As part of the accredited RecyClass Recycling Process and RecyClass Recycled Plastics Traceability certification schemes, it is possible to apply to complete an additional document — the Annex Eco Modulation.
This is an annex to the audit report which documents the data required by the French Extended Producer Responsibility (EPR) system to obtain a fee modulation from an éco-organisme, including CITEO.
The stakeholder is the entity placing the product on the French market — the manufacturer, importer or distributor paying the fee to the éco-organisme. However, a condition for eligibility is the documentation of the recyclate’s compliance by earlier links in the chain: the market introducer alone is unable to demonstrate geographical proximity or process efficiency, so this data must come from a certified recycler and converter (via their Annex, certificate or audit report) and be consistently passed up the chain. Therefore, the certification of the recycler and converter, together with a completed Annex, are prerequisites for a packager placing packaging on the French market to be eligible to apply for modulation (a subsidy).
The basis for this is the Arrêté of 5 September 2025 (effective from 1 January 2026), which sets out harmonised criteria for recycled content in packaging placed on the French market. The decree itself does not specify a certification scheme — it delegates to the éco-organisme the task of defining traceability requirements. The RecyClass Annex meets these requirements by reporting parameters not covered by the standard declaration of recycled content, in a format accepted by CITEO:
In the case of CITEO, the annex is completed for both the recycling and converting stages.
| Access to EPR eco-modulation in France for packaging placeholders A completed Annex Eco Modulation provides the data required by the Arrêté du 5 septembre 2025 in a format accepted by the éco-organisme (CITEO), enabling the placeholder to apply for an EPR subsidy for incorporating recycled material into packaging. | Continuity of evidence throughout the value chain The Annex transfers data on origin, proximity (≤ 1,500 km, EU27+3) and process yield (≥ 50%) from the certified document of the previous link in the chain, thereby providing the packaging placer with consistent evidence from both the recycler and the converter. |
| A supplement to RecyClass certification without a separate audit Annex is an optional supplement to the RecyClass audit report. It is not part of the audit itself — it can be carried out separately, upon a separate request, without the need for an additional on-site visit. | Advantage over a declaration based solely on the percentage of recycled content A standard chain of custody declaration does not provide data on geographical proximity combined with process efficiency. The Annex supplements precisely those parameters required by the French market. |
The certification body (Silk Road Certification) should be informed that the Annex is to be completed, preferably at the stage of submitting the certification application.
Completing the Annex is not part of the certification audit evaluation but consits a part of the report therefore is issued with the report and requires prior audit.
Silk Road Certification prepares the Eco Modulation Annex exclusively for entities certified by Silk Road Certification (holding a valid RecyClass certificate issued by our body).
For a specific recycling process involving a given recyclate — as a single plant indicator (denominator = total plastic waste at the input, excluding additives). This is a mass-based process indicator, with no distance component. In the Annex, it is reported separately for recyclers and converters as ‘Recycling process → XX% yield’
The radius is defined by Article 8 of the decree (Arrêté du 5 septembre 2025) — 1,500 km from the centre of hexagonal France (46°29′38″N, 2°36′10″E), within the EU27+3 or a country with equivalent standards. Four stages are subject to this criterion: collection, sorting, recycling and conversion. Where traceability from the collection point is not possible, the sorting, recycling and conversion stages are taken into account. (Article 8 of the Arrêté of 5 September 2025).
Any of these stages may fall outside the ‘radius’. If a product contains a mixture of compliant and non-compliant recycled material, their proportions are stated.