Recycled
ISO 14021 requires the percentage by mass but does not oblige anyone to say whether the content is post-consumer or pre-consumer, so you have to ask. A headline figure a supplier cannot split is not an answer.
Meaning by context
ISO 14021 defines recycled content as the proportion, by mass, of recycled material in a product or packaging, and counts only pre-consumer and post-consumer material towards it. Where a recycled content claim is made the percentage must be stated, and the product and packaging percentages must be stated separately and never aggregated (ISO 14021:2016, clause 7.8.2). Pre-consumer and post-consumer material are defined separately and are not interchangeable — but the standard does not oblige a claimant to say which category the content falls into, which is why you have to ask.
ECGT sets no pre-consumer/post-consumer disclosure rule — neither term appears anywhere in the Directive. What it does, from 27 September 2026, is ban generic environmental claims where the trader cannot demonstrate recognised excellent environmental performance relevant to the claim (new Annex I point 4a of Directive 2005/29/EC — a high bar tied to EU Ecolabel-type recognition, not an ordinary evidence file), and ban a claim about the entire product where it concerns only one aspect of it (point 4b); recital 11's own example is a product sold as 'made with recycled material' when only the packaging is recycled, so the same wording on a sheet whose recycled input sits only in a backing layer is caught. The pre/post-consumer split itself comes from ISO 14021; for plastic packaging, Regulation (EU) 2025/40 (PPWR) makes the post-consumer half binding by measuring its minimum recycled-content targets against material recovered from post-consumer plastic waste.
The Green Guides advise that a marketer can make an unqualified recycled-content claim only where the entire product or package — excluding minor, incidental components — is made from recycled material; an item only partially made of recycled material should be qualified clearly and prominently as to the amount or percentage, by weight (16 CFR 260.13(c)). The Guides do not bind the FTC or the public (16 CFR 260.1(a)), but the Commission can act against a claim inconsistent with them under Section 5 of the FTC Act, where it must prove the claim is deceptive.
Where this goes wrong
Stating a recycled percentage without saying whether it is post-consumer or post-industrial is the most common substantiation gap we see. Post-industrial scrap is far easier to source and represents a much weaker circularity argument. A supplier who quotes a headline percentage and cannot split it has not answered the question.