What counts as greenwashing on packaging?

Greenwashing is making an environmental claim that is vague, unverifiable, or misleading. 'Eco-friendly packaging' is greenwashing because it contains no testable information. 'Plastic-free' when the adhesive strip contains synthetic polymer is greenwashing because it's factually wrong. 'Compostable' without naming the certification standard and holding the certificate is greenwashing because it's unverifiable. The test: if a regulator asked 'prove it,' could you?

What is the difference between 'compostable' and 'biodegradable' on packaging?

Biodegradable means a material breaks down eventually, somewhere — without a stated environment and timescale, it carries no information. Compostable is a testable property: certifications like EN 13432 verify that a film disintegrates and biodegrades under specific industrial composting conditions within a defined period. In the EU, unqualified 'biodegradable' claims are effectively banned and oxo-degradable plastics are banned outright. Always use the specific certification name, not 'biodegradable.'

Do I need to put the certificate number on the packaging itself?

Not necessarily on the pack — space is limited. But the certificate number must exist, be accessible (e.g. on your website's sustainability page), and be producible on request. What must be on the pack is the disposal instruction and, where you claim a certification, the scheme name (e.g. 'certified to EN 13432'). The certificate number can live online.

Can I say my packaging is recyclable if it's only recyclable in some countries?

You can, but you must qualify it. 'Recyclable where PE film collection exists' is accurate. 'Recyclable' without qualification in a market where film isn't collected at kerbside is misleading. The honest approach is to state the stream: 'kerbside-recyclable in the paper stream' or 'recyclable in-store with plastic film collection.' Match the instruction to the infrastructure your customers actually have.

What should I do if my supplier can't provide certification documents?

Treat it as a risk that needs resolving. A supplier who can't produce a GRS certificate for recycled content or an EN 13432 certificate for compostable film in 2026 is either not certified or not organised — both are problems. If the material itself is the right choice, set a deadline for the supplier to produce documentation, and don't print the claim until you have it. In the meantime, describe the material factually without the certification claim.

What is the EU Green Claims Directive and when does it apply?

The EU Green Claims Directive will require businesses to substantiate explicit environmental claims with recognised scientific evidence, verified by an independent third party before the claim is made. It's separate from the PPWR but interacts with it — a compostability claim on packaging will need both PPWR compliance and Green Claims substantiation. Check the European Commission's website for the current status and implementation timeline.

Packaging Sustainability Claims Without Greenwashing: A DTC Brand Guide

A mailer printed with the word 'eco-friendly' and a leaf icon used to be enough. It is not enough anymore.

Regulators are writing rules that demand evidence behind environmental claims. Customers are learning to spot vague adjectives. And the cost of getting it wrong is climbing: the EU's Green Claims Directive, the UK's CMA Green Claims Code, and US state-level enforcement are all tightening the gap between what you print on a pack and what you can prove about it.

This guide is for DTC brands who want to make honest claims — claims that build trust with customers and hold up if anyone asks for the evidence. No theory, no sermonising. Just a practical framework for saying what's true and not saying what isn't.

This is a practical guide, not legal advice. Green claims law varies by jurisdiction and is evolving. Consult qualified counsel for your specific claims and markets.

Why greenwashing is getting expensive

Three forces are converging on vague packaging claims:

Regulation. The EU Green Claims Directive will require businesses to substantiate environmental claims with recognised scientific evidence. The UK CMA has been actively investigating fashion and FMCG brands over vague sustainability statements. In the US, the FTC Green Guides are under revision, and state AGs are pursuing enforcement.
Customer literacy. Your customers have been burned by meaningless claims. They know 'biodegradable' without a timeframe and environment is meaningless. They know a green leaf icon proves nothing. The segment of buyers who check for certifications is growing — and they talk.
Competitive reality. When every brand's packaging claims to be sustainable, the claim itself conveys zero signal. The only claims that differentiate are the ones with evidence behind them. Specific beats vague every time.

The claims hierarchy: vague → specific → verifiable

Every packaging claim lives at one of three levels. Only the third level holds up.

