Ask for evidence that matches the exact claim. A defensible supplier file identifies the product or component, recycled content as a percentage by mass, the pre-consumer and post-consumer feedstock, the production site and period, and whether the percentage is physically present or attributed through a chain-of-custody system. Then verify the calculation, records, custody model, certificate scope and any EPD against the same product and claim.
Use this opening checklist before accepting a statement such as “circular,” “made with recycled materials” or “contains recycled content”:
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- Save the precise wording, product name or SKU, manufacturing site, publication date and document location.
- Ask for the denominator: whole product or component, percentage by mass, batch or attributed volume, production period and geography.
- Separate pre-consumer from post-consumer material and ask whether same-process rework or scrap was excluded.
- Identify physical segregation, controlled blending, mass balance or book-and-claim custody.
- Request composition and provenance records, calculations, reconciliation, transfer records and independent verification.
- Check every certificate and EPD for product, site, scope, dates, standard, model and limitations.
- Turn “circular” into a measurable attribute such as recycled input, reuse, recyclability, take-back or a defined loop rate.
What a verifiable claim looks like
A useful claim is narrow enough to test. It states what product or component is covered, the recycled percentage by mass, the type of recovered feedstock and the period or volume to which the number applies. It also says whether the material is physically in the supplied item or whether an accounting system attributes the environmental characteristic to that item.
The Federal Trade Commission (FTC) Green Guides summary says a partial recycled-content claim should be qualified with a specific percentage, using “Made from 30% recycled material” as an illustration. FTC guidance limits recycled-content claims to material recovered or diverted from the waste stream during manufacturing or after consumer use. Used, reconditioned and remanufactured components need clear qualification rather than an unqualified recycled-content impression.
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ISO 14021:2026 defines recycled content as the proportion by mass of recycled material in, or attributed to, a product or component. Its cited definition of recycled material covers reprocessed pre-consumer and post-consumer material incorporated into a product. Material recovered within the same process is excluded from the definition of pre-consumer material used in that standard, so a supplier’s treatment of internal regrind or in-process scrap must be checked rather than assumed.
Claims that need different questions
| Claim or document | What it can establish | What it does not establish by itself |
|---|---|---|
| Recycled-content percentage | A quantified amount of recycled material under a stated denominator, feedstock definition and accounting method. | Lower whole-life environmental impact, or physical recycled material in every unit when the percentage is attributed. |
| Environmental Product Declaration (EPD) | Life-cycle information calculated under stated product-category rules, declared unit, boundary and verification procedures. | Automatic proof of every marketing statement or a guaranteed physical percentage in an individual item. |
| Certification or seal | Conformity for the products, sites, percentages and custody model listed in the certificate’s scope. | Substantiation of all express or implied claims on a supplier’s website. |
| “Circular” statement | Only the specific attribute and boundary that the supplier defines and measures. | A universal performance level. Circularity might refer to reuse, recycled input, recyclability, take-back or another metric. |
Step 1: Capture the claim exactly
Save a dated copy or screenshot of the statement, including qualifiers, footnotes and the product configuration. Record the product name or SKU, manufacturing site, supplier contact and the document or page where the claim appears. A phrase such as “circular material” is not a measurable claim until the supplier defines the attribute, denominator, time period and geography.
Preserve the wording before asking questions. A later sales response may narrow the claim, but your procurement record should show what a specifier or owner was originally invited to believe. FTC guidance cautions against broad, unqualified environmental claims and requires meaningful qualification for partial recycled content.
Step 2: Define denominator, scope and period
Ask for the percentage by mass and make the denominator explicit. It may be the complete product, a named layer or component, a batch, or an attributed volume over a specified accounting period. These are not interchangeable. A 30% recycled component is not a 30% recycled product, and a monthly attributed volume is not proof that every shipment contains that percentage physically.
Request the product version, formulation or configuration, manufacturing site, relevant production period, geographic market and calculation boundary. Ask whether packaging, coatings, moisture, additives or ancillary parts are included. Require the supplier to identify exclusions and explain how conversion factors and yields were applied.
Minimum scope statement
- Product, component and configuration covered.
- Percentage and unit, normally mass percentage.
- Numerator: eligible recycled material included or attributed.
- Denominator: product or component mass and all exclusions.
- Production site, geography and claim period.
- Whether the result applies to a batch, annual volume or individual units.
Step 3: Check feedstock definitions
Separate pre-consumer and post-consumer inputs. Ask what was recovered, from which waste stream, how it was collected and how it was reprocessed before incorporation. “Recovered,” “recycled,” “scrap,” “rework” and “waste diverted” can have different meanings under a standard or certification scheme.
Ask specifically whether in-process regrind, trim, off-cuts or rejected material returned to the same manufacturing process is counted. ISO 14021:2026 distinguishes recycled material from recovered material and excludes same-process recovered material from its cited pre-consumer definition. The supplier should show the rule it applied and the records supporting the classification.
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- Supplier declarations identifying pre-consumer and post-consumer quantities.
