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Environmental Claims Under Scrutiny: U.S. Packaging Labelling Laws Explained

This blog was originally posted on 30th March, 2026. Further regulatory developments may have occurred after publication. To keep up-to-date with the latest compliance news, sign up to our newsletter.

AUTHORED BY RUAN DOHERTY, REGULATORY COMPLIANCE SPECIALIST, COMPLIANCE & RISKS

Key Insight

Regulators across U.S. states and at the federal level are proposing stricter rules around recyclability claims, requiring stricter evidence and clearer standards before packaging can be labeled as “recyclable.” These developments signal a shift toward more transparent, substantiated environmental claims and potentially a harmonised national framework.

At a Glance

Environmental claims on packaging are under increasing scrutiny in the United States. Terms like “recyclable,” once broadly used in marketing, are now subject to detailed legal definitions and regulatory oversight to ensure they are accurate, substantiated, and reflect real-world recycling systems.

State governments, led by California, are introducing these standards, while federal proposals suggest the potential for a more harmonised national framework. Together, these developments mark a significant shift in how these claims are communicated to consumers: what producers say about their packaging is no longer just a marketing choice, but a potential legal responsibility.

State-Level Developments

California Senate Bill 343

Enacted in 2021, California Senate Bill 343 has become the reference point for truth in labelling laws.

It prohibits the use of the chasing arrows symbol or similar recyclability indicators on a product or packaging unless the material meets detailed, state-defined criteria. These criteria are grounded in whether materials are collected for recycling by programmes serving at least 60% of the state’s population, sorted into defined streams by facilities covering at least 60% of recycling programmes, and routinely used as feedstock by reclaimers to manufacture new products or packaging.

The restrictions are set to take effect from October 4, 2026, but new legal challenges may affect implementation. On March 17, 2026, a broad coalition of stakeholders filed a lawsuit seeking to block enforcement, arguing that SB 343 infringes on First Amendment protections for commercial speech and imposes overly rigid standards. Overall, these proceedings introduce uncertainty for producers’ enforcement.

New Jersey Senate Bill 630

Senate Bill 630 was reintroduced from a previous legislative session in January 2026, and closely mirrors California’s framework.

The bill requires products to meet both collection and processing benchmarks, each covering at least 60% of the population or recycling programmes, before recyclability claims can be made. Like California, it treats the chasing arrows symbol as inherently misleading unless these conditions are satisfied and introduces restrictions, such as excluding materials containing hazardous substances or PFAS from being considered recyclable.

It also requires the Department of Environmental Protection (DEP) to maintain a publicly accessible list of materials deemed recyclable and to update it regularly. Multi-material packaging must clearly indicate which components are recyclable, and certain substances, such as PFAS, may exclude products from being labelled as recyclable.

Massachusetts House Bill 4810

As revised in December 2025, House Bill 4810 aims to prevent deceptive or misleading claims about the recyclability, biodegradability, or compostability of products and packaging.

Similar to other states, it requires companies making environmental claims to maintain written documentation substantiating these claims. This includes an attestation of recyclability or compostability in the state, disclosure of any significant environmental impacts of the product, and confirmation of compliance with FTC Green Guides. For products with multiple materials, only the recyclable components may carry the recycling symbol, provided non-recyclable components are clearly identified. Exceptions are allowed for legally mandated symbols or products compliant with FTC standards.

New York Senate Bill 420

Senate Bill 420 was introduced in January 2025 and reported to the Finance Committee in February 2026.

It similarly establishes that it is deceptive to misrepresent that a product or package is recyclable unless it can be collected, separated, or otherwise recovered through an established recycling program for reuse or use in manufacturing another item.

The bill differs slightly as it directs the Department of Environmental Conservation to develop regulations specifying which types and forms of plastic products and packaging can legitimately claim recyclability, highlighting that, while the prohibition applies more broadly to all products and packaging, its operational focus is firmly on plastics.

Oklahoma House Bill 4068

Introduced in February 2026, House Bill 4068 is the latest state to introduce recyclability labelling legislation. While similar to other state-level legislation, it is unique as it expands the scope beyond recyclability to encompass broader environmental and climate-related claims.

The bill aims to create a framework governing environmental marketing claims on products, services, and packaging. It covers a wide range of claims, including terms such as recyclable, compostable, biodegradable, carbon neutral, net zero, eco-friendly, sustainable, non-toxic, and zero-waste.

Under the bill, it would be prohibited for any person to sell or market products in Oklahoma using environmental claims or symbols unless those claims are truthful, not misleading, and properly substantiated. For carbon-neutral or net-zero claims, additional disclosure requirements apply, including clear information on how emissions are calculated, whether offsets are used, verification by third parties, and access to supporting documentation via a public website or digital link.

For more information on US state-level packaging legislation, download our comparison guide or check out this blog.

Federal-Level Developments

House Bill 6832 (the PACK Act)

Introduced in December 2025, House Bill 6832 (the Packaging and Claims Knowledge Act), proposes to amend the Federal Trade Commission Act to establish a clear federal standard governing environmental marketing claims for consumer product packaging.

The bill reflects many of the core principles already emerging at state level, as it prohibits the use of claims such as “recyclable,” “compostable,” and “reusable” unless they are truthful, not misleading, and supported by competent and reliable scientific evidence. It further requires that such claims reflect real-world conditions, meaning materials must be capable of being processed through existing and accessible systems, rather than being theoretically possible under limited or non-existent infrastructure.

The bill further directs the Federal Trade Commission to adopt implementing rules that define the conditions under which environmental claims may be made, including the potential use of third-party certification systems to verify compliance. It also addresses the use of symbols, labels, and marketing representations, prohibiting the use of misleading indicators (such as recycling symbols) where the applicable criteria are not met.

House Bill 7502

House Rule 7502 was introduced in February 2026; however, the full legislative text has not yet been published. Based on information available from the U.S. Congress website, the bill would prohibit making misleading recycled content claims in the advertising, marketing, sale, or offering for sale of consumer products. It reinforces the same underlying regulatory direction seen at both federal and state level: increasing scrutiny of environmental claims and a clear move toward requiring robust substantiation.

Looking Ahead

Claims that were once commonplace, such as the chasing arrows symbol or general recyclability language, now carry legal risk if they cannot be substantiated against defined criteria. Producers will need to review existing labelling, assess the recyclability of their packaging materials against applicable standards, and maintain documentation to support any claims made.

For further insight into global greenwashing legislation, check out our blog answering top questions from ICPHSO’s 2026 Green Claims Panel.

Stay Ahead Of Regulatory Changes in US Packaging Labelling Laws

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