Verify the two claims separately. For recycled content, establish exactly what the percentage covers, whether the material is pre-consumer or post-consumer, how it was calculated, and whether it describes physical content or a mass-balance attribution. For carbon, obtain the product’s Environmental Product Declaration (EPD), then check its declared unit, life-cycle modules, product and plant scope, Product Category Rules (PCR), dates, data, and independent verification. A high recycled-content percentage does not by itself prove lower embodied carbon, and an EPD is a quantified disclosure—not a sustainability seal.
What you are actually verifying
Building-product marketing often puts recycled content and carbon performance beside each other, but they answer different questions.
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- Recycled content: How much of the material, a specified component, or the packaging comes from recovered material, and under what accounting method?
- Embodied carbon: What greenhouse-gas emissions are associated with extracting inputs, transporting them, and manufacturing the product, within the life-cycle boundary reported?
A defensible specification records evidence for both axes. Do not accept a recycled-content logo as a substitute for a percentage, and do not treat the existence of an EPD as proof that a product is “low carbon.”
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Step 1: Define the scope of the recycled-content claim
Identify the item covered
Start by asking whether the claim applies to the complete product, only a component, or the package. Federal Trade Commission (FTC) consumer guidance says buyers should determine whether an environmental claim concerns the product, its packaging, or both. A percentage printed on a carton may describe the carton rather than the installed material.
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Ask the supplier to name the product model, size, formulation, and manufacturing location covered by the claim. If only a component is recycled, the documentation should identify that component and explain how its share relates to the finished product.
Require an amount for a partial claim
Claims below 100% should state the amount and the basis. The FTC Green Guides summary uses “Made from 30% recycled material” as an example of a qualified claim. A statement such as “contains recycled materials” is not enough to determine whether the percentage is 2%, 30%, or 90%.
Record the percentage exactly as stated, including whether it is by mass, by volume, or another basis. A mass percentage is not interchangeable with a volume percentage, and a component percentage is not the same as the percentage of the whole product.
Ask what “recycled” means in the claim
The FTC describes recycled content as material recovered or diverted from the waste stream during manufacturing or after consumer use. Request the supplier’s definitions and calculation document rather than assuming that every internal scrap stream qualifies.
Step 2: Separate pre-consumer and post-consumer content
Pre-consumer material
EPA’s construction-material criteria define pre-consumer material as material diverted during manufacturing, excluding in-process rework, regrind, or scrap that can be reclaimed in the same process. Ask for the pre-consumer percentage separately and request a description of the source stream.
Post-consumer material
Post-consumer material comes from end users after it can no longer serve its intended purpose. EPA’s criteria include returns from the distribution chain in this definition. Ask what collection stream supplied the material, when it was collected, and how the supplier determined that it had reached the end of its intended use.
Why the split matters
A single “recycled content” number can conceal very different inputs. Two products could both claim 30% recycled content while one uses 30% pre-consumer process material and the other uses 20% post-consumer material plus 10% pre-consumer material. Put both figures in the project record instead of relying on the combined total.
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Step 3: Examine the calculation and allocation
Request the mass basis and data period
Ask whether the percentage is calculated from the mass of the finished product, the relevant component, or the total material input. Request the source records and period used: purchasing records, supplier declarations, batch records, production summaries, or chain-of-custody statements. A percentage calculated from an annual production average may not describe every batch or shipment.
Understand physical content versus attributed content
ISO terminology allows material to be “in, or attributed to,” a product. Under a mass-balance system, recycled feedstock enters a defined production system and an accounting method allocates an equivalent claim to products leaving that system. The allocation can be valid under the applicable scheme without guaranteeing that an individual delivered unit physically contains the stated share.
Ask the supplier to identify which situation applies:
- Physical-content claim: the specified product or component contains the reported recovered material under the stated calculation.
- Attributed or mass-balance claim: recycled input is accounted for across a production system and allocated to products under a chain-of-custody method.
If the claim is attributed, ask for the chain-of-custody standard, allocation rule, accounting period, and certificate or audit scope. Describe the result to the project team as an attributed share, not as a guarantee about the molecular or physical content of each unit.
