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Refill and zero waste
All Containers›Shop by use case›Refill and zero waste›Claims about the package itselfShop all refill and zero waste →
Getting started

Claims about the package itself

By Dwight Davis, Founder

On this page13
Not what the package must say about the product. What it may say about itself.

Most label rules are about the contents

A net quantity, an ingredient list, a warning, a serving size. The package is the surface and the product is the subject.

These two are about the package

Whether it is refillable, and whether it is recyclable. Both are properties of the container and both are claims made on it.

Which makes them unusual among the spines here

The compounding property is about what a container must not do to a drug. These are about what a container may say about its own future.

And both turn on availability rather than on the object

Refillable turns on whether the means to refill is provided. Recyclable turns on whether programs and collection sites are available to consumers.

So neither can be answered from a specification

A resin code and a capacity do not tell you whether a program exists anywhere, and that is what the claims are about.

Which is why our Recyclable field is a problem

It is a specification field carrying a claim that depends on facts outside the product. 803 rows, all Yes.

The Green Guides are guidance on claims

They set out how the Commission views environmental marketing claims. Nothing on these pages describes the rest of them.

And they reach a marketer, not a container

Which is the division. We supply the container and whoever puts a claim on it is the marketer the guidance addresses.

Except where we make the claim ourselves

Which is exactly what a Recyclable field on a product page is. That part is ours.

So this property has two audiences

A buyer deciding what to print, and us. The second half is the one with the number in it.

The sixty percent figure is the one to remember

The guidance states that substantial majority, as used in that context, means at least 60 percent. A rare hard number in a document about claims.

And nothing in our data speaks to it

We record no program availability, no collection site data and no geography. Only Yes.

References

16 CFR 260.12(a): "It is deceptive to misrepresent, directly or by implication, that a product or package is recyclable." (b): "Marketers should clearly and prominently qualify recyclable claims to the extent necessary to avoid deception about the availability of recycling programs and collection sites to consumers." The section states that "The term 'substantial majority,' as used in this context, means at least 60 percent." law.cornell.edu
The Davis Pack Supply catalog, measured 19 October 2026. A "Recyclable" specification is published on 803 rows catalog-wide and the value is "Yes" on all 803; there is no other value in the field anywhere. On this group's shelf it is present on 39 of the 83 containers, all of them Yes. So a blank cannot be distinguished from a negative, and a bare Yes is an unqualified recyclable claim. Nothing in our data says which programs or collection sites are available to anyone.
16 CFR 260.14, "Refillable claims.": "It is deceptive to misrepresent, directly or by implication, that a package is refillable." The section continues: "A marketer should not make an unqualified refillable claim unless the marketer provides the means for refilling the package." And: "The marketer may either provide a system for the collection and refill of the package, or offer for sale a product that consumers can purchase to refill the original package." The section also gives two examples, which are described rather than quoted here. law.cornell.edu
Written from 16 CFR 260.12 and 260.14 and from the catalog as it stood on 19 October 2026. Our own Recyclable specification has exactly one value, Yes, on all 803 rows that carry it, which means a blank and a negative cannot be told apart and a bare Yes is an unqualified claim. Nothing here states whether any container is recyclable or whether programs are available anywhere. The Green Guides are guidance on claims and nothing on these pages describes the rest of them, nor state recycled-content or labeling statutes.