Words such as “recycled”, “recyclable” and “eco-friendly”, and forest-certification logos, can do a lot of work on a box. They are also the parts of the pack a regulator, retailer or competitor can ask you to prove, and the proof is hard to assemble because the evidence behind them sits with a paper mill and a printer several steps away from your brand.

This guide is for brands and buyers who want environmental claims on packaging made in Asia. It explains how to check an FSC claim before it reaches your artwork, what evidence a recycled-content claim needs, and what the rules say in the markets we checked against primary sources: the United States, the European Union and the United Kingdom. It does not tell you which words make a pack legal. No word does that on its own; the evidence does.

💬 Want an FSC or recycled claim on your packaging? Send us the claim you have in mind and the pack, and we will ask the factory for the certificates and records behind it before artwork is final. Tell us about your packaging.

Check an FSC claim before it reaches the artwork

An FSC label on finished packaging needs a certified supply chain; check the factory’s certificate in FSC’s public database and make sure the claim on its invoice matches the label you plan to print.

The Forest Stewardship Council (FSC) uses three labels on products:

FSC labelWhat FSC says it means
FSC 100%All materials come from FSC-certified forests
FSC RecycledThe product is made from 100 per cent recycled materials
FSC MixA mixture of materials from FSC-certified forests, recycled materials and/or FSC-controlled wood

FSC describes chain of custody certification as the route for companies that label finished goods as FSC certified or sell FSC-certified products with FSC claims on sales documents. In practice, the printer or converter that makes your box usually needs its own chain of custody certificate for the label to be used on the finished pack. FSC also notes that most retailers that do not manufacture finished goods do not need chain of custody certification and can use a promotional licence instead.

How to check:

  1. Ask the factory for its FSC certificate code and licence code. The licence code appears on FSC labels and promotional material.
  2. Look it up in FSC’s public database. FSC Search (search.fsc.org) is FSC’s public database of certificate and licence holders. The older public certificate search accepts any part of a licence code, certificate code or organisation name.
  3. Check the certificate detail: the organisation name and address match the factory you are buying from, the certificate is current, and the product group covers paper or board packaging.
  4. Check the claim on the invoice. The factory’s sales documents for your order should carry the FSC claim that matches the label you print.
  5. Get the label artwork from the certified party. FSC controls how its labels and trademarks are used. Ask the certified party for label artwork that follows FSC’s current rules rather than copying a logo from another pack.

If the certificate cannot be found, belongs to a different company, or does not cover the product, do not print the label. Ask the factory to explain before the artwork goes any further. For timber products more generally, our article on timber legality papers for furniture buyers explains how certification and legality records fit together.

Recycled content: what the evidence looks like

A recycled-content claim needs records showing the material really came from the waste stream and, if you state a percentage, how much of the finished pack it makes up.

Ask the factory, before artwork is final, for:

  • the paper or board mill’s specification sheet stating recycled fibre content
  • whether the content is pre-consumer (recovered during manufacturing) or post-consumer (recovered after consumer use), if you plan to say which
  • purchase records linking that board to your order
  • any certificate covering the claim, such as FSC Recycled, where used

The US Green Guides give a useful benchmark. Under 16 CFR 260.13, it is deceptive to represent that an item contains recycled content unless it is made of materials recovered or diverted from the waste stream, either during manufacturing (pre-consumer) or after consumer use (post-consumer). Where pre-consumer material is counted, the marketer should be able to show it would otherwise have entered the waste stream. For items only partly made of recycled material, the claim should be clearly and prominently qualified with the amount or percentage, by weight, of recycled content in the finished product or package.

Treat a percentage as a number you must be able to prove for each production run, not a figure from a mill brochure.

United States: the FTC Green Guides

In the US, the Federal Trade Commission’s Green Guides (16 CFR Part 260) explain how the FTC applies the law on deceptive claims to environmental marketing, including “recyclable”, “recycled” and general “eco” claims.

The Green Guides are guidance, not a stand-alone rule: 16 CFR 260.1 says they do not confer any rights on any person and do not bind the FTC or the public, and that they do not preempt federal, state or local laws. Some US states have their own rules on environmental claims, so confirm the current rule in each state where you sell.

The points most relevant to packaging:

SectionTopicWhat it says
260.2SubstantiationA reasonable basis often requires competent and reliable scientific evidence
260.4General environmental benefitMarketers should not make unqualified general environmental benefit claims, such as “eco-friendly”, and should qualify them to a specific benefit
260.12RecyclableA package should not be marketed as recyclable unless it can be collected, separated or otherwise recovered through an established recycling program; unqualified claims are possible when facilities are available to a substantial majority of consumers or communities, defined as at least 60 percent
260.13Recycled contentMaterial must come from the waste stream; partly recycled items should state the amount or percentage by weight

Under 260.12, where recycling facilities are available to less than a substantial majority, recyclable claims should be qualified, for example by stating that the package may not be recyclable in the reader’s area. A paper box with a plastic window, heavy lamination or a magnet raises questions a plain board box does not.

European Union: generic claims rules from 27 September 2026

From 27 September 2026, EU Member States must apply Directive (EU) 2024/825, which bans generic environmental claims a trader cannot back with recognised excellent environmental performance, and sustainability labels not based on a certification scheme or set up by public authorities.

