01What "sustainable" means on a package
No federal rule defines "sustainable packaging". What is regulated is what you claim.
The FTC's Green Guides (16 CFR part 260) cover environmental claims on labels, ads and packaging (260.1). They are not binding rules, but the FTC can act under Section 5 of the FTC Act against a claim that is inconsistent with them. Three principles do most of the work:
- Be specific. "Marketers should not make unqualified general environmental benefit claims" (260.4); the guides' example is "eco-friendly". Qualify the claim to a specific benefit, clearly and prominently.
- Say which part. Make clear whether the claim covers the product, the package or a component (260.3).
- Don't overstate. A true claim about a negligible benefit can still mislead (260.3).
When the FTC revised the guides in 2012, it said they do not address the term "sustainable". That is not a green light: a bare "sustainable packaging" reads like the broad claim the guides warn against. Print the specific fact instead, such as "box made from 80% recycled paperboard", if it is true and documented.
Review status. The FTC asked for comment on updating the guides on December 14, 2022. Packaging Dive reported in February 2025 that the FTC had nothing new to share. As of October 22, 2026, we found no revised guides on ftc.gov, and the 2012 text in the eCFR is current. Check before you print.
02Your options and their trade-offs
EPA ranks source reduction and reuse as the most preferred way to manage materials, ahead of recycling and composting, energy recovery, and treatment and disposal. It lists "reducing packaging" as source reduction.
| Option | What it gets you | The catch |
|---|---|---|
| Right-sizing | Less material and void fill | Test that the product still arrives intact |
| Mono-material | No mixed layer that limits recycling | May lose the barrier or strength of a laminate |
| Recycled content (PCR) | A claim you can state as a percentage | You need the supplier's documentation |
| Paper-based | 80.9% of paper packaging was recycled (EPA, 2018) | Plastic windows and laminates can limit recycling |
| Compostable | A route for food-soiled packaging | Needs a qualifier unless facilities are widely available |
| Reusable or refillable | Fewer packs made | Needs a real return or refill system |
EPA put containers and packaging at 28.1% of US municipal solid waste in 2018, recycled at 53.9% overall: 80.9% for paper and paperboard, 73.8% for steel, 31.3% for glass and 13.6% for plastic.
For shipping, plain paper and corrugated are the easiest packs to call recyclable. An American Forest & Paper Association study put US recycling access at 93% for corrugated boxes and 90% for paper bags in 2021, above the 60% bar. See kraft paper, corrugated boxes and mailer boxes.
Plastic film is harder: EPA says bags and film can't go in household recycling bins and points to store drop-off. For a poly mailer or pouch, a stated recycled content percentage may be easier to support than "recyclable". See recycled polyester and stand-up pouches.
Decision rules:
- Cut material first: right-size the box and drop extra layers, then pick the material.
- Shipping box or mailer: paper or corrugated, with no plastic window or film laminate.
- Need a barrier: ask for a mono-material structure and test it before you accept it.
- Food-soiled packaging: compostable only with certification and a qualified claim.
03What you can and can't print
Each claim has its own section of the Green Guides. Paraphrased:
| Claim | OK unqualified when | Otherwise |
|---|---|---|
| Recyclable (260.12) | Recycling reaches a "substantial majority", at least 60%, of consumers or communities where it sells | Qualify: "may not be recyclable in your area", or state the percentage with access |
| Recycled content (260.13) | The whole pack, minor parts aside, is recycled | State the amount: "50% recycled content" |
| Compostable (260.7) | Evidence shows all materials become usable compost in a timely way, including in a home pile | Qualify if it needs a commercial facility, and if facilities don't reach a substantial majority |
| Biodegradable (260.8) | Evidence shows the whole item breaks down within a reasonably short time after customary disposal | Don't use it for items that go to landfill or incineration |
| Refillable (260.14) | You provide a refill system or a refill product | Don't claim it |
The details that catch brands:
- One part can sink "recyclable." If any component significantly limits recycling, a recyclable claim is deceptive (260.12(d)).
- The one-year rule. An unqualified "biodegradable" claim is deceptive for items entering the solid waste stream that don't completely decompose within one year after customary disposal (260.8(c)). The guides' example is a trash bag that ends up in a landfill or incinerator.
- Seals are claims. A seal doesn't replace your own evidence, and one that doesn't say what it certifies reads as a general claim (260.6).
04Labels and certifications
- How2Recycle: an on-pack disposal label that began in 2008 as a Sustainable Packaging Coalition project, with a recyclability assessment behind each label. Widely Recyclable means at least 60% of Americans can recycle it, Check Locally less than 60%, Not Yet Recyclable less than 20%.
