Recycled content, recyclability and carbon claims require different evidence. Packaging businesses need reliable data, clearly defined statements and records that remain relevant as suppliers and markets change.
A bottle described as “made with recycled plastic” raises several questions. Does the statement cover the bottle body, the cap and the label? What proportion is recycled? Can the business making the claim trace that figure back to the material supplied?
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Similar questions apply to packaging described as recyclable or lower carbon. A short statement on a pack can depend on evidence from material producers, packaging converters, brand owners and waste-management systems across several countries.
For packaging manufacturers and buyers, substantiating a claim means establishing precisely what it says, identifying the evidence needed to support it and keeping that evidence current.
Define what the claim covers
A claim may concern one component, the complete packaging system or the packaged product. Its wording should make that distinction clear.
Consider a bottle body containing recycled plastic, fitted with a cap made from virgin plastic and a separate label. Evidence about the body alone cannot establish the recycled content of the complete pack.
Comparative claims need further detail. “Lower carbon” should identify the packaging being compared, the basis of comparison and the stages included in the calculation. A reduction in manufacturing emissions does not necessarily demonstrate a reduction across the packaging’s full life cycle.
Each statement therefore calls for different evidence.
| Claim | Evidence to assess | Common weakness |
| Recycled content | Material origin, quantities, calculation method and traceability records | A figure for one component is presented as applying to the whole pack |
| Recyclable | Packaging composition and compatibility with collection, sorting and reprocessing systems in the intended market | Technical recyclability is treated as sufficient everywhere |
| Lower carbon | A defined comparison, equivalent packaging function, consistent assessment boundaries and documented assumptions | Figures from studies using different methods are compared |
| Reduced material use | Measured weights, a clear baseline and checks that the packaging still performs its required function | Lower weight is presented as proof of lower overall environmental impact |
These are starting points for assessment. The final wording must also reflect the rules and conditions of the market where the packaging is sold.
Build the evidence across the supply chain
Much of the information supporting a packaging claim sits outside the organisation communicating it.
A converter — a business that turns materials into packaging — may hold production records and material specifications while relying on upstream suppliers for recycled-content information or environmental data. A brand owner may then depend on the converter for evidence about the finished pack.
Supplier requirements should specify the information needed, how it should be calculated and which records must support it. A declaration is more useful when it identifies the material, production site, reporting period and assessment method.
International sourcing adds complexity. Suppliers may use different reporting periods, assumptions and units. Some figures may describe a particular production site; others may be industry averages.
Businesses should resolve inconsistencies before combining data and document any remaining limitations. Estimates can be useful, provided they are clearly identified and appropriate for the claim.
The UK Competition and Markets Authority’s guidance on environmental claims across supply chains addresses the responsibilities of retailers, brands, manufacturers and suppliers. It highlights the need for businesses to work together when important information needed to substantiate a claim sits elsewhere in the supply chain.
That cooperation needs clear ownership. A material supplier may hold information about raw materials, a packaging manufacturer may control production records, and a brand owner may approve the consumer-facing statement.
A supplier declaration can contribute to the evidence base, but the company making the claim still needs to understand what it proves and whether it applies to the packaging being sold. Evidence for one material, production site or market may not apply elsewhere.
Match the assessment to the statement
Life cycle assessment (LCA) helps businesses examine how a packaging change affects environmental performance across the stages included in a study. The international LCA framework in ISO 14040 covers the definition of the study’s goal and scope, inventory analysis, impact assessment and interpretation.
Reducing packaging weight, for example, may lower material use and transport impacts. A meaningful comparison also needs to account for the packaging’s function. If a lighter format changes product protection, damage rates or product waste, those effects may influence the result.
Comparisons should assess equivalent functions, such as delivering the same quantity of product with equivalent protection. Comparing equal weights of different materials may not answer the practical question facing a packaging buyer.
Carbon calculations address climate impact. ISO 14067 provides requirements and guidance for quantifying and reporting a product carbon footprint consistently with the LCA standards. It covers climate change as a single environmental impact category.
A lower carbon footprint therefore does not establish that packaging performs better across other environmental categories, such as water use or resource consumption.
Recycled content is also a specific material attribute. Evidence supporting that attribute does not, by itself, demonstrate lower overall environmental impact.
The assessment should answer the question posed by the claim, and the wording should reflect its findings and limitations. A narrowly defined statement may require very different evidence from a broad claim about overall environmental performance.
Understand what verification covers
Independent review, testing, certification and auditing can strengthen evidence, but each has a defined scope.
A certificate may cover a material, production site or chain-of-custody system, which tracks material through the supply chain. An environmental product declaration (EPD) reports environmental information under the rules of a particular programme.
Businesses should establish what was assessed, which method was used, what period the evidence covers and whether it applies to the packaging being marketed. Neither a certificate nor an EPD automatically supports every environmental statement associated with a product.
The US Federal Trade Commission’s Green Guides make the distinction clear: third-party certification does not remove a marketer’s responsibility to substantiate the express and implied environmental claims it communicates. The Guides also state that recyclable claims can depend on consumers’ access to appropriate recycling facilities.
Verification is most useful when its scope matches the claim. Any gaps between the two need to be addressed before the statement is approved.
Check the destination market
A common evidence system can support international operations, but claim wording may need to vary by market.
Recycling infrastructure, consumer expectations and legal requirements differ. Packaging accepted in one collection system may be excluded from another.
For recyclability claims, businesses need to consider both packaging design and the availability of appropriate collection, sorting and reprocessing systems. The FTC’s Green Guides, for example, call for qualifications where access to recycling facilities is limited.
In the EU, the Packaging and Packaging Waste Regulation (PPWR) applies from 12 August 2026. It establishes a harmonised framework for packaging and packaging waste, with different requirements taking effect at different stages. The European Commission has published guidance to support implementation.
Businesses should distinguish documentation demonstrating regulatory conformity from evidence supporting a marketing claim. The records may overlap, but meeting a packaging requirement does not automatically substantiate a broader environmental statement.
For international suppliers and brand owners, a practical approach is to maintain a core record of packaging specifications and supporting data, then assess each intended claim against the requirements and conditions of its destination market.
Keep claims connected to current evidence
An effective approval process should record the exact claim, the packaging it covers, the intended markets and the supporting evidence.
It should also identify who maintains the records and which changes trigger a review. These may include a new material supplier, a different production site, revised component weights, a change in recycled-content source or an updated calculation method.
Claims about disposal and recycling need similar attention. Changes in collection, sorting or reprocessing arrangements can affect whether a statement remains accurate in a particular market.
A company should be able to reconstruct how it reached a claim using retained specifications, production records, calculations and review documents.
For manufacturers, this means documenting the materials and formats they supply. For brand owners, it means understanding suppliers’ evidence before turning it into a statement on packaging, a website or procurement material.
Before approving or renewing a claim, the business should be able to answer three questions: what exactly does it cover, how was it established, and does the evidence still apply to the packaging being sold?
