What counts as a sustainable packaging label?

There is no single object of study

“Sustainable packaging label” is not a term of art. It has no settled definition in law, in the standards literature, or in the academic work that studies its effects. It is a convenience phrase that gathers a chasing-arrows symbol, a compostability certification, a deposit legend, a carbon score, a resin identification code and a licensing trademark, and treats them as instances of a single phenomenon. They are not. They differ in what they assert, in who is bound by them, and in the body of law, if any, that governs their display.

The absence of an agreed object of study is not a difficulty of terminology alone. It produces three concrete failures, set out below: one legal, one empirical and one regulatory.

The first is legal. Whether a mark is lawful, mandatory, or actionable depends entirely on which kind of mark it is. Under Directive (EU) 2024/825, a "sustainability label" is defined as "any voluntary trust mark, quality mark or equivalent, either public or private, that aims to set apart and promote a product, a process or a business by reference to its environmental or social characteristics, or both", and the definition expressly excludes any mandatory label required under Union or national law (Directive (EU) 2024/825, Art. 1(1)(b), inserting Art. 2(q) into Directive 2005/29/EC). A regime built on that definition does not extend to a mandatory sorting pictogram, which falls outside the defined category by operation of the exclusion in Article 2(q). Conversely, the harmonised marks introduced by the Packaging and Packaging Waste Regulation are obligations rather than claims (Regulation (EU) 2025/40, recital 66), and analysing them as marketing devices misdescribes what they are.

The second failure is empirical. Consumer research routinely reports aggregate confusion figures across heterogeneous marks. The Recycling Partnership (2021), surveying 1,310 US consumers, found that of the 78% who look at labels, "nearly two-thirds or 63% report confusion about whether an item is recyclable after looking at the product label." The published summary does not, however, disaggregate the responses by symbol type, so it does not establish whether the confusion arises from disposal instructions, from material codes, from certification marks, or from marks that make no recyclability claim at all. The consequence is that the figure records the aggregate effect of the on-pack label field without identifying which category of mark contributes to it, and an intervention directed at one category cannot be evaluated against it.

The third failure is regulatory. Interventions are drafted against categories. A rule restricting recyclability claims does not reach a mark that asserts scheme membership; a rule governing voluntary labels does not reach a mandated pictogram. Where the categories are unclear, regulation lands unevenly and enforcement follows the marks that are easiest to characterise rather than the conduct the instrument was drafted to reach.

Why the existing frameworks do not fit packaging

Two classification schemes dominate. Both were built for adjacent purposes.

The ISO 14020 series treats four instruments as species of a common genus, the "environmental statement": self-declared environmental claims, ecolabels, environmental product declarations, and footprint communications (ISO, 2022). This is a scheme organised around who asserts the statement and on what verificatory basis. It is not indifferent to content — footprint communications are defined by what they quantify — but its primary cut is governance.

Its coverage is also incomplete on its own terms, as two published assessments of the series record. Minkov et al. (2020), assessing a sample of ecolabels against the series' criteria, found that "approximately 60% of the explored ecolabels in our sample did not declare any ISO typology, whereas none assigned a type II classification", and identified a residual class of "undefined ecolabels" using "different awarding formats and criteria in combination and hybrid forms that are not recognized and described by ISO or any other observed classification approach." An earlier study by the same group found that a prominent multi-attribute certification programme could be classified "neither as a Type I, nor a Type III label", occupying what the authors called an "undefined affiliation in the realm of environmental labels" (Minkov, Bach and Finkbeiner, 2018).

A further limitation, relevant for present purposes, concerns intended scope rather than execution. The ISO series governs statements a party chooses to make about environmental performance. A material identification code is not such a statement; it is a technical designation. A deposit legend is not such a statement; it is a legal notice. A licensing trademark is not such a statement; it records a transaction. These marks are outside the series not by oversight but by design, and they constitute a large share of what is physically printed on packaging.

EU law supplies a second scheme, whose exclusions are complementary to those of the ISO series. As noted, Directive (EU) 2024/825 defines a sustainability label as a voluntary trust mark and excludes mandatory labels. This is coherent for a consumer-protection instrument concerned with unfair commercial practices: the mischief is a trader making a discretionary promise. The consequence, however, is that statutory material codes, mandated disposal pictograms and deposit legends sit definitionally outside the category.