- FSC: chain-of-custody certification tracks certified material from forest to finished product. Labels are FSC 100%, FSC Recycled and FSC Mix. Printed materials carry the label only if produced under a valid chain-of-custody certificate, so use an FSC certified printer (more on rigid boxes).
- BPI: certifies items for commercial composting against ASTM D6400, with D6868 optional for eligible items. D6400 covers plastics designed to compost in municipal and industrial facilities; D6868 covers plastics laminated, extruded or mixed onto a substrate such as paper. Since January 1, 2020, BPI has barred fluorinated chemicals, including PFAS, and required a test showing at most 100 ppm total fluorine.
Get the certificate number and check it with the certifier. A supplier's "compostable" on a spec sheet is not your evidence.
05State laws: EPR, SB 343 and heavy metals
Extended producer responsibility (EPR) laws make companies that sell packaged goods into a state pay to recycle the packaging. What each agency said when we checked on October 22, 2026:
- Oregon: Recycling Modernization Act (SB 582, 2021); producers began paying fees to Circular Action Alliance on July 1, 2025.
- Colorado: since July 2025, producers must participate to sell covered materials in the state; dues began January 2026.
- California: SB 54 (2022); permanent regulations approved May 1, 2026; Circular Action Alliance's plan received October 13, 2026.
- Maine: law passed 2021 (38 M.R.S. § 2146); no stewardship organization yet, and DEP is revising its RFP (September 11, 2026) and reassessing the schedule.
- Minnesota: Packaging Waste and Cost Reduction Act (2024); Circular Action Alliance confirmed as its organization in February 2025.
- Maryland: signed May 13, 2025; notice of final regulations May 15, 2026.
- Washington: Recycling Reform Act (SB 5284); after March 2029, non-members of the producer organization can't sell in the state.
These rules change fast and each state defines producers and fees, so check the state agency before you launch there.
California SB 343 bars the chasing arrows or any recyclability indicator unless the material meets the state's criteria, using CalRecycle's material study, for products manufactured after October 4, 2026. On July 14, 2026, the US District Court for the Southern District of California granted a preliminary injunction barring the Attorney General from enforcing SB 343 until further order of the court (California League of Food Producers v. Bonta, No. 3:26-cv-01675), and CalRecycle says the deadline may be affected. An injunction is not a final ruling, so we'd plan artwork as if the law applies.
Toxics in Packaging: laws based on the model law, in 19 states as of 2021, bar intentional lead, mercury, cadmium and hexavalent chromium and cap their combined incidental level at 100 ppm by weight.
06Before you sign off
- Get documents before you pay for artwork. No document, no claim.
- Quote the right-sized box and your current size side by side.
- When a supplier offers "biodegradable" plastic, ask what claim you can print in the US, then read 260.8.
- Re-check claims whenever the supplier or material changes.
- The course's packaging lesson in Product Sourcing Secrets covers matching packaging to the product.
07How to spec it with a supplier
Put the environmental requirements in the packaging spec, so your claim rests on documents you hold. The Vault lists packaging manufacturers to send it to.
| No. | Field | What to write |
|---|---|---|
| 01 | Material by component | Box, insert, tape, label, window and coating, each with material and weight |
| 02 | Recycled content | Post-consumer and pre-consumer percentage by weight, with a declaration or certificate (pre-consumer needs proof it would otherwise have been waste, 260.13(b)) |
| 03 | Fiber certification | FSC claim and the supplier's chain-of-custody certificate code |
| 04 | Compostability | Certificate number and the ASTM standard tested to |
| 05 | Coatings | Coating, lamination or window, and whether it can be left off |
| 06 | Heavy metals | Toxics in Packaging compliance statement |
| 07 | Food contact | Letter of guaranty naming the 21 CFR sections for your food and use |
| 08 | Claims artwork | The exact claim and label you plan to print, checked against their documents |
08FAQ
Q01What is the most sustainable packaging?
It depends on the product and where the pack ends up. EPA ranks using less and reuse above recycling, so start with a smaller pack, then a material your customers can recycle.
Q02What is the difference between biodegradable and compostable?
Biodegradable means it breaks down and returns to nature; an unqualified claim needs that to happen within one year for solid waste. Compostable means it becomes usable compost, and certifiers such as BPI test against ASTM D6400 or D6868.
Q03Is biodegradable packaging better than compostable?
Not as a claim. Unqualified, "biodegradable" fails for trash that won't decompose within a year (16 CFR 260.8); certified compostable has a test standard behind it.
Q04Can I call my packaging recyclable?
Unqualified, only if recycling reaches at least 60% of consumers or communities where you sell and no component limits recycling (16 CFR 260.12). California's SB 343 adds its own criteria.
Q05Can I say my packaging is eco-friendly?
Not on its own. State the specific benefit, such as "100% recycled paperboard" (16 CFR 260.4).