Recyclable, sustainable, eco: the CAP Code rules for environmental words on cup artwork

A brand that prints cups for an event has to choose the words for the artwork: recyclable, sustainable, eco, plastic-free. The advertising rules treat each of those as a claim that needs a basis. This article sets out section 11 of the CAP Code and two pages of CAP's advice, with a note on where the Code's scope leaves a printed cup. The CAP Code is the UK advertising rulebook that the ASA applies. It is general information, not legal advice. For the competition regulator's view of the same kind of claim, see our guide to compostable and biodegradable cup claims.

Where the Code reaches a printed cup

The Scope of the Code page lists what the Code applies to, including advertisements in printed material (part I a) and promotions in non-broadcast media (part I f). Part II m says it does not apply to packages, wrappers, labels, tickets, timetables and price lists, unless they advertise another product or a promotion or are visible in a marketing communication. None of the pages names a cup. In our reading, the words on a cup are closer to the label exclusion than to an advertisement, but the same words on a poster, a website page or a brochure for the event are within the Code. The Scope page notes that non-broadcast marketing communications are also subject to legislation, and the Code's own background note tells marketers to take account of the CMA's Green Claims Code.

The rules in section 11

Rule 11.1 says the basis of environmental claims must be clear, and that unqualified claims could mislead if they omit material information. Rule 11.2 says the meaning of all terms used in marketing communications must be clear to consumers. Rule 11.3 says absolute claims must be supported by a high level of substantiation, and that comparative claims such as greener or friendlier can be justified, for example, if the product provides a total environmental benefit over the marketer's previous product or competitor products and the basis of the comparison is clear.

Rule 11.4 says marketers must base environmental claims on the full life cycle of the advertised product, unless the communication states otherwise, and must make clear the limits of the life cycle. If a general claim cannot be justified, it adds, a more limited claim about specific aspects of a product might be justifiable, and claims based on only part of the life cycle must not mislead consumers about the product's total environmental impact. Rule 11.7 says communications must not mislead about the environmental benefit a product offers, for example by highlighting the absence of an environmentally damaging ingredient that is not usually found in competing products, or by highlighting a benefit that results from a legal obligation if competing products are subject to the same obligation. Rules 11.8 and 11.9 are shown as deleted on 24 October 2025.

Rule 3.7, in section 3, says marketers must hold documentary evidence to prove claims that consumers are likely to regard as objective and capable of objective substantiation, before distributing or submitting the communication, and that the ASA may regard claims as misleading without adequate substantiation.

What CAP's advice adds

CAP's advice page on green claims, dated 9 June 2026, says it is given by the CAP Executive, is not legal advice and does not bind the ASA. It says a product's full life cycle includes everything from the inputs in production, such as energy and raw materials, to packaging, transport, active use and finally disposal, and that broad claims such as "good for the planet" are usually understood to relate to the full life cycle. It says a claim that relates only to certain aspects, or to one component, should be limited and qualified. It reports that the ASA has treated "eco" as an absolute claim in one 2026 ruling on baby products and ruled against the word "sustainable" in a 2024 car advertisement where the basis had not been made clear, and in each case the ASA had not seen evidence for the absolute meaning.

The recycling page, dated 20 January 2026, says marketers should hold evidence to substantiate claims about the extent to which their products are recycled or can be recycled. It says the ASA has ruled that consumers will understand "100% recyclable" to mean that a product can potentially be recycled, not necessarily that it will be recycled, and it warns marketers not to exaggerate, for example by implying that all of a product can be recycled if only part of it can be. It also says that because components can be recycled, it does not follow that the average consumer would find it easy to do so, and that, particularly for unusual materials such as ice packs, claims like "widely recycled" are likely to be considered misleading without evidence.

What that means for cup artwork

In our reading, four habits follow from those texts. A word such as "eco" or "sustainable" on a cup can be read as an absolute claim under the ASA's approach unless the basis is stated, so the safer artwork names the specific feature, such as the material or the number of times the cup has been tested. A reuse figure printed on a cup is an objective claim, so the test record for it should exist before print. A "recyclable" claim should name what can be recycled and where, since the advice treats the consumer's practical route as part of the picture. And a claim on one component, such as a lid or a sleeve, should say so. Our guide to whether polypropylene cups are recyclable in the UK sets out the material facts.

On the product side

The reusable event cups range is printed to order from 50 cups, and the promotional cups page lists the artwork options. Artwork is checked by the team before a run goes to print, according to the wholesale cups page, and a buyer who wants to print an environmental claim should bring the evidence for it when they request a quote.

Where this stands

This was checked on 28 October 2026. The CAP Code and CAP's advice pages are revised from time to time, and the ASA decides complaints on the facts of each advertisement. A brand with a specific claim should read the current section 11 and take advice before printing.