Making Sense of On-Pack Recycling Labelling

The claims brands make on packaging is under scrutiny. A recent review of consumer-facing websites across a number of sectors found that over 50% were making unsubstantiated claims about their green credentials.

For this reason, your communication team must have complete knowledge of current and upcoming regulatory requirements before designing your on-pack labelling.

There is a clear cross over between regulations that protect the consumer from ‘greenwashing’ and policy related to on-pack recycling labelling.

There are five types of on-pack sustainability requirements:

• Mandatory or voluntary recycling labelling
• Info to signify compliance to a local EPR scheme (i.e. der Grune Punkt)
• Brand copy to outline packaging or recycling priorities
• Broader brand sustainability copy
• Category or pack specific claims

Within the EU, countries are at liberty to interpret many European initiatives related to recycling and sustainability at a local level. They can decide what works best for their citizens, society and infrastructure.

Products are sold across multiple countries in many instances, with different labelling requirements. Space is usually at a premium on packaging, especially for products that target multiple markets or packaging with limited space. So, a plethora of country-specific information crowding a pack is impractical.

It can also be potentially damaging from a brand image perspective as consumers may be put off by brands they perceive as ‘less local’ than they thought they were buying into.

Some countries’ policies prohibit the use of self-regulated eco-labels, and recycling labelling can come under this umbrella.

Some recycling labelling schemes are voluntary, such as the US How2Recycle and the UK’s OPRL scheme, but some are punitive, for example:

In Italy

In 2021 Italy brought in some of the toughest regulations in the world to drive better packaging recycling labelling. They now have in place strict rules about how you need to label your packaging that includes:

• Identifying the component type (i.e bottle / box / jar)
• The European standard material code (amber glass = 72 GL)
• The material stream name that the item needs to be placed (i.e. paper)
• Instructions to check local recycling

In France

Since 2021 in France, displaying the Triman logo on recyclable household packaging has been compulsory.

In the UK

Displaying an on-pack recycling labelling will become mandatory in 2026. Far enough away to give all brands plenty of time to develop a new labelling solution and get it to market.

Many brands find it difficult to know where to start when it comes to on-pack labelling. Without advice from an expert such as Root, it can be confusing, with many requirements appearing to conflict with one another.

For instance, technically, anything is recyclable.  But green claims policies state that you can no longer just ‘depict technical potential’. Instead, your claims should be based on likelihood of recycling.

You must ensure consumers are not fooled into thinking that their pack actually gets recycled because the likelihood of this happening is minimal. So rather than basing your claims on theory, you need to base your claims on probability.

It is a minefield and one that our team of sustainability consultants are well-placed to help you navigate. Here’s an example of a project we completed for a global FMCG brand.