1. General information on environmental claims

Environmental claims relate only to the product, material or configuration variant expressly specified and to the particular environmental aspect described. They do not constitute a comprehensive assessment of a product’s environmental or social sustainability or of its entire life cycle.

Depending on the environmental claim, different requirements, assessment methods and framework conditions may apply. The relevant limitations and supporting evidence are explained in the corresponding glossary entry.

2. Structure of the Glossary

2.1 Product Segments

As environmental terms may have different meanings and requirements depending on the product and material, the glossary is divided into the following product segments:

3. Product Segment: Stand-up pouches, flat pouches & flexible packaging

3.1 Recyclable / Suitable for Recycling

The terms “recyclable” and “suitable for recycling” describe, in this context, the suitability of packaging for a recycling process in which the recovered materials can be reused as secondary raw materials in applications typical of the respective material. The assessment takes the complete packaging structure into account.

For stand-up pouches and flat pouches, the ability to sort and recycle the packaging may be affected not only by the main material, but in particular by barriers and coatings, printing inks and varnishes, adhesives, and additional components such as zippers or closures. Actual collection, sorting and recycling also depend on the intended disposal and recycling route and on the recycling infrastructure available.

Basis for the claim: The ZSVR Minimum Standard for determining the recyclability of packaging – 2025 edition contains specific assessment requirements for flexible PE and PP packaging, including bags, stand-up pouches and pouches (Annex A 2.11 and A 2.13), and takes into account the material structure, sortability, recycling pathway and available recycling infrastructure. For flexible packaging, the CEFLEX D4ACE Design Choices and the RecyClass Design for Recycling Guidelines for flexible PE films and flexible PP films are additionally used to assess the material structure and packaging components within the respective recycling stream. 

3.2 Mono-Material / Packaging Structure Designed for Recycling

“Mono-material” refers to a flexible plastic packaging structure in which one polymer type, such as PE or PP, accounts for the vast majority of the material. In the CEFLEX D4ACE context, a mono-material approach is based on a main component comprising more than 95% of a single polymer type.

A packaging structure designed for recycling also takes into account the compatibility of the materials and packaging components used with the intended recycling stream. A mono-material structure therefore cannot automatically be equated with recyclability. Barriers, coatings, adhesives, printing inks, varnishes, closures and other components may affect sortability and recyclability.

Basis for the claim: The term “mono-material” is based on product-specific material data and the composition of the complete packaging structure. The CEFLEX D4ACE Guidelines on the mono-material approach and the current CEFLEX D4ACE Design Choices provide guidance on mono-PE and mono-PP structures and on the influence of additional packaging components. The RecyClass Design for Recycling Guidelines for flexible PE packaging and flexible PP packaging assess the material composition as well as barriers, adhesives, closures, printing inks and other components with regard to their compatibility with the respective recycling stream. For Germany, the ZSVR Minimum Standard contains specific assessment criteria for flexible PE and PP packaging, including bags, stand-up pouches and pouches. 

3.3 Sustainable / Environmentally Friendly / Resource-Efficient

The terms “sustainable”, “environmentally friendly” and “resource-efficient” are broad environmental claims that may relate to different environmental characteristics and stages of the life cycle. When used in connection with a pouch variant, these terms therefore refer exclusively to the environmental aspect expressly specified, such as reduced material use or a specifically assessed recycling-related property. A single environmental characteristic does not provide a basis for a comprehensive positive assessment of the pouch as a whole or of its entire life cycle. This qualification must be made clearly and prominently in the immediate vicinity of the claim itself (e.g. on the same packaging surface or within the same online sales interface), so that the claim is not considered a generic environmental claim within the meaning of Directive (EU) 2024/825.

Where the claim is additionally quantified (e.g. percentage figures relating to environmental footprint, cost savings or resource consumption), a clearly identifiable and verifiable source for the specific figure must be stated in the immediate vicinity of the claim. If no such source is available, the quantified claim must be removed or replaced with a general, unquantified and narrowly defined statement in accordance with paragraph 1. This clarification does not retrospectively substantiate figures that have already been published where the source cannot be identified (e.g. “environmental footprint -85%”, “business costs -15%” in the mono-materials article) – the internal search for supporting sources for these figures therefore remains outstanding.

Basis for the claim: The respective claim is based on product-specific data or assessments relating to the environmental aspect expressly stated. For flexible packaging, the CEFLEX D4ACE Guidelines are used in particular to assess recycling- and circularity-related characteristics. Environmental impacts across the life cycle can be assessed using the LCA Guidance for Flexible Packaging published by Flexible Packaging Europe. Claims relating to resource efficiency are based on the relevant material and weight data; the IFEU studies on the resource efficiency of flexible packaging may also be used as a technical basis. Quantified individual values must additionally be substantiated by a specific source that is identifiable in the context of the claim. 

3.4 Material Savings / Reduced Material Use

Claims relating to material savings or reduced material use describe a reduction in the amount of material used for a packaging solution compared with a defined reference basis. For comparative or quantified claims, the amount of material is compared using a comparable functional reference, for example for the same or a comparable fill volume. The necessary functions of the packaging, in particular the protection of the contents, must be maintained. Reduced material use refers solely to the amount of material saved and does not constitute a comprehensive assessment of the packaging’s environmental impact.

For specific percentage claims (e.g. “up to X% less material”), the comparison packaging must be clearly identified in the immediate context of the claim, and the figure used must be demonstrably derived from the underlying study rather than from a different, unspecified calculation.

A reduction in weight or volume that merely meets the statutory minimum requirements for minimising packaging weight and volume under Regulation (EU) 2025/40 (PPWR) (Article 10, Annex IV) must not be promoted as a separate, voluntary environmental benefit. Material savings that go beyond the applicable statutory minimum requirement may be communicated, provided that this additional benefit is clearly identified in the immediate vicinity of the claim.

Basis for the claim: The claim is based on product-specific material and weight data for the packaging variants under consideration. For comparative or quantified claims, the comparison packaging, the functional reference and the resulting material savings are also taken into account. The IFEU study “Resource Efficient Packaging” for Flexible Packaging Europe assesses the resource efficiency of comparable packaging systems based on material and energy use as well as material losses, and includes a flexible stand-up pouch as one of its case studies. In addition, Flexible Packaging Europe documents the importance of low material use and packaging weight for this product segment. The requirements for minimising packaging weight and volume while maintaining packaging functionality are also set out in Regulation (EU) 2025/40 on packaging and packaging waste (PPWR), in particular Article 10 and Annex IV. The distinction between statutory minimum requirements and voluntary measures that go beyond those requirements follows the provisions of Directive (EU) 2024/825 on empowering consumers for the green transition (Empowering Consumers Directive). 

3.5 CO₂e / Greenhouse Gas Balance / Transport Emissions

CO₂e (carbon dioxide equivalents) is a unit of measurement used to express the climate impact of different greenhouse gases on a comparable basis. Claims relating to greenhouse gas or transport emissions refer to the defined scope of assessment and the emission sources included within that scope.

The result of a greenhouse gas calculation depends, among other factors, on the system boundaries defined, the reference unit and the data and emission factors used. For comparative claims, the underlying basis of comparison is also relevant. The claim describes the climate impact within the respective scope of assessment and does not constitute a comprehensive assessment of other environmental impacts of the packaging.

The scope of assessment may also include customer-related, Scope 3-type claims (e.g. “...can reduce a company’s carbon footprint”), provided it remains clear that the reduction relates to lower material use or transport requirements for the customer’s business and not to the product itself. This entry does not cover claims formulated as conclusive, product-related carbon neutrality or offsetting claims. These fall under the separate restricted entry “Carbon neutral” and are inherently prohibited.

