Recycled Content Claims: What You May Say, and What Must Stand Behind It

A recycled-content claim is a factual assertion with a file behind it, and the PPWR era disciplines it in two ways. The regulation provides for recycled-content information in its labelling framework, so the claim increasingly appears in harmonised form rather than free text. And green-claims discipline - consumer law as applied to environmental assertions - requires the claim to be accurate, specific and substantiated by current evidence. In practice the lawful claim is the certified figure, expressed on the same basis as the calculation: the post-consumer recycled share of the packaging's plastic part, or of the pack where the pack is all plastic.

Claims that outrun the basis - whole-pack percentages computed on plastic only, pre-consumer content counted in, 'up to' figures from a best batch - are the standard findings in claims enforcement, and they are all preventable by one join between marketing and the evidence file.

Three formulations cover most honest needs. 'Made with 35 percent post-consumer recycled plastic' - where the whole pack is plastic and the figure is the Article 7 figure. 'This bottle is made with 30 percent recycled plastic (plastic part)' - where the unit has non-plastic components and the basis must be visible. 'Contains recycled plastic from certified post-consumer sources' - the qualitative form for cases where a precise figure would mislead (variable supply across a transition period, honestly described elsewhere). Each names its basis or its nature in the claim itself. The formulations to retire are equally listable: 'eco plastic', 'ocean-friendly resin', 'fully recyclable and recycled', and any percentage without a basis a reader can identify. If a claim needs a lawyer to defend its reading, it needs a rewrite, not a defence.

The labelling station owns the full regime; the content-specific point is that recycled-content information joins the harmonised label family as the implementing acts settle, with the percentage and its basis presented consistently across the Union. Brands printing content claims now should design the claim panel as a placeholder for the harmonised form - same data, same basis - so the 2028 artwork cycle converts rather than rebuilds. Digital information (the data-carrier route) suits content claims particularly well, because content figures can move with supply across a year while the printed pack cannot; a QR-carried figure with a dated basis statement is often the most honest version of a true claim.

The governance artefact is a claims register: every public content claim, its exact wording and placement, its basis, the evidence file version supporting it, and its review date. Marketing owns the register; compliance owns the evidence link; neither publishes without the other's field complete. Review triggers mirror the evidence triggers - certificate renewal, specification change, methodology adoption - plus the artwork cycle. It is a small system, and it converts claims from a recurring negotiation between enthusiasm and caution into an administrative act with a paper trail. In a claims challenge, the register is the first thing to hand over, and handing it over early is a strategy, not a concession.

Before 2030, content figures are voluntary claims on the way to becoming duties, and the transition invites a characteristic error: claiming the target as if it were the current fact ('2030-ready: 35 percent recycled') in language a shopper reads as present tense. Transitional claims should carry their date in the claim - 'on track for the 2030 target, currently at 22 percent post-consumer plastic' is longer, uglier and defensible, which is the correct order of virtues. Marketing teams who internalise that order early will find the mandate's arrival almost relaxing: their claims apparatus and their compliance apparatus will already be the same machine.