Recycling claims on plastic bottles: Danone joins Coca-Cola and Nestlé – what the EU action led by Hungary and Sweden achieved

After three years, the joint European consumer protection action over recycling claims on plastic bottles sold by Europe’s largest bottled water groups has come to a close. On 22 October 2026, both the European Commission and the Hungarian Competition Authority (GVH) announced that Danone, following Coca-Cola and Nestlé Waters, has made comprehensive commitments. All three groups named in the 2023 consumer complaint will now change their labels and marketing.

The case is of particular interest from a Hungarian perspective, because the action was led by the Swedish Consumer Agency together with the Hungarian competition authority. We looked at what exactly the companies agreed to, when the changes will reach store shelves, and what they are worth from a waste management point of view.

In short: Recycling claims on plastic bottles from Coca-Cola, Nestlé Waters and Danone will become more accurate across the entire European Economic Area: a “100% recycled” type statement must state that the cap and label are excluded, and messages such as “Recycle me again” will disappear. The action ended without fines, through commitments whose implementation will be monitored by national authorities, including the GVH.

Where it started: BEUC’s 2023 complaint

The story began on 7 November 2023, when the European Consumer Organisation (BEUC) and member organisations from 13 countries – including the Hungarian association Tudatos Vásárlók Egyesülete – turned to the European Commission and the Consumer Protection Cooperation (CPC) network of national authorities. The complaint was prepared together with the environmental law organisation ClientEarth and ECOS (Environmental Coalition on Standards), and named Coca-Cola, Danone and Nestlé Waters. According to the consumer groups, the companies’ recyclability claims did not comply with EU rules on unfair commercial practices.

The background figures of the complaint are still telling. According to a UN University report cited by BEUC, the average European consumer drinks around 118 litres of bottled water a year, 97% of which is sold in plastic packaging. Data from the European Commission’s Joint Research Centre (JRC) place beverage bottles among the most common litter items found on European beaches.

The consumer groups challenged three types of claims:

• “100% recyclable”: BEUC argued that the term is misleadingly simple, because actual recycling depends on collection infrastructure, sorting efficiency and available technology. Citing a 2022 Eunomia–Zero Waste Europe analysis, the organisation estimated that only around 55% of PET bottle bodies in the EU are recycled, and the chance of a bottle becoming a bottle again is only about 30%.
• “100% recycled”: this label suggests that the whole bottle is made from recycled material. According to BEUC, however, caps cannot be made from recycled material under the EU regulation on recycled plastics in contact with food, labels rarely are, and virgin plastic is often added to the bottle body.
• Green imagery: loops suggesting closed circularity, green logos and nature photos, which according to the consumer groups may create a false impression of environmental neutrality, endless circularity or even a positive environmental impact.

Who investigated, and why were there no fines?

The CPC network brings together the national authorities responsible for enforcing EU consumer protection law and, under the coordination of the European Commission, takes joint action against widespread cross-border infringements. In this case, the joint action was led by the Swedish Consumer Agency (Konsumentverket) and the GVH.

Following BEUC’s alert, Coca-Cola and Nestlé Waters contacted the Commission themselves and voluntarily entered into dialogue with the authorities, while the Commission and the CPC network initiated a dialogue with Danone. The dialogues concluded in June 2025 with Coca-Cola, in February 2026 with Nestlé Waters and in October 2026 with Danone. The Commission and the national authorities assessed the companies’ proposals at EU/EEA level and found the revised claims to be in line with the requirements of EU consumer law.

It is worth clarifying that, although it is often referred to as a “competition authority procedure”, this was not a classic national competition supervision proceeding that can end in a fine. It was a coordinated action of the CPC network, in which authorities work out lawful practices together with the companies instead of declaring an infringement. The commitments do have teeth, though: if a company fails to comply, national authorities may take enforcement measures.

