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BETTESWORTHConstruction
chain of custody

How to Verify Recycled-Content Claims in Plastic Packaging

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Verify a recycled-content claim by matching five things: the exact package component covered, the stated percentage and denominator, the origin and processing of the recycled material, records linking inputs to the finished packaging, and the accounting model used. A certificate can support that review, but it does not prove every express or implied claim on its own.

For construction buyers, this means checking packaging claims before accepting them in procurement records, environmental declarations, project submittals or sustainability reports. The steps below provide a defensible file for each claim without assuming that a green symbol or a percentage applies to the whole package.

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Start by defining exactly what the claim covers

Packaging can contain several separate items: a film wrap, bag, bottle, tray, label, cap, liner or a multilayer barrier. A statement such as “30% recycled plastic” may refer to one of those components rather than the complete package. The first verification task is therefore to identify the object named or implied by the claim.

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The U.S. Federal Trade Commission (FTC) advises consumers to check whether an environmental statement concerns the product or its packaging and how much of the relevant item is recycled. Read the wording, symbols, images and nearby qualifications together; the overall presentation can communicate a broader message than the sentence alone. See the FTC’s Eco-Friendly and Green Marketing Claims guidance (May 2021).

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  • Object: Record whether the claim concerns the product, the complete package, a named component, a plastic layer or a closure.
  • Material: Identify the polymer or material covered, such as a specified plastic resin, rather than treating “plastic” as a single uniform category.
  • Percentage: Capture the number, the denominator and whether the figure is by mass or another basis.
  • Qualification: Note words such as “up to,” “made with,” “contains,” “on average,” “attributed” or “mass balance.”
  • Location and date: Photograph the package or save the artwork, and record where and when the claim was seen.

Do not convert a component percentage into a package-wide percentage. If a cap is claimed to contain recycled material, that evidence does not establish the content of the bottle, pouch or entire shipping unit.

A seven-step verification workflow

1. Capture the public claim exactly

Save a photograph or screenshot showing the full claim, qualifying text, logos and surrounding graphics. Copy the wording into your review record without correcting it. Include the product identifier, packaging format, supplier, market and production or purchase date when available.

This record matters because an implied claim can be challenged even when the literal words are technically narrow. The FTC’s Environmental Claims: Summary of the Green Guides explains that marketers must substantiate both express and implied environmental claims. A recycling logo, image of a circular arrow or prominent “eco” statement may alter what a reasonable purchaser understands.

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2. Fix the package boundary and denominator

Ask the supplier to identify the mass being used as the denominator. It might be the mass of one component, the mass of all plastic in a package, or the mass of the full package including non-plastic materials. Require the claim and the supporting calculation to use the same boundary.

For a partial claim, request an explicit percentage and its basis. FTC guidance calls for qualifying recycled-content claims when only part of an item is recycled. A useful record states, for example, that a named component contains a stated percentage by mass, rather than leaving the reader to infer that the complete package has the same share.

Question What to record Why it changes the conclusion
What is covered? Whole package, component, layer, closure or product A component result cannot be applied to the rest of the package.
What material is covered? Polymer, blend or specified plastic stream Different materials may have different eligible inputs and records.
What is the denominator? Component mass, plastic mass or total package mass The same numerator produces different percentages under different boundaries.
What is the basis? Mass, average over a period, batch or attributed quantity The basis determines what the number actually describes.

3. Establish what “recycled” means in the records

Request a description of the inputs, not merely a statement that they are recycled. The FTC describes qualifying recycled content as material recovered or diverted from the waste stream during manufacturing or after consumer use. ISO 14021:2026 defines recycled material as pre-consumer material, post-consumer material, or both, reprocessed from recovered material and incorporated into a product or component. The terminology and definitions are available in the ISO 14021:2026 standard text.

Ask the supplier to distinguish:

  • Pre-consumer material: material recovered from manufacturing or another process before it reaches a consumer, with the source and recovery step identified.
  • Post-consumer material: material recovered after consumer use, with the collection and preparation route described.
  • Reprocessed output: the operation that turns recovered material into an input used for the claimed packaging.
  • Incorporation: where and how that input enters the product or component covered by the claim.

Do not assume that factory scrap, production trim or a recycled feedstock automatically qualifies in every jurisdiction or under every claim wording. The claim, definitions used, and applicable law must align.

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4. Follow the chain of custody from input to package

Traceability is a connected set of records, not one declaration. Request documents that show the same material moving through the relevant suppliers, facilities and production period. RecyClass describes tracing recycled plastics through the value chain and calculating recycled-content shares in its FAQ and its Recycled Plastics Traceability Audit Scheme, version 2.3 (17 December 2024).

