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TerraCycle: sustainable or greenwashing?

Recycling company TerraCycle says that it is “Eliminating the Idea of Waste”. However, journalists, campaigners and Ethical Consumer have previously criticised the company for its work with some of the world’s biggest polluters, as well as for a lack of public transparency. 

In this article, we ask how far TerraCycle is going to combat packaging pollution and whether it has taken meaningful steps to address concerns.

(A version of this article was originally published in 2022, and has been updated in February 2026.) 

What is TerraCycle?

TerraCycle is a company that collects hard-to-recycle waste from toothbrushes to pet food packaging, and claims to have developed “hundreds of never-before-seen recycling solutions”. It also manufactures recycled products using waste collected through its programmes, and has a division focused on selling recycled raw materials back to manufacturers.

The corporation describes itself as a “mission-driven company”. It made over $43 million in sales in 2024, and over $25 million in gross profit. It has received venture capital and private equity investment in recent years.

Major corporations have paid TerraCycle to set up free recycling programmes for everything from Pringles tubes to old Marigold gloves. But the company also makes money from consumers themselves, who can pay hundreds of pounds to recycle items that fall outside of its corporate schemes, such as contact lens cases, coffee pods and medicine blister packs. 

TerraCycle has been celebrated by organisations from the UN to the World Economic Forum. However, the firm has also previously faced major criticisms, including from NGOs and the BBC. A spokesperson for TerraCycle told Ethical Consumer that the allegations were “misleading”.   

Below, we explore some of these criticisms, examine whether they stand up to scrutiny, and outline the company’s response to them.  

Should consumers avoid TerraCycle?

Recycling almost always benefits the climate and environment compared to sending waste to landfill. Although there is little data to show the impact TerraCycle could be having, its programmes are likely to be a positive alternative to landfill overall. We therefore don’t think that consumers should avoid TerraCycle. 

TerraCycle is, however, no magic bullet, and we do think it’s important to highlight the criticisms and limitations the company has faced. In particular, major polluting brands have been accused of using TerraCycle to suggest they’re helping solve plastic pollution, and we think the company could do much much more in terms of transparency to address this concern. 

In our view, issues with TerraCycle highlight the need for regulatory change to reduce and reuse waste rather than leaving it to the market. Pushing for this kind of change, while using programmes like TerraCycle, is probably the most effective step that consumers can take. 

Collaborating with the world’s worst plastic polluters

In 2024, academics from the U.S., Australia and elsewhere analysed the world’s worst plastic polluters, based on more than 1,500 audits of branded plastic pollution worldwide since 2018. The top most polluting companies were:

  • Coca-Cola
  • PepsiCo
  • Nestlé
  • Danone
  • Altria (previously Philip Morris)

All five companies currently or have previously partnered with Terracycle.

A spokesperson for TerraCycle told Ethical Consumer that partnering with the biggest plastic polluters was important for ensuring impact. “We work to make the biggest impact possible which means partnering with all companies, including the companies that produce the products the public consumes en masse,” they said. 

Little impact on pollution caused by big brands

The recycling TerraCycle does for big brands appears to be just a drop in the ocean compared to the amount of waste they produce.

We made a rough calculation in 2022 to work out how much packaging had been recycled through the Nestlé-funded TerraCycling programme, and found that it equated to recycling less than one in 25,000 Nestlé wrappers. To give a sense of scale, in 2024, Nestlé produced over 870,000 metric tonnes of packaging. That’s equivalent to the weight of almost 175,000 Asian elephants. 

In response to questions from Ethical Consumer, TerraCycle provided some examples of programmes in which they said they had been able to collect a “significant” percentage of a brand’s waste. This included collecting and recycling over 30% of all Nespresso cups in Canada each year; and collecting and recycling 20% of packaging for cosmetics company Lancome sold through participating retailers in China.  

It added: “Voluntary sustainability programmes typically start from zero and take time to grow and scale”, stating that programmes “can scale if brands are willing to invest”. 

Green promo

Campaign groups say that many of these companies are using the partnership to promote their green credentials despite being major polluters. Environmental NGO Changing Markets Foundation published a report in 2020, which found that brands were promoting partnerships with TerraCycle in sustainability reporting, despite the fact that programmes were regularly small-scale, or only available in a limited number of cities or countries.

TerraCycle itself provides brands with marketing services to promote the fact they are involved in a TerraCycle recycling programme, and has featured extensively in adverts for some brands. 

Asked about its marketing services, the company said, “TerraCycle does indeed work with the partnering brands to help raise awareness to the public so they know there is a way for the product and/or packaging of the specific free program to be recycled where previously this wasn’t possible.”

Limits on recycling programmes

Corporations can pay TerraCycle to set up a recycling programme for specific packaging - a major step towards the ‘polluter pays’ principle. 

In practice, however, this approach also means that the companies can set a budget cap. Once recycling costs hit that budget limit, TerraCycle will no longer recycle the brand’s packaging

Of the 120 free recycling programmes listed on the U.S. site as of April 2025, well over half had budget limits, including for well-known brands such as Babybel and Colgate.

In the past, TerraCycle faced major criticism, including a lawsuit in California (see below), because companies were marketing their packaging as “recyclable” even when budget limits meant that only a portion of it could ever be accepted into the programme. 

TerraCycle appears to have taken some steps to address the issue. It told Ethical Consumer via email, “When our partners use our trademarks such as our logo or our company name, their contracts include language that we need to review and approve the work. We edit out terms like “100% recyclable” or “recyclable” (which is reserved for kerbside/municipal recycling) and change the copy to “Recycle with TerraCycle”. This is a global directive.”

We still think that the company could do more, however, to make the limits transparent. In the US, TerraCycle now includes declarations on its own website when “enrollment limits apply”. No such notices, however, were found on the UK website, despite the fact that some pages do say “there are currently no more spaces available”. 