Level 1: Vague (avoid)

Claims that sound good but carry no testable information:

"Eco-friendly packaging"
"Green mailer"
"Sustainable packaging"
"Kind to the planet"
"Earth-conscious materials"

These are the claims regulators are targeting first. They mean nothing because they can mean anything — and they can never be proven or disproven because they contain no measurable property.

Rule: If you cannot design a test that would tell you whether the claim is true or false, don't print it.

Level 2: Specific (better, but incomplete)

Claims that name a property but don't provide the evidence framework:

"Made with recycled materials" — what percentage? Verified how?
"Compostable packaging" — industrial or home? To which standard?
"Recyclable mailer" — in which collection stream? Everywhere or somewhere?
"Plastic-free" — really? What about adhesives, coatings, inks?

These are better because they say something concrete. But they're still incomplete: a specific claim without evidence is a vague claim wearing a tie.

Level 3: Verifiable (the target)

Claims that name a specific property, a recognised standard or scheme, and — where the scheme requires it — a certificate number:

"Made with 100% recycled PE, GRS-certified (certificate no. XXXX)"
"Certified industrially compostable to EN 13432 (certificate no. XXXX)"
"Kerbside-recyclable in the paper stream — all-fibre construction, no plastic liner"
"FSC-certified paper from responsibly managed forests (FSC CXXXXXX)"

These claims can be verified by a third party reading the certificate. They tell the customer what to do with the pack and why they should believe it. And they survive a regulator's request for evidence because the evidence exists.

The claims audit: six questions for every claim you print

Before you print any environmental claim on packaging, answer these six questions. If you cannot answer all six, don't print the claim.

What exactly are you claiming? State it as a measurable property, not an adjective.
Which recognised standard or scheme backs it? EN 13432, ASTM D6400, GRS, FSC, TÜV OK compost HOME — name the standard.
Can you produce the certificate? With the certificate number, for the specific material and specification you're buying.
Is the claim true for the whole pack or just a component? If only the outer layer is recycled but the liner isn't, 'recycled packaging' is misleading.
Does the disposal instruction match what your customers can actually do? Telling someone to industrially compost a mailer when their municipality doesn't accept compostable packaging converts goodwill into cynicism.
Would the claim survive a regulator asking 'show us the evidence'? If the answer is anything other than a confident yes, you have work to do.

The specific claims that need the most care

'Compostable'

The highest-risk claim in e-commerce packaging because it is the most infrastructure-dependent. A film certified to EN 13432 or ASTM D6400 is tested for industrial composting conditions — elevated, controlled temperatures over weeks to months. A garden heap does not replicate those conditions. Home compostability requires a separate, stricter certification (TÜV OK compost HOME is the best-known scheme).

The rule: Never print 'compostable' without naming the standard (EN 13432 / ASTM D6400 / OK compost HOME) and the disposal pathway. If your customers don't have industrial organics collection that accepts packaging, a compostable mailer with no disposal instruction is an expensive label on general waste.

Our compostable mailers ship with the certificate path documented — because the certificate is part of the product.

'Recyclable'

Recyclability is not a property of the material alone — it's a property of the material plus the collection and sorting infrastructure where the customer lives. A PE film mailer is recyclable in Germany's lightweight-packaging collection and largely not at kerbside in much of the US (where film recycling relies on store drop-off). An all-paper mailer is recyclable almost everywhere kerbside paper collection exists.

The rule: State 'recyclable' only with the stream: 'kerbside-recyclable in the paper stream' or 'recyclable where PE film collection exists.' Mono-material design makes recycling technically possible — but only infrastructure makes it actually happen.

'Recycled content'

Two traps here. First: 'made with recycled materials' without stating the percentage. Is it 100% or 10%? The difference matters, and omitting the number implies more than you may mean. Second: 'recycled content' and 'recyclable' are independent properties. A pack can be made from recycled material but not be recyclable itself, and vice versa.

