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BETTESWORTHConstruction
chain of custody

What Evidence Should You Keep for Recycled-Content Claims?

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Keep a traceable evidence file for every recycled-content claim. It should connect the exact wording used in an advertisement, specification, website or package to the material source, quantities received, production or allocation records, percentage calculation, claim scope and approval history. Keep any certificate or audit report with those company records; certification does not remove the marketer’s duty to substantiate express and implied claims.

  • Record whether the claim covers the product, a component, the packaging, or a combination.
  • Retain supplier declarations, invoices, delivery and weight records, lot identifiers, and production records.
  • Preserve the numerator, denominator, units, period, exclusions and allocation method behind the percentage.
  • State whether the accounting uses physically segregated material or a mass-balance attribution model.
  • Set a retention period after checking the applicable law, contract, certification scheme and market; no universal period is established by the sources discussed here.

Start with the claim you actually make

Evidence is only useful if it supports the precise statement a customer sees. Save the final wording, not just an internal description of the product. The record should include the label, advertisement, webpage, tender response, environmental product statement or specification in which the claim appears, together with the date and market where it was used.

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Write down the claim’s subject in the same record. Recycled content may be attributed to an entire product, a named component or the packaging. A statement such as “Made from 30% recycled material” needs a clear answer to the question, “30% of what?” The U.S. Federal Trade Commission (FTC) advises qualifying partial-content claims so consumers can tell whether the statement refers to the product, the package or both. Its Green Guides use wording of this kind as an example; the 30% figure is illustrative, not a required threshold.

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Define the material category

Identify the material and the terminology used by the claim. If the distinction is relevant to your market or standard, record whether the input is pre-consumer, post-consumer or a combination. Do not let a supplier’s broad phrase such as “recycled feedstock” stand in for the definition your claim requires. Preserve the supplier’s declaration and your interpretation of it in the claim file.

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Record the market and date

Environmental-claim rules can differ by country, product sector and sales channel. Note the jurisdiction, customer or project, publication date and the person responsible for approval. If the same product is marketed with different wording in different places, create a separate claim record or clearly identify each version.

The core evidence file

Organize records so an independent reviewer can follow the material from source to claimed output without relying on memory. A practical file contains the following linked sections.

1. Claim record

  • Exact wording, artwork or specification language.
  • Date issued, market and intended audience.
  • Whether the statement covers a product, component, packaging or more than one of these.
  • The percentage or other quantitative term, including any qualifying language.
  • Approval owner and the date on which the claim must be reviewed.

2. Material identity and origin

  • Material name, grade or specification and the supplier or processor.
  • Supplier declaration describing the recovered or recycled input.
  • Whether the input is pre-consumer, post-consumer or a combination, where that distinction is used.
  • Site, facility or production line associated with the input when relevant to traceability.
  • Contractual definitions or purchase specifications that limit what the supplier is promising.

3. Transactions and quantities

  • Purchase orders, invoices, transfer documents and delivery records.
  • Weights or other quantity measurements, with units and measurement dates.
  • Lot, batch, shipment or container identifiers that can be matched to production records.
  • Adjustments, rejects, returns, moisture corrections or other factors that change the usable quantity.

4. Production linkage

  • Manufacturing records showing when and where the recovered or recycled input entered production.
  • Batch tickets, bills of material, inventory movements or work orders linking input lots to output lots.
  • Output quantities and any material losses, scrap or rework included or excluded from the calculation.
  • The product, component or package to which the output is assigned.

5. Calculation and allocation

  • Numerator, denominator and units used for the percentage.
  • Accounting period and the products or batches included.
  • Exclusions, conversion factors, yield assumptions and rounding rules.
  • For an attributed claim, the input ledger, allocation rule, output ledger and reconciliation showing that assigned quantities do not exceed eligible inputs.
  • A dated worksheet or system export that can be reproduced from the underlying records.

6. External assurance

  • Certificate or audit report, issuer and document number.
  • Covered sites, materials, products and chain-of-custody method.
  • Issue date, expiry or validity period and any conditions or limitations.
  • Corrective actions, surveillance findings or suspended-scope notices.

Keep this external material beside, not instead of, the company’s own records. The FTC states: “A marketer with a third-party certification still must substantiate all express and implied claims.”

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7. Review trail

  • Name and role of each approver.
  • Evidence reviewed and unresolved assumptions.
  • Date of approval and next review trigger.
  • Change events that require reassessment, such as a new supplier, material grade, manufacturing site, allocation method or claim wording.

Calculate the percentage so another person can reproduce it

ISO 14021:2026 describes recycled content as the proportion by mass of recycled material in, or attributed to, a product, component or packaging. Your worksheet should therefore make the mass basis visible. A basic physical-content calculation is:

recycled content (%) = eligible recycled material mass ÷ total product, component or packaging mass × 100

State what each term means. “Eligible recycled material mass” might exclude moisture, additives or processing aids under the applicable methodology; “total mass” might refer to the finished item or a defined component. Do not silently switch denominators between products or reporting periods.

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Show the boundaries

List the included input streams and the output they support. If a product contains several components, show the component masses before presenting a product-level percentage. If the claim concerns packaging, keep the packaging calculation separate from the product calculation unless the wording expressly combines them.

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Preserve time and reconciliation

Identify the period covered by the inputs and outputs. Reconcile opening inventory, receipts, production use, closing inventory and losses where inventory carries across periods. If a supplier revises a weight or declaration, retain the original and the corrected version, explain the change and identify which claims were affected.

Physical segregation and mass-balance attribution are different claims systems

ISO’s chain-of-custody overview describes segregation, mass balance and transferable instruments as different traceability mechanisms. They should not be presented as interchangeable proof that every individual unit physically contains the claimed recycled material.

