100% recycled? And what does EmpCo want from the cap?

Colourful plastic bottle caps packed closely together, some printed with “Please recycle me”

One month after EmpCo took effect, a current European case shows how precisely companies should now word their plastic and recycling claims. The updated flustix white paper sets out what matters now.

“This bottle is made from 100% recycled plastic.” Sounds clear. But does that also apply to the closure? To the label? And what does “Recycle me again” actually mean? Will the bottle really become a new bottle again?

These are exactly the questions occupying Europe’s consumer protection bodies. Recently, on 22 October, the European Commission published the outcome of a dialogue with Coca-Cola, Nestlé and Danone. The companies have committed to making the recycling claims on their plastic bottles more precise. For example, it must be made clear when a stated share of recycled content does not cover the closure and label. Consumer organisations had already challenged the companies in 2023. Wording that suggests a closed recycling loop is also to be changed.

With plastic claims, every word counts

Since 27 September 2026, stricter requirements for environmental claims and sustainability labels have applied in many European countries. Non-specific green promises are coming under pressure, and private sustainability labels need a suitable certification scheme with independent monitoring.

For the plastics and packaging industry, one distinction matters in particular: recycled content is not the same as recyclability. A certified bottle body does not automatically make the whole pack certified. And “less plastic” needs a transparent point of reference backed by independent evidence.

Specific, substantiated environmental claims remain possible. But they must match what was actually verified and must not suggest a wider environmental benefit than can be independently demonstrated.

New flustix white paper: from requirement to practical implementation

Our fully updated EmpCo white paper “Back Up Green Claims with Evidence” addresses exactly these questions.

The new edition not only explains the requirements in force since September but also distinguishes systematically between specific environmental claims, generic environmental claims, sustainability labels and future claims. It adds concrete wording examples, guidance on assessing existing packaging stocks and advice on independent substantiation.

Particularly important: specific environmental claims require evidence. Anyone who also uses communication that resembles a sustainability label must take into account the specific requirements for the underlying certification scheme.

From claim check to independent certificate

For companies that want to review their existing communication, flustix offers a free EmpCo claim check.

Up to five environmental claims can be submitted, for example “Microplastic-Free”, “PFAS-FREE”, “Contains Recycled Plastic” or “Recyclable”. flustix reviews the claims in the specific context in which they are used and shows where wording should be made more precise or evidence added.

Within two to three working days, companies receive a written initial assessment. The check is free of charge and non-binding.

Where independent product evidence is required or useful, the flustix certification programmes LESS PLASTICS, RECYCLED, RECYCLABLE, MICROPLASTIC-FREE and PFAS-FREE provide a basis that can be used internationally. Accredited testing and certification partners ensure that the properties verified in each case are assessed against defined criteria.

Particularly interesting for brands, retailers and private label suppliers: with the flustix sub-licence system, products that are already certified can also be marketed under their own brand, with their own certificate, an individual licence number and an independently backed trustmark. If the product is unchanged, no new laboratory tests are needed. This saves time and money and protects confidential supplier relationships.

Find out more about the flustix sub-licence system

Because credible environmental communication does not begin with a green promise, but with verifiable evidence.

Download the updated EmpCo white paper.

EmpCo white paper

Use the free flustix EmpCo claim check.

Free claim check

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