Editorial Standard -- No. 07 / 2026
The Terminology Index.
Words are compliance risks.
"Bio-based", "recycled", "vegan", "plant-based" -- these are not synonyms. Each carries a distinct legal meaning, a distinct test method, and a distinct liability under EU Directive 2024/825. This reference defines the terms, groups the confusions, and tells you where each claim breaks.
Alphabetical Index of Material Claims
Every term below is defined by its regulatory basis, its measurable property, and the claim it does not support. Terms marked ochre carry elevated legal risk under the EmpCo Directive.
- Bio-based
- Material whose carbon content derives wholly or partly from biological origin (EN 16785-1). The bio-based content is measured by mass percentage, not by product story. A 30% bio-based material is 70% synthetic, and must be labelled as such.
- Biodegradable
- Micro-organisms convert the material into water, CO₂ and biomass under specified conditions (EN 13432 for industrial composting). It says nothing about marine degradation, home composting, or toxicity of residues. Do not extrapolate.
- Carbon Neutral
- Banned as a product claim from 27 September 2026 under Directive 2024/825 unless substantiated by direct emissions reductions, not offsets. A product cannot be "carbon neutral" if its production emits CO₂ and the seller merely purchases offsets.
- Circular
- Material flows in a closed loop -- designed for reuse, repair or recycling. The term alone is not a claim; it requires a documented take-back or recycling stream. Without a verified chain, "circular" is aspirational, not factual.
- Eco-Leather
- Prohibited as a generic claim under 2024/825. The term implies environmental superiority without a comparative baseline. If a material is 60% polyurethane, calling it "eco" is a legal liability, not a marketing choice.
- EmpCo
- The Empowering Consumers for the Green Transition Directive (EU) 2024/825. The binding legal instrument for environmental claims. Transposition deadline: 27 March 2026. Rules apply from 27 September 2026.
- Full-Grain
- The entire hide surface is retained, un-sanded and un-corrected. A quality descriptor for genuine leather -- it says nothing about environmental impact, tanning chemistry, or chromium content.
- GRS
- Global Recycled Standard. Verifies recycled content and chain of custody. It does not verify biodegradability, toxicity, or carbon footprint. The question is not "is it GRS certified" but "what does the certificate not cover".
- LWG
- Leather Working Group. An environmental certification for tanneries -- covering water, energy, waste and chemical management. It is a facility audit, not a product claim. A leather product cannot be "LWG certified"; a tannery can.
- Martindale
- Abrasion resistance test (ISO 12947). Measures rubs to failure or visible change. A high Martindale number does not indicate tensile strength, flex durability, or hydrolytic stability.
- Plant-Based
- Material derived from plants. It is a source descriptor, not a composition claim. A "plant-based leather" can be 70% polyurethane with a thin plant-fibre backing. The term does not imply biodegradability or environmental superiority.
- PU (Polyurethane)
- A synthetic polymer widely used as the binding matrix in "vegan" and "plant-based" leathers. Typically 30-70% of the material by mass. PU is not biodegradable in standard conditions and is petroleum-derived in most commercial grades.
- Recycled
- Material diverted from the waste stream and reprocessed into a new product (ISO 14021). Requires a documented chain of custody. "Recycled" does not mean "recyclable", "bio-based", or "low-impact" -- recycling itself consumes energy and water.
- Vegan
- Contains no animal-derived inputs. It is an ethical descriptor, not an environmental claim. A vegan material can be petroleum-based, non-biodegradable, and carry a higher carbon footprint than genuine leather.
Bio-Based vs. Recycled vs. Vegan vs. Plant-Based
These four terms are routinely used as if they were interchangeable. They are not. The table below is the standalone reference -- screenshot it, forward it to legal, pin it to the wall.
| Claim Term | Legal / Standard Basis | What It Actually Measures | What It Does NOT Imply | Compliance Risk (2026) |
|---|---|---|---|---|
| Bio-Based "30% bio-based PU" | EN 16785-1 (bio-based content by mass) | Percentage of carbon from biological origin. A 30% bio-based material is 70% synthetic. | Does not imply biodegradable, compostable, or low-impact. A bio-based PU can be toxic and persistent. | HIGH IF % NOT STATED "Bio" alone is generic → banned from Sept 2026 |
| Recycled "100% recycled rPET" | ISO 14021 / GRS Chain of Custody | Material diverted from waste stream and reprocessed. Requires documented traceability. | Does not imply bio-based, biodegradable, or carbon-neutral. Recycling is energy-intensive. | LOW IF DOCUMENTED Risk arises from unverified content claims |
| Vegan "Vegan leather" | No formal standard -- self-declared | Contains no animal-derived inputs. An ethical descriptor, not a material property. | Does not imply environmental benefit. A vegan product can be 100% petroleum-based with a high carbon footprint. | MEDIUM IF PAIRED WITH "ECO" "Vegan" + "sustainable" requires substantiation |
| Plant-Based "Plant-based leather" | No formal standard -- source descriptor | Material derived from plants. Does not state the percentage of plant content by mass. | Does not imply bio-based majority. A "plant-based" material can be 90% polyurethane with 10% plant fibre. | HIGH IF % NOT DISCLOSED Misleading omission under 2024/825 Art. 5 |
Carbon from biological origin. Measure the percentage.
Diverted from waste. Requires documented chain of custody.
Source descriptor. Does not state composition percentage.
No animal inputs. An ethical choice, not an eco-claim.
Do not use "bio-based", "plant-based", "vegan" or "recycled" as interchangeable synonyms in any public claim. Each term is measured by a different standard, verified by a different document, and carries a different penalty for misuse. From 27 September 2026, a generic or conflated claim under Directive 2024/825 exposes the seller to fines up to 10% of annual EU turnover. When in doubt, state the measurable property -- bio-based content by mass percentage, recycled content by chain-of-custody certificate, absence of animal inputs by declaration, and plant content by formulation sheet.
What These Terms Look Like in Practice
Each image below corresponds to a material class covered by this reference. The caption states what the term actually means in practice -- and where the claim fails. The figures are compiled from supplier-published specifications, certificate scopes and primary regulatory sources; Material Primer does not operate a laboratory and has not bench-tested these materials.
Nopal Cactus Composite
Supplier-published composition: 32-38% bio-based content by mass. The remaining 62-68% is polyurethane binder and polyester backing. "Cactus leather" is a marketing name; the legal claim is "bio-based composite, 35% bio-content".
Apple Waste Coated Webbing
Supplier-published composition: 48-52% plant content by mass, with a 48% waterborne PU coating. The term "plant-based" is accurate only when the percentage is disclosed. Without the number, the claim is misleading.
Post-Consumer rPET Microfibre
Supplier-published composition: 100% recycled content, GRS certified. Zero bio-based content. The environmental benefit is real but specific: waste diversion, not carbon neutrality. Recycling energy is still fossil-based in most geographies.
Pure Mycelium Sheet
Supplier-published composition: 88-94% bio-based, 100% vegan. No animal inputs, no synthetic binder beyond 6-12% bio-plasticizer. The claim "vegan" is accurate; the claim "leather" is not -- it is a mycelium composite with different mechanical properties.
Submit a Claim for Neutral Wording Verification
Forward a supplier claim, a product label, or a draft marketing phrase. We check the wording against Directive 2024/825, EN 16785-1, ISO 14021, and the supplier's own published specification and certificate scope. This is a documentary check, not a laboratory test. No marketing contact; no sales follow-up.