The two dominant frameworks therefore exclude, between them, most of the marks a consumer encounters in practice on a package — the first because such marks are not claims, the second because they are not voluntary.

The field has been mapped before, and two bodies of prior work bear on the question. UNEP and Consumers International (2020) conducted a global mapping and assessment of standards, labels and claims on plastic packaging, and Teymouri et al. (2026) systematically reviewed 52 studies of the eco-labelling landscape across sectors, though not packaging specifically. What has not emerged from this work is a settled taxonomy: the mapping exercises catalogue instances rather than proposing categories, and the systematic reviews take eco-labels as their unit of analysis, which excludes by construction the mandatory and transactional marks discussed here.

Two axes, five families

A taxonomy useful for packaging should classify by two things determinable from the mark and its legal context: what the mark asserts, and who is bound by it. On that basis, packaging marks fall into five families.

1. Disposal and sortation marks

These tell a person what to do with the item, and they assert a fact about infrastructure rather than about the material. How2Recycle's four designations — Widely Recyclable, Check Locally, Store Drop-off and Not Yet Recyclable — are defined by population access: "Widely Recyclable" means "at least 60% of Americans and 50% of Canadians can recycle these packages through curbside or drop-off programs", while "Not Yet Recyclable" applies where fewer than 20% can, "or there are significant challenges in sortation, reprocessing, or end markets" (How2Recycle, n.d.). OPRL issues Recycle where 75% or more of UK local authorities collect the packaging type, Do Not Recycle where fewer than 50% do, and retains an intermediate Check Home Collections status for fully recyclable formats falling in the 50–75% band (OPRL, n.d.). The Australasian Recycling Label uses Recyclable, Conditionally Recyclable and Not Recyclable, the middle state defined as recyclable "if the instructions below the symbol are followed" (UNEP and Consumers International, n.d.).

The two three-state schemes issue the same number of designations, and their third designations perform different functions. OPRL's intermediate label expresses uncertainty about infrastructure: the packaging is recyclable but collection is patchy. The ARL's expresses conditionality on consumer action: the packaging is recyclable provided something is done to it first. Both are commonly described as "three-category schemes", which obscures that they are resolving different problems.

One statement of what this family does and does not assert, and the most explicit of those located among the scheme operators examined, comes from the operator of the Dutch Weggooiwijzer, which states that correct disposal offers no guarantee that the packaging can be sorted or fully recycled, and directs users to a separate assessment tool for that question (KIDV, n.d.). The Nordic Eupicto system is more constrained still: its pictograms denote material streams and waste-management routes rather than recyclability verdicts, and are administered on a not-for-profit basis for free public use (Eupicto, n.d.).

Two properties distinguish the family. It is geographically contingent — the same package is legitimately labelled differently in two jurisdictions because the underlying infrastructure differs. It also frequently carries an instruction layer analytically separate from the verdict: OPRL's call-to-action options are "clean", "rinse", "scrape", "empty" and "scrunch" (OPRL, n.d.), which are behavioural directives attached to, but not identical with, the recyclability assessment.

2. Material identification marks

These identify what the item is made of and assert nothing further. The resin identification code is the canonical case, and the governing standard addresses the point expressly: ASTM D7611/D7611M states in its Significance and Use that "Resin Identification Codes are not 'recycle codes'", that "the term 'recyclable' or other environmental claims shall not be placed in proximity to the Code", and that the presence of a code "does not imply that the article is recycled or that there are systems in place to effectively process the article" (ASTM International, 2026).

The alphanumeric material codes required in several European markets belong to the same family, deriving from the identification system established by Commission Decision 97/129/EC. The material-composition pictograms envisaged under PPWR may also be placed in this family: recital 74 describes them as resting on a Commission methodology "for identifying the material composition of packaging" (Regulation (EU) 2025/40). They are, however, designed to drive sorting behaviour, and they accordingly sit at the boundary with family 1.

3. Certification marks

These assert that a third party has verified conformity with a defined standard. Compostability marks, forest certification marks and multi-criteria ecolabels belong here. What unites them is not their subject matter, which varies widely across the family, but their structure: an independent body, a published criteria set, an audit, and a licence to display.

