How to spec recycled merch — rPET, recycled cotton and claims without greenwashing

Why recycled merch needs a different brief (it is not just "use less plastic")

Recycled merch — PET bottles turned into tees, totes or bottles; recycled cotton in tees and hoodies; recycled glass in cups and bottles — sits under a regulatory magnifying glass in Mexico and abroad. A tee that says "100% recycled cotton" when it is really 30% recycled and 70% virgin is greenwashing and violates LFPDPPP. A bottle that says "rPET" without traceability can be challenged by customers in Europe under Directive (EU) 2019/904 on single-use plastics.

That is why the recycled merch technical brief is not the same as the conventional one. It needs to define, with numbers: minimum recycled content (not "uses recycled", for example), chain-of-custody traceability, applicable certifications (GRS, RCS, GOTS when it applies to organic recycled), claims allowed on label and advertising, and measurement tolerances (% recycled is measured by weight and varies naturally).

The brief also has to distinguish two things the market confuses: "made from recycled input" and "recyclable at end of life". An rPET tee is made from recycled input; a GOTS-organic cotton tee may or may not be recyclable at end of life. These two claims are regulated differently under LFPDPPP and NOM-141 in Mexico.

For programs that cross a border, two more rules: under USMCA/T-MEC, rules of origin change when there is an origin claim (for example "made in Mexico with recycled cotton"). And NOM-141 on waste separation and recycling applies to packaging and to end-consumer information. The brief must anticipate all of that, not on event day.

Common mistakes that turn a good recycled claim into greenwashing

The first mistake is putting "eco", "green" or "sustainable" on the label without a certification that backs it. LFPDPPP and NOM-028 on commercial practices treat such claims as misleading to the consumer when there is no metric. Better to make a concrete claim: "50% GRS-certified rPET" or "100% RCS-certified recycled cotton".

The second mistake is not requiring the Transaction Certificate. The supplier says the material is recycled, shows a letter, shows a logo. Without a TC issued by the certifier (Textile Exchange, Control Union, ICEA), the recycled claim is not auditable. Ask for TC per batch, not per year.

The third mistake is confusing recycled with post-consumer recycled. There is pre-consumer recycled (factory scraps, cuttings) and post-consumer recycled (used bottles, post-consumer apparel). The "recycled" claim, by international convention, refers to post-consumer recycled. If your product uses pre-consumer recycled, say so. Mixing the two without clarification is greenwashing.

The fourth mistake is forgetting that recycled cotton shrinks more than virgin. Recycled cotton has shorter fibers, shrinks 5-8% in the first washes without additional pre-shrink. Ask for pre-shrink by sanforizing and a shrinkage tolerance per ISO 6330.

The fifth mistake is not verifying the recycled source. A supplier that buys recycled material without traceability may be reselling pre-consumer recycled as post-consumer, or blending recycled with virgin. The certifier's TC protects the entire program.

The sixth mistake is not updating the claim when the supplier or batch changes. If the fabric supplier changes and recycled content drops from 50% to 30%, the label, claims and advertising must update. What was printed on the prior run does not work for the new one.

The seventh mistake is not considering the foreign-trade regime when recycled merch crosses a border. Under T-MEC, origin claims may require a specific certificate of origin if the claim says "made in Mexico" with imported recycled material.