The company said that it had not made the change in the UK because many consumers dropped off their packaging at in-person sites rather than sending it from home through the website.

Lack of transparency on impact

TerraCycle itself appears to have a shocking lack of transparency for a company claiming to be tackling environmental harms. 

It claims to have “developed the world’s first solutions in everything from recycling to reuse”, and states that it recycles “98.3% of the waste we receive, which account[s] for all compliant waste.” However, the company does not appear to publish any kind of sustainability or impact reporting on its website. We could not find any figures about how much material it has recycled in total, or the weight or percentage of recycled packaging from any one of its partnerships. 

The website does state: “a recent, third-party-verified, Life Cycle Assessment (LCA) showed that all TerraCycle recycling models have lower environmental impacts when compared to traditional solutions (like landfilling and incineration) across eight major impact categories, including global warming.” 

However, when we looked at the Life Cycle Assessment, it only considered recycling of flexible film in the United States and there were no details publicly available on what data TerraCycle had used to calculate its savings. Terracycle talk about this issue in their response below.

Incorporated in Delaware

TerraCycle’s parent company is registered in Delaware in the U.S., even though its headquarters are in Trenton, New Jersey. Delaware is notorious for its lack of corporate transparency rules, and has been called “the US corporate secrecy haven” by advocacy group Transparency International, as well as being a tax haven. 

When asked about the location, TerraCycle told Ethical Consumer, “Delaware being our place of incorporation has no effect on any taxes we owe and where we owe them, and it [the company] doesn’t shift income from one tax jurisdiction to another.”

It added: “Ensuring that you pay what’s due, and no more, is a good tax strategy, not tax avoidance. Specifically, at TerraCycle, we don’t use tax shelters, offshore schemes, or anything that hides income to ‘avoid’ tax. Our approach is straightforward: we pay tax where we actually do business, exactly as the law requires.”

The company did not publish or provide any public country-by-country reporting, a breakdown of finances by region, which is considered the gold standard for transparency and demonstrating that companies are paying their fair share. It stated that the scale of its operations were below the threshold where such reporting was expected. 

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Consumers face difficulties recycling products

TerraCycle has repeatedly been criticised for difficulties faced by consumers in trying to recycle products that are part of its free corporate programmes. Items cannot be put out with normal recycling, but have to be sent to the company. 

In the past, all products included in the schemes had to be dropped off at special collection points, and this is still the case for certain brands. These collection points can be miles from a person’s house and in certain areas (Scotland in particular) there may not be any available. 

In recent years, the company seems to have made some positive steps to address this issue following criticism, and in the UK most products can now also be posted. 

Where drop off points are used, unpaid volunteers run them, although the company does donate $0.02 to charity for every item collected. TerraCycle told us in 2022 that the volunteers had “raised over $44 million globally for the school or charity of their choice in return for collecting for our recycling programs.” Nonetheless, we think it’s unclear why a company making millions in profit should be relying on volunteer-led schemes. 

TerraCycle doesn’t publish any statistics showing how much recycling takes place in each location, due to “privacy agreements”. Sadly we can't therefore compare its effectiveness to other environmental volunteering schemes due to the lack of available data.

Waste shipped to Bulgaria

In 2021, a documentary called ‘The Recycling Myth’ accused TerraCycle of exporting and incinerating plastic waste it had pledged to recycle in the UK – allegations that the company vehemently denies. 

Investigative journalists stated that a batch of recycling collected in the UK has been shipped to an incineration plant in Bulgaria. The journalists also claimed that TerraCycle had applied legal pressure to try and prevent the documentary from being aired – a claim that TerraCycle denies.

TerraCycle told Ethical Consumer that the documentary was inaccurate, that the findings only concerned a single small batch of plastic packaging which had been shipped to Bulgaria as a result of one-off human error. It also stated that the waste was found at a recycling rather than an incineration plant.

“Though this was a one-time incident, out of an abundance of caution, we also ceased work with that specific subcontractor as soon as we became aware of the error,” a spokesperson for the company said, adding that the issue was resolved as soon as TerraCycle was made aware.

Zero waste boxes cost up to £400

Where corporations haven’t sponsored a particular recycling programme, consumers can buy their own ‘zero waste’ boxes for everything from plant pots to paint tins. However, each zero waste box costs between £100-£395, depending on the size and the complexity of sorting the items included, making them unaffordable to many individuals or households. 

The company told Ethical Consumer, “The cost of a zero waste box reflects the cost of the box, shipping (in and out), sorting, and recycling its contents, minus the value of the recycled material. This is why we offer multiple size options, so that there are multiple cost options.”

The boxes do hold a huge amount of packaging. For example, its large box for crisp and snack packaging can hold approximately 3,500 wrappers – which could take years to fill!

TerraCycle’s Loop scheme could have a positive impact

TerraCycle’s Loop Scheme involves creating reusable packaging for brands, so consumers can return it when finished and the packaging will be used again. It has partnered with brands from Nutella to Orangina. 

The Loop scheme eliminates waste, as opposed to just recycling it. This is significant because, while brands that fund a recycling programme are permitted to keep using vast quantities of first-use plastic, the Loop scheme instead cuts single-use plastic packaging out of the equation altogether. If widely adopted this could end up changing the whole culture around packaging.

Over 400 organisations, from Greenpeace, to the Muslim Council of Britain, and the Women's Institute, have called on polluting brands to commit to "transparent, ambitious and accountable reuse and refill systems".

Unfortunately, roll out of Loop in the UK has been very limited. 

In 2021, Tesco partnered with Loop to launch a trial enabling customers to buy products from participating brands, and return the packaging to the store to be recycled. The project was piloted in 10 Tesco stores, but was cancelled 12 months later, with Tesco’s responsible sourcing director Giles Bolton writing, “while the potential [for reusable packaging] is huge – and we should all be excited about a solution where packaging can be used and reused in a circular system – the implementation challenge is equally significant.” 

