“Recycled content” on a paper towel package is a claim the Federal Trade Commission defines. Under its Green Guides, the material has to have been recovered from the waste stream, either during manufacturing or after someone used it, and a product can only call itself recycled without a number if the whole thing is made from recycled material. Anything less has to state the amount. The figure that separates the strongest claims is post-consumer fiber, paper that already went through a recycling bin, and of the two manufacturers we read, one puts that number on the page and one doesn’t.

What the FTC says the word has to mean

The rule is section 260.13 of the FTC’s Green Guides, Recycled content claims, and it is short enough to read in full. It is deceptive to claim recycled content “unless it is composed of materials that have been recovered or otherwise diverted from the waste stream, either during the manufacturing process (pre-consumer), or after consumer use (post-consumer).”

Two more lines carry most of the weight. “Marketers can make unqualified claims of recycled content if the entire product or package, excluding minor, incidental components, is made from recycled material.” And for a product that is only partly recycled, “the marketer should clearly and prominently qualify the claim to avoid deception about the amount or percentage, by weight, of recycled content in the finished product or package.”

So a bare “recycled” means all of it. A percentage means some of it, and the percentage is required. The Guides add that a claim may, but need not, split the figure into pre-consumer and post-consumer, and that a marketer who does split it needs substantiation for each share.

What is post-consumer content?

Post-consumer content is material recovered after consumer use, in the Guides’ words. That is the paper that went into a recycling bin. Pre-consumer content was diverted from the waste stream during manufacturing, before it ever reached a consumer. The Guides draw one line inside that second category. A manufacturer’s own spills and scraps, reused within the same process, “would not normally have entered the waste stream,” so a recycled claim built on them is deceptive. Pre-consumer content has to be material that would otherwise have been thrown away.

That distinction is why the post-consumer number is the one to look for. It is the share of the roll that a manufacturer can’t source from its own factory floor.

How two manufacturers state it

Seventh Generation’s page for its 100% Recycled Paper Towels states the towels “are made of 100% recycled fiber, with a minimum of 50% post-consumer recycled fiber.” It adds a caveat in its own words: because the brand prioritizes post-consumer content, “contaminants found in the recycling stream may be found in our paper towels.” The same page states the towels are “whitened without chlorine bleach” and made with no dyes, inks, or fragrances, and the brand sells an unbleached version alongside. It also states the towels are FSC certified, and explains that the certificate is held under the brand’s parent company’s legal name rather than the brand name, which is what a search of the certifier’s database returns.

Who Gives A Crap’s page for its 100% Recycled Paper Towels states the towels are made “from 100% recycled paper, not virgin trees,” and lists the roll as 2-ply with 135 sheets. That page doesn’t state a post-consumer share. Under the Guides, a 100% recycled claim can stand without one. It just answers less than Seventh Generation’s page does.

Both of those are the manufacturers’ own statements, quoted from their own pages, and Runlow has not verified either figure independently.

What to read on the package

Look for three things, in this order. Whether the recycled claim carries a percentage or stands alone, because that tells you whether the roll is entirely recycled or partly. Whether a post-consumer share is stated, because that is the part of the claim the Guides hold to the strictest standard. And whether a separate bleaching or whitening statement appears, because recycled and unbleached are two different claims that happen to sit on the same packages.

If you’re working out how many rolls a year your household actually goes through, our paper goods calculator turns household size and your own habits into a number.

Where this comes from

Every regulatory statement above is quoted from the FTC’s Green Guides at 16 CFR 260.13, linked in the text. The manufacturer statements are quoted from Seventh Generation’s and Who Gives A Crap’s own product pages, also linked. Runlow has not tested any paper towel and makes no claim about any brand beyond what that brand states on its own site.

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Frequently asked questions

What is the difference between pre-consumer and post-consumer recycled content?
Both count as recycled under the FTC's Green Guides. Post-consumer material was recovered after someone used it, like paper from a recycling bin. Pre-consumer material was diverted from the waste stream during manufacturing. The Guides say a marketer that distinguishes the two needs substantiation for the percentage of each, and that scraps normally reused inside a factory don't count as recycled at all.
Can a package say "recycled" without a percentage?
Only when the whole product is made from recycled material, apart from minor incidental parts. The Green Guides say a product that is partly recycled has to qualify the claim clearly and prominently with the amount or percentage by weight. A bare "made with recycled content" on a partly recycled product is the case the rule is written to prevent.
Are recycled paper towels bleached?
It depends on the brand, and the label is where it says. One manufacturer in this post states its recycled towels are whitened without chlorine bleach and sells an unbleached version alongside. That is a separate claim from recycled content, and a roll can carry either one without the other.