Saying '30% recycled' without creating a legal problem

1. What you may and may not say

The rule of thumb is precision. 'Made from recycled material' invites a challenge; '30% post-consumer recycled polyolefin by weight, produced following UNE 53925:2026' does not, because every element of it is checkable. Claims about the whole product when only a component qualifies are a classic enforcement target.

• Say the number, the basis (by weight) and the scope (which component)
• Say 'post-consumer' when it is post-consumer — and only then
• Avoid 'eco', 'green', 'climate neutral' without recognised substantiation
• Keep the evidence for as long as the claim is on the market

2. Why the supplier chain decides your exposure

You can only substantiate what your supplier can evidence. If a resin certificate says 'recycled' without specifying post-consumer origin, or reports a mass-balance allocated figure without saying so, your public claim inherits that ambiguity — and the consumer-protection risk sits with you, not the recycler.

This is the practical link between compliance and marketing: the same batch certificate that supports your PPWR technical file supports your product claim.

• Require post-consumer wording on the certificate
• Record whether the figure is physical or allocated
• Match public claims to the documented batch data

3. ESPR and the Digital Product Passport

The Ecodesign for Sustainable Products Regulation (EU) 2024/1781 is the framework under which product-specific requirements, potentially including recycled content, will be set by delegated acts. It also introduces the Digital Product Passport, whose registry implementation rules were adopted on 16 July 2026 by Regulation (EU) 2026/1778.

The direction is unmistakable: material composition and recycled content become structured, machine-readable data attached to the product. Companies whose recycled-content data lives in PDFs and emails will have to rebuild it; companies with batch-level traceability will mostly have to export it.

• ESPR: framework for product-specific ecodesign requirements
• DPP registry rules adopted 16 July 2026 (Reg. (EU) 2026/1778)
• Recycled content becomes structured product data, not marketing copy

4. Construction products and other sectors

The new Construction Products Regulation (EU) 2024/3110, in force since 7 January 2025, brings environmental performance declarations into the CE-marking framework and empowers future delegated acts on recycled content and durability. If you supply construction or urban-furniture components, expect declared environmental data to become a market-access condition rather than a differentiator.

This page is general information about EU legislation, not legal advice. Check the consolidated text of each instrument and your national transposition before you rely on a figure.

• CPR (EU) 2024/3110 in force since 7 January 2025
• Environmental declarations move into the regulated framework
• Recycled-content delegated acts expected, not yet adopted