Interpreting Pre-consumer Recycled Content Claims

The importance of defining pre-consumer recycled content

Various guidance and regulations have been published on the use of recycled content claims. For example, the Federal Trade Commission (FTC) issued its Green Guides to help marketers avoid deceptive environmental claims, explaining how “reasonable consumers” would likely interpret such claims. ISO 14021 guidance notes that the reliability of self-declared environmental claims depends on adequate verification to “avoid negative market effects such as trade barriers or unfair competition, which can arise from unreliable and deceptive environmental claims.” 

UL takes these definitions into account in UL 2809, the Standard for Environmental Claim Validation Procedure (ECVP) for Recycled Content. The Standard states that pre-consumer recycled content is, “Material that has never reached the end-user, having been diverted from the waste stream during a manufacturing process.” 

Definitions of key recycled content terms 

Understanding what is pre-consumer recycled content or simply repurposed material can be challenging.  In this white paper, readers will learn the most relevant terms associated with pre-consumer recycled content based on publicly available definitions from various sources as well as UL’s experience and insight. The terms defined in this white paper include: 

• closed loop systems
• by-product synergy
• post-consumer recycled content
• pre-consumer (post-industrial) recycled content
• recovered or reclaimed material recycled content and material
• refurbished material
• reused material 

Related Standard

Environmental Claim Validation Procedure (ECVP) for Recycled Content