Basis for the claim: The respective claim is based on a product-specific greenhouse gas calculation with a defined scope of assessment, system boundaries, reference unit and calculation data. The LCA Guidance for Flexible Packaging specifically addresses flexible packaging and sets out how to define system boundaries and functional reference units, select appropriate data, and account for transport and greenhouse gas emissions within the relevant life cycle. In addition, the IFEU comparative study on flexible pouches and alternative packaging illustrates how climate impacts and transport are taken into account in the life cycle assessment of pouch packaging and compared with functionally equivalent packaging systems. 

3.6 Material Cycle / Circularity

In this context, the term “material cycle” describes the route through which recoverable packaging materials can be returned to material use after collection, sorting and recycling. Whether a stand-up pouch or flat pouch variant is suitable for such a recycling route depends, among other factors, on the complete packaging structure, sortability, the intended recycling route and the available recycling infrastructure.

The claim does not mean that the material used is actually kept fully or permanently within a closed material loop or reused at the same level of quality.

Basis for the claim: The classification is based on product-specific material data and an assessment of the respective packaging variant for the intended recycling route. The CEFLEX D4ACE Guidelines describe the design of flexible packaging for collection, sorting and recycling, with the aim of returning recovered materials to material use. The ZSVR Minimum Standard 2025 contains specific assessment categories for flexible PE and PP packaging, including bags, stand-up pouches and pouches, and takes into account factors including recoverable material content, sortability, recycling routes and recycling infrastructure. In addition, the RecyClass Packaging Recyclability Methodology using a specific PE pouch example, shows how the packaging structure, local collection, sorting and recycling, as well as the potential impact of individual packaging components on recyclate quality, are assessed. 

3.7 Disposal / Yellow Bin / Waste Paper

Disposal instructions describe the intended collection route for the respective packaging variant. In Germany, emptied plastic packaging generated by private end consumers should generally be placed in the collection system for lightweight packaging, for example the Yellow Bin (Gelbe Tonne) or Yellow Bag (Gelber Sack); in some regions, a recycling bin (Wertstofftonne) may be provided instead.

Empty paper, paperboard or cardboard packaging is generally collected through the waste paper collection system. For paper-based composite packaging, coatings or other material components, the appropriate collection and recycling route may differ. The specific packaging structure and the disposal requirements applicable to the respective packaging variant are therefore decisive.

Basis for the claim: The allocation of collection routes in Germany is based on the current information provided by the German Environment Agency (Umweltbundesamt) on packaging law and packaging disposal. For the product-specific classification, the ZSVR Minimum Standard for assessing packaging design for recycling – 2025 edition is also used. It contains specific categories for flexible PE and PP packaging, including bags, stand-up pouches and pouches, as well as for flexible paper packaging and paper-based composite packaging. The specific disposal information is additionally determined by the material data and the complete structure of the respective packaging variant. 

3.8 Organic / Organic Products

The term “organic” refers in this context to the packaged product or to the intended use of the packaging for organic products. It does not describe a material property of the packaging itself.

Using packaging for organic products therefore does not mean that the stand-up pouch or flat pouch itself is bio-based, biodegradable, compostable or recyclable. Each of these terms describes a separate property that must be assessed independently.

Basis for the claim: The use of the terms “organic” and “ecological” for products is governed by Regulation (EU) 2018/848 on organic production and labelling of organic products. The Ökolandbau.de information portal on packaging for the organic sector explains the requirements for packaging used for organic food products and makes clear that the organic status of the food does not in itself imply a corresponding material property of the packaging. The distinction between packaging properties such as “bio-based”, “biodegradable” and “compostable” is also supported by the information provided by the German Agency for Renewable Resources (Fachagentur Nachwachsende Rohstoffe) on bioplastic packaging. 

3.9 Environmental Influences

In this context, the term “environmental influences” refers to external factors affecting the packaged product, such as oxygen, moisture or light. Depending on the material structure, the packaging’s barrier and protective properties can help protect the contents from these influences and limit adverse effects on aroma or quality.

The claim therefore describes a product protection function and does not refer to a positive environmental impact of the packaging.

Basis for the claim: The respective claim is based on the product-specific technical material data and barrier properties of the packaging variant concerned. The CEFLEX D4ACE overview “Materials and their Properties” describes, specifically for flexible packaging materials, properties including gas, moisture, aroma and light barriers. The current CEFLEX D4ACE Design Principles confirm the importance of product-specific barrier functions, such as protection against gases and moisture, for flexible packaging. In addition, the LCA Guidance for Flexible Packaging published by Flexible Packaging Europe describes the different barrier properties of typical flexible packaging materials, including against moisture, gases, oxygen and light. 

3.10 Reusable / Multiple-Use

“Reusable” describes packaging that is designed and placed on the market to be reused multiple times and to complete several rotations during its life cycle.

This is distinct from resealability during the use of a packaged product. A zipper or press-to-close seal allows a stand-up pouch or flat pouch to be opened and closed repeatedly, but this alone does not make it reusable packaging.

Basis for the claim: The classification of reusable packaging is based on the requirements of Regulation (EU) 2025/40 on packaging and packaging waste (PPWR), in particular Article 11. Under these requirements, reusable packaging must be designed for repeated reuse and multiple rotations and must meet further requirements relating, among other things, to emptying, refilling, safety, hygiene and reconditioning. Flexible Packaging Europe describes zippers and comparable closure systems used in flexible packaging as re-closing devices. The resealability of a specific pouch is additionally based on the technical characteristics of the closure system used. 

3.11 Recycled Content / Recyclate Content

The terms “recycled content”, “recyclate content” and “made from recycled material” describe, in this context, packaging that is manufactured wholly or partly from material that has already been recycled (post-consumer or post-industrial recyclate). This is a claim about the material used in manufacturing (an input characteristic). 

This claim must be clearly distinguished from 3.1 “Recyclable / suitable for recycling”: 3.1 describes the suitability of the packaging for recycling after use (an end-of-life characteristic), whereas 3.11 describes how much previously recycled material is contained in the packaging itself. Packaging may be recyclable without containing any recyclate, and vice versa. The two claims must not be combined or used interchangeably.

For stand-up pouches and flat pouches, it must also be taken into account that the use of recyclate in flexible plastic films is assessed differently, both technically and from a regulatory perspective, from its use in paper or cardboard products (e.g. recycled paper in shipping boxes). Any stated percentage must refer to the actual recyclate content used in the respective film and cannot simply be transferred from other product segments.

A legally required minimum recycled content (e.g. under Regulation (EU) 2025/40 on packaging and packaging waste, PPWR) must not be promoted as a separate environmental benefit, as compliance with statutory minimum requirements does not constitute an additional environmental performance. However, a recyclate content that exceeds the applicable statutory minimum may be communicated, provided that the additional proportion is clearly identified in the immediate vicinity of the claim.

Basis for the claim: DIN EN 15343:2008-02 “Plastics – Recycled plastics – Plastics recycling traceability and assessment of conformity and recycled content; German version EN 15343:2007”, RecyClass Recycled Plastic Traceability Certification, ISCC PLUS. In addition, the requirements of Directive (EU) 2024/825 on empowering consumers for the green transition (Empowering Consumers Directive) must be taken into account, according to which environmental claims must not be made without substantiation or validation, as well as the requirements of Regulation (EU) 2025/40 (PPWR) regarding statutory minimum recycled-content levels. 

4. Product Segment: Labels

4.1 Recyclable / Recyclability of Label Materials

The terms “recyclable” and “suitable for recycling” describe, in this context, the suitability of a label for entering a recycling process together with the packaging to which it is applied (e.g. a bottle, cup or folding box), without significantly impairing the sortability or recyclability of the overall packaging. The label and the packaging are always assessed as a complete system rather than the label being considered in isolation.

For labels, factors that may affect the sortability and recyclability of the complete packaging include, in particular, the label material itself (paper or plastic film), material compatibility with the packaging substrate (e.g. a PP label on a PET bottle acting as a contaminant), the type of adhesive and its removability during the respective recycling process (wash-off behaviour), the size of the label or the proportion of the packaging surface that it covers, as well as printing inks and any coatings. Whether a label is ultimately suitable for recycling therefore always depends on its specific interaction with the respective packaging and the intended recycling route.

