Coca-Cola, Nestlé Waters and Danone have agreed to revise recycling claims on plastic beverage bottles sold in Europe, following a consumer complaint challenging the accuracy of recycled-content and recyclability messaging.
The commitments, announced by the European Commission on 22 October, will require the companies to clarify which packaging components are covered by recycled-content claims and remove wording that could suggest plastic bottles can be recycled repeatedly in a closed loop.
The changes follow a complaint lodged in November 2023 by the European Consumer Organisation (BEUC), supported by consumer organisations from 13 countries, which challenged claims including '100% recyclable' and '100% recycled', as well as the use of green imagery suggesting environmental benefits.
Following discussions with the European Commission and the Consumer Protection Cooperation (CPC) network, the three companies have agreed to revise their on-pack and digital marketing communications to comply with EU consumer protection requirements.
Changes to on-pack claims
Under the commitments, claims such as 'I am a bottle made from 100% recycled plastic' will be replaced with wording that makes clear the claim excludes the cap and label.
The European Commission gives the example 'This bottle is 100% recycled. Excluding cap and label', with the qualification required to appear directly alongside the recycled-content claim and in the same font size.
The companies have also agreed to replace messages such as 'Recycle me again' with 'Recycle me', avoiding the implication that bottles have already been recycled and will necessarily be recycled into new bottles.
In addition, the overall presentation of labels, including symbols, graphics and other environmental messaging, must not mislead consumers about the environmental benefits of plastic packaging. The commitments extend to websites and social media campaigns.
Complaint challenges recycling messages
BEUC argued that claims of 100% recyclability can mislead consumers because actual recycling depends on collection infrastructure, sorting efficiency and the availability of suitable recycling processes.
The organisation also challenged recycled-content claims that appeared to apply to an entire bottle when caps and labels were not made from recycled materials.
According to BEUC, approximately 55 per cent of PET beverage bottles are recycled in the EU, while the likelihood of a bottle being recycled into another bottle is around 30 per cent.
Agustín Reyna, director general of BEUC, welcomed the companies' commitments.
"It is great news that the three companies flagged by consumer organisations, Danone, Nestlé and Coca-Cola, have now committed to changing their practices to stop misleading consumers about the recyclability of their products. Consumers need to be able to trust companies' environmental claims," he said.
Coca-Cola concluded its discussions with EU authorities in 2025, followed by Nestlé Waters in early 2026. Danone's agreement in October completes the commitments from the three companies named in the original complaint.
The European Commission said Coca-Cola and Nestlé had already implemented some changes to recycling claims in digital campaigns.
National consumer protection authorities will monitor implementation and may take enforcement action if the companies fail to meet their commitments. Authorities will also assess practices among other major bottling companies operating in the European market.
Implications for Australian packaging
The European action highlights the importance of distinguishing between recycled content, technical recyclability and actual recycling outcomes when developing environmental claims for packaging.
In Australia, the ACCC's guidance on environmental and sustainability claims similarly requires businesses to ensure claims are accurate, supported by evidence and do not create misleading overall impressions through wording or imagery.
For packaging suppliers, brand owners and designers, the European commitments reinforce the need to substantiate recycled-content percentages, identify which packaging components are covered and consider how recycling symbols and supporting messages are interpreted by consumers.
The agreements do not impose new requirements on Australian packaging, but provide a practical example of regulatory scrutiny extending beyond the accuracy of individual claims to the overall presentation of environmental information on pack.