Delmas and Grant (2014) draw a distinction that bears directly on this family, arguing that "the certification of environmental practices by a third party should be analyzed as a strategy distinct from — although related to — the disclosure of the eco-certification through a label posted on the product." Their empirical finding, that certification earned a price premium while displaying the label did not, cautions against treating the mark and the underlying assurance as one object. A taxonomy of labels is not a taxonomy of certifications; the label is the communicative act, and it can be present without, or absent despite, the assurance.

4. Performance scores

These grade or rank rather than passing or failing. Carbon footprint labels, letter-graded eco-scores and comparative environmental ratings belong here. They differ from certification marks in conveying magnitude rather than threshold compliance, and from disposal marks in concerning production impact rather than end-of-life routing. This family maps most closely onto the ISO series, which addresses it directly through footprint communications.

This family is nonetheless subject to a specific constraint under EU consumer law. Directive (EU) 2024/825 renders it an unfair commercial practice to display "a sustainability label that is not based on a certification scheme or not established by public authorities" (Annex I, point 2a of Directive 2005/29/EC as amended), a provision that bears directly on a self-operated retailer score, since such a score makes a comparative environmental assertion without the third-party structure that the certification family supplies by definition.

5. System-participation marks

These indicate membership of a scheme, usually because a fee has been paid or a legal obligation discharged. The Green Dot is the paradigm, and its owner is explicit: PRO EUROPE states that "Green Dot® is a financing symbol and not an environmental symbol", and that its presence indicates "a financial contribution has been paid to a nationally authorised take-back system" (PRO EUROPE, n.d.a). Deposit return marks belong to the same family, as do producer responsibility registration identifiers.

This family is invisible in both dominant frameworks. It is not a claim about the product, so it is not an environmental claim under EU consumer law; it is not a verified environmental assertion, so it is not an ISO environmental statement. Its volume on European packaging is nonetheless substantial: PRO EUROPE reports that more than 150,000 companies are licensees and over 400 billion packaging items have carried the symbol (PRO EUROPE, n.d.b).

Consequences of misclassification

The distinctions between the families have practical consequences where a mark from one family is read as belonging to another.

The case documented most fully in the sources examined concerns families 1 and 2. The US National Academies' consensus study on municipal solid waste recycling states that "inconsistent and misleading packaging labels, including the use of the chasing arrows symbol and resin identification codes, are significant causes of consumer uncertainty and misunderstanding", and that "many consumers are confused by on-product resin identification codes, which use the chasing arrows symbol around a number 1 through 7, as an indicator of a product's recyclability" (National Academies of Sciences, Engineering, and Medicine, 2025). This is a material identification mark being read as a disposal instruction, which is the confusion between families 1 and 2 that the taxonomy identifies, and it is the reading that ASTM's own standard disclaims in the passage quoted above.

The evidence on family 5 is weaker but not absent, and it points in the direction the taxonomy would predict. A survey of 2,000 UK adults conducted by the consumer organisation Which? in 2018 reportedly found that 48% incorrectly believed the Green Dot indicates an item can be recycled (Packaging Insights, 2018). Set against this, an observational study by RECOUP in 2019, also available only through trade coverage and without a stated sample size, reported that where clear on-pack sorting instructions were visible, symbol confusion did not appear to drive disposal behaviour, even though the same study was reported as finding that the Green Dot adds to consumer confusion (Interplas Insights, 2019). Both are grey literature. No peer-reviewed study quantifying Green Dot misinterpretation could be located, and the two available sources, taken together, report substantial misunderstanding of what the symbol means alongside unclear consequences for disposal behaviour.

No study of any kind was located examining whether consumers conflate forest sourcing marks with disposal instructions. That hypothesis follows directly from the taxonomy, and no test of it was identified in searches conducted for this article.

Limits of the classification

Three limitations of the classification are set out below.

