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title: If a Package Says "Recyclable," Someone Has to Back It Up: How a New U.S. Bill Could Change the Print-Approval Workflow
lang: en
source: https://mindsprt.dev/en/knowledge/research-brief-truth-in-labeling-act-packaging-compliance/
---

# If a Package Says "Recyclable," Someone Has to Back It Up: How a New U.S. Bill Could Change the Print-Approval Workflow

*Mai Strategy Lab · 10 min read · 2026-08-11*

> The U.S. Congress's Truth in Labeling Act would turn words such as "recyclable," "compostable," and "biodegradable" into claims with legal thresholds, with violations subject to penalties from the FTC and state attorneys general. For Taiwanese brands and printers taking U.S.-bound orders, this means environmental wording is no longer just a matter of design tone. It becomes a compliance field that must be checked before accepting the job. This article breaks down how responsibility is shared, why "recyclable" is hard to prove in technical terms, and which three checkpoints should be built in before sending a job to print

**Quick answer:** The U.S. Congress's Truth in Labeling Act would turn words such as "recyclable," "compostable," and "biodegradable" into claims with legal thresholds, with violations subject to penalties from the FTC and state attorneys general

## Overview

A familiar scene: a client's product is headed for U.S. retail shelves. The artwork comes back, and a new line appears on the back of the package: "100% recyclable, compostable packaging." When you see that sentence, do not start by checking the font size. The printer first needs to ask who can produce the proof.

In the past, that question usually ended with the client taking responsibility. But the Truth in Labeling Act, introduced in the U.S. Congress by Correa and Merkley, is turning it into a supply-chain issue. The bill would require clear federal certification grounds when packaging uses terms such as "recyclable," "compostable," and "biodegradable," and it authorizes the FTC and state attorneys general to penalize violators [1].

In other words, environmental wording is being promoted from marketing language to a regulated claim. Once that line is drawn, printers need to know where they sit in the responsibility chain, and what should be checked before a job goes to print.

## If Printers Only Print the Supplied Artwork, Why Could They Still Get Pulled In?

Responsibility is judged by who turns the claim into a physical product, not only by who gave the instruction. The bill authorizes the FTC and state attorneys general to enforce against false or improper labeling [1]. In practice, the boundary of enforcement often depends on who in the chain took part in creating the misleading statement. That is my reading. The bill text itself focuses on labeling requirements rather than listing every possible defendant.

But the risk does not need to wait for a courtroom. In daily operations, printers are more likely to run into these situations:

・After being penalized, the client turns back to question who was responsible for artwork review. If the contract is vague, the printer absorbs the cost of the dispute.

・One hundred thousand finished cartons get rejected by a retailer because of a single phrase. The reprint cost and delivery gap land on the manufacturing side in real terms.

・Retail channels, especially large U.S. retailers, tighten their listing reviews before the bill is even passed, creating an invisible threshold before delivery.

In these cases, the loss usually appears before anyone goes to court. If you only ask "is there legal liability," the risk will be estimated far too narrowly.

## Why Are "Recyclable" and "Compostable" So Hard to Prove?

Because in materials science, neither term can be settled in one sentence. The answer often depends on the material formula, coating, and whether the right back-end processing facilities actually exist.

Take paper containers as an example. Research has shown a path for paper coated with modified soybean oil to achieve water and oil resistance while also being claimed as compostable and recyclable [2]. There are also technical reports on fully compostable and fully recyclable paper cups [4]. But those results depend on specific coating systems and specific processing conditions. They cannot be stretched into "any coated paper box can be labeled this way."

The harder part is that "compostable" and "recyclable" are often treated as interchangeable environmental plus points. Literature on biodegradable plastics has long pointed out that compostable and recyclable are two different end-of-life routes, and they may even pull against each other. They are not attributes you can simply tick side by side [3]. Polymer compatibilization research also shows that making a material system satisfy both composting and recycling requires deliberate molecular design. It is not a by-product of a small formula adjustment [5].