- Invoices, weigh tickets, purchase records and material-provenance documents.
- Processing or recycling certificates describing the input and output streams.
- Bill of materials or composition records, with confidential details redacted or reviewed by an independent verifier.
- Rules for contaminated loads, moisture, rejects, rework and yield losses.
Step 4: Identify the chain-of-custody model
Chain of custody determines what a buyer may infer from an attributed percentage. Require the supplier to name the model in the claim and describe its system boundary.
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Physical segregation
Eligible material is kept separate from conventional material through specified stages. Ask where segregation starts and ends, how identity is maintained, and how mixed or contaminated loads are handled. A segregation claim still needs product, site and period records.
Controlled blending or mass balance
Mass balance permits eligible and conventional inputs to mix within a defined system while an accounting system tracks quantities entering and leaving. Request eligible inputs and outputs, conversion factors, allocation rules, reconciliation records, accounting period and double-counting controls.
ISO 14021:2026 states that mass-balance attribution cannot guarantee recycled content in any individual product supplied. Therefore, describe an output as containing attributed recycled content unless separate evidence supports a stronger physical-content statement.
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Book-and-claim transfers an attribute administratively through instruments that are issued, transferred and retired. Ask who issues and retires the instruments, the covered geography and period, the volume represented, and how duplicate claims are prevented. An administrative attribution is not evidence that the same physical material is present in the delivered item.
ISO 22095:2020 provides general chain-of-custody terminology and models, but ISO says the framework alone is not sufficient to make or verify a materials claim. On 20 March 2026, ISO announced ISO 22095-2 for mass balance and ISO 22095-3 for book-and-claim. Check which edition and model a certificate or contract actually uses.
Step 5: Build an evidence file
Request a package that lets a reviewer reproduce the claim without exposing unnecessary confidential formulation details. UK government guidance recommends retaining product-composition, testing and provenance records, maintaining systems for verifying environmental claims and updating them when raw materials change. Where composition is confidential, an independent verifier’s review can provide assurance without disclosing the formula to every buyer.
- Supplier declaration: exact wording, product and component scope, percentage, measurement basis and claim period.
- Composition records: bill of materials, formulation or mass breakdown, with a controlled redaction process where needed.
- Provenance records: purchase records, supplier certificates, invoices, weigh tickets and recovery or processing documentation.
- Calculation workbook: denominator, exclusions, conversion factors, yields, scrap treatment, allocation rules and reconciliation.
- Custody records: procedures, model, system boundary, transfer or retirement records and double-counting controls.
- Assurance report: verifier, standard, products and sites covered, dates, sampling or testing approach and limitations.
- Change control: approval and re-verification steps for changes in feedstock, formulation, supplier, site or accounting method.
If a supplier withholds a confidential bill of materials, document exactly what an independent verifier reviewed, the verifier’s scope and any limitation on your own review. Incomplete disclosure is a reason to qualify the procurement record; it is not, by itself, proof that the claim is false.
Step 6: Inspect certifications and seals
Do not treat a logo as a universal environmental endorsement. Record the standard and version, certificate holder, facility, covered product range, feedstock category, percentage, chain-of-custody model, effective and expiry dates, verifier and any exclusions. Match the public certificate or directory entry to the product and site offered in the project.
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SCS-103 allows physical segregation or mass-balance chain of custody and requires the model used to be specified in the claim. FTC guidance says third-party certification does not relieve a marketer of substantiating express and implied claims. A certificate may verify one product line or site while a website makes broader statements about an entire company.
Where supplier documentation is insufficient, independent recycled-content certification or claim validation can be an optional assurance route. Services associated with SCS-103 or UL 2809 should be assessed by their current product and site scope, custody model, evidence requirements and certificate status rather than by the logo alone.
Step 7: Read an EPD for its intended purpose
An EPD is a life-cycle declaration under stated rules, not an automatic recycled-content certificate. Check the exact product and declared unit, product-category rules (PCR), program operator, applicable standards, life-cycle modules, geography, publication and validity dates, and third-party verification statement.
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The USGBC guide describes, for the cited LEED credit, an EPD scope of at least cradle-to-gate aligned with ISO 14025, ISO 14040, ISO 14044 and EN 15804 or ISO 21930. Those are credit-specific guide statements; confirm current project and program rules before relying on them. The guide also describes third-party verification of the life-cycle assessment process and EPD conformity to the PCR.
Read the declaration’s recycled-content information and allocation method alongside the custody evidence. An EPD can support comparable life-cycle analysis when products use compatible rules and boundaries, but it does not audit every supplier web claim or guarantee physical recycled content in each item.
Step 8: Turn “circular” into a testable claim
Ask the supplier to replace “circular” with one or more defined attributes:
- Recycled input: percentage by mass, feedstock category and custody model.
- Reuse: what component is reused, how many cycles are measured and what condition is required.
- Recyclability: available collection, processing and end-use route in the project geography.