A spokesperson for TerraCycle told Ethical Consumer that the programme had “failed to scale at the time, due to tough UK market conditions and challenges such as the cost of living crisis.” 

However, it has seen significant success in France, where regulations have set reuse targets for retailers. The programme is “available today in more than 450 stores (across multiple retailers) across more than 400 products”, TerraCycle said, and “shows that mandatory government regulation is highly important”. 

We agree that this case again shows the vital need for regulatory change. 

Is TerraCycle greenwashing?

Recycling and replacing hard-to-recycle plastics is without doubt a positive step when it comes to the environment and climate change, and at Ethical Consumer we would support consumers accessing any recycling programmes.

However, we do think that many polluting brands may be using their partnerships with TerraCycle to help suggest that they are solving the plastic pollution problem, without making truly meaningful change.

TerraCycle could do much much more to address this issue. The company is woefully untransparent about its impact, failing to publish any detailed data on its recycling programmes. 

Without transparent information about brands’ overall waste and recycling, we believe there is a risk that TerraCycle programmes could result in consumers believing that brands’ recycling programmes are having more of an impact than they actually are – the definition of greenwashing.

If TerraCycle isn’t the solution to plastic pollution, what is?

Polluter Pays

We believe that issues with TerraCycle show the vital need for regulatory change.

Since 2025, some companies have had to pay a fee for the packaging they supply to or import into the UK. Known as extended producer responsibility, the money will support local authorities in collecting, managing, recycling and disposing of household packaging waste.

The new law is part of global efforts towards a ‘polluter pays’ principle, which says that the companies behind packaging pollution should fund efforts to manage and tackle it. 

Reuse systems

Lots of organisations are also campaigning for a switch to reuse systems – where packaging is returned, washed, and used again – a change that could be revolutionary for tackling the waste crisis. 

Academics and campaigners envisage a future where councils undertake curb-side collections of reusable boxes, bottles and tubs. However, much work still needs to be done to persuade policymakers and companies to commit to this vital change. 

#BreakFreeFromPlastic provides resources for individuals and organisations that want to help end plastic pollution. These range from corporate campaigning, to becoming zero waste in your own life, and pushing for policy changes.

In 2022 we published an earlier version of this article on our website, following dialogue with TerraCycle. In December 2025, when updating it to reflect recent developments, we received very detailed responses from Terracycle to some of the criticisms discussed in it.  

We have incorporated some elements of this response in the article above. For reasons of transparency, full details of their responses also appear in the section below. The questions we put to TerraCycle are in italics at the beginning of each section.

Responses from TerraCycle

TerraCycle has been celebrated by organisations from the UN to the World Economic Forum. However, the firm has also faced major criticisms, including from NGOs. In 2022, it was the focus of a BBC Panorama investigation, which alleged that the company had extremely low recycling rates, was working with a waste handler in the UK who had a criminal conviction, and was likely misleading the public. 

TerraCycle has been working as a mission-driven company for 25 years to address the global waste crisis. We’re proud of the work we do, including our first-of-their-kind solutions to recycle traditionally hard to recycle waste, meaning products and packages that aren’t typically accepted via kerbside recycling services and would otherwise end up in landfills and incinerators, polluting the environment.

The theory of waste sits at the core of our business. Recycling is entirely an issue of economics, with the following economic equation that drives practical recyclability:  Costs of Collection + Costs of Processing < Resulting Recycled Material Value = Recyclable. Nearly everything can be technically recycled, but 95% of all waste is not locally recycled today. This is because it costs more to collect and process the waste versus what the resulting recycled material can be sold for.  

TerraCycle is constantly in the media, featuring in over 150,000 articles to date, and in 2025, we were featured in over 15,000 articles. Negative pieces, like the BBC Panorama piece in 2022, you referenced, are extremely rare (less than 0.01% of all media) and disappointing exceptions.

We guarantee to recycle the accepted waste sent to us through all of TerraCycle’s recycling solutions. Third party independent external and internal audits are performed on an ongoing basis, and over 98% of the waste received is recycled, which accounts for all compliant waste we receive. Please see our website to view this information and more. 

In response to the BBC Panorama investigation, we sent detailed responses to many questions from Ethical Consumer in 2022 regarding the programme, although most of the information sent was not included in the subsequent article. Below is a quick recap of the scenario and our response to the Panorama programme:

TerraCycle featured in a BBC Panorama programme that aired on Monday 30th May 2022. We were informed a few weeks prior to this date that BBC Panorama would be running an episode on TerraCycle, and it was clear they were going to depict TerraCycle in a negative light.  However, the programme that aired was more measured in its depiction of TerraCycle, which we believe is a result of our having worked openly and transparently with the BBC to respond to every question they posed. This also included a two-hour recorded interview with TerraCycle CEO Tom Szaky, and a visit to film at a TerraCycle recycling facility in the UK. But we still believe the BBC Panorama episode misrepresented the work we do. 

The programme asserted four main criticisms of TerraCycle / our system which we have addressed below. 

1. Access to TerraCycle drop off location points: TerraCycle drop-off points operate differently to the model suggested by Panorama. Rather than driving long distances with minimal waste, participants typically use these drop-off points like community Bring Banks. Individuals generally collect larger volumes of empty packaging at home, dropping them off during existing journeys to school, work, or other errands to be recycled. Also, some choose to support their local community by establishing themselves as a dedicated TerraCycle public drop-off point.

2. Programme impact: The Panorama programme asserted that the impact of TerraCycle recycling programmes to be small (<1%) of the waste being created by CPG companies, even though we had provided multiple examples of programs collecting 20-30% of the products being sold.