Basis for the claim: The ZSVR Minimum Standard for determing the recyclability of packaging – 2025 edition assesses labels as a potential factor influencing the recyclability of the respective packaging substrate, including in terms of material compatibility, removability and degree of coverage. For the respective substrate materials — including PET bottles, PE films, PP films, HDPE containers and PP containers — the RecyClass Design for Recycling Guidelines assess the compatibility of the label material and adhesive with the respective recycling stream and classify labels, depending on their design, as non-disruptive, disruptive or as rendering the packaging non-recyclable. In addition, the FINAT white paper on the role of self-adhesive labels in PET recycling uses test data to show how label material, adhesive and size affect the recyclability of PET packaging; the FINAT Test Methods provide the underlying test procedures. 

4.2 Recycled Paper / Recycled Material / Recycled Film

The terms “recycled paper”, “recycled material” and “recycled film” describe, in this context, label materials that are manufactured wholly or partly from material that has already been recycled (post-consumer or post-industrial recyclate). This is a claim about the material used in manufacturing (an input characteristic), not about the recyclability of the label after use.

This claim must be clearly distinguished from 4.1 “Recyclable / recyclability of label materials”: 4.1 describes the suitability of the label (together with the packaging to which it is applied) for recycling after use (an end-of-life characteristic), whereas 4.2 describes how much previously recycled material is contained in the label material itself. A label may be recyclable without containing any recyclate, and vice versa. In addition, the use of recyclate in paper labels must be assessed differently, both technically and in terms of certification, from its use in plastic film labels. Any stated percentage must always refer to the material actually used in the respective label variant and cannot simply be transferred to other label types.

Basis for the claim: For paper labels, the Blue Angel DE-UZ 14b “Finished Products Made from Recycled Paper and Cardboard” (overview page) sets out specific requirements for the minimum proportion of recovered paper required for a product to be labelled as recycled paper. For plastic film labels, DIN EN 15343:2008-02 on traceability and the assessment of recycled content, together with the RecyClass Recycled Plastic Traceability Certification and ISCC PLUS, provide the basis for substantiating the actual recyclate content used. 

4.3 Paper Labels / Plastic-Free

The terms “paper label” and “plastic-free” describe, in this context, a label whose facestock is made from paper rather than plastic film. This claim relates exclusively to the material specifically referred to and does not automatically apply to the label as a whole.

In addition to the facestock, a paper label generally consists of other components such as adhesive, release liner and, where applicable, coatings or laminates, which may themselves contain plastic. The claim “plastic-free” is therefore only permissible if it is clearly limited to the specific component concerned (e.g. “plastic-free facestock”) or if all components of the label — including the adhesive, liner and any coatings — are in fact free from plastic. A claim that relates only to the facestock but gives the impression that the entire label is plastic-free constitutes an impermissible claim about the product as a whole where the actual benefit applies only to one component.

Basis for the claim: The ZSVR Minimum Standard 2025 contains specific assessment categories for paper labels and paper-based composite materials and takes into account the complete material structure, including adhesives and coatings. Under Directive (EU) 2024/825 on empowering consumers for the green transition (Empowering Consumers Directive), claims relating to a product as a whole are not permitted where the environmental characteristic claimed actually applies only to a specific component or aspect of the product. Unless all components meet the claimed characteristic, the claim must therefore be clearly limited to the component actually concerned (e.g. the facestock). 

4.4 Blue Angel

“Blue Angel” refers to the German environmental label awarded by the Federal Ministry for the Environment and administered by RAL gGmbH. Use of the label is only permitted if the respective label, or the paper or cardboard material used, meets the specific award criteria for the applicable certification category and a valid certificate has been issued by the responsible awarding body.

For labels, the DE-UZ 14b “Finished products made from recycled paper and cardboard” category is particularly relevant. It specifies a minimum proportion of recovered paper as well as additional requirements, for example relating to harmful substances and the manufacturing process. Any “Blue Angel” claim may refer only to the specific certified material or product and cannot be transferred to other, non-certified label variants within the same product range. If the certificate expires or is withdrawn, use of the label must cease immediately. 

Basis for the claim: The Blue Angel DE-UZ 14b award criteria, Version 6 (overview page), set out the specific requirements for recovered paper content, the absence of harmful substances and other criteria governing the award of the label to products made from recycled paper and cardboard. Under Directive (EU) 2024/825 (Empowering Consumers Directive), claims relating to labels and certifications are only permitted where they are based on a certification scheme with publicly available criteria or are awarded by a public authority — both conditions are met by the Blue Angel as a government-backed environmental label. 

4.5 FSC / PEFC / Certified Paper Fibres

The terms “FSC” and “PEFC” refer to the chain-of-custody certification of paper and pulp fibres used in a label. They confirm that the paper fibres used originate from forests managed in accordance with the respective standards of the Forest Stewardship Council (FSC) or the Programme for the Endorsement of Forest Certification (PEFC), and that the traceability of the fibres is fully documented throughout the entire supply chain.

Use of the FSC or PEFC logo, or a corresponding certification claim, on a label is only permitted if a valid chain-of-custody certificate is in place for the specific label or the underlying paper fibre supply. For labels applied to other packaging, it must also be ensured that the certification claim correctly refers to the fibre content of the label itself and does not misleadingly imply that the entire packaging, including the container to which the label is applied, is certified where this is not the case. Any combination of certified and non-certified fibres (e.g. under mixed-source certification) must be labelled in accordance with the applicable rules of the respective certification scheme.

Basis for the claim: The FSC Chain of Custody Standard FSC-STD-40-004 V3-1 sets out the requirements for the traceability of certified fibres and the correct use of the FSC logo; the FSC Germany interpretation INT-STD-40-004_67 further specifies its application specifically to labels applied to packaging. The FSC Germany overview on logos and trademarks provides additional guidance on the correct use of certification marks. For PEFC, the corresponding Chain of Custody rules of the Programme for the Endorsement of Forest Certification Schemes apply. 

4.6 Wash-off / Detachable Labels in the Recycling Process

The terms “wash-off” and “removable during the recycling process” describe, in this context, the ability of a label and its adhesive to detach completely and without leaving residues from the packaging substrate under the conditions prevailing in the relevant recycling process (e.g. wash liquor temperature, pH value and residence time). This property relates exclusively to the behaviour of the label and adhesive during the recycling process for the packaging substrate and must be distinguished from the general recyclability of the label material itself (see 3.1).

Whether a label can actually be considered “wash-off” depends on the specific adhesive formulation, the label material, the label size or surface coverage, and the specific process conditions of the respective recycling facility. A wash-off property demonstrated under test conditions for a particular recycling stream (e.g. PET bottle recycling) cannot automatically be transferred to other packaging substrates or recycling processes. The claim must therefore clearly relate to the specific recycling stream tested and the underlying test conditions.

Basis for the claim: The RecyClass Design for Recycling Guidelines assess, for the respective packaging substrates, including PET bottles, the removability of label adhesives under defined washing and process conditions and classify them as non-disruptive, detrimental or incompatible with recycling. The FINAT white paper on the role of self-adhesive labels in PET recycling documents, on the basis of test data, the removal behaviour of different adhesive and label combinations during the washing process; the FINAT Test Methods specify the underlying test procedures for assessing the wash-off property. In addition, the ZSVR Minimum Standard 2025 takes the removability of labels into account as an assessment criterion for the recyclability of the overall packaging. 

4.7 Film Labels made of PP, PE, PET or PVC

The stated polymer type (PP, PE, PET or PVC) for film labels describes the material from which the label is made. Whether a film label is compatible with the recycling of the respective packaging substrate depends largely on whether the polymer type of the label matches that of the packaging container or can at least be separated or tolerated in the relevant recycling process.

