For packaging companies, making an environmental claim is increasingly only the first step. The harder question is whether the business can prove it.
Claims that packaging is “recyclable”, contains recycled material or has a lower carbon footprint can depend on a chain of evidence stretching from material specifications and test results to supplier data and life-cycle assessments.
Go deeper with GlobalData
Discover B2B Marketing That Performs
Combine business intelligence and editorial excellence to reach engaged professionals across 36 leading media platforms.
Even a technically accurate claim can be misleading if its limitations or conditions are not made clear.
That is changing how sustainability is communicated across the packaging industry. Regulation and advertising standards are pushing companies away from broad environmental language and towards claims that are specific, measurable and supported by credible evidence.
For packaging businesses, the consequences extend beyond marketing. Environmental claims can appear on packs, websites and advertising, as well as in communications between suppliers, brands and retailers.
The evidence behind them can therefore involve packaging designers, converters, material suppliers, recyclers, procurement teams and sustainability specialists.
Regulation is accelerating the shift. In the EU, member states were required to transpose the Directive on empowering consumers for the green transition by 27 March 2026, with the new rules applying from 27 September 2026.
In the UK, the Competition and Markets Authority (CMA) expects businesses making environmental claims to hold robust, credible and up-to-date evidence and to consider the overall impression created by their marketing.
The emerging test is straightforward: what environmental benefit is being claimed, how was it measured and what evidence supports it?
Why green claims are becoming evidence claims
Packaging presents particular challenges for environmental marketing because apparently simple terms can conceal considerable complexity.
A claim that a pack is “recyclable”, for example, may depend on more than whether its principal material can theoretically be recycled. Closures, labels, adhesives, coatings and barrier layers can affect the outcome, while collection, sorting and recycling infrastructure can influence what happens to the packaging after disposal.
Similar questions apply to other environmental claims. A recycled-content claim needs a clear basis for calculating the percentage and reliable information about the materials used.
A compostability claim may need to distinguish between industrial and home composting conditions. A carbon-reduction claim needs a defined comparison and an assessment methodology capable of supporting the reduction being advertised.
This means a claim can be technically correct in a narrow sense while still creating a misleading overall impression.
The CMA’s Green Claims Code says environmental claims should be clear and unambiguous, should not omit or hide important information and should be supported by credible evidence. Businesses should also consider the full life cycle of a product where relevant.
The guidance highlights the risk of describing a product as “recyclable”, for example, when only part of it can be recycled. It also makes clear that environmental impressions can be created by imagery, logos, colours and symbols as well as words.
The UK’s Advertising Standards Authority and Committee of Advertising Practice take a similar approach, with environmental claims requiring robust substantiation and general environmental claims normally needing to take the full life cycle of the advertised product into account unless their scope is clearly limited.
For packaging companies, the practical result is greater pressure to replace broad descriptions such as “green”, “eco-friendly” and “sustainable” with statements that define the environmental characteristic being claimed.
The shift is also reflected in industry forecasting. Innova Market Insights identified “Substantiated Sustainability” as its leading packaging trend for 2026, highlighting growing demand for scientifically supported environmental claims as regulation and consumer expectations develop.
The issue, then, is no longer simply whether a packaging claim sounds credible. It is whether the company can demonstrate exactly what the claim means.
The data behind a packaging claim
As environmental claims become more precise, the quality and traceability of the underlying packaging data become more important.
Different claims can require different forms of supporting evidence:
| Environmental claim | Potential supporting evidence |
| “Recyclable” | Packaging composition, component compatibility, design-for-recycling assessment and information about relevant collection, sorting and recycling conditions |
| “Contains 50% recycled plastic” | Material specifications, supplier documentation and the methodology used to calculate recycled content |
| “Compostable” | Testing or certification against an applicable standard and clear information about the conditions required for composting |
| “30% lower carbon footprint” | Defined comparator, assessment methodology, life-cycle boundary and underlying emissions data |
| “Uses less material” | Current and previous packaging specifications, weight data and a clearly defined basis for comparison |
These are illustrative examples rather than universal legal requirements. The appropriate evidence will depend on the wording of the claim, the packaging and market involved, and the rules that apply.
The underlying principle is that the scope of the evidence needs to match the scope of the claim.
Recyclability illustrates the challenge. A material may be technically recyclable under certain conditions, but that does not automatically mean the finished packaging will be accepted through the collection and recycling systems relevant to the market where it is sold.