There is another link that often gets overlooked on the production floor: sorting. Recent research has used hyperspectral imaging with machine learning to identify food-contaminated compostable and recyclable plastics [6]. The fact that this needs research says exactly that back-end sorting is hard to verify. Even if the label sounds confident, whether the material can be correctly separated after entering the recycling stream is a separate matter.

The conclusion is blunt: if the client cannot say which test, which certification, and which processing system supports the claim, that line should not go onto the printing plate.

## What Should Be Checked Before Printing? Use the "Three Print-Approval Gates"

Compliance checks should be fixed inside the workflow. They cannot depend only on someone's instinct while reviewing artwork. This is the method I have narrowed down from practice. I call it the three print-approval gates:

Gate 1 | Wording inventory, at the quotation stage

Pull every environmental claim from the artwork and list it clearly, including Chinese, English, and icons. Recyclable, compostable, biodegradable, eco-friendly, and sustainable all go under control. The output of this gate is not a right-or-wrong judgment. It is a clear answer to "who is responsible for proving these words."

Gate 2 | Evidence request, before proofing

Every controlled term must map to a verifiable document: a certification number, test report, or written client statement. The core of the Truth in Labeling Act is that these terms must have clear certification grounds [1]. This gate is basically doing the bill's homework in advance. If a document cannot be provided, weaken the wording or remove it.

Gate 3 | Market separation, before going on press

For the same product, the U.S., EU, and Taiwan versions should not share the same artwork when environmental wording is involved. This matters more than most people think. Different jurisdictions set different thresholds for the same term. One artwork for multiple markets is the easiest way to get into trouble.

The three gates are not only for blocking problems. More importantly, they preserve the record. If a dispute happens later, being able to show that "we requested the supporting basis before proofing, and the client confirmed it in writing" changes the responsibility picture completely.

## What Is the First Thing to Do Now?

Start by reviewing current U.S.-bound orders and finding every artwork file that contains environmental claims. Do not wait for the bill's final passage.

The reason is timing. The bill is still in Congress [1], but retail review and client self-protection will move ahead of legislation. Your next batch of orders may already face questions. More practically, this inventory can be reused long term. Build an internal "controlled wording list" and matching document requirements, then apply it to each job afterward.

I also suggest adding artwork-review responsibility to quotation forms or contract disclaimers. State clearly that the client is responsible for providing the basis for the accuracy of environmental claims, and that the printer executes based on the documents provided. That sentence cannot remove every risk, but it can make the gray area much clearer.

Scope: the judgments above apply to cases exported to the United States where the packaging contains clear environmental claims. Domestic-only orders, or packaging that does not touch environmental wording at all, do not need extra process cost for this. Also, the bill is still in the legislative process. The final certification thresholds and enforcement scope may differ from the proposal version [1]. Before it formally takes effect, concrete compliance requirements should follow the final enacted text. What should be built now is a workflow and recordkeeping habit, not a rushed revision of every plate.

## Key Takeaways

The U.S. Truth in Labeling Act would require terms such as recyclable, compostable, and biodegradable on packaging to have federal-level certification grounds, and it authorizes the FTC and state attorneys general to issue penalties [1].

For printers, the real risk usually does not come from litigation. It comes from client claims against the printer, retail returns, and reprint costs. Those losses can happen without ever going through court.

In materials science, compostable and recyclable are different end-of-life routes, and they may even work against each other. They cannot be treated as environmental bonus attributes that can simply be ticked side by side [3].

The recommended approach is to fix compliance review at three points: wording inventory at quotation, evidence request before proofing, and market separation before going on press. The point is to leave behind verifiable communication records.

One artwork for multiple markets is the highest-risk approach. Different jurisdictions set different thresholds for the same environmental term, so environmental claims should be versioned by export market.

