Since July 2026 we have been receiving one and the same question from certified converters and recyclers, in different wordings:
These questions arise from Commission Implementing Decision (EU) 2026/1425 of 30 June 2026, which came into force on 23 July. The document lays down rules for the application of Directive 2019/904 with regard to the calculation, verification and reporting of data on the content of recycled plastic in single-use plastic beverage bottles.
The short answer: nobody has lost anything, but two things now need to be calculated separately. The long answer follows in the subsequent sections of this article.
23.09.2026
The Decision lays down how to calculate, verify and report the 25% recycled-content target for single-use PET beverage bottles under the SUPD. That is all. It does not regulate the status of the material, does not restrict its import or use. Recital 20 states explicitly that the import of recycled plastic for the manufacture of bottles remains possible — and does not refer to any certification scheme. Nor does it concern the PPWR targets for 2030: the methodology under Article 7 PPWR will be adopted separately (Article 7(8)), and recital 32 merely announces that alignment “should be considered”.
Art. 1 (1):
„recycled plastic” means plastic from post-consumer waste that has been recycled — including sorting — in the Union..
From 21 November 2027 the definition will also cover recycling in OECD countries, unless the Commission issues a negative assessment of a country’s management of plastic waste under Article 45(5) and (6) of Regulation 2024/1157, and in non-OECD countries only once an agreement with the EU has been concluded.
Translated onto a map:
Over the past three years a commercial model became established: waste becomes a raw material where it acquires its specification and changes customs code from 3915 to 3907, so the country of that step is the country of production of the recyclate.
Flakes washed and sorted in a third country travelled to the EU, went through extrusion or SSP here and left the plant as “recyclate produced in the EU”. In the declarations this was true, extrusion did take place in the EU, and the definition did not ask about earlier steps.
It appears that the definition simply measured something other than what the legislator wanted to measure.
Decision 2026/1425 is the first act that, instead of asking “where did the material cease to be waste”, asks “where did each recycling step take place” and explicitly adds sorting to the list of steps. Annex V requires the weight and percentage of material “for which all recycling steps (including sorting) have taken place in countries that are in scope of Article 1(1)”; the plural and the parenthesis are not accidental. The same direction is visible in three other places at once:
This is not a single decision; it is a change of direction and of method.
At present, collection outside the EU is not an obstacle: Article 1(2) covers waste from products placed on the market in a third country. Sorting is becoming the obstacle. Sorting has two practical meanings:
The provision does not say which one it means. If only the second, a bale sorted in a third country and fully processed in the EU counts towards the target; if both, it does not.
The regulatory direction described above suggests the stricter reading: since the legislator is consistently moving control up the chain, there is no reason to assume it will exempt the sorting facility.
Until Commission guidance is available it is therefore worth considering the cautious option: document the place of sorting for every batch and do not count bales sorted outside the EU towards the SUPD target. If the Commission adopts the milder reading, nothing is lost; if the stricter one, no reports need to be corrected retroactively. And add a field “country of each step, including sorting” to the input register today, because whatever the reading, that field will be required under every subsequent act.
A RecyClass certificate has never been a criterion for counting towards the SUPD target — not under the previous Decision 2023/2683 and not now. The Decision does not mention certification schemes with a single word. A recycler in Türkiye or India continues to be certified under Recycling Process with Module A1 and/or A2; its pellets enter the converter’s Traceability certificate, the controlled-blending calculation, the technical documentation and the EU declaration of conformity under the PPWR. Nothing will “regain” its status in November 2027, because nothing has lost it.
What changes is that what used to be one claim becomes two:
The mechanism that enforces this is simple and worth knowing, because it will be copied. Article 8(3) imposes a per-batch declaration on every operator in the chain; whoever does not change the composition of the material passes the supplier’s declaration on. In this way the information on the geography of the steps travels from the sorting facility to the filler with no possibility of being “lost” along the way, and the Member State collects the declarations from the operator placing bottles on the market and verifies them on a risk basis (Article 8(1) and (10)). The certificate is not a criterion in this mechanism, but it is the only independent evidence that the figures in the declarations derive from records rather than from copying.