Carbon claims can require an even broader evidence base. Depending on what is being communicated, the evidence may involve raw materials, packaging manufacture, transport, use and end of life.
Life-cycle assessment can provide a framework for measuring environmental impacts, but its assumptions, system boundaries and comparison need to support the specific claim presented to customers.
This turns packaging sustainability data into more than information used during product development. It can become part of the substantiation behind a commercial statement.
It also creates a supply-chain challenge. A brand may make the claim, but relevant evidence could originate with a converter, polymer producer, paper mill, recycler, testing laboratory, certification body or another supplier several stages upstream.
CMA guidance published in January 2026 specifically addresses responsibility for green claims across supply chains.
It is aimed at retailers, brands, manufacturers and suppliers and emphasises the need for businesses at different stages of a supply chain to work together to ensure environmental claims are accurate.
For procurement teams, this can increase the importance of obtaining and maintaining material specifications, certificates, recycled-content documentation, test results and other supporting records.
For suppliers, the ability to provide reliable sustainability information can become a commercial capability in its own right. A converter that can demonstrate the composition, recycled content or relevant performance of its packaging may be better placed to help a brand substantiate claims made to retailers and consumers.
Conversely, gaps in supplier information can create problems when a claim is challenged or when a customer asks for evidence.
The consequences can extend beyond regulatory risk. Missing or unreliable data can force companies to revise packaging artwork, delay product launches, repeat assessments or invest in additional testing.
Substantiation is therefore becoming part of packaging development risk: the necessary evidence may need to be available before a claim reaches the artwork stage rather than assembled after a challenge is raised.
Stronger data management can support both compliance and faster packaging decision-making.
How PPWR connects claims with technical evidence
The EU’s Packaging and Packaging Waste Regulation (PPWR) creates a particularly direct connection between packaging performance, environmental claims and technical evidence.
The regulation establishes sustainability and labelling requirements for packaging placed on the EU market and introduces measures covering areas including recyclability and recycled content.
Article 14 addresses environmental claims about packaging properties covered by the regulation. Such claims can only be made in relation to packaging properties that exceed the applicable minimum requirements set out in the PPWR. Businesses must also specify whether the claim concerns the packaging unit, part of the packaging unit or all packaging placed on the market by the economic operator.
Compliance with the relevant requirements must be demonstrated in the packaging’s technical documentation.
This creates an important link between technical and marketing functions. Technical documentation is not simply a regulatory record held separately from commercial communications. For some environmental claims, it forms part of the evidence supporting what a company tells customers about its packaging.
The PPWR also introduces progressively stricter recyclability requirements. From 2030, packaging covered by the relevant provisions must meet recyclability performance requirements expressed through grades A, B or C, subject to the regulation’s timing provisions and exemptions.
From 2035, the assessment adds a recycled-at-scale element, while from 2038 packaging will generally need to achieve grade A or B.
Minimum recycled-content requirements for certain plastic packaging are also scheduled from 2030. These include requirements that vary according to the type and format of plastic packaging.
Together, these measures bring packaging design, regulatory compliance and environmental communications closer together.
Marketing teams need to define claims precisely and consider the overall impression created by wording, qualifications and visual presentation. Packaging designers and developers need to consider potential environmental claims during development and ensure that the packaging delivers the characteristics being communicated.
Procurement and supply-chain teams may need to treat sustainability evidence as part of normal supplier-data requirements rather than requesting it only when a claim is challenged.
Regulatory and sustainability teams, meanwhile, are likely to have a greater role in reviewing packaging artwork and environmental communications before they reach the market.
None of this means that every sustainability claim requires the same test, certification or life-cycle assessment. The appropriate substantiation depends on the nature and scope of the statement being made.
The direction, however, is clear: the claim and the evidence increasingly need to travel together.
For packaging companies, that makes sustainability data a commercial asset as well as a compliance resource.
Businesses able to connect packaging design, material information, environmental assessment and supply-chain documentation will be better placed to support credible claims and respond when regulators, retailers or customers ask for substantiation.
Packaging sustainability claims are moving away from broad statements of intent and towards measurable characteristics that businesses can demonstrate.
In the emerging packaging market, making the green claim may be the easy part. The competitive and regulatory advantage will increasingly lie in being able to prove it.