3. TerraCycle’s supply chain: The Panorama programme alluded to a single error on the part of a subcontractor for flexible film recycling, which was rectified as soon as it was brought to our attention. The waste in question was located at a Bulgarian recycler, and was recycled in the UK as originally intended. Though this was a one-time incident, out of an abundance of caution, we also ceased work with that specific subcontractor as soon as we became aware of the error. 

We were disappointed with this misleading portrayal as we provided the producers with significant and compelling evidence to support the above.

In 2024, academics from the U.S., Australia and elsewhere analysed the world’s worst plastic polluters, based on more than 1,500 audits of branded plastic pollution worldwide since 2018. The top most polluting companies were: Coca-Cola, PepsiCo, Nestlé, Danone, Altria (previously Philip Morris). All five companies currently or have previously partnered with Terracycle. 

Yes this is perfectly logical and exactly what we would expect to see. 

Typically, the more a company sells into the market the more waste it will generate in the process. This is exactly why TerraCycle is working with such companies, along with over 40,000 small companies, to help address the problem as this can bring the greatest scale in terms of solution. We work to make the biggest impact possible which means partnering with all companies, including the companies that produce the products the public consumes en masse.

3. TerraCycle’s programmes with major companies appear to address only a very small proportion of the waste they produce.

TerraCycle exists to help solve a challenge. In our case the challenge is products and packages that don't have an end-of-life option beyond landfill and incineration. We always advocate that the right solution is to first reduce (buy less), and then to design products and packages that can be locally recycled when possible (and provide consulting services to help companies achieve this).

It’s important to note that manufacturers are not required to provide end-of-life solutions for their products and packages. Even with EPR (Extended Product Responsibility) or DRS (Deposit Return Scheme) legislation, hard-to-recycle materials are not legally required to be recycled, and as a result, are typically not.  
In most cases, there are no commercially viable design options that would render such products/packages locally recyclable. 

A few examples:

Crisp Packets:  If a crisps brand would want a locally recyclable package, they would have to move from a flexible film to a rigid plastic (PET) container, aluminium tub, or glass jar, all options that would not be commercially viable.

Pill Packaging:  Due to the need of child-resistant packaging, there is no design solution today that would allow such an item to be locally recyclable.

Dirty Diapers:  due to their complex composition and contamination there is no way to design them to be locally recyclable. 

We are happy to provide many other examples, noting that typically only uncoated paper, aluminium, #1 rigid plastic (PET), or #2 rigid plastic (HDPE)--and only when the object is greater than 5cm cubed–has broad local recycling solutions available across multiple countries.

Beyond recommending this path, TerraCycle has invested the majority of our profit to date into building Loop (see www.exploreloop.com), a reuse platform currently live in France with multiple major grocery retailers in over 400 stores. This platform helps brands shift from disposable products to reusable options, where packages are cleaned and refilled. This avoids the need for recycling. 

4. In 2022, Ethical Consumer calculated the amount of packaging that had been recycled through the Nestlé-funded TerraCycle programme, and found that it equated to less than one in 25,000 Nestlé wrappers. During an interview with sustainability Youtuber Shelbizleee in 2022, Terracycle founder and CEO Tom Szaky gave examples of some “very big” projects it had run with partners. He stated, “we collect 30% of all the Nespresso capsules produced in Canada. We collect 20% of all the Lancome packaging produced in China”.  

Voluntary sustainability programmes typically start from zero and take time to grow and scale.  

Moving to locally recyclable or reusable packaging is a significantly more important step in the right direction and TerraCycle actively supports brands in doing both. 

TerraCycle’s aim, with the support of the brand partners that fund free recycling programmes, is to grow the recycling programmes and make them as big and meaningful as possible. This takes time, collaboration and investment.

TerraCycle’s free programmes can scale if brands are willing to invest: There are many examples where brands have invested meaningfully in their TerraCycle programmes and have been able to collect a significant % (comparable to municipal recycling) of their product or package to be recycled. Our brands do not always provide their proprietary data to us, but have shared estimates that:

  • Lancôme China: we collect and recycle 20% of all products (by this we mean the recycling of the packaging, not the contents) they sold in the retailers where we launched programmes (achieved in 2 years).
  • Nespresso Canada: we collect and recycle over 30% of all capsules produced in Canada per year (took 10 years to achieve).
  • Nestlé Dolce Gusto Coffee Capsules in Nordics: we collect and recycle 7% to 10% of all capsules sold online via KaffeKapslen.
  • WalMart US for Car Seats: In less than one week, we collected and recycled more than one million car seats. Based on our understanding of Walmart’s market share, we estimate that this represents 10-20% of their total car seats sold.
  • SuperDrug stores in the UK:  Our Medicine Packet Recycling Programme collected and recycled more than 30% of Superdrug Healthcare units sold across all stores assuming 2 blister packs per package.
     

5. Major polluting brands appear to have used TerraCycle to suggest they’re helping solve plastic pollution. Environmental NGO Changing Markets Foundation published a report in 2020, which found that multiple brands were promoting partnerships with TerraCycle in sustainability reporting, despite the fact that programmes were regularly small-scale, or only available in a limited number of cities or countries. 

TerraCycle is one of the only ways for companies today to take some form of voluntary responsibility over their externality of hard-to-recycle packaging and/or products. This creates an economic flow where there wasn’t one before. Take into context that the vast majority of manufacturers do nothing to fund this specific externality.

Some of TerraCycle’s programmes are earlier in their evolution and small whilst others are more established and larger in scale. This echoes the lifecycle of almost all voluntary sustainability programmes. 

Brands partner with TerraCycle as part of their sustainability / ESG initiatives so it’s only natural that many will include this in their sustainability reporting. 