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A practical review file normally includes the following, subject to the supplier’s confidentiality controls:

  • Supplier declarations identifying the recycled input, its classification and the quantity supplied.
  • Purchase orders, delivery notes, transaction records or equivalent evidence connecting the input to a named supplier and date.
  • Receiving, storage and production records showing where the material entered the process.
  • Output quantities for the relevant product, package component or product family.
  • Yield and loss records, including how contaminated, rejected or otherwise unusable material is treated.
  • The calculation that converts inputs and outputs into the claimed recycled share.
  • Identification of the facilities, production lines, products and time period covered.

Check that every document covers the same material, supplier chain, facility, time period and package boundary named in the marketing claim. A delivery record for recycled resin at one site does not substantiate a claim for a different site or an unrelated package unless the allocation method connects them.

5. Identify the accounting model

Ask whether the claimed percentage represents recycled plastic physically present in each package or an amount attributed through a controlled accounting system. In a physically segregated model, eligible material is kept separate or otherwise assigned directly to the output. In a mass-balance model, specified and non-specified materials may be mixed during processing while inputs and outputs are tracked and allocated.

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ISO 14021:2026 states that content attributed through mass balance cannot be guaranteed in any individual product supplied. Therefore, an attributed percentage must be described as an allocation result; it must not be presented as proof that every package physically contains that exact percentage. The accounting model belongs in the verification record and, where necessary, in the public qualification.

ISO’s March 2026 explanation of new chain-of-custody standards describes mass-balance and book-and-claim models, including systems in which materials with and without specified characteristics are mixed. Read that context in New ISO standards bring clarity to chain of custody. The description of a model is not evidence that a particular package contains a specified amount.

6. Examine certification without treating it as a guarantee

For any certificate, record the scheme name, standard or audit protocol, certificate holder, covered sites, processes, eligible inputs, product or product-family scope, chain-of-custody boundary, issue date and expiry or validity period. Confirm that the certificate covers the packaging and production period in your claim, rather than merely the supplier’s organization in general.

RecyClass presents its traceability certification as a way to track recycled plastics through the value chain and calculate content shares. Its FAQ also states that applicants need certified recycled input or a scheme it recognizes. Those details can help you understand what a certificate is designed to address, but they do not expand its scope beyond the listed sites, materials and products.

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The FTC expressly warns that third-party certification does not remove the marketer’s duty to substantiate express or implied claims. Certification is one piece of evidence; review what was audited, what was excluded, and whether the public wording says more than the certificate supports.

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7. Compare the claim and evidence side by side

Create a comparison sheet with one row for each public statement. Mark whether the evidence matches every material element. Escalate a row when the percentage, material, component, geography, production period or accounting model differs.

Claim element Evidence to match Acceptable outcome
Percentage Calculation and denominator Same number or a clearly qualified range or average.
Material Input specification and processing records Same polymer or material boundary.
Package boundary Product drawing, bill of materials or component definition Evidence covers the named package item.
Period and location Production logs, delivery records and certificate scope Same facility and relevant production period.
Accounting model Chain-of-custody procedure and allocation calculation Public wording accurately states physical or attributed content.

How to test the percentage calculation

Do not accept a percentage without seeing its numerator, denominator and treatment of losses. A calculation should make clear whether recycled input is measured before processing, after processing, or as incorporated output. It should also state whether the figure applies to one batch, a production period, a product family or an attributed quantity.

Use a simple reconciliation approach:

  1. Write down the claimed package boundary and total mass for that boundary.
  2. Identify the eligible recycled quantity assigned to the same boundary and period.
  3. Check the process yield and losses between incoming material and finished output.
  4. Recalculate the share using the supplier’s stated formula and units.
  5. Compare the result with the rounded public claim and document any rounding rule.

For illustration only, if a component weighs 100 kilograms and the records assign 30 kilograms of eligible recycled material to that component under the stated model, the arithmetic share is 30% by mass. That example does not establish that any real package or supplier achieves that result; the records, boundary and accounting model determine whether the calculation is valid.

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When mass balance is used, verify the control period, input eligibility, allocation rules, carry-forward or carry-back provisions, and the point at which credits are retired or assigned. If those details are not available, describe the evidence limitation rather than implying physical composition.

Comparing verification approaches

Different approaches answer different questions. Select the one that matches the claim you intend to publish or accept.

