Tackling greenwashing through the Green Claims Directive – the importance of reporting real recycling
By Steve Claus, Secretary General, Steel for Packaging Europe 
In my two previous articles, I highlighted the damaging effect of misleading environmental claims on consumer trust, and the negative impact such claims have upon credible efforts to drive real improvements in sustainability, complicating the journey towards a more circular economy.
For many consumers, whether packaging can be recycled or not, is a fundamental consideration in their purchasing behaviour. The significance of recyclability claims, and whether such claims are transparent, substantiated and based on reliable, up-to-date data is therefore critical and must be a key focus for the Green Claims Directive (GCD).
It is significant that the independent third party[1] review, commissioned by Steel for Packaging Europe and Metal Packaging Europe, of the two IFEU studies[2] which compared multi-layer laminated cartons and steel cans, revealed critical limitations in data quality. These included an outdated proxy for steel cans and an exaggeration of carton recycling credits.
The review noted specifically that the collection and recovery rates used to model the End-of-Life recycling credits of multi-layer laminated cartons were overestimated, as they do not use the most recent data and do not follow the latest EU methodology.
Previously EU member states used varying methods to determine recycling rates for different materials, leading to inflated rates and obscuring the recycling challenges associated with some packaging formats. According to the harmonised method for calculating packaging recycling rates, member states should report only what is “really recycled” at the entrance of recycling operations, not what is “collected for recycling.”
Indeed, the most recent data and independently verified figures for steel packaging recycling, released in 2024, confirm that 80.5% of steel packaging placed on the market was ‘really recycled’ in 2022.
Significantly, the Packaging & Packaging Waste Regulation (PPWR) includes a range of stricter recyclability measures, including the introduction of a performance grading system with clear criteria that will ultimately drive any material that is less than 80% recyclable from the market. 
Steel packaging, with all formats graded A or B, demonstrates a superior performance compared to other materials such as plastics and multi-layer laminated cartons. For while such cartons are in theory recyclable, only a small percentage on the market are really recycled, due to the complexity, cost, and availability of the specialised recycling infrastructure multi-layer formats like cartons require. Claims to the contrary are not transparent and are potentially misleading for consumers.
The importance of using transparent, evidence-based environmental claims to foster informed consumer decisions and support ongoing efforts to improve environmental sustainability in packaging, such as recycling rates that reflect what is really recycled rather than merely collected, cannot be overstated. We urge all EU institutions, brands, retailers and packaging manufacturers, to maintain high levels of ambition to collectively build a greener, more circular future in Europe.
Read more about the full third-party review of the IFEU studies here.
[2] IFEU, 2017. Comparative Life Cycle Assessment of shelf stable canned food packaging, Final Report. Heidelberg, December 2017. IFEU, 2020. Comparative Life Cycle Assessment of Tetra Pak® carton packages and alternative packaging systems for beverages and liquid food on the European market. Final report. Heidelberg, March 9, 2020 (extended version with further specific supplements for selected EU countries).