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Check the unit of sale against the evidence
For a project purchase, compare the claim’s declared product and manufacturing site with the item on the quotation, submittal, and delivery ticket. A corporate average or a different plant may not support the specific product being installed.
Step 4: Treat certification marks as evidence pointers, not proof
A certification mark can identify a scheme, but a logo alone does not establish what was certified. Request:
- the name and version of the standard or protocol;
- the exact product, component, or facility in the certificate’s scope;
- the claim the certificate permits the supplier to make;
- the certification body or auditor;
- the verification date and expiration or renewal status; and
- any restrictions on percentage, geography, or chain-of-custody method.
FTC guidance requires environmental marketing claims to be truthful and substantiated. Your file should contain the underlying certificate or verification statement, not just a screenshot of a mark.
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Step 5: Obtain and read the product’s EPD
What an EPD does—and does not—say
An EPD is a quantified environmental declaration prepared under predetermined parameters. It reports impacts for a defined product and life-cycle scope. It does not, by its existence, certify that the product is sustainable, low carbon, or preferable to every alternative.
EPA defines embodied carbon as greenhouse-gas emissions associated with product extraction, transport, and manufacturing stages. An EPD may cover those stages and additional life-cycle modules, so read the boundary rather than assuming that every declaration measures the same impacts.
Record the product and manufacturing scope
On the first page and in the results tables, record:
- the exact product name, type, grade, and configuration;
- the plant or plants included, including manufacturing geography;
- whether the declaration covers one facility, a representative group, or an industry average;
- the declared or functional unit; and
- the life-cycle modules included.
A product-family EPD may cover several formulations or plants. Confirm that the specified item falls within the stated range and that the applicable plant is represented.
Check the PCR and its version
The PCR supplies product-category-specific rules for preparing the declaration. Record the PCR title, edition, publication date, and referenced standards. EPA’s Version 1—2024 construction-material criteria state that, from January 1, 2026, PCRs under that program are to conform with ISO/TS 14027:2017. That date requirement does not mean every product in every program uses the same PCR; confirm the rule applicable to the material category and EPD program.
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Record the EPD publication date, validity end date, version or revision number, program operator, and named independent verifier. If a revised EPD exists, use the current version and preserve the version that supported the procurement decision. Confirm that verification covered the stated product and manufacturing scope, not merely the manufacturer’s management system.
Step 6: Interpret the carbon result correctly
Capture GWP with its unit and modules
Write down the reported global-warming-potential (GWP) value exactly as shown, including units such as kilograms of carbon-dioxide equivalent per declared unit. Also record whether the value covers modules such as product-stage extraction and manufacturing, transport, installation, use, end of life, or a combined total. A number without its unit and modules cannot support a fair comparison.
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Do not rank unlike EPDs
Compare carbon results only when the products and declarations are materially comparable:
- the same or aligned product category and PCR;
- equivalent function and declared or functional unit;
- comparable life-cycle boundaries and modules;
- disclosed manufacturing geography;
- similar data periods or clearly explained data-vintage differences; and
- consistent treatment of recycled inputs, energy, transport, and end-of-life assumptions.
If one EPD reports kilograms of CO2e per tonne for an “average product” and another reports kilograms per square metre for a specific thickness, convert only when the physical performance and conversion assumptions are documented. Otherwise, present the results as not directly comparable and explain why.
Use the functional result for the installed application
For specification decisions, the relevant question may be emissions per square metre of wall, per metre of pipe, or per service life—not simply emissions per kilogram of raw material. Use the EPD’s declared or functional unit and verify that it represents the performance required by the design. Do not create a functional comparison by guessing density, coverage, durability, or replacement frequency.
Step 7: Investigate renewable-electricity and other adjustments
Manufacturers sometimes attribute lower emissions to renewable electricity. If that explanation is part of the carbon claim, ask how the electricity accounting was performed and what evidence supports it.
EPA’s criteria say an EPD verifier should check that energy attribute certificates (EACs) supporting a specific-generation claim are owned by the manufacturer and have not been sold or transferred after the claim. The criteria also describe review by an impartial third party. Request the relevant accounting statement, EAC ownership evidence, and verification scope. Do not assume that every EPD makes a renewable-electricity claim or that a renewable-power purchase changes every life-cycle module.