Approach What it verifies Typical boundary Main limitation
Input documentation Origin and quantity of material entering a process Supplier or facility input Does not by itself prove how much reached the finished package.
Chain-of-custody review Links suppliers, process steps, outputs and allocation records Facility, product family or defined period Strength depends on complete, consistent records and the stated accounting rules.
Physical segregation Direct assignment of eligible material to specified output Batch, line or product Requires controls that prevent mixing or misidentification.
Mass-balance accounting Calculated attribution of eligible input across mixed production Defined site, product group and accounting period ISO 14021:2026 says the attributed content cannot be guaranteed in each individual product.
Certification or audit Conformity with a named scheme’s criteria and scope Listed holder, sites, materials and processes A certificate does not automatically substantiate broader express or implied marketing claims.
Final-package composition testing Potential physical characteristics of a sample Tested sample or lot The sources reviewed do not establish one universal laboratory test or a single document checklist for every polymer and claim.

Do not combine results from different boundaries as if they were interchangeable. For example, an audited resin input, a mass-balance product allocation and a laboratory result from one sample answer separate questions and need a documented relationship before supporting one public statement.

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Red flags and corrective actions

The percentage has no denominator

Problem: “Made with 40% recycled plastic” appears without saying what weighs 40% of what.

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Action: Request the component or package boundary, basis and calculation. Until clarified, narrow the wording or do not accept the claim.

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A component claim is presented as a whole-package claim

Problem: Evidence covers a cap, label or film, while artwork suggests the entire package is recycled.

Action: Require component-specific language and visual qualification, or obtain evidence covering the full package boundary.

The certificate covers the supplier but not the product

Problem: The certificate lists a site or input category but not the package, product family or relevant process.

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Action: Check the certificate scope and validity dates. Ask the certification body or supplier to identify the exact covered product and chain-of-custody boundary.

Records stop at the resin supplier

Problem: A recycled input is documented, but there is no production, yield or allocation record connecting it to the finished packaging.

Action: Request the missing process and output records. Treat the input evidence as incomplete rather than as proof of finished-package content.

Mass balance is hidden

Problem: The public statement sounds like every package physically contains the claimed share, while the records show attribution across mixed production.

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Action: Identify the model, disclose the attribution limitation and revise the claim so it does not guarantee a physical amount in every unit.

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“Up to” or average language is omitted

Problem: A maximum, range or period average is displayed as a fixed amount.

Action: Restore the qualification and state the relevant production period or calculation basis.

Applying the review to construction procurement

Construction teams often buy products whose packaging passes through several companies before delivery to a site. Assign responsibility at each handoff so that a claim does not become broader as it moves from resin supplier to converter, distributor and project documentation.

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  1. At specification: State whether the project needs a recycled-content claim for the package, a particular component or the product itself. Define the required material boundary and whether mass-balance attribution is acceptable.
  2. At submittal: Request the exact claim artwork, percentage basis, supporting calculation, chain-of-custody evidence and certificate scope before approval.
  3. At purchasing: Tie the approved evidence to the supplier, product code, package format and production period in the purchase record.
  4. At delivery: Check labels and packaging against the approved version. Photograph discrepancies and quarantine or escalate loads whose claim is materially different.
  5. At reporting: Report only the boundary and accounting model actually supported. Keep the evidence with the environmental or sustainability file so later reviewers can reproduce the decision.

If a project uses several package formats for the same product, do not assume one certificate or calculation covers all of them. Ask whether the product-family scope includes each format and whether the percentages differ.

Legal and geographic limits

The FTC materials cited here are U.S. consumer and business guidance. The Green Guides were issued in 2012, and the consumer page was published in May 2021. They explain how U.S. environmental marketing claims may be understood and substantiated; they are not a universal legal rule for every country.

ISO 14021:2026 supplies terminology and context for self-declared claims, while ISO chain-of-custody standards describe accounting models. Neither replaces the law or regulator guidance applicable where the package is marketed. If a project is outside the United States, obtain current primary guidance for that jurisdiction before making a legal-compliance representation.

The sources do not establish a single laboratory test, universal audit checklist or market-wide success rate for recycled-content claims. A sound review therefore states what the records demonstrate, identifies what remains unverified and avoids promising that paperwork alone proves the physical composition of every package.

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What a defensible conclusion looks like

A claim is supportable only when its words and visual presentation match the evidence on scope, percentage, material origin, traceability, accounting model and certification coverage. Keep the claim narrow enough to describe the package item and production basis actually documented. If a link in that chain is missing, record the gap, seek clarification or use a qualified statement rather than treating a logo, certificate or recycled input as automatic proof.

The FTC summarizes the governing principle in its consumer advice: “The law requires these ‘eco-friendly’ or ‘green’ claims to be truthful, and the FTC’s Green Guides tell businesses how to comply with the law when they make environmental claims.” Read the quotation in context on the FTC’s consumer guidance page.

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