Can I say “recyclable”, “biodegradable” or “compostable”?

Published 9 July 2026 · Directive (EU) 2024/825 · General information, not legal advice

Short answer

Allowed — but you must substantiate it

Yes — these are not on the banned list, but you can only make them if you can prove them. “Recyclable”, “biodegradable” and “compostable” are specific environmental claims. Under Directive (EU) 2024/825 and the misleading-actions rule of the UCPD, they need accessible evidence and clear qualification — the standard, the conditions, and where the shopper can check. Unqualified, they can become misleading (and if left vague, a “generic” claim). Qualify each one properly and hold the evidence.

This is general information to help you screen your own copy — not legal advice. A flag here is a well-founded warning, not a ruling. Only the Court of Justice of the European Union (CJEU) can interpret the directive with binding force, and the European Commission’s guidance on it is non-binding. Where money or reputation is at stake, take the cited provision to qualified counsel before you act.

Why these are different from “eco-friendly”

“Eco-friendly” is a generic claim banned unless you hold recognised excellent-performance certification. “Recyclable” and friends are specific claims about a real, testable property. The directive doesn’t ban them — but under Article 6(1) of the UCPD (misleading actions), a claim that isn’t true, or is presented so as to deceive the average consumer, is unlawful. And the directive is explicit that a specific claim left unqualified — where the specification isn’t given clearly on the same medium — can itself tip into being a generic claim. So substantiation is the whole game.

“Recyclable”

The trap is claiming recyclable-in-theory when the item isn’t actually recycled at scale where your customers live. Qualify it and hold the evidence:

“Recyclable where kerbside facilities exist” rather than a bare “100% recyclable”.
Be honest about which component is recyclable if the whole item isn’t (or you risk the partial-claim ban in Annex I point 4b).

“Biodegradable”

“Biodegradable” means nothing without a standard, a timeframe and a disposal environment. Everything biodegrades eventually. State the specifics:

Name the standard and conditions — e.g. “industrially compostable, certified to EN 13432” — rather than an unqualified “biodegradable”.
Don’t imply it will break down harmlessly in the environment or at home if that isn’t true.

“Compostable”

Distinguish home from industrial composting, and certify it:

“Industrially compostable (EN 13432) where facilities exist” is far safer than a bare “compostable”.
If it’s only home-compostable under specific conditions, say so.

The common thread: accessible proof

For every one of these, the evidence must be accessible to the consumer — not sitting in a lab report no one can see. Put the qualification on the same medium as the claim, and be ready to show the substantiation. Absolute versions (“plastic-free”, “zero waste”) are held to an even higher bar because they must be true across the whole product and packaging.

Frequently asked questions

Is "recyclable" banned under the EU rules?

No. "Recyclable" is a specific claim, not on the Annex I banned list. But it must be substantiated with accessible evidence and reflect whether the item is actually recycled at scale, not merely recyclable in theory — otherwise it is a misleading action under Article 6(1) of the UCPD.

How do I qualify "biodegradable" correctly?

State the standard, timeframe and disposal environment — for example "industrially compostable, certified to EN 13432" — rather than an unqualified "biodegradable". An unqualified claim has no defined meaning and can mislead.

What is the difference between home and industrial compostable?

They are different disposal conditions with different certifications. A claim of "compostable" should specify which one applies (e.g. industrially compostable to EN 13432 where facilities exist), because most industrial-compostable items will not break down in a home composter.

Where does the evidence need to be?

Accessible to the consumer, and the specification should appear clearly on the same medium as the claim. Evidence locked away where a shopper cannot see it does not satisfy the substantiation duty and can leave the claim looking generic.