Here a third act closes the loop: the EmpCo Directive (2024/825), applicable from 27 September 2026. From that date every recycled-content claim addressed to consumers in the EU must be substantiated, and a sustainability label without third-party certification goes on the blacklist of practices deemed unfair in all circumstances. A producer who prints “30% recycled” on a pack and, in the technical documentation, bases it on an Annex V declaration showing a zero in-scope share has two different sentences glued into one — and that gluing is exactly what EmpCo penalises. Two claims, two boxes: “certified post-consumer recyclate” goes on the pack and into the PPWR documentation; “counted towards the SUPD target” goes into the filler’s report.
They must not be mixed, either in communication or in evidence.
From 23 July 2026 every batch of material containing recyclate in the bottle chain must carry a declaration under Annex V to the Decision (Article 8(3)). For material covered by 2022/1616 this is Part C an add-on to the declaration of compliance under Annex III. It requires:
Whoever does not change the composition of the material passes the suppliers’ declarations on. They are kept for five years.
In a food-contact chain with recyclate there are therefore now three declarations that must not be confused:
The RecyClass certificate is none of them. It is the evidence they rest on.ą.
The RecyClass schemes (Recycling Process, Recycled Plastics Traceability and the Food Contact Module A) common to both, in their current versions of December 2024, were written a year and a half before Decision 2026/1425. They refer neither to it nor to Annex V. The Annex V declaration is therefore not the subject of certification, and no certification body can “confirm compliance with the Decision”.
But the RecyClass scheme is ambitious: it generates almost all the data that Part C requires, and it already contains a requirement that checks them. This is requirement A2.5.2 “Declaration of Compliance” in the RecyClass Audit Scheme Module A: Food Contact, which is a mandatory requirement instructing the auditor to check the declaration of compliance issued under Annex III to Regulation (EU) 2022/1616 and compare it with the batch release records, the label and the intended use of the material. Part C of Annex V to the Decision is physically an add-on to that same declaration. A certification body can therefore, without stepping outside the existing requirement, verify whether the figures in Part C are consistent with the certified data for that batch.
The result is a confirmation of “consistent with certified records”, not “compliant with the Decision”. The latter always lies with the Member State authorities, which verify the data on a risk basis (Article 8(1) of the Decision). That is how we treat it at SRC and how we describe it in the audit report. Information the RecyClass scheme does not require today, without which Part C of Annex V to the Decision is defective:
If the place of sorting has become a criterion, it has to be proven, and a supplier’s declaration “sorted in the EU” is weak evidence.
A RecyClass Sorting Process certificate is issued to a specific sorting facility at a specific address. The same certificate, with Module Alpha, confirms origin and separate collection for food-contact purposes. One tool has thus started to serve two obligations: Article 6 of Regulation 2022/1616 and Article 1 of Decision 2026/1425. Today neither of them requires a sorting-facility certificate, but the direction is set and it can be expected to become required in food-contact applications.
Silk Road Certification is a certification body accredited by the PCA (No. AC249) to certify products under the following schemes:
Certification enables you to organise and verify data relating to the recycling process, the origin and the traceability of recycled materials.
In addition, we carry out assessments and audits under the RecyClass Sorting Process and RecyClass Recyclability schemes.
Contact us to find out which solution is right for your organisation.
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From 6 to 9 October 2026, we will meet you at PLASTEX – the International Trade Fair of Plastics and Composites in Brno, Czech Republic. Silk Road Certification will be exhibiting at this major event, which brings together companies, experts and professionals from across the plastics value chain every two years. For us, PLASTEX is an opportunity to meet businesses working with plastics, recycled materials, plastic packaging and recycling technologies and to talk about some of the issues that are becoming increasingly important for the industry: recycling, recyclability, recycled plastics, traceability and certification.
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