Apply the same discipline to other adjustments, such as supplier-specific emission factors, offsets, carbon capture, recycled-feedstock credits, or estimated transport distances. Identify where the adjustment appears in the life-cycle model and whether the verifier reviewed it.
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Keep the two evidence tracks separate
| Recycled-content evidence | Carbon evidence |
|---|---|
| Scope: product, component, or packaging | Product and manufacturing scope in the EPD |
| Total percentage and mass or other basis | GWP value and its unit |
| Pre-consumer and post-consumer percentages | Declared or functional unit and life-cycle modules |
| Physical content or attributed content | PCR title, edition, and reporting rules |
| Allocation method and supporting records | Plant, geography, data period, EPD date, and verifier |
EPA’s criteria call for separate recycled-content disclosure and an explanation of allocation in EPDs. The relationship between recycled content and embodied-carbon emissions depends on material type, mass, and regionality. More recycled material can reduce some extraction impacts, but processing energy, transport, additives, yield, and allocation can change the result. Evaluate the two columns independently.
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A supplier-document request you can send
Use the following request for a submittal or prequalification package. It is an evidence checklist derived from FTC substantiation guidance and EPA disclosure and verification criteria, not a universal legal checklist for every product.
- State the exact environmental claim and whether it covers the product, a component, or packaging.
- Provide the product- and plant-relevant EPD, including its current version, publication date, validity date, and program operator.
- Name the applicable PCR, edition, referenced standards, and product category.
- Report pre-consumer and post-consumer recycled-content percentages separately, with the mass basis and data period.
- Explain whether the claim represents physical content or attributed content, and provide the chain-of-custody and allocation method.
- Identify the verifier, verification scope, and certificate or statement supporting the claim.
- Provide the carbon result, unit, life-cycle modules, manufacturing geography, and underlying data period.
- If renewable electricity or another emissions adjustment is claimed, provide the accounting method, ownership evidence where applicable, and impartial-verification record.
How to evaluate the package when documents conflict
The marketing page gives a percentage, but the EPD does not
Ask for the recycled-content calculation and determine whether the EPD intentionally omits that disclosure. Do not infer a percentage from an EPD’s generic narrative or from a logo.
The certificate covers a company, but not your plant
Request a certificate or verification statement that names the relevant facility or explains the approved multi-site scope. A corporate certificate may not substantiate a plant-specific product claim.
The EPD is valid, but the PCR is obsolete for your program
Ask the program operator or manufacturer which PCR governs the current declaration and whether a revised EPD is required for your procurement rule. Keep the applicable program’s date and conformance requirements in the project record.
The two carbon values look dramatically different
First compare units, product function, thickness or strength, plant geography, modules, PCR, data vintage, and treatment of recycled inputs. A numerical gap is not a performance ranking until those conditions align.
The supplier will not disclose the allocation method
Record the recycled-content claim as unverified for the intended use and ask whether a physical-content product or independently documented chain-of-custody claim is available. Do not convert an undisclosed method into a definite physical percentage.
Project-file checklist before approval
- The claim’s scope is named and matches the specified item.
- The percentage and calculation basis are explicit.
- Pre-consumer and post-consumer shares are separately reported.
- Any mass-balance attribution and allocation method are explained.
- The certificate or verification covers the relevant product and plant.
- The EPD identifies product, plant, declared or functional unit, modules, PCR, dates, and verifier.
- GWP is recorded with its unit, modules, and EPD version.
- Any comparison uses compatible products, functions, boundaries, and reporting rules.
- Renewable-electricity or other adjustments have supporting accounting and verification evidence.
- Unresolved differences are documented rather than hidden in a single “green” score.
US scope and date notes
This method is centered on US FTC marketing guidance and EPA construction-material criteria. EPA’s cited criteria are Version 1—2024 and include the January 1, 2026 PCR-conformance note described above. The ISO official online entry surfaced for this topic is ISO 14021:2026. A project in another jurisdiction, a public procurement program, or a particular material category may impose different legal, PCR, labeling, or verification requirements. Always check the live EPD and the rule governing the actual specification.
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