In June 2026 the Paris judicial court held that "100% recyclable" and "100% recycled" on a brand of plastic water bottles were misleading commercial practices: the label glue and ink were not recyclable, and the cap and label were not recycled material. Since 27 September 2026, EU Directive 2024/825 also bans generic claims such as "eco-friendly" or "green" unless you can prove recognised excellent environmental performance. If you sell into France, every recyclability or recycled-content claim on your packaging or listing must be specific, cover the whole item or say which part it covers, and be backed by evidence you can show.Sources (7)France 24 / AFPFrance 24 / AFP — Volvic jugée coupable de « pratiques commerciales trompeuses », tribunal judiciaire de Paris (29 June 2026)
LégifranceLégifrance — Code de l'environnementDGCCRFDGCCRF — Allégations environnementales : ce qu'il faut retenir (article R. 541-228 VI)
EUR-LexEUR-Lex — Directive (EU) 2024/825, empowering consumers for the green transitionEuropean CommissionEuropean Commission — Sustainable consumption: green claims rules and Q&ABEUCBEUC — Danone, Nestlé and Coca-Cola commit to address greenwashing (22 October 2026)European CommissionEuropean Commission — Coordinated actions on sustainable consumption (bottled water claims)
The ruling
A consumer association, CLCV, sued over the claims printed on a well-known brand of mineral water bottles. On 23 June 2026 the Paris judicial court found the claims misleading, and the judgment was made public on 29 June. France 24 / AFP The reasoning matters more than the brand:
- "100% recyclable" failed because the whole item is what the buyer sees. The label used glue and ink that are not recyclable, so the bottle as sold was not 100% recyclable.
- "100% recycled" failed because the cap and the label were not made of recycled material. A footnote-style "excluding cap and label" was not enough to save it.
- A carbon-neutral claim also failed: the bottle's emissions were not fully offset.
The court ordered the producer to publish the judgment and pay damages to the association.
French law already set the bar
France regulates these words directly. Article L. 541-9-1 of the Environmental Code forbids "biodegradable", "environmentally friendly" or any equivalent wording on a product or its packaging. Légifrance Article R. 541-228 lists the conditions a product must meet before it can be called "recyclable", and they are cumulative: meeting most of them is not enough. DGCCRF The court applied these rules to a claim printed in very large type, and the claim lost.
The EU layer, since 27 September 2026
Directive (EU) 2024/825, known as EmpCo, amends the EU unfair commercial practices rules. EUR-Lex From 27 September 2026 it adds to the blacklist:
- Generic environmental claims ("eco-friendly", "green", "ecological", "climate-friendly", "biodegradable") unless you can show recognised excellent environmental performance, for example an EU Ecolabel.
- Claims about the whole product when they are true of only part of it. That is exactly the bottle case.
- Sustainability labels that are not based on a certification scheme or set up by a public authority.
There is no transition period for stock already on shelves; the Commission's guidance says claims can be covered or corrected with a sticker. European Commission Some member states transposed late. Do not wait for your local text: the date that counts is 27 September 2026.
Three drinks groups changed their labels
In November 2023 BEUC and consumer groups from 13 countries complained to EU consumer authorities about recyclability claims on bottled water. Coca-Cola committed first, then Nestlé. On 22 October 2026 the Commission announced that Danone had followed. BEUC All three will now state that "100%" recycled claims exclude the cap and the label, and will stop suggesting a closed recycling loop. European Commission
Read the two cases together. A qualified claim ("100% recycled body, excluding cap and label") is now what the EU authorities accept. A French court held that a small-print exclusion did not cure a bold "100%". The safe ground is a claim that is precise where the buyer reads it, not further down.
What to check on your own packaging and listings
- Remove generic words: eco-friendly, green, ecological, planet-friendly, climate-friendly. In France some were already illegal; across the EU they now need certified proof.
- "Recyclable": only if the whole item meets the R. 541-228 conditions, labels, inks, sleeves and closures included. Otherwise say which part is recyclable.
- "Recycled" or "made from x% recycled": give the percentage of the whole item, or name the part, in the same place and size as the claim.
- No loop arrows or nature imagery that implies the product has no impact.
- Keep the evidence: supplier certificates for recycled content and the recyclability assessment, per SKU. A marketplace or a consumer authority will ask for them.
- Listings count too. The rules apply to any commercial communication, so check Amazon bullet points, Shopify pages and A+ content, not just the box.
None of this replaces the mandatory sorting information. The Triman logo and sorting instructions are still required on household packaging sold in France, and they are not an environmental claim. Your EPR registration and IDU are separate again: see the Free EPR Calculator for what the eco-contributions cost and the pricing page for ours. Sources (2)LégifranceLégifrance — Article L541-9-3 (signalétique de tri)
ADEMEADEME — Filière REP Emballages ménagers et papiers (EMPAP)
Frequently asked questions
Can I still write "recyclable" on my packaging in France?
Only if the whole item meets the conditions in article R. 541-228 of the Environmental Code, labels and inks included. If only part of it does, say which part.
Is "100% recycled, excluding cap and label" allowed?
It is the wording the EU consumer authorities accepted from Coca-Cola, Nestlé and Danone. Put the exclusion next to the claim, in a readable size, not in a footnote.
Does the EU ban on generic claims apply to my Amazon listing?
Yes. Directive 2024/825 covers any commercial communication to consumers, so listing text and images count, not only the printed packaging.
Is the Triman logo an environmental claim?
No. It is mandatory sorting information under French law and stays on household packaging whatever claims you remove. ADEME
Razvan Toma is the founder of EPR France Rep, a France-established authorised representative (mandataire) for producers with no French establishment. He has worked in waste management and recycling since 2009, running waste-separation programmes inside large B2B organisations in France for clients including Chanel, Microsoft, Decathlon, Pirelli, IKEA, Vinci, Capgemini and E.Leclerc.
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