Materials 

Paper and print vendors nationwide have long lead times for obtaining blank ballot paper and ballot envelopes. In some cases, paper mills have rationed supplies and restricted ballot printers to less paper than previous orders. In others, ballot printers have had to break contracts entirely due to insufficient materials. Across the board, orders that once took days or weeks are now taking months.  

The Elections Infrastructure Sector Coordinating Council (EI-SCC) summarizes the particular and dire impact of these market trends on election administration: 

“With the COVID-19 pandemic and various supply chain challenges, the print and mail industry has experienced some of the worst supply chain disruptions and price volatility in many decades. Prior to the pandemic, paper mills could produce and deliver up to ten truckloads of paper in as few as four weeks.  In February 2022, print and mail vendors are not always guaranteed the full quantity of paper forecasted months in advance.” 

The shortage of paper materials and long lead times for orders means that election officials, lawmakers, and vendors must be intentional in their preparations for November. While, in the past, vendors may have been able to fulfill last-minute orders or changes with ease, that will likely not be an option moving forward.  

The burden for supplying paper in accordance with contracted specifications is squarely on the vendor. However, factors outside of vendors’ control may keep vendors from meeting pre-established agreements. Given the uncertainty around vendors’ relative abilities to meet contract obligations, the following recommendations strive to help election officials and state lawmakers prepare for inevitable market disruptions around the supply and storage of ballot materials.  

Recommendations to Improve the Supply and Storage of Ballot Materials 

1. Election officials should contact their vendors to verify that they have sufficient materials to fulfill orders and contingency plans for unforeseen circumstances. Any office without a contract in place for the midterm elections should secure one immediately.  

Even the most reliable vendors are facing supply chain issues outside of their control, including a shortage of raw materials, subcontractors breaking agreements, delivery delays, rising costs, and labor shortages. With the rise of mail voting in 2020, a handful of new print vendors entered the market. Print vendors, particularly those new to ballot printing, may be unprepared to cope with the complexity of current supply chain constraints and may over-promise orders ahead of November.  

Election offices typically enter multiyear contracts with print vendors. Despite a three-year print contract, one Michigan county had to place its orders in October 2021 to ensure delivery for the August 2022 primary. Many vendors have responded to paper shortages with a plea to election officials to place orders early, but that isn’t always feasible. Elections have multiple, mutually reliant statutory obligations and timelines. Federal law requires that ballots are mailed to uniformed and overseas voters 45 days before the election, yet ballot materials can only be finalized after candidates and ballot questions are determined. Often, election officials do not know what size ballot paper will be needed until the questions that will be on the ballot are known. This leaves election officials with a narrow window to place print orders. 

Election offices that have not already placed their orders for November should do so immediately. Those unable to place orders due to uncertainty about the size of paper needed (or other similar factors) should alert vendors to anticipated order sizes and timelines. Those that have placed orders already should contact their vendors to ensure that they are on track to fulfill the orders on time. Any election office without a contract in place for November should identify a vendor, secure a contract, and place their print orders as soon as possible.  

2. Election officials should test paper well in advance of the election. Vendors should not substitute the paper types of ballot materials without the explicit approval of election administrators. 

To cope with the paper shortage, vendors have begun ushering clients toward any paper type they have on hand. In worst-case scenarios, unsuspecting vendors are substituting similar paper types for orders without their clients’ knowledge. While a slight change in paper type might seem unimportant for those in the private sector, it has serious implications for election administration.  

Ballot tabulators are specialized machines designed for paper types with specific caliper, opacity, brightness, smoothness, and weight. Changes in any of these categories could result in read errors during tabulation, making it of the utmost importance that vendors meet all specifications provided to them by election officials. While the burden is on vendors to meet the terms of their contracts, election officials should contact their vendors before orders are placed to verify that paper will meet all specifications for tabulation. 

Additionally, election officials should test ballots as early as possible, ideally before all ballots have been printed. If an election official discovers an issue with ballot paper after voting has begun, there is no good remedy except to require those ballots to be hand counted.  

Nearly all jurisdictions conduct logic and accuracy (L&A) testing before elections to confirm that the voting system can accurately count and tabulate votes. L&A testing will alert election officials to any read issues resulting from ballot paper, even if vendors substitute paper types without officials’ knowledge. This demonstrates an essential security component of our election system working—tabulation errors will not go unnoticed.  

However, as L&A testing was originally geared toward error-checking tabulators, it is typically conducted in the days or weeks before an election, after ballots have begun being distributed to voters. To catch issues in time to respond, testing must happen as long as possible before voting begins. 

