Abstract: Waste paper recycling has become the primary approach and trend to solve the pressing problem of insufficient traditional pulp and paper raw materials. A comprehensive efficiency evaluation model of waste paper recycling involving multiple indexes was proposed to analyze the comprehensive efficiency of the waste paper recycling process. An evaluation index system of the comprehensive efficiency of the waste paper recycling process was established by specifying five indexes according to material flow and energy flow involved in the process. Based on the combination weighting of game theory, the optimal combination weight of the evaluation index was obtained by optimizing the combination of subjective and objective weights. After that, the comprehensive efficiency evaluation model of waste paper recycling was established based on the matter element model. By applying the proposed evaluation model to the waste paper recycling process of nine enterprises, the comprehensive efficiency level of each enterprise was obtained. The results showed that two enterprises were at a high level, three were medium-high, and four were poor. The study case showed that this model was feasible in reflecting the relative level of comprehensive efficiency and the promotion direction of each enterprise.