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Hawaii: sustainable packaging labelling
Hawaii requires resin identification on covered plastic bottles and rigid plastic containers and a separate Hawaii-specific mark on beverage containers in the HI-5 deposit program. The two marks serve different legal functions and must be assessed independently.
Executive summary
Hawaii has two mature, mandatory marking systems that can apply to the same package. Chapter 342H requires a resin-identification code on specified plastic bottles and rigid plastic containers. Chapter 342G and the implementing HI-5 rules require covered beverage containers to identify their Hawaii refund status. A beverage bottle may therefore need both a material code near the base and a deposit statement elsewhere on the container.
Neither requirement is a general recyclability certification. The resin code identifies the predominant plastic material. The HI-5 mark identifies a container that participates in Hawaii's deposit-and-redemption system. Artwork review should classify the package separately under each statute and should not convert either mark into a broader claim that the package is environmentally preferable or will be recycled.
Legal status at a glance
| Requirement | Status | Operational meaning |
|---|---|---|
| Plastic resin identification | mandatory | Covered bottles and rigid plastic containers must carry a molded, imprinted or raised 1-7 resin code on or near the bottom. |
| HI-5 deposit identification | mandatory | Covered deposit beverage containers must show the refund value and “Hawaii” or “HI” in characters at least one-eighth inch high. |
| Deposit statement on a noncovered container | prohibited | A beverage container outside the statutory deposit definition may not indicate “Hawaii” or “HI” as though it were redeemable. |
| General recyclability claim | claim-dependent | No state resin or deposit symbol independently proves recyclability; federal environmental-marketing standards remain relevant. |
Resin identification requirement
Sections 342H-41 and 342H-42 cover a plastic bottle with a neck smaller than its body and a capacity of at least 16 fluid ounces but less than five gallons, and a rigid plastic container with a capacity of at least eight ounces but less than five gallons. A covered item distributed, sold or offered for sale in Hawaii must carry a code identifying the resin used to produce it. The code is molded, imprinted or raised on or near the bottom, where it is intended to remain with the container through use.
The statutory format is the legacy three-sided chasing-arrows symbol containing a number from 1 through 7, with the corresponding material abbreviation beneath. If a label or base component uses a different resin, the code follows the primary basic material of the bottle or container. This mark is a composition identifier. It does not establish local collection access, sorting capability or end-market demand, and it should not be described as a mandatory recycling claim.
HI-5 deposit marking
Section 342G-112 requires every beverage container sold or offered for sale in the state and within the deposit program to indicate the refund value and the word “Hawaii” or the letters “HI.” The characters must be at least one-eighth inch high. The statement must appear on the top or side of the container and may be painted, printed, scratch-embossed, raised-letter embossed or applied through a securely affixed sticker. The implementing rule prevents placement on a removable portion that can be detached before redemption.
The program refund is five cents per eligible container. A refillable glass container can use a permanently marked brand in place of the ordinary state wording when it has a refund value of at least five cents. Comparable state names or abbreviations may accompany the Hawaii mark for multistate deposit packaging. Those additional marks should be checked against the laws of the other states and should not reduce the legibility of the Hawaii statement.
Scope and package classification
The HI-5 program applies only after both the beverage and its container satisfy the definitions in Chapter 342G. Beverage type, container size, material and statutory exclusions matter. A package should not be marked merely because it resembles a familiar deposit container. Hawaii expressly prohibits a noncovered beverage container from carrying “Hawaii” or “HI” in a manner indicating deposit eligibility, because a false program mark can cause improper redemption and system cost.
Compliance files should retain the product classification, container dimensions, material specification, distributor registration information, approved barcode or product record, and a production proof showing the location and measured character height. The resin-code analysis should be recorded separately because its bottle and rigid-container definitions are not identical to the beverage-program definition.
Who bears the obligation
The resin-marking prohibition operates at distribution, sale and offer for sale, so manufacturers, importers and commercial distributors need a reliable specification even when molding occurs outside Hawaii. Under the deposit program, distributors are central regulated actors and are responsible for ensuring that covered containers are properly labelled before sale. A brand owner may control the artwork, but the local distributor cannot assume that the brand's national package already satisfies Hawaii law.
Contracts should identify who determines deposit coverage, registers products, controls the state statement and retains evidence. A private allocation of responsibility does not alter the authority of the Department of Health to administer the program or prevent enforcement against the party identified by law.
Enforcement and operational consequences
The Hawaii Department of Health administers the HI-5 program and its rules. The enforcement framework includes administrative penalties for deposit-program violations; the schedule has treated failure by a distributor to label a container properly as a specific violation. Product rejection, corrective relabelling and interruption of distribution can also be more immediate commercial consequences than a monetary penalty.
Because program rules and registration procedures can change, teams should verify the current HI-5 instructions before each launch. The safest approval record combines the controlling statute and rule with the current program guidance rather than relying on a photograph of an existing package.
Practical artwork checklist
First determine whether the plastic item satisfies the resin-code size and form definitions. If it does, verify the principal resin and the molded code. Next determine whether the beverage and container fall within HI-5, select an authorized form of the Hawaii statement, measure the characters and confirm that the location remains attached during redemption. Finally, review any accompanying recycling language as a separate claim under the FTC Green Guides.
Primary sources and verification
Hawaii Legislature. Hawai‘i Revised Statutes, Chapter 342H, sections 342H-41 and 342H-42. Official chapter text
Hawaii Legislature. Hawai‘i Revised Statutes section 342G-112, beverage-container labelling. Current consolidated text
Hawaii Department of Health. HI-5 consumer and redemption-program information. Official program page
Hawaii Department of Health. HI-5 rules and regulations. Official rules index
Hawaii Administrative Rules. Section 11-282-21, container labelling. Consolidated rule
Federal Trade Commission. Guides for the Use of Environmental Marketing Claims, 16 C.F.R. Part 260. Official Green Guides
Federal Trade Commission. Environmental Claims: Summary of the Green Guides. Business guidance
The deposit classification and current program procedures should be confirmed before release. Last verified: 21 August 2026.