Directive (EU) 2024/825 amends the EU rules on unfair commercial practices. Member States apply the measures from 27 September 2026 through their national law. It adds the following to the list of practices that are always considered unfair:

  • displaying a sustainability label that is not based on a certification scheme or not established by public authorities
  • making a generic environmental claim for which the trader cannot demonstrate recognised excellent environmental performance relevant to the claim
  • making an environmental claim about the entire product when it concerns only a certain aspect of it

A “generic environmental claim” is defined as an environmental claim not included on a sustainability label, where the specification of the claim is not given in clear and prominent terms on the same medium. In practice, a vague word such as “eco” on its own carries risk, while a specific statement, such as which component contains recycled fibre and how much, is easier to support. A “certification scheme” is defined as a third-party verification scheme whose requirements are publicly available and that meets further criteria set out in the Directive.

Because each Member State writes these rules into its own law, confirm the current national text in each country where you sell.

EU packaging regulation: labels and recyclability later

Regulation (EU) 2025/40 on packaging and packaging waste applies from 12 August 2026. Two of its dates matter for printed packs:

  • Article 12 requires packaging placed on the market to carry a harmonised label on material composition from 12 August 2028 or 24 months after the relevant implementing acts enter into force, whichever is later.
  • Article 6 says all packaging placed on the market shall be recyclable, with the design-for-recycling condition applying from 1 January 2030 at the earliest, and the condition on separate collection, sorting and recycling at scale from 1 January 2035 at the earliest.

Many details depend on acts the Commission has still to adopt. Plan artwork space for future labelling, and confirm the current rule in the market where you sell before each new print run.

💬 Selling the same pack in the US, the EU and the UK? We collect the factory’s certificates and material records in one file so each market’s claim can be checked. Ask us about your claims.

United Kingdom: the CMA Green Claims Code

In the UK, the Competition and Markets Authority’s Green Claims Code sets out six principles that environmental claims should follow under consumer protection law.

The CMA published its guidance on environmental claims on goods and services in September 2021. Its six principles are that claims must:

  1. be truthful and accurate
  2. be clear and unambiguous
  3. not omit or hide important relevant information
  4. make only fair and meaningful comparisons
  5. consider the full life cycle of the product or service
  6. be substantiated

The CMA says it will review the guidance if relevant differences emerge between UK and EU law. Check the current guidance and the law it relies on before printing claims for the UK.

Other markets

We have not set out rules for other markets here; confirm the current rule in the market where you sell.

Other markets have their own consumer-protection laws, and some regulators publish guidance on environmental claims or recycling marks. This article covers only the markets whose texts we checked. If you sell elsewhere, check the current law and any regulator guidance in that country, and ask a local adviser where the claim is central to your marketing.

An evidence file for every claim

Before artwork is approved, build a file that links each claim on the pack to a document, and keep it for every production run.

Claim on the packEvidence to collectWho provides it
FSC labelCertificate and licence code, FSC Search record, invoice with FSC claim, approved label artworkCertified printer or converter
”Made with recycled paper” or a percentageMill specification, pre- or post-consumer split if stated, purchase records for the orderFactory and paper mill
”Recyclable”Material breakdown of every component, and the recycling access in the selling marketYou, with factory data
”Plastic-free”Confirmation for every component, including windows, lamination, coatings, tape and adhesiveFactory and component suppliers
Third-party label of any kindCertificate from the scheme, scheme rules for logo useCertified party

Keep the evidence with the approved sample and artwork version, as described in our guide to dielines, artwork and colour proofing. If the factory changes paper supplier or finish, check the evidence again before the next print run. Our guides to custom printed boxes and mailer boxes for e-commerce show where finishes and materials change what you can claim.

Frequently asked questions

1. How can I check whether a factory really holds an FSC certificate?
Ask for the certificate and licence codes and look them up in FSC’s public database at search.fsc.org. Check the name, address, status and product scope match your factory and your packaging.

2. Can I print the FSC logo if my box is made from FSC paper but the printer is not certified?
FSC lists labelling finished goods among the activities that call for chain of custody certification, so an uncertified printer is a warning sign. Ask the factory and check FSC’s current rules before printing.

3. Is “eco-friendly” allowed on packaging?
It is risky. The US Green Guides advise against unqualified general environmental claims, and from 27 September 2026 EU law bans generic claims without recognised excellent environmental performance. Make a specific, supported claim instead.

4. When can I call a package “recyclable” in the US?
Under the Green Guides, an unqualified claim needs recycling facilities available to at least 60 percent of consumers or communities where it is sold. Otherwise qualify the claim. State laws may add rules.

5. What about markets other than the US, EU and UK?
Each market sets its own rules on environmental claims. Confirm the current rule in the market where you sell before printing.

Summary

An environmental claim on packaging is only as strong as the document behind it: check FSC codes in the public database, collect recycled-content records, and match the wording to the rules of each market. All three markets covered here expect a specific claim backed by proof.

Sunsho Trade is a trading company, not a factory. For packaging with environmental claims we find factories in Asia whose certificates can be verified, collect the evidence for each claim, and keep it with the approved samples and inspection records.

💬 Ready to make packaging with claims you can prove? See our custom packaging service, or send us your pack and the claims you want and we will check them with the factory.

Sources

Checked on 26 October 2026.