"100% recyclable" means different things in different markets. Governance closes the gap.
Recyclability claims are among the most heavily scrutinised in environmental marketing. What is technically recyclable in one jurisdiction may be misleading in another. Verdanox governs the claim before it reaches the label.
Recyclability claims carry disproportionate risk because they appear on every unit, in every market
Technical recyclability is not consumer recyclability
A material can be technically recyclable in laboratory conditions while no curbside collection programme accepts it. Regulators in the EU, UK, and US now require claims to reflect real-world recycling infrastructure, not material science.
Infrastructure varies by territory
Flexible multilayer film is accepted in kerbside programmes in some regions and landfilled in others. An unqualified claim on a format with fragmented infrastructure creates enforcement risk anywhere the claim does not hold.
Production runs lock in the claim
Once packaging is printed and shipped, the claim is fixed. Unlike digital marketing copy, on-pack claims cannot be revised after the fact. A problematic claim discovered post-production can mean relabelling, withdrawal, or a regulatory response.
From material assessment to on-pack claim, governed
Infrastructure-mapped recyclability
Recyclability claims are assessed against the collection infrastructure data available in each target market, not against the material spec alone.
Market-specific qualification
Surfaces when a claim likely needs qualification in a particular jurisdiction. "Widely recycled", "check local recycling", and unqualified claims each create different substantiation questions.
Third-party assessment tracking
Links RecyClass, WRAP PREP, and equivalent assessments directly to the claim. Flags when an assessment rating is incompatible with the claim language.
Pre-production clearance
Governance status is surfaced before production runs are committed. Claims that are not cleared in all target markets are flagged before print approval.
Scenario: a 100% recyclable packaging claim
A packaging company is preparing to print an unqualified recyclable claim on flexible multilayer film packaging. Here is the governance record for that claim.
“100% recyclable packaging. Designed to be fully recovered at end of life.”
- 01
"100% recyclable" is an absolute claim. For the EU markets in scope, the record shows major gaps between technical recyclability and the collection and sorting infrastructure actually available to consumers. The claim carries high risk as drafted.
- 02
FTC Green Guides 16 CFR 260.12: flexible multilayer film is not accepted in curbside programmes serving 60% of the US population. An unqualified recyclable claim on this format is deceptive under current guidance.
- 03
UK consumer-law analysis: "100% recyclable" is likely to overstate consumer outcomes unless the practical basis of the claim is made clear. Current copy does not do that.
- Verified
Material composition certification (Intertek), multilayer film structure confirmed
- Verified
RecyClass recyclability assessment, rated D (not recommended for recycling claims in EU)
- Pending
UK WRAP PREP assessment. Collection scheme coverage data not yet submitted.
submitted for review
placed on hold pending WRAP assessment
RecyClass D rating is incompatible with unqualified recyclable claim in EU. Claim requires reformulation before market release.
Packaging claims carry disproportionate regulatory risk because they appear at the point of sale, in every market, on every unit. Verdanox maps each packaging claim to the recycling infrastructure data and regulatory standards in force in each territory, and surfaces conflicts before production runs are committed.
The regulations that matter for your team
EU consumer law / ECGT context
EU consumer-law reforms increase scrutiny of recyclability claims that do not reflect real consumer conditions. Technical recyclability on its own is not enough if collection and sorting infrastructure do not support the claim in practice.
FTC Green Guides (16 CFR Part 260.12)
Unqualified recyclable claims are deceptive unless recycling facilities are available to at least 60% of the US population where the product is sold. Claims must be qualified if infrastructure is limited.
CMA Green Claims Code
Claims should be truthful, clear, and not omit material information about real-world recyclability. Unqualified wording can mislead where collection or sorting varies by market.
See governance for your packaging claims.
Bring 2-3 on-pack claims from your current packaging portfolio. We map them against the recycling infrastructure data and regulatory standards in each of your target markets.
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