Regulation and sustainability
Labelling and what your product claims
Every claim on a label has to be backed by a document.
Everything a label says is a claim someone can ask you to prove: that it is recyclable, that it contains recycled content, where it comes from, that it meets a standard. The label is the easy part; the paperwork behind it is not.
Each claim, its backing
| If you claim… | You need… | Who holds it |
|---|---|---|
| Composition or material | The supplier's data sheet, current | Your supplier |
| Recycled content percentage | A declaration or certificate with its date | Your supplier, sometimes with testing |
| Origin | Upstream traceability documentation | The whole chain, and it takes longest |
| Compliance with a standard | Certificate or declaration of conformity | A body or yourselves |
| Any environmental benefit | Specific backing for that specific claim | Depends what you claim |
Important
The last row is where most companies get into trouble unintentionally. Generic environmental claims — "environmentally friendly", "sustainable" — without concrete, verifiable backing are increasingly scrutinised, and responsibility sits with whoever places the product on the market, not the supplier who said it verbally.
The practical rule
Before putting something on a label, ask: if tomorrow I am asked to prove this, with what document and who has to give it to me? If the answer is "I will ask the supplier", ask before printing the label, not after.
Watch out
Supplier changes are where this breaks. If you change the supplier of a component and the label keeps making the same claim, that claim may have stopped being true without anyone noticing.
Frameworks cited
Consumer information, environmental claims and their substantiation, product-specific labelling rules, and where applicable the requirements of any certifications you use as an argument. What you may claim and with what backing is confirmed by your adviser: this only explains how to have the backing gathered and dated.
Worth knowing
Marking backing documents for annual review is what stops a label printed three years ago from still claiming something no longer supportable.
›Is a supplier declaration enough?
It depends on the claim; some need testing. Ask before assuming.
›What if the supplier changes the formula?
The claim may stop being true: hence periodic review.
›Who answers if a claim is false?
Usually whoever places the product on the market; confirm for your case.
A real case
The situation
A company changes packaging supplier and keeps the label with the previous recycled content figure.
What you do
- Requests the new supplier's data sheet before printing more
- Marks the sheets for annual review
What you get
Spots that the figure has changed before anyone asks.
The situation
The label claims something and nobody knows what backs it.
What you do
- Links each claim to its document
What you get
Every line on the label has its paper behind it.
The situation
The supplier changes and the claim stops being true.
What you do
- Reviews labels when suppliers change
What you get
The label keeps telling the truth.
The situation
A client asks you to evidence one specific claim.
What you do
- Checks that reference's file
What you get
You answer without searching email.
The situation
The label is approved without reviewing what it claims.
What you do
- Reviews claim by claim before printing
What you get
Reprinting a whole run is avoided.
The situation
The document backing a claim expires.
What you do
- Records its validity when filing it
What you get
The warning arrives before the label stops being true.
This article answers
- what can i put on the label
- product environmental claims
- claiming recyclable requirements
- greenwashing what documentation do i need