- Take-back: eligible products, collection responsibility, transport, destination and operating period.
- Loop or recovery rate: numerator, denominator, timeframe, geography and verification.
ISO 14021:2026 defines recyclability by reference to available processes and programs that collect, process and return material to use. Ask for the collection infrastructure and end market, not merely a material name. A product may be technically processable yet not recyclable in the project location if no collection or processing route is available.
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Step 9: Compare suppliers on like-for-like terms
Put competing claims into the same comparison sheet. A larger percentage is not automatically the stronger claim if its denominator, feedstock definition, custody model or assurance level differs.
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| Comparison axis | Align these items |
|---|---|
| Product scope | Product, component, configuration and manufacturing site. |
| Percentage and basis | Mass percentage, denominator, exclusions and claim period. |
| Feedstock | Pre-consumer and post-consumer definitions and proportions. |
| Chain of custody | Segregation, mass balance or book-and-claim, including boundaries and attribution rules. |
| Assurance | Equivalent independent review, certification scope, verifier and validity. |
| EPD comparability | Declared or functional unit, PCR, life-cycle modules, geography and standards. |
| Circularity | Same attribute, collection or end-of-life route, geography and measurement method. |
Do not infer that recycled content alone lowers total environmental impact. FTC guidance notes that a recycled-content claim can be deceptive if environmental costs outweigh benefits. A life-cycle comparison requires matched scopes, compatible units and defensible impact data, not a recycled percentage in isolation.
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United States: marketing claims
The FTC Green Guides summary calls for a specific percentage for partial recycled content and limits the claim to material recovered or diverted from the waste stream during manufacturing or after consumer use. It also says certification does not substantiate every express or implied claim. Apply the qualification to the exact product and custody model being marketed.
United States: federal procurement
EPA’s Comprehensive Procurement Guideline lists recovered-content recommendations for categories including building insulation, carpet and carpet cushion, cement and concrete, latex paint, floor tiles, flowable fill, nonpressure pipe, patio blocks, roofing materials and structural fiberboard. Check the current recommendation and procurement requirement for the specific purchase; a supplier’s marketing percentage is not a substitute for the applicable contract rule.
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ISO 14021:2026 is the current edition shown in the official ISO text used for these definitions. ISO 22095:2020 supplies general custody terminology, while the 2026 mass-balance and book-and-claim parts add model-specific guidance. Record the edition named by the supplier and avoid treating a general custody framework as product verification.
European Union construction products
A European Commission Joint Research Centre study published in March 2026 describes the revised Construction Products Regulation (EU) 2024/3110 as linking environmental information to applicable harmonised standards or common specifications. The study says the regulation does not create one uniform minimum recycled-content threshold for every construction product. For a live procurement, identify the applicable product specification and current law rather than assuming a single EU percentage.
United Kingdom supply chains
UK government guidance recommends records for composition, testing and provenance, verification systems for environmental claims and updates when raw materials change. It notes that from April 2025 the previous consumer-protection legislation was replaced by the Digital Markets, Competition and Consumers Act 2024, while the guidance continues to apply in substance.
Failure modes and corrective actions
“Circular” is left undefined
Problem: The statement has no attribute, denominator or boundary. Action: require a defined claim for recycled input, reuse, recyclability, take-back or a measured loop rate before scoring it.
Attributed content is presented as physical content
Problem: A mass-balance or book-and-claim percentage is described as present in every delivered unit. Action: label it attributed, obtain the system accounting and controls, and reserve a physical-content statement for separately supported evidence.
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Internal scrap is counted automatically
Problem: Same-process rework or regrind is counted as pre-consumer recycled material without checking the governing definition. Action: identify the source and treatment of the scrap and apply ISO 14021:2026 or the named certification rule.
An EPD is used as a universal certificate
Problem: The EPD is cited as proof of every environmental claim. Action: check PCR, declared unit, modules, geography, validity and verification, then obtain separate recycled-content evidence.
A logo is accepted without scope review
Problem: The certificate covers a different site, product or period. Action: match certificate holder, facility, product, percentage, custody model, verifier and dates to the offered material.
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Problem: One supplier reports a component percentage and another reports whole-product mass. Action: normalize the denominator and exclusions or mark the comparison as non-equivalent.
Evidence is not updated after a change
Problem: Feedstock, supplier, formulation, site or accounting method changes while the old claim remains published. Action: require change control, re-calculation and re-verification before the claim continues.
A procurement decision rule
Accept a claim as comparable only when its product scope, mass basis, feedstock definitions, custody model, period, accounting controls and assurance level are documented. If one element is missing, record the missing evidence and limit the specification or score accordingly. If the supplier supplies only a broad label, do not convert it into a percentage or imply a physical attribute that the records do not support.
Keep EPD review separate from recycled-content verification. An EPD verifier assesses the declaration, PCR and life-cycle assessment within the applicable program; that work does not necessarily audit every product-level recycled-content statement. Conversely, a recycled-content certificate does not provide a complete life-cycle comparison.
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