6. TerraCycle provides brands with marketing services to promote the fact they are involved in a TerraCycle recycling programme, and has featured extensively in adverts for some brands. In a 2017 advert for shampoo company Head & Shoulders, the brand promoted its collaboration with TerraCycle and the waste management company Suez to make “the world’s first recyclable shampoo bottle made with beach plastic”, which had been collected by volunteers. The brand is owned by Procter & Gamble, one of the world’s 10 largest plastic polluters

TerraCycle does indeed work with the partnering brands to help raise awareness to the public so they know there is a way for the product and/or packaging of the specific free program to be recycled where previously this wasn’t possible. In the same way many brands (and we actively encourage them to do so), also promote the partnership and their free recycling programmes.

7. Corporations can pay TerraCycle to set up a recycling programme for specific packaging. Once recycling costs reach the company’s budget limit, TerraCycle will no longer recycle the brand’s packaging

For every free TerraCycle programme, the sponsoring brand sets the recycling budget each year. It is TerraCycle’s role to run the programme within this parameter. Based on our experience and knowledge of similar programmes and waste streams, we advise the brand on the budget we feel is required at that stage of the programme's evolution. Ultimately, the decision on the budget is up to the sponsoring brand. As budgets change, we communicate to the collectors to send their shipments to us, and the waste is then recycled.

Remembering that brands are not legally required to fund end-of-life solutions for their products and packages is key. Even with EPR (Extended Product Responsibility) or DRS (Deposit Return Scheme) legislation, hard-to-recycle materials are not legally required to be recycled and as a result, are typically not. 

8. In 2021, the environmental campaign group Last Beach Cleanup launched a lawsuit in California against Terracycle and eight consumer product companies, which alleged that the companies’ recycling claims were unlawful and deceptive, in part because of their “unqualified representation” that their difficult-to-recycle plastic products were recyclable through the partnership, ignoring the budget limitations.

The organisations and companies agreed a settlement before the case reached the courts, as part of which TerraCycle agreed to label on its website and on packaging when programmes had budget constraints. Of the 120 free recycling programmes listed on its U.S. website as of April 2025, over half stated “Enrollment limits apply”, including for well-known brands such as Babybel and Colgate. No such notices were found on the UK website, although some pages did say “there are currently no more spaces available”.  

In our 25-year history, this is the only lawsuit ever filed against TerraCycle for anything to do with its recycling claims, recycled content or reuse services. 

The lawsuit was initiated by Last Beach Cleanup, a one person NGO, and was settled in 2021. Both sides agreed to settle this matter without any damages paid.  The implicated brands were required to change their product labels following the settlement, prohibiting them from marketing products as “100% recyclable” through TerraCycle. It is important to note that  TerraCycle had already started implementing these changes with brand partners (to provide additional clarity to consumers) prior to LBC making any demands, and had agreed with LBC on making these changes prior to LBC filing its lawsuit; however LBC filed its lawsuit nonetheless.

These changes strictly apply to brand partners’ packaging and their marketing claims. It was not a required change for the TerraCycle programme pages. 

Although the product/packaging labelling changes resulting from the 2021 lawsuit were only mandated in the state of California, we decided however to implement them nationally in the US. There is no global remit applicable here.  

When our partners use our trademarks such as our logo or our company name, their contracts include language that we need to review and approve the work. We edit out terms like “100% recyclable” or “recyclable” (which is reserved for kerbside/municipal recycling) and change the copy to “Recycle with TerraCycle”. This is a global directive.

However, as you state above with the UK example, where a programme is full it is stated on the website page that “there are currently no more spaces available.” 

9. The settlement agreed between the organisation and companies also required TerraCycle to “provide assurances for every recyclable claim made by TerraCycle or its clients”, as well as ensuring that it changed the labelling on its website. Brands involved in the settlement had to change their product labels so that they did not say “100% recyclable” if the programme had a limit placed upon how much waste it would accept. TerraCycle paid the attorney fees and Last Beach Cleanup’s legal fees, though it makes clear “Neither TerraCycle nor the other companies that were sued by LBC admitted any liability or paid damages”. “This matter never went to court and we had agreed with LBC on the principal terms of settlement before the lawsuit was filed,” the company said. “TerraCycle took LBC’s claims seriously and addressed them quickly in a constructive manner (which included showing them significant documentation to substantiate our recycling processes in response to what they asked for)”. 

Both sides agreed to settle this matter without any damages paid.  The CPG companies that LBC elected to sue agreed to change their product labels as part of the settlement, and. it is important to note that TerraCycle had already started implementing these changes with brand partners (to provide additional clarity to consumers) prior to LBC making any demands and had agreed with LBC on making these changes prior to LBC filing its lawsuit; however, LBC filed its lawsuit nonetheless, and TerraCycle did pay LBC’s legal fees (which is the same thing as attorney’s fees referenced in your bullet point). The 100% recyclable point is distinct in that it is related to whether absolutely all (i.e. 100%) of a product can be recycled; and yes, the parties also agreed to no longer make those claims in the settlement (also something TerraCycle had agreed to do prior to LBC filing its lawsuit).

Although the product/packaging labelling changes were only mandated in the state of California, we decided to implement them nationally in the US  because we advocate for clarity around recycling claims.

These changes strictly apply to brand partners’ packaging and their marketing claims. It was not a required change for the TerraCycle programme pages. However, as you state in the previous question with the UK example, where a programme is full it is stated on the website page that “there are currently no more spaces available”.  

10. TerraCycle has extremely little transparency on its impacts. The company does not appear to publish any kind of sustainability or impact reporting on its website, and does not share any data on collection rates, recycling rates or the total amount of a brand’s packaging that is recycled through its programmes compared to that which ends up in incineration or landfill. While it claims to have “developed the world’s first solutions in everything from recycling to reuse”, Ethical Consumer could not find any figures about its recycling rates, how much material it has recycled in total, or the percentage of recycled packaging from any of its partnerships.

