Rules and ethics
Part of Printed claims or proven facts? Packaging marketing rules and ethics
When to update your packaging marketing disclosure policy
How English brands keep a packaging marketing disclosure policy current, from recycled content claims to creator briefs, with a before and after table.
What to take away
- Plastic Packaging Tax applies to plastic packaging with less than 30% recycled content, so recycled claims on packs and in unboxing content need documentary support.
- Consumer law disclosure sits with the DMCC Act 2024 and the CAP Code. A green benefit implied on a pack or in a creator video must be substantiated before it goes live.
- A disclosure policy is not a one-off document. Review it when materials, creator arrangements or data capture routes change.
- Keep one owner and a dated evidence file for each claim. That is the fastest answer to a regulator or a retail buyer.
- This is general guidance for England. Individual cases need a qualified adviser, especially on tax and data protection.
How to spot when your disclosure policy is out of date
Check the pack before the campaign
If a pack says "made with recycled plastic", the Plastic Packaging Tax guidance sets the threshold at 30% recycled content. The wording must match the material you bought. Ask your converter for a dated certificate and file it with the artwork.
Pack claim review checks
- Recycled content meets 30% threshold
- Wording matches material bought
- Dated converter certificate filed
- Material cost shift triggers review
- Creator brief states allowed claim
- QR data has privacy notice
Costs move too. Producer price indices from the Office for National Statistics track material costs, so a shift from virgin to recycled stock mid-year should trigger a fresh claim review.
For the wider rule set, the UK packaging marketing rules and compliance guide maps each rule to the part of a campaign it affects.
Check the channel and the creator brief
A policy that only covers the pack misses the unboxing video. If a creator is paid or gifted, the commercial relationship must be clear in the content itself. The CAP Code and the Competition and Markets Authority both require that clarity.
The simplest control is a one-page brief stating the exact claim allowed, the evidence reference number, and the words the creator must not use. If a creator cannot show the evidence, the claim comes out.
Data belongs in the same review. A QR code asking for an email address pulls the campaign into data protection territory. The packaging marketing data protection in England article covers consent and retention for those touchpoints.
Build the review into your yearly programme
Set a trigger list and a review date
Write a trigger list: new material, new supplier, new creator, new QR journey. Each trigger starts a short review. Add a fixed yearly review in the same month as your budget cycle, so artwork and disclosure updates land together.
Yearly disclosure review steps
- Write trigger list
- Start short review per trigger
- Fix yearly review with budget cycle
- Create folder per claim
- Archive old folder on change
- Review tax position
BSI publishes a standards catalogue covering packaging standards, and buying the relevant standard gives you a documented benchmark for quality and compliance claims. Use the BSI standards catalogue when a buyer asks which standard a pack claim follows.
Keep evidence and sign-off in one place
Create a folder per claim: supplier certificate, artwork version, go-live date, and the name of the person who signed it off. When a claim changes, archive the old folder rather than deleting it.
Review the tax position at the same time, because it affects cost and material choice. The Plastic Packaging Tax guidance is the primary source for the recycled content threshold and who pays. If the tax changes your material, the claim review follows.
A before and after example
Before
- Claim wording
- "Eco-friendly pack"
- Evidence
- Supplier email
- Creator brief
- Verbal
- QR data
- No privacy notice
- Review
- Ad hoc
After
- Claim wording
- "Pack contains 35% recycled plastic, certificate dated March 2026"
- Evidence
- Dated certificate in claim folder
- Creator brief
- One page with allowed claim and evidence number
- QR data
- Consent wording and retention period stated
- Review
- Trigger list plus yearly review date
For example, a team paying £400 a month for creator content can add the brief and evidence check without extra spend.
Common questions
Does this apply across the UK?
Consumer law and advertising rules apply across the UK, and Plastic Packaging Tax is UK-wide. This article covers England practice. Scotland, Wales and Northern Ireland may have separate environmental guidance.
How often should the policy be reviewed?
At least once a year, and every time a trigger occurs. A material change, a new creator, or a new data capture route should prompt a review before publication.
What happens if a claim is wrong?
A misleading claim can lead to action by the Advertising Standards Authority or the Competition and Markets Authority, and to retailer delisting. Correct it, record the correction, and take advice on your case.
Who should own the policy?
One named person, usually in marketing or compliance, with support from packaging, legal and data teams. Shared ownership without a named lead is how reviews get missed.
