Recently, the European Commission announced that Coca-Cola has agreed to modify its recycling-related claims on plastic bottles in response to a "greenwashing" complaint filed by the European Consumer Organization (BEUC). The complaint pointed out that Coca-Cola used words such as "100% recyclable" on its packaging, which may mislead consumers into thinking that its products are harmless to the environment.

This incident stems from the accusation made by BEUC and environmental organization ClientEarth in November 2023 against Coca-Cola, Danone, Nestlé and other companies that they made misleading commercial propaganda about the recyclability of their products.

The complaint mainly targets the following three points:

• “100% recyclable”: This ambiguous term depends on many factors such as the available infrastructure to collect material, the effectiveness of the sorting process, or appropriate recycling processes. The recycling rate for PET beverage bottle bodies is estimated to be only 55% in the EU and the chance of it becoming a bottle again around 30%.
• “100% recycled”: This claim wrongly implies the full bottle is made entirely from recycled materials. The fact is that bottle lids cannot be made of recycled materials by EU law and labels are rarely made from recycled material either. In addition, adding virgin plastic (i.e., non-recycled plastic) to the body of the bottle is also a common practice.
• Use of green imagery: Closed loops, green logos or nature images are used for branding many water bottles across Europe. They prompt the false idea of environmental neutrality, endless plastic circularity and may even give the impression that the bottles would have a positive impact on the environment.

Following a dialogue with the CPC Network (Consumer Protection Cooperation Network) 
(led by the Swedish Consumer Agency and the Hungarian Competition Authority), Coca-Cola voluntarily committed to make the following changes to its packaging and marketing materials:

• Change label wording: Change "I am a bottle made of 100% recycled plastic" to "This bottle (excluding label and cap) is made of 100% recycled plastic" to clarify the scope of recycled materials.
• Adjust recycling prompts: Change "Recycle me again" to "Recycle me" to avoid misleading consumers about fully closed-loop recycling.
• Limit the use of green imagery: Avoid using green imagery or symbols on packaging and in digital marketing that could mislead consumers.

The European Commission stressed that the changes are intended to ensure that consumers are not misled about the environmental impact of products due to environmental claims on packaging.

BEUC said Coca-Cola is the first company to voluntarily change its recycling claims and labeling since the initial complaint was made.

Agustín Reyna, Director General of BEUC, commented:

“It is good news that Coca-Cola has heeded consumers’ call and commits to clarify that its ‘100%’ recycling claims only apply to parts of the bottle. However, if it’s written in small print, the ‘100%’ figure will keep giving the impression that it’s harmless to the environment to buy plastic bottles.

“It is crystal clear that a 100% recycling rate will never be reached. Affirming that a bottle is 100% recycled or recyclable is outright misleading and should stop, just as green imagery giving the wrong impression that plastic drink bottles have zero impact on the environment. We expect authorities to monitor if Coca-Cola turns their words into deeds and to take strong measures if this is not the case.”

This incident exposed the gap between corporate environmental protection commitments and actual conditions, and also issued a warning to corporate ESG communication:

• Transparency and accuracy: When companies carry out environmental protection propaganda, they must ensure the accuracy of information and avoid using words and images that may cause misunderstandings.
• Compliance and responsibility: Complying with relevant regulations and taking responsibility for consumers are the basis for corporate sustainable development.
• Continuous improvement and communication: Companies should continuously improve their products and promotional strategies based on regulatory requirements and consumer feedback to establish an authentic and credible brand image.

Author：Qinger