The website does state: “a recent, third-party-verified, Life Cycle Assessment (LCA) showed that all TerraCycle recycling models have lower environmental impacts when compared to traditional solutions (like landfilling and incineration) across eight major impact categories, including global warming.” However, the Life Cycle Assessment only considered recycling of flexible film in the United States and there were no details on what data TerraCycle had used to calculate its savings. 

Transparency is important to us, which is why we previously offered Ethical Consumer a tour of our UK sites. While we understand Ethical Consumer weren't able to join us in September, that invitation still stands. We would be happy to facilitate a visit to our offices and operational sites so Ethical Consumer can see our work first-hand.

TerraCycle is the most transparent recycler we know of, and we will continue to build out content on our website to showcase our work. We guarantee to recycle all accepted waste that’s sent to us through any of our free or paid recycling solutions see https://www.terracycle.com/en-GB/about-terracycle/recycling_guarantee, and regularly audit (internal and external audits) our supply chain see https://www.terracycle.com/en-GB/terracycle-difference

Additionally, TerraCycle works with Ecovadis to inspect and continuously improve sustainable and ethical supply chain policies and controls. Each year TerraCycle undergoes their evaluation and currently, TerraCycle holds a Silver Medal for its work, noting that the 2024 Silver Medal ranks TerraCycle in the TOP 15% out of 130,000+ companies for sustainable business practices.  Ecovadis is a global leader of business sustainability ratings, evaluating corporate social responsibility and sustainable procurement practices for over 130,000 companies worldwide.

We guarantee to recycle the accepted waste sent to us through all of TerraCycle’s recycling solutions. Third Party external and internal audits are performed on an ongoing basis, and over 98% of the waste received is recycled, which accounts for all compliant waste we receive. Please see our website to view this information and more. 

While recycling is an imperfect solution, it is a major improvement over disposing of our waste in landfills or through incineration. Recycling's main benefit is that it reduces the need to extract new raw materials from the planet (for an average product, the vast majority of the negative environmental impact comes from extracting and refining the raw materials from which it is made).

The recent, third-party-verified, Life Cycle Assessment (LCA) for flexi film showed that all TerraCycle recycling models have lower environmental impacts when compared to traditional solutions (like landfilling and incineration) across eight major impact categories, including global warming. This translates to TerraCycle outperforming traditional disposal models by an average of 45 %. Please let us know if you’d like to receive a full copy of that third party reviewed LCA.

11. TerraCycle’s parent company is registered in Delaware in the U.S.. However, its headquarters are in Trenton, New Jersey. Delaware is known for its lack of corporate transparency rules, and has been called “the US corporate secrecy haven” by advocacy group Transparency International, as well as being a tax haven.

One important reason why many companies in the US register in Delaware is because of the Delaware Court of Chancery (which is unique in the US), and how it manages corporate and business matters, its judges are also appointed specifically for their expertise in corporate law. Because they hear such cases every day, decisions tend to be faster, more consistent, and more predictable. 

12. TerraCycle has been criticised for difficulties faced by consumers in trying to recycle products that are part of its free corporate programmes. In the past, all products included in the schemes had to be dropped off at special collection points, and this is still the case for certain brands. These collection points can be far from a person’s house and in certain areas, (Scotland in particular), there may not be any available. If a consumer wants to set up a new drop off point, TerraCycle says it has to be within 2 miles of an existing one.

No, the guidance on all TerraCycle UK programme pages is that ‘a minimum of 2 miles distance from an existing drop-off point for the same programme.’ We implement this rule to help ensure that collection points are not too close together with an aim of being able to facilitate as wide a spread of collection points as possible geographically.’,

This means that options for reaching remote regions are limited. In recent years, the company seems to have made some positive steps to address this issue following criticism, and in the UK most products can now also be posted in a reused cardboard box.

TerraCycle’s guidance has always been that collectors should reuse old envelopes or cardboard boxes to ship the collected waste back to TerraCycle’s Materials Recovery Facility (MRF).

On many of TerraCycle’s free programmes in the UK as well as the option to find the nearest public drop-off location from the interactive map, there is also the option to send in waste from home as a private collector if there isn’t already one locally or the person doesn’t want to set up their own drop-off location.

12b. This means that options for reaching remote regions are limited. In recent years, the company seems to have made some positive steps to address this issue following criticism, and in the UK most products can now also be posted in a reused cardboard box.

TerraCycle’s guidance has always been that collectors should reuse old envelopes or cardboard boxes to ship the collected waste back to TerraCycle’s Materials Recovery Facility (MRF).

On many of TerraCycle’s free programmes in the UK as well as the option to find the nearest public drop-off location from the interactive map, there is also the option to send in waste from home as a private collector if there isn’t already one locally or the person doesn’t want to set up their own drop-off location.

13. Unpaid volunteers run TerraCycle drop off points. The company donates $0.02 to charity for every item collected. TerraCycle told us in 2022 that the volunteers had “raised over $44 million globally for the school or charity of their choice in return for collecting for our recycling programs.” 

While the majority of our revenue comes from offering paid recycling solutions, we do also offer free programmes. These free programmes give participants access to free recycling solutions for waste types not accepted by kerbside council systems (meaning they would end in landfill / incineration if properly disposed). We also offer in many programs the added benefit that funds are raised by the participants for schools, charities and nonprofits at the same time. 

In comparison, kerbside waste management and recycling is not a free service, but one paid by citizens through council tax. 

14. TerraCycle doesn’t publish any statistics showing how much recycling takes place in each location, and previously told us that it could not disclose this amount due to its privacy rules, stating “You may contact any location and ask them what they have recycled.” 

This is correct as it would be a direct breach of each collection location's privacy agreement with us and its administrator.