PVC film labels in particular are regarded as a significant contaminant in almost all common plastics recycling streams, as PVC is not compatible with PET, PE or PP recycling processes and even small amounts can impair the quality of the entire recyclate. The use of PVC film labels on recyclable packaging substrates should therefore generally be avoided. For PET, PE and PP film labels, it must also be taken into account that simply matching the material of the label to that of the packaging container (mono-material approach) does not in itself guarantee recyclability. Adhesives, printing, coatings and other components may still impair sortability and recyclability even where the same polymer type is used.

Basis for the claim: The RecyClass Design for Recycling Guidelines assess, for the respective packaging substrates — PET bottles, PE films, PP films, HDPE containers and PP containers — the compatibility of the respective label polymer type with the substrate material and classify PVC-containing labels in particular as contaminants that render the packaging incompatible with recycling. The ZSVR Minimum Standard 2025 likewise takes the material compatibility of the label and packaging substrate into account as an assessment criterion for the recyclability of the complete packaging. 

4.8 Environmental Influences / Human, Animal and Environment

Claims such as “harmless to humans, animals and the environment” or “environmentally compatible” refer, in this context, to the chemical safety of the materials used in the label (facestock, adhesive, printing inks and coatings) with regard to humans, animals and the environment when used as intended or following disposal. This claim describes a material safety characteristic and does not constitute a general claim of a positive environmental impact of the label.

Such a claim may only be made if the substances used comply with the applicable chemical legislation and do not contain relevant quantities of substances classified as being of particular concern (e.g. certain heavy metals in printing inks, PFAS or other substances restricted under REACH). The claim must also be limited to the specific application for which it has been assessed — a general safety claim must not be extended to aspects that were not covered by the underlying assessment (e.g. food contact where only general compliance with chemical legislation has been assessed).

Basis for the claim: The material safety of the materials used is governed by Regulation (EC) No 1907/2006 concerning the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH), which in particular provides for restrictions on substances of very high concern (SVHC) in Annex XVII, as well as notification and information obligations. Where the label is applied to food-contact packaging, the specific requirements for food-contact materials must also be taken into account; compliance with these requirements must be demonstrated separately and is not automatically covered by general REACH compliance. 

4.9 Resistance to Environmental Influences (Film Labels)

In this context, the term “resistance to environmental influences” describes the physical and chemical resistance of the film label itself to external factors such as moisture, water, acids, chemicals, UV radiation or greasy substances. This property relates to the durability and functionality of the label over its intended period of use and does not constitute a positive environmental impact of the label; it is purely a material property.

The actual level of resistance depends on the polymer type used (e.g. PP, PE, PET), the material thickness, any protective varnishes or laminates, and the adhesive system. A general claim such as “weather-resistant” or “resistant to environmental influences” is only permissible if it relates to the effects and test conditions actually assessed (e.g. a specific duration of UV exposure, chemical class or temperature range); an unspecified blanket claim without reference to the underlying test conditions should be avoided. This property must also be clearly distinguished from material safety with regard to humans, animals and the environment (see 4.8) — here, the claim concerns the resistance of the material, not its toxicological safety.

Basis for the claim: The respective claim is based on the product-specific technical material data of the label material used and on the underlying test results relating to chemical, moisture and UV resistance. The FINAT Test Methods set out recognised test procedures for assessing the material resistance of self-adhesive labels, including weathering and chemical resistance. Technical data sheets provided by the manufacturers of the film materials used serve as an additional product-specific basis of evidence for the particular effects and conditions tested. 

4.10 Sustainable / Environmentally Friendly for Labels

he terms “sustainable”, “environmentally friendly” and “resource-efficient” are broad environmental claims that may relate to different environmental characteristics and stages of the life cycle. When used in connection with a label variant, these terms therefore refer exclusively to the environmental aspect expressly specified, such as reduced material use, a specific recycled content or a specifically assessed recycling-related property. This qualification must be made clearly and prominently in the immediate vicinity of the claim itself (e.g. on the same label or within the same online sales interface), so that the claim is not considered a generic environmental claim within the meaning of Directive (EU) 2024/825. A single environmental characteristic does not provide a basis for a comprehensive positive assessment of the label as a whole or of its entire life cycle.

Where the claim is additionally quantified (e.g. percentage figures relating to recycled content, material savings or resource consumption), a clearly identifiable and verifiable source for the specific figure must be stated in the immediate vicinity of the claim. If no such source is available, the quantified claim must be removed or replaced with a general, unquantified and narrowly defined statement in accordance with paragraph 1.

Basis for the claim: The respective claim is based on product-specific data or assessments of the specifically stated environmental aspect. For labels, the RecyClass Design for Recycling Guidelines and the ZSVR Minimum Standard 2025 are used in particular to assess recycling- and recyclate-related characteristics. Under Directive (EU) 2024/825 on empowering consumers for the green transition (Empowering Consumers Directive), unqualified generic environmental claims are generally considered impermissible unless recognised excellent environmental performance can be demonstrated, for example through Regulation (EC) No 66/2010 (EU Ecolabel) or through a recognised environmental labelling scheme in accordance with EN ISO 14024 — unless the claim is clearly limited to the specific environmental aspect as described in paragraph 1. Quantified individual values must additionally be substantiated by a specific source that is clearly identifiable in the immediate context of the claim. 

5. Product Segment: Folding boxes

5.1 Recyclable / Recyclability of Folding boxes

The terms “recyclable” and “suitable for recycling” describe, in this context, the suitability of a folding box for a recycling process in which the recovered paper fibres can be reused as secondary raw materials in applications typical of the material. The assessment takes the complete board structure into account, not just the main fibre component.

For folding boxes, factors that may affect sortability and recyclability include, in particular, protective varnishes, protective laminates (matt/gloss/soft-touch), hot foil stamping, adhesives and functional barrier layers (e.g. for food or moisture protection). Plastic laminates and coatings in particular may act as contaminants in the paper recycling process, depending on their proportion and removability. Actual collection, sorting and recycling also depend on the intended disposal route and the recycling infrastructure available.

Basis for the claim: The ZSVR Minimum Standard for determing the recyclability of packaging – 2025 edition contains specific assessment criteria for paper, board and cardboard packaging, including folding boxes, and takes into account the material structure, coatings, laminates and sortability. The 4evergreen Circularity by Design Guideline for Paper-Based Packaging, Version 4 / 2026, additionally assesses the recyclability of fibre-based packaging on the basis of material combinations, barrier layers and adhesives within the European waste-paper recycling stream. The FFI/PTS brief report on the recyclability of different folding-carton material combinations uses test data to examine how different finishes and material combinations affect the recyclability of folding cartons. In addition, the ECMA position paper on the recyclability of folding cartons and functional barriers addresses the compatibility of functional barrier layers with the paper recycling process. 

5.2 Recycled Board / High Recovered-Paper Content

The terms “recycled board” and “high recovered-paper content” describe, in this context, board used for folding boxes that is manufactured wholly or partly from previously recycled recovered paper (secondary fibre). This is a claim about the material used in manufacturing (an input characteristic), not about the recyclability of the folding box after use.

This claim must be clearly distinguished from entry 1 “Recyclable / recyclability of folding boxes”: entry 1 describes the suitability of the folding box for recycling after use (an end-of-life characteristic), whereas entry 2 describes how much previously recycled recovered paper is contained in the board material itself. A folding box may be recyclable without containing a significant proportion of recovered paper, and vice versa. At Labelprint24, this distinction applies in particular to secondary-fibre boards (GD1, GD2, GD3, GT) as opposed to primary-fibre boards (GC1, GC2, GGZ, GZ), which are made predominantly from virgin wood and pulp fibres. Any specific percentage stated for recovered-paper content must always refer to the board grade actually used and cannot simply be transferred to other board grades within the same product range.