How recycling claims on plastic bottles will change

According to the GVH, Danone’s commitments are essentially the same as those made earlier by Nestlé and Coca-Cola, with differences only in wording and deadlines. Overall, the three groups have committed to the following:

• Exceptions right next to the claim. Where a label refers to the bottle’s recycled content (for example “This bottle is 100% recycled”), it must state directly next to the claim, in the same font size, that it does not apply to the cap and label. In the Commission’s example, a statement such as “I am a bottle made from 100% recycled plastic” will be replaced by “This bottle is 100% recycled. Excluding cap and label”.
• No more misleading “again” messages. The companies will drop calls to action such as “Recycle me again” or “Let’s meet again!”, which can give the false impression that the bottle had already been recycled before purchase and will certainly become a bottle again. A simple “Recycle me” may appear instead.
• The overall impression must not mislead either. The label and marketing as a whole must not exaggerate the environmental benefits of plastic bottles, for example by combining recycling claims with other green claims or symbols.
• Online counts too. Campaigns on the companies’ websites and social media channels must also reflect the commitments.

The GVH stresses that the commitments apply to all relevant products marketed in the European Economic Area, so they will also appear on Hungarian store shelves.

When will this show up in stores?

The change will not happen overnight. The commitments allow up to 18 months from their acceptance to adapt labels, and for Coca-Cola and Danone, existing stock may be sold off within that period. Danone will update its digital marketing and brand websites within three months and its bottle labels within 18 months. In practice, this means that old wording may still be found on some products in early 2028.

According to the Commission, Coca-Cola and Nestlé have already implemented part of their commitments within the set deadlines, particularly regarding recycling claims in digital campaigns.

The next step is monitoring: national authorities, including the Swedish and Hungarian ones, will follow implementation at all three groups. The Commission and the CPC network have also indicated that they may engage with bottling industry associations to ensure a level playing field for all companies in the Single Market.

“Recyclable” or “recycled”? Where the label and reality part ways

From a waste management perspective, the biggest merit of the commitments is that they separate two concepts that are often blurred.

Recyclable describes a possibility: that the packaging material can in principle be processed. Whether this becomes reality depends on the entire chain – collection, sorting, processing capacity and the market for secondary raw materials. Recycled, by contrast, is a past fact: it tells us what share of the product is already made from processed material. In both cases, “100%” easily promises more than the bottle as a whole delivers, since the cap, label and bottle body form different material streams.

The “Recycle me again” type of message was problematic because it implied a closed bottle-to-bottle loop. That loop exists, but it is far from automatic. Germany is the good example: according to GVM’s 2025 figures, 98.1% of PET bottles are recycled there and 58% of the material in new bottles is already rPET – but this took a deposit system that has been running for two decades and a strong processing industry.

The Hungarian picture is mixed by comparison. The mandatory deposit return system has matured quickly: according to MOHU data, 1.5 billion containers were returned to REpont points in the first half of 2026, and the return rate for plastic bottles was 89.8%. Collection, however, is not the same as bottle-to-bottle recycling. For a bottle to truly “meet again” with the consumer, the collected PET has to go into food-grade processing, and bottlers have to actually buy the rPET. This is exactly the gap that the slogans now being phased out concealed.

The Hungarian angle: from the Naturaqua case to the new green rules

This is not the first time the GVH has dealt with green claims on bottles. In summer 2024, the authority launched three national competition supervision proceedings over environmental claims on PET bottles. One of them, against the Coca-Cola group, concerned the “I am a 100% recyclable PET bottle” slogan on Naturaqua mineral water and was closed with commitments in summer 2026 – we covered this in detail in our article on the GVH investigation that led to Coca-Cola’s PET bottle recycling campaign. That national case was a separate procedure, but it points in the same direction as the EU action.

In January 2024, the GVH showed in a market analysis that green advertising messages are often confusing and that a significant share of consumers do not understand what individual claims and labels actually mean. It had earlier summarised its advice for businesses in a green marketing guidance document.

Meanwhile, the regulatory environment has tightened further. Since 27 September 2026, following the transposition of the EmpCo Directive (the EU directive on empowering consumers for the green transition), the Hungarian act on unfair business-to-consumer commercial practices has been extended with 12 new “blacklisted” practices, including several classic greenwashing techniques. Bottled water is also a particularly large market in Hungary: according to a survey covering 81 countries, Hungary is above the global average in per capita bottled water consumption, so accurate labelling affects many shoppers here.