15. In 2021, a documentary called ‘The Recycling Myth’ accused TerraCycle of exporting and incinerating plastic waste it had pledged to recycle in the UK – allegations that the company vehemently denies. Investigative journalists uncovered that a batch of recycling collected in the UK has been shipped to an incineration plant in Bulgaria. TerraCycle claims this was a one-time error and that it was in fact found at a recycling plant. The journalists also claimed that TerraCycle had applied legal pressure to try and prevent the documentary from being aired – a claim that TerraCycle denies. 

This documentary falsely accused TerraCycle of sending waste to Bulgaria to be incinerated. In fact, several years ago a supply chain subcontractor (contracted to recycle certain flexible films locally in the UK) had one of their temporary workers in the UK during the COVID pandemic mistakenly load a small amount of our collected flexible film waste onto the wrong truck. As a result, the material ended up at a recycler in Bulgaria (not an incinerator as the documentary claims). Once we became aware of this error, we were able to trace the material and locate it very quickly.  As soon as we located the material, we transported it back to the UK, where it was  recycled as originally planned. Though this was a one-time incident, out of an abundance of caution, we also ceased work with that specific subcontractor as soon as we became aware of the error. 

TerraCycle is disappointed with this misleading portrayal as we provided the producers a&o with significant and compelling evidence to support the above.

TerraCycle has never filed a lawsuit against any member of the media, including Mr. Wermter from a&o.   
We certainly stand for free speech and for accurate reporting. Mr. Wermter’s production did not inform the viewers that (i) the incident in Bulgaria was a one-time and unintentional (and admitted) human error (substantiated with evidence) and (ii) the UK volunteer’s consent to the filming (which is presented as the hook of the documentary) was obtained by deception and that she had revoked that consent after reviewing the findings of our investigation.  

16. Where corporations haven’t sponsored a particular recycling programme, consumers can buy their own ‘zero waste’ boxes for everything from plant pots to paint tins. These cost between £100-£395 per box, depending on the size and the complexity of sorting the items included. TerraCycle says: “The cost of a Zero Waste Box includes the production of the box, shipping to you and then back to our recycling facilities, and the actual cost of sorting, cleaning, processing, and recycling the box, liner, and all accepted waste inside.” 

Yes, the above paragraph is correct. This is indeed how the Zero Waste Boxes work.

The cost of a zero waste box reflects the cost of the box, shipping (in and out), sorting, and recycling its contents, minus the value of the recycled material. This is why we offer multiple size options, so that there are multiple cost options. 

The larger the shipment, the more efficient the recycling cost is to the consumer. We find that many of our consumers opt for a larger box and fill it up over time. For example, a large Crisp Packet and Snack Packaging Zero Waste Box can hold approximately 3,500 wrappers. Similarly, a large Food Pouch box can hold over 2,700 pouches.

As is the case with all TerraCycle recycling solutions, we guarantee all compliant materials are recycled. 

17. TerraCycle’s Loop Scheme involves creating reusable packaging for brands, so consumers can return it when finished and the packaging will be used again. Roll out of Loop in the UK has been limited. In 2021, Tesco partnered with Loop to launch a trial enabling customers to buy products from participating brands, and return the packaging to the store to be recycled. The project was piloted in 10 Tesco stores, but was cancelled 12 months later, with Tesco’s responsible sourcing director Giles Bolton writing, “while the potential [for reusable packaging] is huge – and we should all be excited about a solution where packaging can be used and reused in a circular system – the implementation challenge is equally significant.” 

Yes Loop did run a pilot with 10 Tesco stores in the UK in 2021. The pilot was highly successful but ultimately failed to scale at the time, due to tough UK market conditions and challenges such as the cost of living crisis. 

Our experience in France, where Loop has scaled to the country's largest reuse platform, and is available today in more than 450 stores (across multiple retailers) across more than 400 products shows that mandatory government regulation is highly important. Pilots initiated through voluntary corporate efforts in countries like the UK, Canada, US and Japan failed to scale nationally. In contrast, in France, when the Loi AGEC regulation dictated the obligations and financial support was provided, major retailers like Carrefour began actively investing in a long-term transition of their distribution model. Without regulation, reuse is unlikely to become commercially viable. The key is the right regulatory framework with both a reuse mandate and the proper incentives to make it financially competitive during scale-up.

The success and commercial scaling of Loop in France has helped us identify the following market conditions that can act as a blueprint for how reuse can scale in other markets such as the UK:

1. Commercial commitment: Strong support and long-term partnerships with leading retailers, like Carrefour. Carrefour invested in making Loop successful by implementing the system in a large number of their stores (now over 350 stores and growing),  putting pressure on their vendors to join (now over 400 products, including their private label), raising awareness among French consumers, and much more.  This paved the way for other retailers to join and scale the system (since Carrefour, more than 5 other major retailers have joined in France).

2. Regulation (“Stick”): The Anti-Waste Law for a Circular Economy (Loi AGEC) gave retailers clear mandates to incorporate reusable packaging by 2027, creating compliance targets that drove commitment (under France's loi AGEC regulations, a 10% target for reusable packaging by 2027 is set, meaning 10% of packaging placed on the market must be reusable).

3. Regulation and financial support (“Carrot”): Targeted financial support from extended producer responsibility organisations helped fund reuse infrastructure and collection systems, offsetting upfront costs for retailers and brands (in France, EPR organisations must spend 5% of their revenue, around €100M per year, on funding reuse until 2029. This covers to up to 70% of the brand and retailers’ direct and indirect costs).

Importantly, Loop builds the operational system for extreme simplicity and convenience. Not just for consumers, but especially for the commercial actors (retailers and brands).

When these conditions are in place in the UK, we are confident that Loop will launch again amid the required conditions that will enable the system to thrive and commercially scale as in France.

