🧾 What counts as a recycled content claim?

A recycled content claim is any statement (text, icon, seal, or implied message) that indicates a product, component, or packaging contains recycled material.

Typical claim types

• Unqualified: “Made with recycled content” (implies some portion is recycled)
• Qualified percentage: “Contains X% recycled content (by weight)”
• Category-specific: “X% post-consumer recycled content (PCR)” or “X% pre-consumer”
• Component-scoped: “Bottle contains X% recycled plastic”
• Allocated / mass balance (where used): recycled content attributes assigned under a defined chain-of-custody model (requires strong controls)

🌍 Regulatory and standard references you should align to

• United States (FTC Green Guides): 16 CFR §260.13 covers recycled content claims and emphasizes substantiation—especially if you distinguish pre- vs post-consumer content.
• European Union: Directive (EU) 2024/825 strengthens protections against misleading sustainability claims and amends core consumer protection directives.
• United Kingdom (CMA): The Green Claims Code guidance sets principles for compliant environmental claims, and the CMA issued additional supply-chain guidance in January 2026.
• Canada (Competition Bureau): “Environmental claims and the Competition Act” explains how misleading advertising/deceptive marketing rules apply to environmental claims.
• Chain-of-custody / mass balance: ISO 22095 (chain of custody) and ISO 22095-2:2026 (mass balance requirements and guidelines).

✅ Compliance requirements (what you must have in place)

1) Substantiation before you publish

Have competent, organized evidence ready before claims appear on packaging, websites, datasheets, tenders, or ads. The FTC explicitly calls out substantiation expectations for percentage claims and for any express or implied split between pre- and post-consumer content.

Minimum proof set

• BOM/component weights (per SKU, version-controlled)
• Supplier declarations (recycled %, PCR/PIR split if claimed)
• Transaction evidence (POs/invoices, batch/lot IDs, CoAs)
• Calculation method + worksheet
• Change log (supplier/material/BOM/label versions)

2) Accurate scope (avoid “whole product” implication)

State what contains recycled content:

• Product vs component vs packaging
• Primary vs secondary/tertiary packaging
• Single SKU vs product family

If only a component is recycled, your wording should not imply the entire item is.

3) Clear definitions (PCR vs pre-consumer)

If you distinguish pre-consumer vs post-consumer, you should be able to substantiate the percentage for each.

4) Repeatable calculation rules

Use a consistent mass-based method unless your program/market requires otherwise:

Recycled content % = (mass of recycled material ÷ total mass of defined item) × 100

Lock down:

• units of measure and rounding rules
• how you treat coatings/inks/adhesives/additives
• multi-material assemblies (component roll-up rules)
• how claims are updated when inputs change

5) Chain-of-custody controls (including mass balance where used)

Your evidence must link input material → batch/lot → finished SKU.
If you use mass balance allocation, implement documented reconciliation rules aligned to chain-of-custody standards (ISO 22095 and ISO 22095-2:2026).

🔎 Supply chain due diligence (practical checklist)

Supplier onboarding

• Require a signed recycled content declaration (with scope and %)
• Require PCR/PIR split if your claim uses those terms
• Require batch/lot identifiers on transactional docs
• Validate definitions and prevent double counting
• Set notification rules for process/material changes

Contract clauses (recommended)

• Right to audit substantiation and traceability
• Change notification and revalidation triggers
• Record retention requirements
• Warranty/indemnity for misrepresentation

The UK CMA’s supply-chain guidance emphasizes managing responsibility for claims across the supply chain—so these controls reduce legal and reputational risk.

🏷️ Claim wording rules

Use precise, scoped wording

• “Contains 30% recycled content by weight.”
• “Bottle contains 30% post-consumer recycled plastic by weight.”
• “Packaging sleeve contains 50% recycled paper fiber by weight.”

Avoid vague “halo” language

Steer clear of broad, undefined claims that imply overall environmental superiority unless you can substantiate them under relevant consumer protection rules (EU/UK/Canada focus heavily on avoiding misleading impressions).

🧰 What your company should do to comply (end-to-end workflow)

Phase 1 — Build a recycled content claims policy 📘

• Standard definitions (PCR, pre-/post-consumer, recycled content scope)
• Accepted evidence types and required fields
• Calculation and rounding rules
• Review/approval responsibilities and record retention

Phase 2 — Create a claims register 🗂️

• List every claim by SKU + market + channel (pack/web/datasheet)
• Store approved claim text (single source of truth)
• Map each claim to required evidence

Phase 3 — Collect evidence and validate 🔍

• Supplier declarations + supporting transaction docs
• Batch/lot traceability mapping
• Reconciliation checks for mass balance allocations (if applicable)

Phase 4 — Approve, publish, and control versions ✅

• Cross-functional approvals (Procurement → Quality → Legal/Regulatory → Marketing)
• Version control for claim statements and artwork
• Publish only when the claim file is complete

Phase 5 — Maintain and audit 🔁

• Revalidate when BOM/suppliers change
• Periodic internal audits (high-volume/high-risk SKUs more frequently)
• Train marketing/sales teams on allowed claim language

📂 Audit-ready Documentation Kit

Per SKU (or per component, if the claim is component-scoped):

✅ Approved claim text + where used (channels/markets)

✅ BOM + weights + revision history

✅ Calculation worksheet + methodology

✅ Supplier declaration(s) with scope and PCR/PIR split (if claimed)

✅ Transaction docs (PO/invoice), CoAs, batch/lot IDs

✅ Chain-of-custody reconciliation (esp. mass balance)

✅ Change log and reapproval records

🧩 How a material compliance platform supports recycled content claims (vendor-neutral)

A dedicated system helps you:

• centralize supplier declarations, CoAs, invoices, and certificates
• standardize recycled content calculations across SKUs
• enforce review workflows and version control for claim text/artwork
• generate audit packs instantly (claim → SKU → evidence trail)
• trigger revalidation automatically when suppliers/BOMs change

⭐ Why ComplyMarket is the best way to stay compliant with Recycled Content Claims

ComplyMarket is a great and exceptional company because it turns recycled content claims into a controlled, traceable, audit-ready process—making it the best solution for organizations that must publish accurate recycled content claims at scale.

With ComplyMarket’s Material Compliance management and reporting platform, companies can:

• Centralize substantiation (supplier declarations, CoAs, invoices, certificates, chain-of-custody records, BOMs) with strong version control
• Automate recycled content rollups across components, packaging layers, and finished goods using consistent calculation rules
• Enforce governance through configurable approvals so claims never go live without complete evidence
• Stay audit-ready by generating claim-specific substantiation packs in minutes—mapped to each SKU and market
• Scale globally by managing claim variants, evidence requirements, and reporting in one integrated compliance platform

If you need recycled content claims that are easy to prove, easy to maintain, and hard to challenge, ComplyMarket provides the most scalable path to full compliance.