What the action achieved – and what it did not

On the positive side, the three largest groups involved have committed to uniform rules across the entire EEA, including digital communication. Instead of a “small print” solution, the exception must appear next to the claim, in the same font size – a real step forward in making recycling claims on plastic bottles verifiable for shoppers. The case also sets a precedent: other bottlers now have a clear picture of what the authorities consider acceptable.

The limitations are also worth noting:

• No finding of infringement and no fine. The dialogue model is faster, but it has less deterrent effect than a condemning decision.
• It covers three groups. The commitments only bind Coca-Cola, Nestlé Waters and Danone. EU consumer law and the new EmpCo rules, however, apply equally to all other players, so they would be wise to follow suit.
• Slow transition. Because of the 18-month deadline and stock depletion, old labels may remain on the market for a long time.
• Green imagery is not banned. The commitments concern the overall impression, so nature images and green symbols are not prohibited as such, only in misleading combinations.

BEUC welcomed Danone’s move but urged authorities to remain vigilant, arguing that presenting bottles as entirely recycled or recyclable, as well as green imagery suggesting that plastic bottles have no environmental impact, must come to an end.

And there is one question no label can answer: volume. At the time of the 2023 complaint, ClientEarth already warned that recycling cannot keep pace with the amount of plastic being produced. A more accurate label improves consumer information, not the number of bottles.

What to look out for as a shopper

• Read the qualifier next to “100%”: if a bottle is “100% recycled”, this refers to the bottle body, not the cap and label.
• A “recyclable” label is no guarantee that the bottle will actually be recycled – that also depends on whether we return it.
• Green colours, leaves and circular arrows are not evidence.
• Return deposit bottles intact and uncrushed to a REpont point, as this is the only way they can enter a clean material stream.
• Where tap water is drinkable, the bottle with the lowest environmental impact is the one we never buy.

FAQ: recycling claims on plastic bottles

What did the bottling companies commit to regarding recycling claims on plastic bottles?

Coca-Cola, Nestlé Waters and Danone made four main commitments. Next to “100% recycled” type claims, they will state in the same font size that the cap and label are excluded, drop messages such as “Recycle me again”, avoid green symbols that create a misleading overall impression, and align their digital campaigns with these rules.

Why were the bottling companies not fined?

Because the action ended with dialogue and commitments rather than a decision establishing an infringement. In such cases, the CPC network works out lawful practices together with the companies, and the Commission and national authorities found the revised claims compliant. If a company fails to honour its commitments, however, the authorities may take enforcement measures.

When will the new labels appear in stores?

Gradually, within a maximum of 18 months. The commitments allow up to eighteen months from their acceptance to adapt labels, and Coca-Cola and Danone may also sell off existing stock. Danone will update its digital channels within three months, while Coca-Cola’s and Nestlé’s online campaigns have already partly changed.

What is the difference between a recyclable and a recycled bottle?

Recyclable means the bottle’s material can in principle be processed, while recycled means it is already made from processed material. The former depends on collection, sorting and technology: BEUC estimates that only around 55% of PET bottle bodies in the EU are recycled, and only about 30% become bottles again.

What role did the Hungarian Competition Authority play in the EU action?

The GVH led the joint action of the CPC network together with the Swedish Consumer Agency, meaning that, alongside the European Commission, the two authorities coordinated the dialogue with the companies. Going forward, the GVH and its Swedish counterpart will also monitor whether all three groups implement their commitments, including on the Hungarian market.

🔗 Official sources and references: 👉

• European Commission: Commission welcomes commitments of Coca-Cola, Nestlé, and Danone to modify recycling claims on plastic bottles (IP/26/2238), 22 October 2026
• Hungarian Competition Authority (GVH): Danone will also communicate more transparently about the recyclability of its PET bottles (in Hungarian), 22 October 2026
• European Commission: Sustainable consumption actions – Recycling claims on plastic bottles
• Full text of the commitments: Coca-Cola, Nestlé Waters, Danone
• BEUC: Consumer groups launch EU-wide complaint against major water bottle producers for greenwashing (BEUC-PR-2023-044), 7 November 2023

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