What happened
The European Commission announced on 22 October 2026 that Coca-Cola, Nestlé and Danone have committed to change the recycling claims on their plastic bottles, following a dialogue with the Commission and the Consumer Protection Cooperation (CPC) network, the group of national authorities that enforce EU consumer law. The action was led by the Swedish Consumer Agency and the Hungarian Competition Authority. It started with an alert from the European Consumer Organisation (BEUC) in November 2023, as Mark Segal reported for ESG Today.
According to the Commission, the companies committed to:
- replace label claims such as "I am a bottle made from 100% recycled plastic" with "This bottle is 100% recycled. Excluding cap and label", so the claim says exactly which parts it covers;
- replace "Recycle me again" with "Recycle me", so shoppers aren't given the impression the bottle was already recycled and will become another bottle;
- make sure the overall impression of the label and marketing doesn't mislead about the environmental benefits of plastic bottles, for example by adding other green claims or symbols;
- make their website and social media campaigns match the new commitments.
The Commission's press release (IP/26/2238) says the dialogues with Coca-Cola and Nestlé Waters concluded in June 2025 and February 2026, and its records date the three companies' commitments 6 May 2025, 30 March 2026 and 16 October 2026. National consumer authorities will monitor the changes and may take enforcement action if the companies don't comply. The Commission says the network may also engage with bottling industry associations so that other companies make the same changes.
What it means for a small UK business
The EU action doesn't bind you in the UK, but the problem it fixes is exactly what UK law covers too. The CMA's Green Claims Code says claims must be truthful, clear, complete and backed by evidence. On recycling it is specific: you must not call a product "recyclable" if only parts of it are, and you should make clear whether a claim covers the whole product, its packaging or just part of it, and say how to recycle it. The CMA says claiming recycled content you don't have is always liable to mislead.
The stakes went up in April 2025. Under the Digital Markets, Competition and Consumers Act 2024 the CMA can now decide for itself that consumer law has been broken and fine a business up to 10% of its global turnover. If you sell to consumers in the EU as well, the Commission is clear that EU consumer law, including on environmental claims, applies to every company selling there.
What to do now
- List every recycling claim you make: on packaging, product pages, social posts and tender answers. Include symbols and green imagery, which the Commission treated as part of the overall impression.
- Say what each claim covers. "Box made from 100% recycled card, tape and window film not included" is clearer than "100% recycled packaging". "Recyclable" should say which parts and how.
- Keep the data behind it. For recycled content, that means supplier specifications or certificates and the weight of each packaging component. For "we recycle our waste" claims, keep your waste contractor's transfer notes or annual report, which give tonnes by material and how it was treated.
- Check your packaging figures line up. If you are an obligated producer, the weights you report for packaging EPR should match what your claims imply.
- Watch the wording of targets. Future promises such as "fully recyclable packaging by 2028" need a real plan, as our post on net zero and target wording explains.
A worked example: the carbon behind a recycling claim
The same waste records that back up a claim also go into your carbon footprint, in Scope 3 category 5. Say a small business sends 2 tonnes of mixed plastic waste a year (an illustrative figure). With the 2026 government factors:
| Route | Factor (kg CO2e per tonne) | Emissions (kg CO2e) |
|---|---|---|
| Landfill | 9.00687 | 18 |
| Recycling | 4.65358 | 9 |
That is about 9 kg CO2e a year less in your reported figures: small, partly because the recycling factor only covers getting the waste to the recycler. The bigger carbon gain from recycled plastic shows up when it replaces new plastic: the 2026 government material use factors put a tonne of average plastic at 3,171 kg CO2e made from virgin sources against 1,573 kg CO2e from recycled sources. That is exactly why a "recycled content" claim has to be accurate. Our post on recycling against landfill compares materials, including making them from recycled rather than virgin sources.