## Further Thinking

For print manufacturers, the biggest impact of this kind of regulation is not a material changeover. It is that "artwork review" changes from a service gesture into a workflow node with a retention duty. That means prepress systems need to record which supporting document corresponds to each environmental claim, and most current MIS platforms do not have that field. For designers, environmental wording must be downgraded from a visual element into a data field that requires source notation. Artwork delivery should include a claim list. AI has a clear entry point here: detecting environmental claim terms is a highly rule-based text-matching task, well suited for automatic scanning and tagging in prepress checks, leaving human reviewers to judge rather than search. But deciding whether a certification is valid involves jurisdiction and document authenticity, so automated decision-making is not a good short-term fit. For SaaS, a possible product form is a three-way matching service for "controlled term library × market threshold × client document library." The hard part is that national thresholds change often, and no unified data source exists. Two questions remain open. First, whether the final bill will adopt existing third-party certification systems as certification thresholds, which directly affects how hard it is to request documents. Second, the supply chain still lacks an industry-standard contract template for assigning responsibility, so each factory is currently left to draft its own.

## References

[1] [U.S. Truth in Labeling Act Enters Congress: If Packaging Labels Are False, Both Brands and Printers Could Be Sued](https://www.packagingdive.com/news/truth-in-labeling-act-correa-merkley/827421/)

[2] [Design of Compostable and Recyclable Modified Soybean Oil-Coated Paper with Enhanced Water and Oil Resistance](https://doi.org/10.1021/acssusresmgt.4c00356.s001). DOI: 10.1021/acssusresmgt.4c00356.s001

[3] Tábi T. (2022). [Biodegradable bio-based plastics: Compostable or recyclable?](https://doi.org/10.3144/expresspolymlett.2022.9). Express Polymer Letters. DOI: 10.3144/expresspolymlett.2022.9

[4] [First fully compostable and recyclable paper cup](https://doi.org/10.1016/s1364-5439%2814%2970309-0). Focus on Powder Coatings. DOI: 10.1016/s1364-5439(14)70309-0

[5] [Counterintuitive Compatibilization of Poly(-valerolactone) and Poly(llactic acid) by Statistical Copolymers toward Compostable and Recyclable Packaging](https://doi.org/10.1021/acssuschemeng.6c00712.s001). DOI: 10.1021/acssuschemeng.6c00712.s001

[6] Taneepanichskul N., Hailes H., Miodownik M. (2025). [Using hyperspectral imaging and machine learning to identify food contaminated compostable and recyclable plastics](https://doi.org/10.14324/ucloepreprints.282.v2). DOI: 10.14324/ucloepreprints.282.v2

## FAQ

### Which packaging terms would the U.S. Truth in Labeling Act regulate?

The bill would require clear federal certification grounds when packaging uses environmental claim terms such as recyclable, compostable, and biodegradable, and it authorizes the FTC and state attorneys general to penalize violators [1]. This means these terms would move from marketing language to regulated claims.

### If a Taiwanese printer only prints artwork supplied by the client, is it still responsible?

The bill text focuses on labeling requirements and does not list the full scope of defendants. In practice, though, printers more often face client claims over artwork-review responsibility, retail returns, and reprint costs. These losses can happen without litigation, so printers should still build a review and recordkeeping process for environmental wording in artwork.

### Can "compostable" and "recyclable" appear on the same package at the same time?

Not recommended without specific supporting evidence. Research shows that compostable and recyclable are different end-of-life routes, and may even pull against each other, rather than being attributes that can simply be checked side by side [3]. Making a single material system satisfy both requires deliberate molecular design [5].

### If the bill has not passed yet, should the print workflow be adjusted in advance?

Yes, build the workflow early, but there is no need to rush changes to every existing version. The bill is still in Congress [1], but U.S. retailers and brand clients usually tighten self-protection reviews before legislation is finalized. Creating a controlled wording list and evidence-request mechanism now is low-cost and reusable over the long term.

### Can the same product use one packaging artwork file for both the U.S. and Europe?

Not recommended for environmental claims. Different jurisdictions set different certification thresholds for the same environmental term. One artwork for multiple markets is the easiest way to cross a line, so environmental wording should be managed in separate versions by export market.


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