FTC Green Guides: What Do They Require of a Recycled Content Claim?

The FTC Green Guides are administrative guidance on how environmental claims are presented, not a product standard. That distinction matters: nothing in them tells you what a bag must be made of, and everything in them tells you how you may describe it. A buyer who reads them as a specification writes the wrong document; a buyer who reads them as a copy discipline writes the right one.

This page turns the guidance into a working checklist for bag programmes. It covers the general duty to qualify and substantiate, the claims that draw the most challenge in this product category, what counts as a competent basis for a number, how seals and certifications have to be presented, and the internal sign-off that stops a claim drifting after approval.

What Do the Green Guides Ask of a Claim?

Two things, and they are the same two things whether the claim is on a hangtag, a listing or a tender response. First, qualify it: a general claim that a reasonable reader would take to mean more than it does has to be narrowed so that it means what it says. Second, substantiate it: the evidence has to exist at the time the claim is made, not assembled after a challenge.

The second point is the one that catches programmes out. Substantiation is a point-in-time test. A claim that was true when it was approved and is not supported by the document you hold today is a claim without substantiation, whatever its history. This is why the file has to be indexed by lot: the test is applied to the goods in the market now, not to the goods in the first sample.

Which Bag Claims Draw the Most Challenge?

The same five, in the same order, year after year. General environmental benefit claims — "eco", "green", "earth-friendly" — because they assert a broad benefit with no evidence behind them. Recycled content claims where the fraction or the scope is unclear. Claims about a component presented as claims about the product. "Recyclable" claims that say nothing about whether collection exists where the buyer lives. And certifications or seals presented without the standard behind them.

Each of the five has the same structural weakness: the words do work the evidence cannot carry. The fix is not more evidence, it is narrower words. A claim that says less is easier to substantiate and, in a category where buyers are sceptical, it usually performs better as well.

How Do You Qualify a General Environmental Benefit Claim?

You usually do not qualify one — you replace it. A general benefit claim asserts that the product is environmentally preferable overall, and substantiating that requires a life-cycle view across every stage and impact category, which almost no single-product programme can produce. The guidance is explicit that these claims are difficult to substantiate, and the practical advice for a buyer is to find the specific fact the general claim was standing for and print that instead.

Where a general claim is genuinely required by a customer, restrict it to the attribute that is evidenced and say so on the same panel. "Lower impact than our previous model, measured on [attribute]" is a comparison with a stated basis. "Better for the planet" is not, and no amount of documentation turns it into one.

What Counts as a Competent and Reliable Scientific Basis?

Evidence of the type and quality that an expert would accept for the claim being made: competent testing, conducted by a method appropriate to the attribute, with enough samples and enough controls to support the conclusion, and with the results analysed properly. A single test on a single sample is not a basis for a comparative claim; a certificate of input is not a basis for a performance claim; a supplier statement is not a basis for anything on its own.

Two practical tests. Would the evidence convince a competent person who does not work for you? And does the evidence match the claim in scope — same product, same attribute, same market? Where the answer to either is no, the claim is unsubstantiated at the moment it is made, and the remedy is to narrow the claim rather than to commission a study after launch.

The third test is about independence. Evidence produced by the party making the claim is not worthless, but it carries less weight than evidence produced by a laboratory working to an accredited method, and the gap widens as the claim gets broader. Where a number is going to be printed on a product and repeated in a tender, commission it from an accredited laboratory on production goods and keep the report with its scope statement; the cost is modest and the document ends most arguments before they start.

1. Attribute

What exactly is being claimed, named as a technical attribute?

2. Method

Which test method or standard produced the number?

3. Sample

How many units or lots, and are they production goods?

4. Scope match

Does the evidence cover the same product, attribute and market as the claim?

5. Timing

Does the evidence exist today, and is it dated before the claim went live?

How Do Certifications and Seals Have to Be Presented?