Basis for the claim: The board stock used may in principle be certified in accordance with DE-UZ 14a; however, the finished folding box as a packaging product does not fall within the scope of a separate Blue Angel ecolabel category. The primary basis of evidence is therefore the FFI Folding Cartonboard Grade Directory and the ZSVR Minimum Standard 2025. The FFI Folding Cartonboard Grade Directory documents the technical characteristics and fibre composition of common primary- and secondary-fibre cartonboard grades (including GC1, GC2, GD1, GD2, GD3 and GT) and therefore serves as a product-specific substantiation basis for the respective cartonboard grade used. In addition, the ZSVR Minimum Standard 2025 contains specific assessment categories for paper and cartonboard packaging with different recovered-paper contents. 

5.3 Grass Board / Natural Board

The terms “grass board” and “natural board” refer to special board grades that differ from standard primary- and secondary-fibre boards in both fibre composition and appearance. Grass board consists of a blend of secondary fibre and grass fibre and is often marketed using claims such as “recyclable” or “compostable”; natural board consists of a blend of secondary fibre and primary fibre and has a brown, rough appearance. Die Begriffe „Graskarton" und „Naturkarton" bezeichnen Sonderkartonsorten, die sich in Faserzusammensetzung und Optik von den Standard-Primär- und Sekundärfaserkartons unterscheiden. Graskarton besteht aus einer Mischung von Sekundärfaser und Grasfaser und wird häufig mit Aussagen wie „recycelbar" oder „kompostierbar" beworben; Naturkarton besteht aus einer Mischung von Sekundärfaser und Primärfaser mit brauner, rauer Optik.

These terms require a differentiated assessment. “Recyclable” refers to suitability for paper recycling and must be assessed in the same way as under entry 1. “Compostable” must be considered separately and may only be claimed where testing in accordance with a recognised compostability standard is available; the use of grass fibre alone does not establish compostability in the legal sense. Both characteristics must be substantiated separately and must not be conflated, as a folding box may be recyclable without being compostable, and vice versa.

Basis for the claim: The section “Base material and alternative fibres” of the 4evergreen Circularity by Design Guideline for Paper-Based Packaging, Version 4 / 2026, assesses the use of alternative fibre sources such as grass fibre with regard to their compatibility with the established waste-paper recycling stream. The press release of the German Agency for Renewable Resources (Fachagentur Nachwachsende Rohstoffe, FNR) on innovative paper grades classifies grass-fibre paper from a technical perspective as an alternative, resource-efficient fibre source. A “compostable” claim additionally requires testing and certification in accordance with a recognised compostability standard (e.g. EN 13432); corresponding test evidence for the specific board grade used must be provided separately and falls outside the scope of the sources listed here. 

5.4 FSC / PEFC / Certified Paper Fibres

The terms “FSC” and “PEFC” refer to the chain-of-custody certification of paper and pulp fibres used in the board material of a folding box. They confirm that the paper fibres used originate from forests managed in accordance with the respective standards of the Forest Stewardship Council (FSC) or the Programme for the Endorsement of Forest Certification (PEFC), and that the traceability of the fibres is fully documented throughout the entire supply chain.

Use of the FSC or PEFC logo, or a corresponding certification claim, on a folding box is only permitted if a valid chain-of-custody certificate is in place for the specific product or the underlying paper fibre supply. For FSC, a distinction must also be made between the “FSC 100%”, “FSC Mix” and “FSC Recycled” labels, each of which requires different proportions of certified, mixed or recycled fibres; the label used must correspond to the actual fibre composition of the board concerned. Correct allocation of the appropriate label variant is particularly important for primary-fibre boards (e.g. GC1, GC2), as these generally contain a significant proportion of virgin fibre.

Basis for the claim: The FSC Chain of Custody Standard FSC-STD-40-004 V3-1 sets out the requirements for the traceability of certified fibres; the FSC Germany overview on paper and packaging, as well as the overview of the FSC 100%, FSC Mix and FSC Recycled label variants, further specify the correct application and distinction of the respective labels. For PEFC, the corresponding Chain of Custody rules apply in accordance with the PEFC overview on packaging and the PEFC technical documentation on Chain of Custody requirements. 

5.5 Coatings, Laminates & Finishes

Folding boxes can be finished in various ways, including protective varnishes (matt/gloss, optionally with a clear area for dates or codes), protective laminates (matt/gloss/soft-touch), hot foil stamping (gold/silver/bronze) and Braille elements. These finishes primarily serve a protective or decorative function and do not in themselves constitute an environmental claim. However, their use may affect the recyclability of the folding box within the meaning of entry 1 and must therefore be taken into account whenever a recyclability claim is made.

In particular, large-area plastic laminates or hot foil stamping with a high metal content may act as contaminants in the paper recycling process, depending on the proportion of the surface covered and their removability, whereas thin, removable protective varnishes are generally considered non-disruptive. A general recyclability claim for a finished folding box is therefore only permissible if the specific combination of finishes has been appropriately tested or assessed; a recyclability assessment for an unfinished variant cannot simply be transferred to a finished version made from the same board grade.

Basis for the claim: The ZSVR Minimum Standard 2025 takes coatings, laminates and finishes into account as factors influencing the recyclability of paper and cartonboard packaging. The 4evergreen Circularity by Design Guideline for Paper-Based Packaging, Version 4 / 2026, assesses the impact of coatings, laminates and print finishes on recyclate quality within the European waste-paper recycling stream. The FFI/PTS short report on the recyclability of different folding-carton material combinations provides product-related test data on different types of finishing. In addition, the ECMA position paper on the recyclability of folding cartons and functional barriers specifically addresses the compatibility of functional coatings with the paper recycling process. 

5.6 Food Contact

Claims regarding the suitability of a folding box for food contact refer, in this context, to the material suitability of the board used to come into direct or indirect contact with food without transferring constituents in quantities that could endanger human health or in a way that would unacceptably alter the taste, odour or composition of the food. This is a material safety characteristic and not an environmental claim.

Food-contact suitability may only be claimed if the board used, together with all components that come into contact with the food (e.g. internal coatings or printing inks used for inside printing), complies with the applicable requirements and this is substantiated by appropriate declarations of conformity or test evidence from the material supplier. The claim must also be limited to the specific application that has been assessed — in particular, a distinction must be made between use of the folding box as primary packaging with direct food contact and as secondary packaging without direct contact, as different requirements apply in each case.

Basis for the claim: Regulation (EC) No 1935/2004 on materials and articles intended to come into contact with food sets out the fundamental safety and inertness requirements for food-contact materials. In addition, Regulation (EC) No 2023/2006 on good manufacturing practice for materials and articles intended to come into contact with food regulates requirements relating to the manufacturing process. Specifically for folding cartonboard, the ECMA GMP 2.1 Food Safety Standard sets out industry-specific good manufacturing practice requirements for cartonboard intended for food contact. 

5.7 Environmental Influences / Human, Animal and Environment

Claims such as “protects against external influences” or “resistant to water, dust, light or scratching” describe, in this context, the physical protective function of the folding box against external factors affecting the packaged product during transport, storage and sale. This claim describes a product protection function and not a positive environmental impact of the folding box.

The actual level of protection depends on the board structure used, the grammage, any protective varnishes or laminates, and the structural design (e.g. a flap closure with fully overlapping flaps compared with a simple tuck-in flap). A general protection claim is only permissible if it relates to the external factors that are actually relevant to the intended application (e.g. moisture protection for food products or scratch protection for cosmetics packaging); an unspecified blanket claim without reference to the specific intended use should be avoided. This property must also be clearly distinguished from suitability for food contact (see entry 7) — here, the claim concerns mechanical or physical protection, not material safety in the event of direct contact.