18. Does TerraCycle have any plans to improve transparency?

TerraCycle is the most transparent recycler we know of, and we will continue to build out content on our website to showcase our work. We guarantee to recycle all accepted waste that’s sent to us through any of our free or paid recycling solutions see https://www.terracycle.com/en-GB/about-terracycle/recycling_guarantee, and regularly audit (internal and external audits) our supply chain see https://www.terracycle.com/en-GB/terracycle-difference

Additionally, TerraCycle works with Ecovadis to inspect and continuously improve sustainable and ethical supply chain policies and controls. Each year TerraCycle undergoes their evaluation and currently, TerraCycle holds a Silver Medal for its work, noting that the 2024 Silver Medal ranks TerraCycle in the TOP 15% out of 130,000+ companies for sustainable business practices. Ecovadis is a global leader of business sustainability ratings, evaluating corporate social responsibility and sustainable procurement practices for over 130,000 companies worldwide. 

19. What would TerraCycle say to those who suggest that major polluters use its partnerships for greenwashing purposes? 

Greenwashing is where “green” marketing is deceptively used to promote the perception that an organization’s products, aims, or policies are environmentally friendly when they are not. 

TerraCycle’s recycling programmes are authentically collecting and recycling. Our programmes provide the public a simple and convenient platform to recycle a wide range of types of products and packaging which aren’t recycled by municipal/council systems and so would otherwise end in landfill / incineration. In no cases are claims around our programmes exaggerated.

TerraCycle is a mission-driven company that for over 25 years (16 years in the UK having launched here in 2009) has been doing everything in our power to help with the challenges of waste in our world. Our solutions are by no means perfect, but we’re working every day to make a difference, and it does mean that we will work with the contributors to this problem to try to get them to first care, then invest resources, and finally maintain and scale their investment towards a circular economy. 

20. Why does TerraCycle not mark “enrolment limits” on its UK website? Did the settlement with Last Beach Clean Up extend to the UK?

The settlement with Last Beach Cleanup was limited to the state of California only. Despite the geographical limits, we were pleased to have implemented these important standards nationally in the US because we advocate for clarity around recycling claims.  While not part of the settlement, where a programme is full it will say on that page (as in the UK example you referenced in an earlier question) that “there are currently no more spaces available.” 

In the UK many of TerraCycle’s free recycling programmes operate a network of public drop off locations where you can search for your nearest participating location using the post code search facility. The public drop off mechanic is more advanced / has larger networks of locations  in the UK than it is for TerraCycle in the US where many programmes instead have participants collecting / sending their waste mainly as private collectors from home. As a result many consumers simply find their nearest drop off location to drop off their waste rather than sign up themselves in order to recycle. As such we decided not to implement the same changes in the UK that we made in the US on the programme pages.  

In the UK example, where a programme is full it is stated on the website page that “there are currently no more spaces available.” 

21. Why is TerraCycle registered in Delaware despite being headquartered in Trenton, New Jersey? What is TerraCycle’s stance on the use of tax avoidance schemes? Is TerraCycle able to provide any country-by-country reporting to demonstrate its tax payments?

Delaware being our place of incorporation has no effect on any taxes we owe and where we owe them, and it doesn’t shift income from one tax jurisdiction to another. 

It’s important to separate two things that often get mixed together: legal tax strategy versus tax avoidance. 

Every company — big or small — is expected by its stakeholders to structure itself in a way that follows the tax rules of each state or country where it operates.  Ensuring that you pay what’s due, and no more, is a good tax strategy, not tax avoidance.  Specifically, at TerraCycle, we don’t use tax shelters, offshore schemes, or anything that hides income to “avoid” tax. Our approach is straightforward: we pay tax where we actually do business, exactly as the law requires.

Regarding country-by-country reporting, we comply with all tax filing requirements in the countries where we operate, and are required to maintain detailed records of our tax obligations and payments.  That level of financial detail is confidential and would only be shared under the proper protections — typically an NDA — just as any responsible organization would do. 

Our Company has been in business for more than 25 years, which is good evidence that we play by the rules. We continue to invest in our governance and infrastructure to ensure we continue to comply.  For example, KPMG, one of the world’s leading accounting and audit firms, annually audits our financials. We also have a formal audit committee as part of our board of director governance structure.

Responsible tax strategy is about compliance and clarity — not avoidance. We believe in paying our fair share, and we structure the Company in a way that is transparent, legal, and aligned with standard business practice.

TerraCycle files its taxes locally in every country we operate in and we have consolidated financials where we file taxes at a global level declaring all taxes in the local markets.

Public CBCR reporting is for large multinationals with revenue of over €750m. As a $75m revenue company TerraCycle is some distance from meeting the criteria for public CBCR to be possible.

(Note from Ethical Consumer: Public CBCR reporting is mandatory in Europe for large multinationals with revenues of over €750m. Companies over this threshold are required by law to complete CBCR.)

22. Does TerraCycle have any Loop Schemes currently active in the UK? 

Loop is not currently live in the UK. 

In France however Loop has progressed from pilot to industrial scale and is now available in more than 450 major retailers (i.e. Carrefour, Monoprix and Coopérative U stores etc.) shipping over 400 products in fully reusable packaging (food, beverage, home care and personal care etc.).

When the needed regulatory and financial subsidy conditions are in place in the UK, we are confident that Loop will launch again amid the required conditions that will enable the system to thrive and commercially scale as in France.

23. What would TerraCycle say to those who question its use of unpaid volunteers, as a for-profit company? 
At TerraCycle, while the majority of our revenue is made from selling paid recycling and reuse solutions, we do offer free recycling programs as well. Our free programs are free because other stakeholders (like brands and retailers) fund them. As a bonus, many of our free recycling programs have added benefits in that they help raise funds for schools, charities, and nonprofits in correlation with how much waste a citizen collects.

If you compare TerraCycle’s free recycling programs to local kerbside recycling:

  • While TerraCycle’s free programs have no cost local kerbside programs are funded by participants via their local property taxes
  • While TerraCycle’s free programs in many cases provide donations to local schools and charities kerbside programs typically offer no incentives