As any issue that occurs related to tabulation could become fodder for misinformation, election officials should be prepared for this possibility and build it into their contingency and crisis communications plans. Officials should plan for how they would hand count ballots if tabulators could not be used and how that would be communicated to the public. 

3. Election officials should vigorously and methodically proof all ballot materials before they are sent for print. 

In addition to submitting orders as early as possible, the EI-SCC recommends focusing on reducing paper waste through robust ballot proofing.  

The paper shortage, the lack of a flexible labor force in the print industry, and waning short-notice transportation options have made it costly and difficult, if not impossible, for ballot printers to fulfill last-minute print orders or changes. If election officials do not catch ballot errors early, reprints may not be possible. 

Ballot proofing is the process of reviewing ballots at every stage of the design and production process to catch errors and avoid reprints. Election officials should create a plan for ballot proofing that includes a ballot proofing checklist and multiple stakeholders in the proofing process. Proper and methodical proofing prevents reprints.  

4. Election officials and state rulemaking bodies should prioritize long-term contracts with reliable vendors for future elections.  

In many states, the process for obtaining a contract with a vendor is spelled out in state law or guidance. Often, jurisdictions are required to release a public request for proposal; after a set period, the jurisdiction must then follow state guidelines on how to select the bidder. In Illinois, for instance, contracts are awarded to “the lowest responsible and responsive bidder” unless an exception is made. In Massachusetts, by contrast, rather than the lowest option, proposals are selected by “the best value overall.”  

With election offices competing with private companies for limited resources, jurisdictions may not have the ability to sort through multiple vendors for the most affordable option. Even without supply chain disruptions, there are always limited options for vendors due to an oligopolistic market structure (in which a few firms dominate the market) and the complexity of ballot printing guidelines and security protocols. That said, the introduction of new printers into the market during 2020—as well as the high likelihood that recent price hikes may draw even more new printers to the market—means that some jurisdictions may have more options available to them than in years past. Given the uncertainty and volatility in the ballot paper and printing market, state rulemaking bodies should consider adjusting their bid selection process to prioritize contracts with the best value, rather than the lowest cost. 

5. Election officials should coordinate storage options with vendors in accordance with state law and security best practices. 

Many election offices are under-resourced, with limited storage capacity; as a result, it is common for jurisdictions to build storage into their contracts with vendors. Yet a national scarcity of warehouse space creates two potential problem scenarios for election officials: 

Problem Scenario One: The election office does not currently have storage built into their contract and lacks space to store large orders. 

Recommendation: The election office should work with their vendor and county or state government to coordinate storage and delivery timing. 

Uncertain fulfillment timelines could create difficult situations if large print orders are filled sooner than anticipated, requiring election officials to store materials for extended periods of time.  

Jurisdictions without sufficient space to securely store ballots should build storage options into their ballot procurement contracts. All ballot materials must be stored in secure, climate-controlled facilities that are protected from human- or weather-related threats (especially given the difficulty of getting replacement orders fulfilled). To promote optimal security and integrity, state officials should provide local offices with detailed guidance about chain of custody requirements and other considerations that they need to account for when coordinating storage with a vendor.  

If a vendor is unable to accommodate the storage of ballot materials outside of existing contract obligations, election offices should work with their county and state governments to identify secure storage facilities.  

Problem Scenario Two: The election office has storage built into their vendor contract, but their vendor asks the office to accept the order early due to insufficient or substandard warehousing options.  

Recommendation: For November, the election office should explore whether any county storage is available that meets climate-control standards. For future elections, the election office should prioritize storage reliability in their bidding and selection process.  

While coordinating storage with vendors is common, it may be increasingly challenging moving forward. “As retailers and logistics companies try to stockpile goods to hedge against supply chain problems, they are facing a new challenge: In many parts of the United States, there is little to no space available to stash the merchandise,” the New York Times reports. 

Like companies across industries, in response to supply chain disruptions, print vendors are increasingly adopting a “buy what you can, when you can” mentality. Often, this means that print vendors need to store more product for future use. When combined with the national shortage of warehousing options, print vendors are unusually low on storage space.  

Scarce warehousing options could create problems even for election offices that already have storage built into their print contracts. With limited options, vendors may use warehousing options that don’t meet state requirements for climate-control or security. Alternatively, vendors might request that an election office accept an order earlier than planned.  

