A source claim is not supported merely because an estimate or certification is attached to it. According to the US EPA, recovered-content claims can be supported by estimates and certifications, and those estimates and certifications should be reasonably verified where appropriate. A proper comparison therefore examines both whether the evidence supports the exact claim and whether the evidence has been reasonably verified.
Separate the claim from the evidence
A clear review begins with two distinct elements:
- The source claim: the precise statement about recovered-material content being made.
- The supporting documentation: the estimate, certification, or other material offered as support.
The distinction matters because having a document does not establish what that document supports. The comparison should preserve the claim’s exact wording rather than infer a broader conclusion from it.
| Review point | Question to answer |
|---|---|
| Claim | What exactly is being claimed about recovered-material content? |
| Support | Does the claimant identify an estimate, a certification, or both? |
| Relevance | Does the cited evidence address the same claim, including any stated scope or qualifiers? |
| Verification | Where appropriate, has the evidence been reasonably verified? |
| Gaps | Which parts of the claim remain unsupported or unconfirmed? |
Check what the evidence actually says
The first step is to identify the document being relied upon. The EPA statements recognise both estimates and certifications as forms of support, but the cited statements do not say that the two are interchangeable or automatically carry the same evidential weight.
The next step is to compare the document’s stated subject with the source claim. A general reference to recovered-material content should not automatically be treated as support for every product, material, quantity, or other scope that may fall under the broader claim. Any such connection needs to be established from the document itself.
Verification is a separate question. The US EPA says estimates and certifications should be reasonably verified where appropriate. The cited statements do not define when verification is appropriate, what method must be used, or who should perform it. Those details cannot be inferred from the two EPA statements alone.
What still needs confirmation
Before treating a claim as adequately documented, a reader still needs to confirm:
- the exact wording and scope of the claim;
- whether an estimate, certification, or both are being relied upon;
- whether the cited document actually addresses that claim;
- whether reasonable verification is appropriate for the evidence and has been completed;
- whether any separate programme, regulatory, contractual, or certification requirements apply.
The cited EPA material is a US source. On the evidence stated here, it does not establish a Hong Kong-specific requirement. Any local or programme-specific obligation must therefore be checked against the relevant official material rather than attributed to these EPA statements.
The safest conclusion is equally limited: the source identifies estimates and certifications as possible support and calls for reasonable verification where appropriate. It does not, by itself, resolve document validity, verification methods, or the connection between a particular document and a particular claim.