Recycling Labels: How2Recycle, Resin Codes and FTC

Separate the symbol, the program label and the marketing claim

Resin codes, How2Recycle labels and environmental marketing claims are three different tools. A resin code identifies a plastic material family, usually a number from 1 to 7. A How2Recycle label is a program mark that communicates a disposal pathway under that program's criteria. An FTC-related claim is a statement in commerce that must be truthful, not misleading and substantiated. Putting a number inside chasing arrows does not by itself establish that a package will be accepted in a given community.

Treat the label as the last step after evidence. The question is not whether a symbol looks familiar. The question is whether the specific package, in the specific market, has a verified end-of-life pathway and whether the wording matches the evidence. If the answer is uncertain, use no recycling claim or a clearly qualified statement after review.

Build an evidence file before choosing artwork

Before artwork, assemble a component-level evidence file. List every material, coating, label, closure and adhesive that remains attached. Confirm how the consumer would separate components. Check acceptance with local recycling programs or drop-off networks for the target sales areas. For compostable claims, collect relevant test or certification evidence and confirm the intended composting environment. For recycled-content claims, obtain documentation supporting the claimed content. Separately, ask a regulatory specialist to evaluate applicable food-contact requirements when recycled materials will contact food. FDA describes a process for providing informal advice on recycled-plastic food-contact uses; this is not a requirement for individual FDA approval of every package or recycled-content claim.

A supplier statement that a material is recyclable is not the same as local acceptance. Keep the evidence specific to the package format, the sales market and the date checked. If the material or supplier changes, reopen the file.

• Bill of materials with weights or percentages by component.
• Local acceptance records for each package format.
• Current program criteria and label artwork rules.
• Test or certification documents for compostable claims.
• Supplier declarations for recycled content.
• Legal review notes for claim wording.

Resin codes: identification, not a promise

Resin codes are intended for material identification, not as a consumer promise of recyclability. In common use, code 1 is PET, code 2 is HDPE, code 3 is PVC, code 4 is LDPE, code 5 is PP, code 6 is PS and code 7 covers other resins. Confirm current code definitions and marking format against the applicable ASTM resin identification standard. A package can carry a code and still lack local acceptance because of format, size, color, label or facility capability.

Do not convert a resin code into a recyclability claim without checking the full package and the receiving program. A rigid bottle and a flexible film can share a resin family but have different collection pathways. If the only evidence is the resin code, the evidence is not enough for a consumer-facing recycling label.

How2Recycle review workflow

Start by mapping each component and the likely disposal route. Then compare that route with the current How2Recycle program criteria and the local acceptance evidence. Prepare final artwork only after the route is confirmed. Confirm the program's current participation and review process, and any artwork rules it sets, directly with How2Recycle. This guide does not cite program documentation. Keep a record of the approved version and the evidence date.

Program criteria and local programs change. Build a recheck step into packaging changes and annual label reviews. A label that was suitable for an earlier structure should not be carried forward without confirmation.

• Identify the package format and all attached components.
• Confirm local acceptance or drop-off availability in the sales area.
• Check current program eligibility and label rules directly with How2Recycle.
• Use qualifiers where the pathway is limited.
• Recheck when materials, suppliers or local programs change.

FTC green claims: substantiate and qualify

The EPA states that the FTC is responsible for enforcement against false or deceptive labeling of biodegradable and compostable plastics. That makes claim discipline a legal review issue, not only a design preference. The FTC Green Guides are the reference your legal reviewer should check, and the current text should be confirmed with the FTC. A claim should be specific about what is recyclable, where, and which components are included.

Limited acceptance and differences between components warrant careful claim review. Ask legal counsel to assess whether the wording accurately identifies the components covered and whether limitations, such as a drop-off-only pathway, need to be disclosed. Local acceptance records alone do not establish that an unqualified claim is appropriate across a sales market. Confirm the current FTC Green Guides and any applicable program requirements rather than treating example qualifiers as sufficient. We recommend keeping substantiation files for as long as the claim is in use, with a retention period confirmed by legal counsel. Make sure the package artwork, website and retail listing use consistent wording.

• Claim: what exactly is recyclable or compostable.
• Scope: which components and which markets.
• Evidence: local acceptance, program review, certification or test data.
• Qualification: drop-off only, not accepted curbside, check locally.
• Consistency: pack copy, ecommerce copy and customer service scripts.

Compostable claims have separate and sometimes state-specific rules

Compostable is not a synonym for biodegradable. The EPA explains that compostable plastic is intended to break down in a commercial or industrial composting facility under defined conditions, and that a compostable label does not mean the item belongs in a home compost pile unless the label says so. The EPA also notes that ASTM D6400 and D6868 outline specifications for commercially compostable plastic. State rules can add requirements.

Washington's published guidance illustrates the need for state-specific review. It describes third-party industrial-compostability certification, FTC Green Guides considerations, wording and color signals, and producer declarations. It also identifies restrictions on terms such as biodegradable and describes different labeling provisions for film bags, other films and food service products. These provisions should not be reduced to one universal artwork rule. The supplied excerpt is not sufficient to determine current applicability or the scope of exceptions for a particular product. Before choosing wording, symbols or color signals, confirm the current law and format-specific agency instructions for the product and sales market.

Worked example: five-SKU label review

A hypothetical brand has five retail SKUs: three plastic film pouches, one PET bottle and one paperboard carton. It wants a recycling label on every unit. The team checks local acceptance and finds that two of the three film pouches have a confirmed drop-off pathway, one film pouch has none, the PET bottle is accepted curbside and the carton is accepted curbside.

In this hypothetical example, documented pathways cover four of the five SKUs, or 80 percent. Film pathway coverage is two of three film pouches, or about 66.7 percent. We recommend withholding a recycling claim for the unverified pouch until adequate evidence and any required program review support it. The team could investigate another pathway or redesign the package. These percentages describe SKU review coverage only, not the share of consumers with access, package recyclability, program eligibility or guaranteed acceptance.

Decision table and review checklist

Use the table as a planning aid, then confirm the actual wording and artwork with the program, the receiving program and legal review. The checklist is Teal's editorial planning framework. The cited sources cover only specific underlying principles, not every state or local rule.

• List every component and whether it stays attached.
• Record the exact local acceptance source and date.
• Check current How2Recycle and FTC guidance before final artwork.
• Review state compostable rules for each sales market.
• Keep legal sign-off with the approved artwork.
• Reopen the review when structure, supplier or market changes.

Questions about Packaging recycling label review