Basis for the claim: The respective claim is based on the product-specific technical material data for the board structure used (grammage, layer structure and coating), together with the selected structural design. No specific publicly available standard could be identified for this entry; the basis of evidence therefore consists of the manufacturers’ technical data sheets for the board grades used (see the FFI Folding Cartonboard Grade Directory) and product-specific testing of the particular protective property claimed. 

5.8 Reusable / Reclosable

“Reusable” describes packaging that is designed and placed on the market to be reused multiple times and to complete several rotations during its life cycle. This is distinct from resealability during the use of a packaged product.

For folding boxes, design features such as a flap closure, a tuck-in flap with locking slots or a locking tab, or a tuck-in base allow the box to be opened and closed repeatedly during use (e.g. bag-in-box cartons with a tuck-in base or folding boxes with flap closures). However, this resealability alone does not make the folding box reusable packaging in the regulatory sense. A claim such as “reusable” is only permissible if the folding box is actually designed for multiple rotations and meets the additional requirements applicable to reusable packaging; mere resealability during first use must be described as such (e.g. “resealable” rather than “reusable”).

Basis for the claim: The classification of reusable packaging is based on the requirements of Regulation (EU) 2025/40 on packaging and packaging waste (PPWR), in particular Article 11. Under these requirements, reusable packaging must be designed for multiple reuse and multiple rotations and must meet further requirements relating, among other things, to emptying, refilling, safety, hygiene and reconditioning. The European Commission’s 2026 PPWR Guidance further specifies the distinction between reclosability during use and actual reusability within the meaning of the Regulation. 

5.9 Sustainable / Environmentally Friendly for Folding Cartons

The terms “sustainable”, “environmentally friendly” and “resource-efficient” are broad environmental claims that may relate to different environmental characteristics and stages of the life cycle. When used in connection with a folding box, these terms therefore refer exclusively to the environmental aspect expressly specified, such as a particular recovered-paper content, a fibre certification or a specifically assessed recycling-related property. This qualification must be made clearly and prominently in the immediate vicinity of the claim itself (e.g. on the same packaging surface or within the same online sales interface), so that the claim is not considered a generic environmental claim within the meaning of Directive (EU) 2024/825. A single environmental characteristic does not provide a basis for a comprehensive positive assessment of the folding box as a whole or of its entire life cycle.

Where the claim is additionally quantified (e.g. percentage figures relating to carbon footprint, recovered-paper content or material savings), a clearly identifiable and verifiable source for the specific figure must be stated in the immediate vicinity of the claim. If no such source is available, the quantified claim must be removed or replaced with a general, unquantified and narrowly defined statement in accordance with paragraph 1.

Basis for the claim: The respective claim is based on product-specific data or assessments relating to the environmental aspect expressly stated. For folding cartons, the ZSVR Minimum Standard 2025 and the 4evergreen Circularity by Design Guideline, Version 4 / 2026, are used in particular to assess recycling- and fibre-related characteristics. Claims relating to carbon footprint may be assessed on an industry-specific basis for cartonboard-based packaging using the Pro Carton Carbon Footprint Report 2025. Under Directive (EU) 2024/825 on empowering consumers for the green transition (Empowering Consumers Directive), unqualified generic environmental claims are generally considered impermissible unless recognised excellent environmental performance can be demonstrated, for example through Regulation (EC) No 66/2010 on the EU Ecolabel or a recognised environmental labelling scheme in accordance with EN ISO 14024 — unless the claim is clearly limited to the specific environmental aspect as described in paragraph 1. Quantified individual values must additionally be substantiated by a specific source that is identifiable in the context of the claim. 

6. Product Segment: Shipping boxes

6.1 Recyclability of Corrugated Board Shipping Cartons

The terms “recyclable” and “suitable for recycling” describe, in this context, the suitability of a corrugated shipping box for recovered-paper recycling, in which the recovered fibres can be reused as secondary raw materials. The assessment takes the complete corrugated board structure into account, including the liners, fluting and any coatings or laminations.

For shipping boxes, factors that may affect sortability and recyclability include, in particular, protective varnishes, protective laminates, laminated print finishes (where the liner is printed separately using offset printing and subsequently bonded to the corrugated board), adhesives and adhesive tapes. As corrugated board is generally a highly homogeneous, paper-based mono-material, it is usually considered unproblematic for recovered-paper recycling in its basic form; however, the actual classification depends on the specific design and the intended recycling infrastructure.

Basis for the claim: The ZSVR Minimum Standard for assessing packaging design for recycling – 2025 edition contains specific assessment criteria for corrugated packaging. The FEFCO Corrugated Packaging Recyclability Guidelines 2025 and the accompanying FEFCO factsheet on recyclability provide industry-specific assessments of the compatibility of coatings, laminates and adhesives with the European waste-paper recycling stream for corrugated board. The 4evergreen Recyclability Evaluation Protocol and the Cepi Recyclability Laboratory Test Method, Version 3, 2025 provide the underlying test methods for determining the recyclability of fibre-based packaging. In addition, the German Environment Agency (Umweltbundesamt) provides information on the applicable disposal and recycling routes for shipping packaging in Germany. 

6.2 Recycled Fibre Content in Corrugated Board

The term “recycled fibre content” describes, in this context, the proportion of previously recycled recovered paper contained in the corrugated board used for the shipping box. This is a claim about the material used in manufacturing (an input characteristic), not about recyclability after use (see entry 6.1).

In practice, corrugated board often already contains a significant proportion of secondary fibres, as recovered paper is a key raw material for the corrugated board industry. Any specific percentage stated for recycled fibre content must always refer to the corrugated board grade actually used (the liner and fluting may contain different proportions of fibre) and cannot be applied across the entire product range as a general figure.

Basis for the claim: FEFCO data on paper production, the FEFCO European Database for Corrugated Board Life Cycle Studies and the associated FEFCO LCA database on inputs document the fibre proportions commonly used in the industry and their origins for corrugated board. 

6.3 FSC / PEFC / Certified Paper Fibres

The terms “FSC” and “PEFC” refer to the chain-of-custody certification of paper and pulp fibres used in the virgin-fibre content of corrugated board. They confirm that the paper fibres used originate from sustainably managed forests and that their traceability is fully documented throughout the supply chain.

Use of the FSC or PEFC logo on a shipping box is only permitted if a valid chain-of-custody certificate is in place for the specific product. As corrugated board often contains a mixture of virgin and secondary fibres, the appropriate label variant (e.g. “FSC Mix” rather than “FSC 100%”) must be selected in accordance with the actual fibre composition.

Basis for the claim: The FSC Chain of Custody Standard FSC-STD-40-004 V3-1 sets out the requirements for the traceability of certified fibres; the FSC Germany overview on paper and packaging further specifies its application to packaging products. For PEFC, the corresponding Chain of Custody rules apply in accordance with the PEFC overview on packaging and the PEFC technical documentation. 

6.4 Coatings, Laminates & Finishes

Shipping boxes can be finished with protective varnishes (matt/gloss, optionally with a clear area for dates or codes) or protective laminates (transparent, matt/gloss). Labelprint24 also offers laminated corrugated board, where the liner is printed separately using offset printing and only then bonded to the corrugated board. These finishes primarily serve a protective or decorative function and do not in themselves constitute an environmental claim, but they may affect recyclability within the meaning of entry 1.

A general recyclability claim for a finished shipping box is therefore only permissible if the specific combination of finishes has been appropriately tested or assessed. Adhesive strips (e.g. on folding lid boxes with adhesive strips, FEFCO 0885) must be considered separately, particularly with regard to their material composition and removability during the recycling process.

Basis for the claim: The ZSVR Minimum Standard 2025 and the FEFCO Corrugated Packaging Recyclability Guidelines 2025 take coatings, laminates and adhesives into account as factors influencing the recyclability of corrugated packaging. The 4evergreen Recyclability Evaluation Protocol and the Cepi Recyclability Laboratory Test Method, Version 3, 2025 provide the underlying test methods for assessing finished corrugated-board constructions. 

