Key takeaway
What This Development Means
Proposed US legislation could create more consistent rules for recycled content and packaging claims, including certified mass-balance accounting and FTC oversight. The bills remain at an early stage, but manufacturers and brands can prepare promptly by reviewing substantiation, certification, terminology and approval processes for environmental marketing across products and packaging.
Is mass-balance accounting already approved for US recycled content claims?
H.R. 7502 proposes federal recognition for certified mass-balance accounting, but the bill has not been enacted. Companies must continue applying existing federal and state advertising rules. Claims should be truthful, specific and supported by reliable records, with clear explanations where attributed content differs from physical content in individual products.
When could the recycled content claims rules take effect?
Neither proposal has a fixed commencement date because both remain before Congress. H.R. 7502 would give the FTC one year after enactment to revise its Green Guides. Businesses should monitor committee action and amendments rather than assume the introduced text will become law in its current form without delay.
Source basis: US Congress, House Energy and Commerce Subcommittee Hearing, 22 July 2026
US lawmakers examined proposals affecting recycled content claims and packaging labels at a House Energy and Commerce subcommittee hearing on 22 July 2026. The measures could influence manufacturers, packaging producers, recyclers, brands and retailers making environmental claims in the United States, although neither bill is yet law.
Recycled Materials Attribution Act Addresses Mass Balance
H.R. 7502 would establish federal rules for recycled content claims and recognise certified mass-balance accounting. Mass balance allows recycled feedstock entering a shared production system to be attributed to selected outputs through controlled records, even when recycled and virgin materials cannot be physically separated in every finished item.
The proposal would prohibit misleading recycled content claims, enable Federal Trade Commission enforcement and pre-empt related state requirements. If enacted, it would direct the FTC to update its Green Guides within one year, giving businesses a more uniform framework for substantiation and disclosure.
PACK Act Focuses On Packaging Terminology
The PACK Act would prohibit deceptive recyclable, compostable or reusable claims for consumer product packaging. It would require accredited third-party certification, direct the FTC to issue non-binding guidance within two years and pre-empt state requirements that are not identical to the proposed federal rules.
Companies should not treat the hearing as a compliance deadline. Instead, sustainability, legal and marketing teams should inventory current claims, understand the evidence behind recycled content figures and review chain-of-custody systems. Businesses using mass balance should also examine certification controls and customer-facing explanations.
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