Whenever possible, election offices should hold vendors to their existing storage agreements. That said, jurisdictions should prepare contingency plans for the off chance that they have to store ballot materials in-house. Election officials without room in their election office should coordinate with their county or state governments to identify whether there is any secure government storage space available as a backup.  

Noting the challenge posed by the reduction in warehousing space, the EI-SCC’s working group of print vendors and election technology companies recommended that election officials “Consider if your jurisdiction can take an early delivery of ballots” and “Consider or plan on a warehousing budget in your future election plan.” While the task force maintains that the burden should be on print vendors to meet contract obligations, the EI-SCC recommendations indicate a potential shift in how ballot materials are stored that election officials should be prepared for.  

6. Where applicable, state legislatures should permit jurisdictions to source ballot paper from any legitimate vendor nationwide.  

Select states require that all ballots be printed within or sourced from vendors based in the state. Ohio, for instance, requires that “All ballots shall be printed within the state.”  

In an already volatile and overrun printing market, states should not place any more limits on election officials’ ability to obtain ballot materials than is absolutely necessary. To maximize the chance that sufficient resources can be procured well in advance of the election, states that currently restrict the location of paper or printing services should act fast to remove this limitation. While this is a particular concern for the 2022 midterm elections, recent supply disruptions are only continuations of long-term trends, and this issue is not going away in 2024. As such, rather than a temporary exception, state legislatures should permanently allow the procurement and printing of ballot materials from vendors nationwide. 

7. To reduce the amount of paper needed for ancillary (nonvoting) administrative functions, state legislatures should consider allowing qualified individuals to register to vote and request mail ballots online in future elections.  

The ability to register to vote, request and track absentee ballots, and perform other nonvoting functions online is a cornerstone of accessible, modern election administration. Not only do these options expand voting access to typically disenfranchised voters—and most notably those with disabilities—they also reduce the dependence of ancillary election functions on paper, expanding the stock of paper available for essential ballot and ballot envelope materials.  

This recommendation should be considered by state legislatures only for future elections, as we do not recommend making changes to major election functions in the immediate precursor to an election.  

Contingency Planning for Last-Minute Changes and Delayed Materials 

Superfluous changes to election procedures or materials close to an election are almost always a bad idea—even in a relatively uncontentious election year, they risk administrative mistakes and voter confusion. With current supply chain concerns, eleventh-hour changes now also risk the ability to obtain essential voting materials.  

States are already grappling with this issue in the primary season. For example, Texas’ landmark voting bill SB1 went into effect just three months before the state’s schedule primary. Among a slew of other administrative changes, the law necessitated a minor language change on its voter registration application. As Texas’ voter registration deadline is 30 days before an election, election offices had roughly two months to obtain new registration materials and distribute them to voters in time to register for the primary. Predictably, this did not turn out well. Texas’ Secretary of State did not have enough voter registration forms, and had to ration supplies among registration groups.  

In the ongoing aftermath of the 2020 election controversy, courts and legislatures continue to make unprecedented changes to election procedures, and Texas is far from alone in having to implement sweeping changes while preparing for an election.  

The need for election officials to place print orders early, coupled with the high risk that late-in-the-process changes will be made, shores up the need for robust contingency and operations planning. 

Recommendations for Managing Time and Contingency Planning 

1. Courts and states legislatures should resist last-minute changes to the voting process, particularly those impacting ballot design.  

The task force’s 2021 report Improving the Voting Experience After 2020 recommends that states enact legislative or administrative changes to standing election procedures outside the 90-day window before a general election. The report goes on to recommend that challenges to standing election procedures within 90 days of an election should be considered by courts only for future elections, and that courts should consider challenges to the merits of election administration changes in an election year on an expedited basis. 

While these recommendations were originally crafted in response to the deluge of litigation in the lead-up to the 2020 presidential election, their urgency has only increased in light of current supply chain constraints. Because election offices must place their print orders as early as possible, last-minute changes could mean that orders need to be changed or resubmitted without sufficient lead time, creating uncertainty around whether materials will be obtained in time.  

2. Election officials should prepare contingency plans for how they will respond to materials shortages and last-minute changes to candidates or ballot materials. 

The U.S. Election Assistance Commission (EAC) defines contingency planning as “the development of a management plan that addresses an election office’s response to emergency and crisis situations that might arise unexpectedly.” Contingency planning often refers to external crises like extreme weather events or political upheaval. Increasingly, however, election officials are needing to prepare contingency plans for emergencies that occur closer to home: physical and cyberthreats, poll worker shortages, misinformation, and shortages of essential voting materials. 