Method What the records should show What the claim can safely imply
Physical segregation or identity preservation Eligible material remains separated or identifiable through receipt, storage, processing and dispatch, with lot-level records linking input to output. The supplied output is linked to the specified physical input, subject to the method’s documented boundaries and losses.
Mass-balance attribution Eligible inputs, total outputs, allocation rules, transfer periods and reconciliation ledgers are documented. Recycled content is attributed to the product or output category; ISO cautions that the claimed content cannot be guaranteed in each individual product supplied.

Under mass balance, do not use wording that suggests every unit contains the same physically identifiable share if your evidence supports only an accounting attribution. Keep the model name, allocation rules and consumer-facing qualification together when drafting the claim.

Ask what transferable instruments represent

If a program uses transferable instruments, retain the instrument record, issuer, quantity, covered material and cancellation or retirement information. Explain whether the instrument represents physical material in the supplied unit or an attributed environmental or material claim. The record should not imply stronger physical traceability than the program provides.

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Supplier evidence must connect to your own purchase and production records

A supplier declaration is an input, not the entire proof. Match it to the purchase order, invoice, delivery weight and lot identifier. Then show where that lot went. A declaration covering a supplier’s annual production does not automatically substantiate a claim for one construction product, project batch or package unless your allocation records connect the two.

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Ask suppliers to identify the basis of their statement, the relevant period, the material category and any exclusions. Keep versioned declarations when wording or methodology changes. If a supplier cannot provide a needed detail, narrow your claim or document why the available evidence still supports the exact statement used.

Construction-sector applications

Construction businesses often make recycled-content claims across a supply chain rather than at a single factory. The evidence file should follow the claim’s subject.

Materials incorporated into a product

For a manufactured item such as a panel, pipe, fixture or composite component, retain the material specification, supplier declaration, incoming weights, batch records and finished-product mass. If the claim is for the component rather than the whole building assembly, say so in the specification and calculation.

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Project-specific products

When a project uses a particular batch or delivery, preserve delivery tickets, batch identifiers and the product data submitted to the client. A corporate statement about a product family does not by itself prove the content of a specific shipment unless the family-level accounting method and allocation period support that use.

Packaging and installation materials

Keep packaging evidence separately when the claim concerns cartons, pallets, protective film or other packaging. The FTC expects partial-content claims to make the subject clear. Do not let a recycled-content claim about packaging be read as a claim about the installed product.

What certification can and cannot do

A certificate, audit or chain-of-custody document can provide independent review of defined sites, materials, products and periods. File the complete document, scope and validity information, and check that the claim uses only covered materials and locations.

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Certification does not automatically prove every sentence in your marketing. You still need records for your product’s quantities, calculation, claim scope and wording. A seal that does not explain its meaning can also confuse consumers; provide the relevant qualification or explanatory text required by the certification program and applicable law.

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Review claims when the facts change

Set a change-control trigger rather than relying only on an annual calendar. Reopen the file when any of the following occurs:

  • A supplier, processor, site or material grade changes.
  • The production recipe, yield, loss rate or packaging format changes.
  • The accounting period, allocation rule or chain-of-custody method changes.
  • A certificate expires, changes scope or records a corrective action.
  • The wording moves from a product or component claim to a broader product-and-package claim.
  • A regulator, customer or certifier questions the substantiation.

Record the decision to keep, revise or withdraw the claim. Preserve the superseded wording so you can identify which shipments, tenders or pages used it.

Retention periods: do not assume one universal number

The FTC materials and ISO documentation principles establish the need for substantiation and traceable records, but they do not establish one general number of years for every recycled-content claim. The appropriate period may depend on the jurisdiction, product sector, contract, certification scheme, limitation period and customer-document rules.

Set a documented retention rule after checking those requirements for each market and project type. Include records needed to reconstruct the claim, not only the certificate or final calculation. If a contract requires longer retention than your internal policy, follow the longer applicable requirement and control access to commercially sensitive supplier and production data.

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Common failures and practical fixes

The percentage has no denominator

Symptom: Marketing states “30% recycled” without saying whether the percentage is by mass of the product, a component or packaging. Fix: define the subject, units and calculation boundary in the claim record and rewrite the public wording if necessary.

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A certificate is treated as the whole file

Symptom: The business can show a seal but cannot tie the certified material to its own lots or outputs. Fix: retain the certificate and add purchase, quantity, production and allocation records for the claimed product.

Mass balance is described as unit-level content

Symptom: A mass-balance allocation is advertised as if every supplied unit physically contains the stated share. Fix: identify the attribution model and use wording that does not guarantee physical content in each individual item.

Supplier and production periods do not match

Symptom: An annual supplier statement is used to support a shipment without a period or allocation link. Fix: reconcile the relevant period, lots and quantities, or limit the claim to what the records actually support.

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Old wording remains live after a change

Symptom: A new supplier or recipe is introduced while the old webpage or specification remains unchanged. Fix: use the review trail and change triggers to update or withdraw affected claims and archive the prior version.

Regulatory context for U.S. marketing

FTC guidance says objective express and implied product-attribute claims need a reasonable basis before they are made, with the evidence expected depending on the claim and what relevant experts would regard as reasonable. The FTC’s Green Guides summary says recycled-content claims should concern material recovered or diverted from the waste stream during manufacturing or after consumer use, and that partial-content claims should be qualified.

The FTC topic page says the Guides were most recently revised in 2012. The Commission requested public comment in 2022 on possible revisions, including consumer understanding of “recycled content” and alternative substantiation methods. A request for comments is not a final rule or adopted change. Check the Commission’s current status and obtain jurisdiction-specific advice before relying on an older interpretation.

ISO 14021:2026 is a standard, not a universal determination that a particular claim is lawful. Use the applicable edition, contract requirements and legal advice for the product and market at issue.

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