6.5 Material Savings / Made-to-Measure Cartons

Claims relating to material savings for shipping boxes describe a reduction in the amount of material used or in packaging volume compared with a defined reference basis, for example by producing a made-to-measure box instead of using an oversized standard box with additional void fill. The necessary functions of the packaging, in particular the protection of the contents, must be maintained.

A claim such as “saves resources” or “avoids unnecessary material use” is only permissible if it is based on a specifically quantified or at least clearly substantiated comparison (e.g. the elimination of void fill through made-to-measure production); a general, unsupported claim must either be narrowly qualified or removed. A reduction in weight or volume that merely meets the statutory minimum requirements of the PPWR must also not be promoted as a separate, voluntary environmental benefit.

Basis for the claim: The requirements for minimising weight and volume while maintaining the packaging function are set out in Regulation (EU) 2025/40 on packaging and packaging waste (PPWR), Article 10 and Annex IV. The ZSVR Minimum Standard 2025 also takes the avoidance of unnecessary void-fill material into account as an assessment criterion. The German Environment Agency’s information on shipping packaging (updated 12 August 2026) places material minimisation in e-commerce within the wider regulatory context. 

6.6 Protective Function / Resistance to External Influences

Claims such as “protects against external influences” or “protection against scratches, dirt and moisture” describe, in this context, the physical protective function of the shipping box against external factors affecting the packaged product during transport and storage. This claim describes a product protection function and not a positive environmental impact of the box.

The actual level of protection depends on the selected flute type (E, B or EB flute), the associated load capacity (up to 10, 20 or 30 kg respectively), and any protective varnishes or laminates. A general protection claim is only permissible if it relates to the factors that are actually relevant to the specific application; an unspecified blanket claim without reference to the selected material configuration should be avoided.

Basis for the claim: The respective claim is based on the product-specific technical data relating to burst strength, puncture resistance and edge crush resistance of the corrugated-board grade used. FEFCO information on product protection using corrugated board describes, on an industry-specific basis, the protective properties of corrugated packaging against mechanical and climatic influences. 

6.7 Reusable / Reclosable

“Reusable” describes packaging that is designed and placed on the market to be reused multiple times and to complete several rotations during its life cycle. This is distinct from resealability during use, as may be the case with shipping boxes featuring a tuck-in base that can be reopened so that the box can be stored flat.

A claim such as “reusable” is only permissible if the shipping box is actually designed for multiple rotations and meets the additional requirements applicable to reusable packaging (e.g. sufficient durability for repeated use). Mere resealability during first use must instead be described as “resealable”, not “reusable”.

Basis for the claim: The classification of reusable packaging is based on the requirements of Regulation (EU) 2025/40 (PPWR), Article 11. For shipping boxes specifically designed as reusable transport packaging systems, the Blue Angel DE-UZ 27 “Reusable Packaging Systems for Transport and Shipping”, 2025 edition (overview page), applies, with specific requirements relating to the number of rotations, stability and reconditioning. The German Environment Agency’s information on reusable packaging additionally provides guidance on the distinction between reclosability and genuine suitability for reuse. 

6.8 Sustainable / Environmentally Friendly for Shipping Cartons

The terms “sustainable”, “environmentally friendly” and “resource-efficient” are broad environmental claims that may relate to different environmental characteristics and stages of the life cycle. When used in connection with a shipping box, these terms therefore refer exclusively to the environmental aspect expressly specified, such as a particular recycled fibre content or a specifically assessed material saving. This qualification must be made clearly and prominently in the immediate vicinity of the claim itself, so that the claim is not considered a generic environmental claim within the meaning of Directive (EU) 2024/825. A single environmental characteristic does not provide a basis for a comprehensive positive assessment of the shipping box as a whole or of its entire life cycle.

Where the claim is additionally quantified, a clearly identifiable and verifiable source for the specific figure must be stated in the immediate vicinity of the claim. If no such source is available, the quantified claim must be removed or replaced with a general, unquantified and narrowly defined statement in accordance with paragraph 1.

Basis for the claim: The respective claim is based on product-specific data or assessments of the specifically stated environmental aspect. For shipping boxes, the FEFCO Corrugated Packaging Recyclability Guidelines 2025 and the ZSVR Minimum Standard 2025 are used in particular to assess recycling- and fibre-related characteristics. Under Directive (EU) 2024/825 (Empowering Consumers Directive), unqualified generic environmental claims are generally considered impermissible unless recognised excellent environmental performance can be demonstrated, for example through Regulation (EC) No 66/2010 on the EU Ecolabel — unless the claim is clearly limited to the specific environmental aspect as described in paragraph 1. 

7. Product Segment: Tubes

7.1 Recyclability / Mono-Material for Laminate Tubes

The terms “recyclable” and “suitable for recycling” describe, in this context, the suitability of a tube for plastics recycling, in which the recovered materials can be reused as secondary raw materials. The assessment takes the complete tube structure into account, including the tube body, shoulder, closure and any barrier layers.

A tube is generally only considered recyclable as a mono-material structure if one polymer type (e.g. HDPE) accounts for the vast majority of the material and barrier layers such as EVOH do not exceed a low proportion by weight. By contrast, ABL tubes with an aluminium layer between the plastic layers are considered composite materials and are generally not readily recyclable within plastics recycling streams. A general recyclability claim is therefore only permissible if it refers to the specific tube type assessed (PP mono-material, HDPE mono-material or PBL with a defined EVOH content) and is not applied across the entire tube range.

Basis for the claim: The ZSVR Minimum Standard for assessing packaging design for recycling – 2025 edition contains specific assessment criteria for plastic packaging, including tubes. The RecyClass Guideline “Natural & White HDPE Containers and Tubes” and the RecyClass Design Book 2026 (section “Mono-Material Tube Solutions”) assess the recyclability of mono-material HDPE tubes and take into account, among other factors, the material composition, closures and limited proportions of compatible barrier materials such as EVOH. In addition, the product-specific material data and, where available, relevant test or certification evidence must be taken into account for the specific tube variant. 

7.2 Aluminium-Free

The term “aluminium-free” describes, in this context, a tube that does not contain an aluminium layer in the tube body, unlike ABL tubes (Aluminium Barrier Laminate), in which a thin aluminium layer between the plastic layers provides the barrier function. This claim relates exclusively to the material composition of the tube body and must be distinguished from general recyclability (see entry 1) — an aluminium-free tube is not automatically recyclable if other components (e.g. the closure or coating) impair sortability and recyclability.

The claim “aluminium-free” may only refer to the specific tube type concerned (PBL or PP tubes) and must not be inappropriately extended to ABL tubes within the same product range or used as a blanket claim for the entire tube range where ABL variants are also offered.

Basis for the claim: The ETMA overview of tube types (Laminate Tubes) describes the technical distinction between ABL tubes with an aluminium layer and PBL or PP tubes without aluminium content. In addition, RecyClass documents the material composition of aluminium-free tube solutions using certified HDPE mono-material tubes as examples. 

7.3 Barrier Properties / Protection Against Environmental Influences

The term “barrier properties” describes, in this context, a tube’s ability to protect the contents from external influences such as oxygen, UV light, moisture or loss of aroma. This property describes a product protection function and not a positive environmental impact of the tube.

The actual barrier performance depends on the tube type (ABL with an aluminium layer as a high-barrier solution compared with PBL with an EVOH layer), as well as on the thickness and quality of the respective barrier layer. A general claim such as “provides reliable protection against environmental influences” is only permissible if it relates to the barrier properties actually tested for the specific tube type; an unspecified blanket claim without reference to the material actually used should be avoided.

Basis for the claim: The respective claim is based on the product-specific technical material data of the barrier layer used. The ETMA overview of tube properties (Barrier Properties) describes, on an industry-specific basis, the different barrier properties of ABL and PBL tubes against oxygen, moisture and light. 