Clearly, with the standard named, and with the scope of what was certified stated near the mark. A seal without a name is an unattributed endorsement; a seal whose name the reader cannot look up is worse. Where the certification covers a component or a site rather than the finished product, say so in the same visual field as the seal, in legible type.

There is a second discipline here that programmes get wrong: only use a mark you are entitled to use. Certification marks are licensed to certified parties for certified goods, and using one on a product that is not covered is a separate problem from the claim itself. Check the licence terms before the artwork is approved, and keep the licence reference in the claim file.

What Does "Recyclable" Require Before You Print It?

It is a different claim from recycled content, and it is substantiated by a different evidence set. A recyclable claim is about end of life: whether the product can be collected, separated and reprocessed in the market where it is sold. A material that is technically recyclable in one country with mature collection is not recyclable in the hands of a consumer in a market without it, and the claim has to reflect the market of sale, not the material in principle.

For a multi-material product the question is harder, because a bag is rarely a single material. Where the product has to be disassembled before any part of it can be recycled, a bare recyclable claim is difficult to support, and the defensible version names the part and the condition: which component, and what the consumer has to do. Confirm the current treatment of recyclability claims in your market before publishing.

How Do You Handle Claims About a Component Only?

Say which component, on the same panel, in the same type size. The guidance treats an unqualified claim as a claim about the product, so a claim about the shell that reads as a claim about the bag is a misdescription even where the shell claim itself is true. The most common version of this is artwork: a large statement on the front and a small qualifier on the back.

Where a component claim is the only one you can support, it is still worth making, and it can be made prominently. "Shell fabric made with recycled polyester" is a strong sentence. The error is not in claiming a component; it is in letting the reader believe the component is the product. Two disciplines hold the line: keep the component word — shell, lining or trim — inside the claim sentence itself rather than in a footnote, and keep a single master sentence that every surface copies verbatim, so no local version can quietly widen the scope.

What Should Be Documented Before the Copy Goes Live?

A one-page substantiation sheet per claim: the sentence, the attribute, the method, the sample basis, the date the evidence was produced, the document references, and the signature of the person who approved it. It takes twenty minutes and it is the difference between a claim you can defend and a claim you have to withdraw.

Add the artwork to the same sheet. Imagery, colour and glyphs are part of the claim and they are reviewed as part of it. Where the design implies a broader benefit than the words, the design is the finding, and the fix belongs in the artwork brief rather than in the copy.

Who Inside the Buying Organisation Signs the Claim Off?

One named person, with the authority to say no, and a rule that nothing goes live without that signature. Most claim problems are not drafting problems, they are process problems: a listing is localised, a bullet is shortened, an image is swapped, and the change is never re-reviewed. A single named owner with a version-controlled master sentence stops almost all of them.

Give that owner two things: the master claim file, and a standing instruction that any change to wording, artwork or material re-opens the review. The instruction is the whole control. Where it is written down and repeated at every launch, it holds; where it lives in the memory of one person, it lasts one season.

What Happens When a Claim Is Challenged After Launch?

Three steps, in order. Produce the substantiation sheet for the exact wording that was published, dated before launch. If it exists and it matches, respond with it and close the matter. If it does not exist, or it does not match the published wording, withdraw or amend the claim immediately and then investigate how the wording got published without the file.

The third step is the one organisations skip, and it is where the value is. A claim that was published without a substantiation sheet is a process failure, and the fix is a control — a named owner, a version-controlled master sentence, a mandatory re-review — not a rewrite of the sentence. Programmes that only fix the sentence repeat the failure within two seasons.

There is also a commercial step that belongs in the first hour: tell the customer or the platform what you are doing. A voluntary amendment, communicated with the corrected substantiation, is usually treated as a correction. The same amendment made after an enforcement contact is treated as a withdrawal, and the difference is visible on the listing and in the relationship. Where a claim has to come down across a range, sequence it by exposure — marketplace titles first, then product copy, then printed packaging — because the printed stock is the slowest to change and the least visible to a regulator.

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