Election offices should develop extensive contingency plans for how they would respond to breaches of paper or print contracts, vendor delays that impact mail ballot deadlines, and misprints. Additionally, while in an ideal scenario, election offices would have ample time to implement rules and procedural changes, late changes are becoming a new normal. Offices must also prepare for how they would implement changes to processes or materials after print orders have been placed. Officials should consider requesting additional support from the state or county for a contingency fund that could be used to offset the additional printing or labor costs involved in implementing last-minute changes. 

All types of election staff should be involved in the contingency planning process so that the full suite of potential problems can be understood and addressed. Logistics and operational staff can help brainstorm upstream and downstream implications, while digital and communications staff can help identify solutions for how any issues will be communicated to the public. In today’s contentious media landscape, having a crisis communications strategy is a vital component of any election-related plan. 

Responding to Increases in the Cost of Materials 

It’s a simple principle of supply and demand that when there is a shortage, a price increase follows. Price increases in the paper and print industries have far outpaced rates of inflation across the economy at large. The April 2022 Consumer Price Index revealed an 8.3% rate of inflation compared with the year prior. In the printing industry, costs have soared 40% or more.  

Unable to cope with rising costs of raw materials, some paper mills are breaking price contracts with print vendors. This has resulted in print vendors breaking pre-existing price contracts with election offices, further driving up costs.  

Inflation alone is creating challenges for already resource-strapped jurisdictions nationwide. When coupled with the increase in cost for ballot paper, there is a dire need for additional funding to fill the gaps in election infrastructure. 

Recommendations for Responding to Increases in the Cost of Materials 

1. States legislatures should provide additional funding to election offices to compensate for the increased cost of ballot paper and other election peripherals. 

The diversity of approaches to election administration at the local level means that there is no one “number” for what it costs to run an election, but there is one theme that remains constant across election reform dialogue: election administration is vastly underfunded. Election officials often pride themselves on conducting safe, secure, and accessible elections on inadequate budgets. Too often, however, this requires trade-offs in the services or support available to voters. Election officials regularly work overtime to field requests and lift up basic voter services. A 20-40% increase in the cost of ballot paper will mean less funds for other core election functions like voter education, additional support staff, or new cybersecurity tools.  

State legislatures should act expediently to appropriate additional funds to local election offices to account for rising costs of ballot materials. Additional funding should also be reserved for responding to contingencies, such as needing to reprint materials at the last minute due to unforeseen circumstances. As vendors have extremely limited (if any) paper backstock, it will be costly to print on a rapid turnaround.  

2. The federal government should provide additional funding to states and local jurisdictions, and explore ways to source additional election materials in the short and long term. 

Recent federal investment in elections has been haphazard and unpredictable. Without a regular funding stream, it’s difficult for election offices to make intentional, long-term investments in election operations. 

Paper shortages and supply chain disruptions are here to stay for the foreseeable future; costs will likely continue to rise. A regular stream of federal funding is needed to bolster the ability of election offices to obtain reliable, high-quality contracts with vendors. 

It takes time for federal funds to reach states and even longer for funds to reach local jurisdictions. As such, Congress should act quickly to appropriate regular funding for 2024 and subsequent elections. Given the contentious and difficult nature of the congressional appropriations process, BPC’s Elections Project recently proposed reallocating the Presidential Election Campaign fund to create a regular funding stream for election administration. 

Additional funding is the most important thing that state and federal lawmakers can do to support election administration in light of supply chain constraints, but it only solves demand-side problems. Federal lawmakers should explore ways to support the performance of domestic paper mills. Additionally, federal lawmakers should consider how current laws might be leveraged or revised to incentivize additional foreign imports and domestic production, much like the Biden administration did with the Defense Production Act during the pandemic. 

Conclusion 

Time and time again, election officials have demonstrated their resilience in the face of adversity, whether it be administering a highly secure election during a global pandemic or maintaining professionalism amid an onslaught of personal threats. The paper shortage may complicate the midterms, but election officials will continue to find ways to administer secure and accessible elections regardless of the state of the global economy. That said, there are clear actions that election officials and lawmakers can take to mitigate the impacts of the paper shortage both in November and future elections. Given the months-long lead times for obtaining ballot orders, with each passing day, the available mitigation options will shift from those that prevent problems to those that respond to them. Time is of the essence, and we encourage state and federal lawmakers to act swiftly to promote a smooth and secure election in November.