7.4 Reclosable

“Reclosable” describes, in this context, a tube that can be opened and closed repeatedly using its closure (screw cap, snap-on cap or flip-top) so that the contents can be dispensed in portions. This property must be distinguished from actual reusability in the sense of reusable packaging — a resealable tube is designed for single use until fully emptied and is then disposed of, rather than refilled or placed on the market again.

A claim such as “reusable” would therefore not be accurate for a tube in this context and must be clearly distinguished from “reclosable”.

Basis for the claim: The ETMA overview of tube properties (Convenience and Resealability) describes reclosability as a functional characteristic of tube closure systems for dispensing the contents in portions. 

7.5 Food Contact

Claims regarding the suitability of a tube for food contact refer, in this context, to the material suitability of the laminate used to come into direct contact with food without transferring constituents in quantities that could endanger human health or unacceptably alter the taste, odour or composition of the food.

Food-contact suitability may only be claimed if all laminate layers that come into contact with the food, including the inner plastic layers and any adhesives between the laminate layers, comply with the applicable requirements and this is substantiated by appropriate declarations of conformity from the material supplier.

Basis for the claim: Regulation (EC) No 1935/2004 on materials and articles intended to come into contact with food lays down the fundamental safety and inertness requirements. Specifically for plastic materials intended to come into contact with food — such as those used in PBL laminate tubes — Regulation (EU) No 10/2011 on plastic materials and articles intended to come into contact with food sets out the specific requirements relating to migration limits and authorised starting substances. 

7.6 Sustainable / Environmentally Friendly for Tubes

The terms “sustainable”, “environmentally friendly” and “resource-efficient” are broad environmental claims that may relate to different environmental characteristics and stages of the life cycle. When used in connection with a tube, these terms therefore refer exclusively to the environmental aspect expressly specified, such as its mono-material property or the absence of an aluminium layer. This qualification must be made clearly and prominently in the immediate vicinity of the claim itself, so that the claim is not considered a generic environmental claim within the meaning of Directive (EU) 2024/825. A single environmental characteristic does not provide a basis for a comprehensive positive assessment of the tube as a whole or of its entire life cycle.

Where the claim is additionally quantified, a clearly identifiable and verifiable source for the specific figure must be stated in the immediate vicinity of the claim. If no such source is available, the quantified claim must be removed or replaced with a general, unquantified and narrowly defined statement in accordance with paragraph 1.

Basis for the claim: The respective claim is based on product-specific data or assessments of the specifically stated environmental aspect. The ETMA overview on the sustainability of tubes and the RecyClass Design Book 2026 are used in particular to assess recycling- and material-related characteristics of tube solutions. Under Directive (EU) 2024/825 on empowering consumers for the green transition (Empowering Consumers Directive), unqualified generic environmental claims are generally considered impermissible unless recognised excellent environmental performance can be demonstrated, for example through Regulation (EC) No 66/2010 on the EU Ecolabel — unless the claim is clearly limited to the specific environmental aspect as described in paragraph 1. 

8. Product Segment: Package Leaflets

8.1 Recyclability / Waste Paper Collection for Package Leaflets

The terms “recyclable” and “recyclability” describe, in this context, the suitability of a package insert for recovered-paper recycling, in which the recovered paper fibres can be reused as secondary raw materials. As package inserts are generally made from uncoated, wood-free lightweight printing paper without laminates or plastic components, they are usually considered unproblematic for recovered-paper recycling in their basic form.

However, the assessment must take into account that printing inks, their coverage, and any stamping inks or special inks (e.g. for security features) may affect recyclability. A general recyclability claim is therefore only permissible if the specific printing inks and finishes used have been appropriately tested or classified as non-disruptive.

Basis for the claim: The INGEDE methods for assessing the recyclability of printed products and the INGEDE information on recyclability and environmental labels for printed products set out recognised test methods for assessing the recyclability of printed paper products, including the influence of printing inks on the deinking process. The EPRC Guide to an Optimum Recyclability of Printed Graphic Paper supplements these with practical design recommendations for printed paper products designed for recycling. The German Environment Agency’s information on waste paper provides information on the applicable collection and recovery structures in Germany. 

8.2 FSC / PEFC / Certified Paper Fibres

The terms “FSC” and “PEFC” refer to the chain-of-custody certification of paper and pulp fibres used in the lightweight printing paper of a package insert. They confirm that the paper fibres used originate from sustainably managed forests and that their traceability is fully documented throughout the supply chain.

Use of the FSC or PEFC logo, or a corresponding certification claim, on a package insert is only permitted if a valid chain-of-custody certificate is in place for the specific product or the underlying paper fibre supply and the printing company itself holds valid certification. As package inserts are frequently processed for pharmaceutical and cosmetics companies subject to stringent regulatory requirements, it must also be verified that an unbroken chain of certification is in place from the paper manufacturer through to the printing company.

Basis for the claim: The FSC Germany overview on FSC trademarks and printed products, as well as the FSC Germany information on Chain of Custody and recycling standards, set out the requirements relating to traceability and correct labelling for printing companies. For PEFC, the corresponding requirements apply in accordance with the PEFC Germany Chain of Custody Standard and the PEFC requirements specifically applicable to printing companies. 

8.3 Material Savings / Lower Grammage (Lightweight Printing Paper)

Claims relating to material savings for package inserts describe a reduction in the amount of paper used, particularly through the use of lightweight printing paper with a low grammage (e.g. 40–60 g/m²) compared with a defined reference basis. The necessary functions of the package insert, in particular the legally required legibility and completeness of mandatory information, must be maintained.

A lower grammage cannot therefore be reduced arbitrarily, but is limited by the regulatory minimum requirements applicable to package leaflets, including font size, legibility and sufficient opacity to prevent show-through. A claim such as “material-efficient” or “resource-efficient due to lower paper weight” is only permissible if the grammage used continues to meet the applicable regulatory requirements for legibility and quality.

Basis for the claim: Technical data sheets and product specifications for the lightweight printing papers actually used document the product-specific grammage, opacity and other relevant material properties. The regulatory minimum requirements for package leaflets, in particular with regard to legibility and format, are set out in the European Commission’s EudraLex Volume 2 Guidelines for package leaflets. 

8.4 Sustainable / Environmentally Friendly for Package Leaflets

The terms “sustainable”, “environmentally friendly” and “resource-efficient” are broad environmental claims that may relate to different environmental characteristics and stages of the life cycle. When used in connection with a package insert, these terms therefore refer exclusively to the environmental aspect expressly specified, such as fibre certification or a specifically assessed recyclability characteristic. This qualification must be made clearly and prominently in the immediate vicinity of the claim itself, so that the claim is not considered a generic environmental claim within the meaning of Directive (EU) 2024/825. A single environmental characteristic does not provide a basis for a comprehensive positive assessment of the package insert as a whole or of its entire life cycle.

Where the claim is additionally quantified, a clearly identifiable and verifiable source for the specific figure must be stated in the immediate vicinity of the claim. If no such source is available, the quantified claim must be removed or replaced with a general, unquantified and narrowly defined statement in accordance with paragraph 1.

Basis for the claim: The respective claim is based on product-specific data or assessments relating to the environmental aspect expressly stated. The German Environment Agency’s information on paper and printed products and the INGEDE methods for recyclability are used in particular to assess recycling- and fibre-related characteristics. For a more extensive, recognised environmental performance within the meaning of the EmpCo requirements, the European Commission’s EU Ecolabel for printed paper products may be used as a basis for substantiation. Under Directive (EU) 2024/825 on empowering consumers for the green transition (Empowering Consumers Directive), unqualified generic environmental claims are generally considered impermissible unless recognised excellent environmental performance can be demonstrated — unless the claim is clearly limited to the specific environmental aspect as described in paragraph 1.