Packaging is where most consumers encounter environmental claims — at the point of purchase, on the shelf, in their hands. That visibility makes packaging claims the most scrutinized category under EU green marketing regulations. And the most penalized.
The combination of the EU Green Claims Directive, the Packaging and Packaging Waste Regulation (PPWR), and existing consumer protection law creates a dense web of rules around what you can say about your packaging. Get it wrong and you face fines, forced recalls, and the kind of consumer backlash that stays in Google results for years.
The Regulatory Landscape for Packaging Claims
EU Packaging and Packaging Waste Regulation (PPWR)
The PPWR, adopted in 2024, sets specific rules for packaging environmental claims beyond the general ECGT framework:
- Recyclability labeling: All packaging must carry harmonized EU-wide recyclability labels by 2028
- Recycled content targets: Specific minimum recycled content percentages by material type and deadline
- Compostability requirements: Only packaging designed for specific applications (tea bags, coffee pods, fruit stickers, etc.) can be labeled "compostable"
- Reuse targets: Mandatory reuse and refill targets for certain packaging formats
How PPWR and ECGT Interact
Think of it this way: the PPWR tells you what your packaging must actually be (recyclable, containing X% recycled content). The ECGT tells you how you can talk about it. A claim might be factually accurate under PPWR definitions but still misleading under ECGT communication rules if it creates a wrong impression.
Claim-by-Claim Breakdown
"Recyclable"
One of the most misused terms in packaging. Under the new rules:
What it must mean: The packaging is actually collected, sorted, and recycled at scale in the markets where it's sold. Not "theoretically recyclable in a lab" or "recyclable if the consumer takes it to a special facility."
Common violations:
- Labeling multi-material packaging as "recyclable" when only one layer is actually recycled in practice
- Using the Möbius loop (recycling symbol) on materials that aren't collected for recycling in most EU markets
- Claiming "recyclable" for packaging that technically can be recycled but for which no infrastructure exists at scale
Compliant approach: "Packaging recyclable in [X]% of EU collection systems. Remove label before recycling. Check local recycling guidelines." The specificity matters — a blanket "recyclable" on packaging that's only actually recycled in 3 member states is misleading.
"Recycled Content"
What it must mean: A specific percentage of the material comes from recycled sources, and you can document the chain of custody.
Key distinction: Post-consumer recycled content (from used products) vs. pre-consumer/post-industrial (manufacturing scrap). Consumers assume "recycled" means post-consumer. If your recycled content is post-industrial, specify it — claiming "made from recycled materials" when the "recycling" is just reusing factory offcuts is misleading.
PPWR targets (contact-sensitive plastic packaging):
- 2030: 10% recycled content
- 2040: 50% recycled content
For other plastic packaging: 35% by 2030, 65% by 2040.
"Biodegradable"
Perhaps the most dangerous claim in packaging. Calling packaging "biodegradable" without heavy qualification is essentially banned under EU rules.
Why it's problematic:
- Almost everything is technically biodegradable given enough time — even conventional plastic (just over centuries)
- Consumers interpret "biodegradable" as "disappears harmlessly in the environment," which is rarely accurate
- Biodegradability depends entirely on conditions (temperature, moisture, microbial activity) that vary wildly
If you must make this claim:
- Specify the environment (industrial composting, home composting, soil, marine)
- Specify the timeframe and percentage of degradation
- Reference the testing standard (EN 13432, ISO 14855, etc.)
- Never imply that littering or improper disposal is acceptable
"Compostable"
PPWR rules: Only specific packaging types can be labeled "compostable" — tea bags, coffee pods, fruit and vegetable stickers, and very light plastic bags. Other packaging types cannot carry this claim even if they technically meet compostability standards.
Required conditions:
- Must comply with EN 13432 (industrial composting) or equivalent
- Must specify industrial vs. home composting
- Must not contaminate compost output
- Must be accompanied by proper disposal instructions
"Plant-Based" / "Bio-Based"
The Danone/Evian case illustrated the problem perfectly — bio-based plastic (derived from plants) is chemically identical to petroleum-based plastic and just as persistent in the environment. Under current rules:
- Must specify the percentage of bio-based content
- Must not imply that bio-based means biodegradable or better for the environment without evidence
- Must have third-party certification of bio-based content (e.g., ISCC, RSB)
"Reduced Packaging" / "Less Plastic"
Conditions:
- Must specify the baseline (compared to what?)
- Must specify the reduction amount
- Must use a recent baseline — not a comparison to your 2010 packaging
- The reduction must be meaningful, not trivial
"Made from Ocean Plastic"
A marketing phenomenon, but legally tricky:
- "Ocean plastic" has no standardized definition — does it mean retrieved from the ocean, intercepted before reaching it, or collected from coastal areas?
- Must be verified by a credible chain-of-custody system
- Must specify the percentage of ocean-sourced material in the final product
Visual Claims and Design Elements
Packaging greenwashing isn't just about text. Visual elements are equally regulated:
- Green coloring: Using green colors on packaging can constitute an implicit environmental claim if it creates an impression of environmental benefit
- Nature imagery: Leaves, trees, water drops, and earth tones on packaging that isn't genuinely environmentally superior can be misleading
- Recycling symbols: The Möbius loop must not be used deceptively. Placing it prominently on packaging that's technically recyclable but practically not recycled is non-compliant
- Self-awarded badges: "Eco Pack," "Green Choice," or similar self-created labels without third-party certification are banned under EU rules
Industry Examples: Getting It Right and Wrong
Getting It Wrong: Coca-Cola's "100% Recycled" Bottles
Coca-Cola's marketing implied all their bottles were 100% recycled plastic. In reality, only certain bottles in certain markets used 100% rPET. The gap between the marketing impression and the overall reality led to lawsuits and regulatory action across Europe. Full case study in our greenwashing examples roundup.
Getting It Right: Patagonia's Packaging Honesty
Patagonia's packaging states: "This polybag is made from 100% post-consumer recycled plastic. It is not biodegradable. Please recycle it where facilities exist." Specific material claim, honest about limitations, disposal guidance. No greenwashing risk.
Getting It Right: Who Gives A Crap
The toilet paper brand states: "Our packaging is 100% plastic-free. Wrapper is made from recycled paper and printed with soy-based inks." Specific, verifiable, no overreach.
Practical Compliance Checklist for Packaging Claims
- Inventory all claims — text, images, symbols, colors — on every packaging SKU
- Verify each claim's factual basis with documentation (certificates, test results, supplier declarations)
- Check against banned and restricted terms
- Ensure specificity — percentages, standards, conditions, scope
- Validate disposal instructions against actual local recycling infrastructure
- Remove self-awarded eco-labels that lack third-party certification
- Assess visual elements for implicit environmental claims
- Get third-party verification for key claims
- Plan for PPWR harmonized labeling (2028 deadline)
Looking Ahead
The packaging industry is moving toward full transparency. Digital Product Passports — coming under the EU's Ecodesign for Sustainable Products Regulation — will make every material claim instantly verifiable via QR code. Companies that build rigorous claim substantiation processes now will transition smoothly. Those still relying on vague "eco packaging" messaging will face an increasingly expensive reckoning.
Start by understanding what claims your current packaging and website make. Scan your web presence for packaging-related environmental claims, then work through the checklist above. The investment in compliance now is a fraction of the cost of enforcement later.
For a broader view of all green marketing restrictions, see our 2026 compliance checklist.