EmpCo whole-product claims
“Made with recycled materials” when only the packaging is: the EU whole-product claim rule
Direct answer. From 27 September 2026, making an environmental claim about the entire product or business when it concerns only one aspect or activity is banned in all circumstances (Annex I, point 4b of the Unfair Commercial Practices Directive), and the directive’s own example is a product marketed as “made with recycled material” when only the packaging is. Name the part the claim covers in the same line, for instance “packaging made from recycled paper”, or drop the claim.
Green Claims Guard (Shopify App Store) flags green-claim wording and names the exact provision it cites. Whole-product wording such as “made with recycled materials” is exactly the kind of line to scan and review. The app does not check what your product is made of, and this page is not legal advice.
Related: CLPLens — Hazard pictograms on the product page, not only the parcel.
Free check first: Green claim wording self-check runs in your browser and sends nothing. Paste product copy and see which environmental wording to review.
What the rule says
Annex I point 4b, added by Directive (EU) 2024/825, covers making an environmental claim about the entire product or the trader’s entire business when it concerns only a certain aspect of the product or a specific activity of the business. The recitals give two examples: “made with recycled material” when only the packaging is recycled, and implying only renewable energy is used when several facilities still use fossil fuels.
Source: Directive (EU) 2024/825 on EUR-Lex, Annex, point (2) (new points 4a–4c), and recital 11.
Lines on a Shopify store that blur the part
- “Made with recycled materials” in a product title or short description when the recycled part is the box or mailer.
- “Eco packaging” placed beside the product name so it reads as a product claim.
- “Powered by renewable energy” on a brand page when only some sites use it.
- A badge or tag on a collection that applies to one item in it.
Install Green Claims Guard → scan product copy → review flags
A rewrite pattern: part, claim, scope
State the part, the specific claim and its scope in the same line.
- Instead of “made with recycled materials”: “mailer box made from recycled paper; the product itself is not made from recycled material”, if that is true.
- Instead of “runs on renewable energy”: the sites or processes where it is true, in the same sentence.
The recitals add that a specific claim given in clear and prominent terms on the same medium is not a generic claim, and that claims about the whole business remain possible when accurate, verifiable and not overstated.
Install Green Claims Guard and run the checklist
A short review run
- Scan your product copy with Green Claims Guard.
- For each flag, read the provision it cites and ask which part of the product or business the line is really about.
- Rewrite the line to name that part, or remove it.
- If a percentage is involved, check recycled-content % claims.
- Re-scan after the edit so the live copy matches what you approved.
Install Green Claims Guard → review the cited provision
Not the same as the neighbouring rules
- Unspecified words such as “eco-friendly”: generic claims ban.
- “Recyclable”: recyclable claims.
- Offset-based neutrality: carbon-neutral claims.
Install Green Claims Guard, then re-scan
What this page is not
- Not legal advice or a ruling that a given line is lawful.
- Not a materials test or supplier verification.
- Not a substitute for checking how each Member State transposed the directive.
Related pages
- Recycled-content % claims
- EU generic green claims ban
- EmpCo recyclable claims
- Flag wording and see which provision it cites
- Green Claims Guard
Not legal advice. Re-check the cited law and the current app page before you rely on this page.