The chasing arrows graphic is not itself a member of any family, and it is not, as is sometimes claimed, undefined. The Mobius loop is specified in ISO 14021, and its use when enclosing a resin number is governed by ASTM D7611; in the United States its use in recyclability claims falls under the Federal Trade Commission's Green Guides (16 CFR § 260.12). The problem is not absence of definition but multiplicity: several bodies define the graphic for different purposes, and it appears as a component of marks in at least three families. It is accordingly a visual convention that marks in several families incorporate, rather than a mark in its own right.

Hybrid marks are common. OPRL combines a family 1 verdict with an instruction layer; the ARL's conditional state is a verdict whose meaning is completed by an instruction. The families classify the primary assertion, not every element of a composite mark.

Finally, the taxonomy classifies marks, not schemes. Following Delmas and Grant (2014), a single certification programme may generate an on-pack mark, a business-to-business assurance and a procurement qualification, and only the first is in scope.

Implications for research, regulation and measurement

Three implications follow.

For research: the aggregate figures that predominate in this literature do not identify which family of mark produces the effect they record. Meis-Harris et al. (2021), reviewing ten prior reviews, concluded that "eco-labels on their own are an information-based communication tool that is unlikely to create significant shifts in consumer choices or production." That conclusion is drawn at the aggregate level, and it pools instruments with different mechanisms of action. A disposal mark that improves sorting and a performance score that fails to shift purchasing are not evidence about the same intervention. Galarraga Gallastegui (2002) organised the eco-label literature into consumer-demand, producer-response and trade streams. That scheme classifies the research rather than the labels, and citations treating it as a taxonomy of labels themselves misdescribe it.

For regulation: schemes drafted against voluntary claims will systematically miss families 2 and 5, which are largely mandatory or contractual. This is a jurisdictional artefact rather than an oversight — consumer protection law regulates promises, and neither a material code nor a licensing trademark is a promise.

For measurement: a preparatory study for the European Commission assessed 232 active ecolabels in the EU and found that "almost half of the labels' verification was either weak or not carried out" (European Commission, 2023), while Ecolabel Index recorded 456 ecolabels across 199 countries and 25 sectors as at 17 August 2026 (Ecolabel Index, 2026). Counts of this kind are frequently deployed in support of the proposition that consumers face too many labels. Until the counted objects are separated by family, however, such figures aggregate marks encountered in different contexts and read for different purposes, and the inference from count to confusion remains unproven.

References

ASTM International (2026) ASTM D7611/D7611M-26: Standard Practice for Coding Plastic Manufactured Articles for Resin Identification. West Conshohocken, PA: ASTM International. Available at: Open source (Accessed: 17 August 2026).

Commission Decision 97/129/EC of 28 January 1997 establishing the identification system for packaging materials pursuant to European Parliament and Council Directive 94/62/EC on packaging and packaging waste, OJ L 50, 20.2.1997, pp. 28–31.

Delmas, M.A. and Grant, L.E. (2014) 'Eco-labeling strategies and price-premium: the wine industry puzzle', Business & Society, 53(1), pp. 6–44. doi:10.1177/0007650310362254.

Directive (EU) 2024/825 of the European Parliament and of the Council of 28 February 2024 amending Directives 2005/29/EC and 2011/83/EU as regards empowering consumers for the green transition, OJ L, 2024/825, 6.3.2024. Available at: Open source (Accessed: 17 August 2026).

Ecolabel Index (2026) Ecolabel Index home page. Available at: Open source (Accessed: 17 August 2026).

Eupicto (n.d.) About the pictogram system. Copenhagen: Eupicto. Available at: Open source (Accessed: 17 August 2026).

European Commission (2023) Proposal for a Directive of the European Parliament and of the Council on substantiation and communication of explicit environmental claims (Green Claims Directive), COM(2023) 166 final, 22 March. Available at: Open source (Accessed: 17 August 2026).

Galarraga Gallastegui, I. (2002) 'The use of eco-labels: a review of the literature', European Environment, 12(6), pp. 316–331. doi:10.1002/eet.304.

How2Recycle (n.d.) How2Recycle labels. Available at: Open source (Accessed: 17 August 2026).

International Organization for Standardization (2022) ISO 14020:2022 Environmental statements and programmes for products — Principles and general requirements. 3rd edn. Geneva: ISO. Available at: Open source (Accessed: 17 August 2026).

