← Back to Info Hub

The Recycling Partnership Calls on Federal Trade Commission to Create Rigorous, Data-Driven Approach to Determine Recyclability

Comments underline need for accurate, transparent recyclability claims on product labels

 Washington, D.C. April 19, 2023 – In comments submitted to the Federal Trade Commission today on its Guides for the Use of Environmental Marketing Claims (“Green Guides”), The Recycling Partnership called for a rigorous, data-driven approach to determine recyclability, combined with accurate, transparent recyclability claims on product labels.  

Research conducted by The Recycling Partnership (“The Partnership”), a mission-driven NGO dedicated to improving recycling nationwide, shows that 78% of consumers rely on recycling information on product labels.  However, two-thirds of those who look at labels find them confusing. The study also indicates that 82% of Americans feel misled if product labels inaccurately imply an item is recyclable but in fact cannot be recycled into something new.   

“Our research demonstrates why accurate recyclability claims are critical to maintaining consumer confidence and ultimately participation in recycling,” said Keefe Harrison, Chief Executive Officer of The Partnership. “The Green Guides need an updated approach to provide consistent national guidance for clear, accurate, and accountable claims that both reflect the current environment and adapt to the future.”  

The Partnership’s recommendation for a new standard of determining recyclability is based on its “Pathway to Circularity Framework”, developed in collaboration with leaders from across the recycling value chain. Under the new approach, to claim that a package is recyclable, it must be:  

  1. Designed for recycling following industry guidelines; 
  2. Accessible to be collected or accepted for recycling by a substantial majority of consumers; 
  3. Able to be effectively sorted for recycling at a recycling sortation facility;  
  4. Accepted by the recycling industry for use in the production of new packaging or products – meaning there are sufficient end markets; and 
  5. Effectively recognized as recyclable by consumers. 

“Our proposed standard for recyclability claims builds on the access requirements set out in the Green Guides to provide definitive guidance to determine if an item is actually recyclable – not just accessible for recycling,” said Sarah Dearman, Chief Innovation Officer of The Partnership. “Our comprehensive national approach will lead to more accurate and clear recycling instructions, boosting consumer confidence that their recycling efforts actually do good for the environment.”  

To read The Recycling Partnership’s full FTC Green Guides comment submission, please visit recyclingpartnership.org/green-guides  

View our Submission to the FTC


About The Recycling Partnership 

At The Recycling Partnership, we are solving for circularity. As a mission-driven NGO, we are committed to advancing a circular economy by building a better recycling system. We mobilize people, data, and solutions across the value chain to reduce waste and our impact on the environment while also unlocking economic benefits. We work on the ground with thousands of communities to transform underperforming recycling programs; we partner with companies to achieve packaging circularity, increase access to recycled materials, and meet sustainability commitments; and we work with government to develop policy solutions to address the systemic needs of our residential recycling system and advance a circular economy. We foster public-private partnerships and drive positive change at every step of the recycling and circularity process. Since 2014, we have diverted 770 million pounds of new recyclables from landfills, avoided more than 670,000 metric tons of greenhouse gases, and driven significant reductions in targeted contamination rates. Learn more at recyclingpartnership.org.