The rule: State the percentage ('100% recycled PE') and the verification scheme (GRS) with the certificate number. Our recycled PE mailers are mono-material 100% recycled PE with GRS-verifiable content — documentation follows the quote.

'Plastic-free'

A claim that collapses on inspection more often than you'd think. Does 'plastic-free' include the adhesive strip? The tear tape? The ink? The coating that gives wet-strength? Many 'plastic-free paper mailers' contain synthetic adhesives or polymer coatings that make the claim untrue.

The rule: If you say plastic-free, audit every component — film, adhesive, tape, ink, coating. If any component contains synthetic polymer, 'plastic-free' is false. 'All-fibre construction' or 'paper-stream recyclable' is often more accurate and equally marketable.

'Biodegradable'

In the EU, 'biodegradable' claims on packaging without a specified environment and timeframe are effectively banned under the Single-Use Plastics Directive, and oxo-degradable plastics (which fragment into microplastics) are banned outright. In other markets, the word remains a red flag: everything biodegrades eventually, so the claim without parameters carries no information.

The rule: Don't use 'biodegradable' on packaging. Use 'certified industrially compostable to EN 13432' or 'certified home compostable to OK compost HOME' if you have the certificate. If you don't have the certificate, don't make the claim.

The disposal panel: the most underrated real estate on your pack

If you make a sustainability claim, the disposal instruction is not an afterthought — it is the thing that makes the claim operational. A mailer that says 'compostable' but doesn't tell the customer where or how to compost it has done half the job and outsourced the hard half to a consumer who doesn't know what industrial composting is.

A good disposal panel answers three questions in plain language:

What is this pack made of? (Material, not adjective.)
Which bin does it go in? (Specific to the collection system where your customers live.)
Why should I believe it? (Certification scheme + certificate number where relevant.)

Example of a good panel:

This mailer is made from 100% recycled PE. Where PE film collection exists, please recycle with plastic films. GRS-certified recycled content (cert. no. XXXX).

Example of a bad panel:

Eco-friendly packaging. Please dispose of responsibly.

The second one says nothing, proves nothing, and in 2026 is more likely to attract regulatory attention than customer goodwill.

A simple claims policy for your brand

You don't need a 40-page sustainability report. You need a one-page claims policy that everyone who touches packaging — marketing, ops, procurement — understands and follows.

The policy in five rules:

No unverifiable adjectives. Never print 'eco-friendly,' 'green,' 'sustainable,' or 'kind to the planet' on packaging. They are untestable and indefensible.
Every claim names a standard. Recycled content → GRS. Compostable → EN 13432 or ASTM D6400. Fibre sourcing → FSC. No standard, no claim.
Every claim has a certificate number on file. If the certificate doesn't exist, the claim doesn't get printed. Certificate numbers can live on a website rather than the pack if space is tight, but they must exist and be accessible.
Disposal instructions match real infrastructure. Don't tell a US customer to industrially compost. Don't tell a rural customer their film is kerbside-recyclable when their municipality doesn't collect it. Match the instruction to the bin they actually have.
Claims are reviewed before every reprint. Certification statuses change, material specs drift, suppliers switch. A claim that was true on the last production run may not be true on this one. Verify before you print.

When you don't have the certificate yet

This is the most common situation for growing brands: you want to use a more sustainable material, you're sourcing it, but the certificate isn't in hand yet. What do you say in the meantime?

Say what's true now. 'We're transitioning our mailers to GRS-certified recycled PE — current stock uses [current material].' This is honest, specific, and sets an expectation you can meet. It is far better than claiming a certification you don't hold and hoping nobody checks.

Never pre-claim. Printing 'certified compostable' on a pack you haven't received the certificate for is not aspiration — it's false. Wait for the certificate number, then print.

Spec your pack with verifiable claims. Tell us your dimensions, quantity and the claim you want to make — start an RFQ. We'll come back within 24 hours with a material recommendation, the certification path for it, and a quote.

Our regulatory explainers always state effective dates and scope. They are not legal advice.

How to make packaging sustainability claims without greenwashing