Interplas Insights (2019) Green Dot symbol adds to consumer confusion, finds RECOUP study. Available at: Open source (Accessed: 17 August 2026).

KIDV (Kennisinstituut Duurzaam Verpakken) (n.d.) Weggooiwijzer. Available at: Open source (Accessed: 17 August 2026).

Meis-Harris, J., Klemm, C., Kaufman, S., Curtis, J., Borg, K. and Bragge, P. (2021) 'What is the role of eco-labels for a circular economy? A rapid review of the literature', Journal of Cleaner Production, 306, art. 127134. doi:10.1016/j.jclepro.2021.127134.

Minkov, N., Bach, V. and Finkbeiner, M. (2018) 'Characterization of the Cradle to Cradle Certified™ Products Program in the context of eco-labels and environmental declarations', Sustainability, 10(3), art. 738. doi:10.3390/su10030738.

Minkov, N., Lehmann, A., Winter, L. and Finkbeiner, M. (2020) 'Characterization of environmental labels beyond the criteria of ISO 14020 series', The International Journal of Life Cycle Assessment, 25(5), pp. 840–855. doi:10.1007/s11367-019-01596-9.

National Academies of Sciences, Engineering, and Medicine (2025) Municipal Solid Waste Recycling in the United States: Analysis of Current and Alternative Approaches. Washington, DC: The National Academies Press. doi:10.17226/27978.

OPRL (n.d.) How the scheme works. Available at: Open source (Accessed: 17 August 2026).

Packaging Insights (2018) Are recycling symbols confusing UK consumers? Available at: Open source (Accessed: 17 August 2026).

PRO EUROPE (n.d.a) The Green Dot trademark. Brussels: Packaging Recovery Organisation Europe. Available at: Open source (Accessed: 17 August 2026).

PRO EUROPE (n.d.b) Frequently asked questions. Brussels: Packaging Recovery Organisation Europe. Available at: Open source (Accessed: 17 August 2026).

Regulation (EU) 2025/40 of the European Parliament and of the Council of 19 December 2024 on packaging and packaging waste, amending Regulation (EU) 2019/1020 and Directive (EU) 2019/904, and repealing Directive 94/62/EC, OJ L, 2025/40, 22.1.2025. Available at: Open source (Accessed: 17 August 2026).

Teymouri, A., Feng, L., Wibowo, K., Sánchez Esparza, L., Fatima, N. and Charlton, P. (2026) 'Mapping the eco-labeling landscape: a systematic review for coherent governance and future research', Sustainability, 18(11), art. 5348. doi:10.3390/su18115348.

The Recycling Partnership (2021) Consumer Research on Recycling Behavior and Attitudes Regarding On-Pack Labeling. Available at: Open source (Accessed: 17 August 2026).

UNEP and Consumers International (2020) "Can I Recycle This?" A Global Mapping and Assessment of Standards, Labels and Claims on Plastic Packaging. Nairobi: United Nations Environment Programme. Available at: Open source (Accessed: 17 August 2026).

UNEP and Consumers International (n.d.) Australasian Recycling Label (ARL) [case study]. Available at: Open source (Accessed: 17 August 2026).

Note on sources and verification

The four-instrument scope of ISO 14020:2022 is taken from the standard's published scope statement as reproduced on the ISO catalogue page; the full text was not purchased, and clause-level detail should be confirmed before onward citation. The verbatim text of Article 12 of Regulation (EU) 2025/40 could not be retrieved in full during preparation, and citations to that instrument are therefore to its recitals, retrieved directly from EUR-Lex.

The evidence on Green Dot misinterpretation is grey literature on both sides. The Which? figure of 48% is reported here from trade coverage; the primary survey report was not obtained, and the figure should be treated accordingly. The RECOUP study is likewise available only through trade reporting, without a stated sample size. Both are cited because the alternative — asserting that no evidence exists — would be inaccurate, but neither meets the standard applied to peer-reviewed findings throughout.

The undated case study of the Australasian Recycling Label is cited without a publication year because none is stated in the document. It sits within a body of work by UNEP and Consumers International on plastic packaging labelling of which the 2020 global mapping is the principal published output.

Last verified: 17 August 2026.