Discussions about recycled content in finished products increasingly focus on one key question: how can recycled content be verified in a reliable and auditable way? This issue is particularly important in the context of the PPWR, where the EU Declaration of Conformity is expected to be based on documented evidence for a specific product batch rather than on general claims. Given the widespread use of different certification schemes, a practical question arises: ISCC PLUS, RecyClass or GRS? Each of these systems approaches the verification of recycled content differently and provides a different level of traceability and supporting evidence, such as the ISCC PLUS Sustainability Declaration in the case of ISCC PLUS.
02.07.2026
Consider the following simple scenario: a company purchases plastic granulate. The invoice says: “30% recycled content.” The documentation bears a certification logo. Everything looks solid. But the mere fact that a supplier holds an ISCC PLUS, RecyClass or GRS certificate does not mean that every product you purchase from them contains recyclate. A certificate confirms that the company has a system in place — not that every batch of goods from that company contains the declared percentage.
In the context of the PPWR this distinction is crucial. From 2030, the EU declaration of conformity must include information on recycled content (Art. 7). Market surveillance authorities will not ask whether your supplier has a certificate. They will ask on what basis you declared a specific percentage for a specific batch of packaging.
For details on who bears responsibility for EPR fees, see the following article: Who signs the PPWR Declaration of Conformity?
Under the ISCC PLUS system, the certificate confirms that a facility has a chain of custody system in place — most commonly mass balance. The certificate is issued per site, valid for 12 months. But the certificate itself does not disclose the recycled content of any specific batch of product.
Recycled content is disclosed on the ISCC PLUS Sustainability Declaration (SD) — a transaction document that must accompany every sale of certified material. The SD specifies:
In this context, the following key principle of ISCC PLUS applies:
There is no certified transaction without a sustainability declaration.
Every participant in the supply chain must hold an ISCC PLUS certificate — with one exception: the last entity (end recipient) need not be certified. But the SD must reach them.
Under the dominant mass balance model, the ISCC PLUS Sustainability Declaration declares a percentage derived from accounting, not from the physical presence of the material in the product. This is how mass balance works. Certified and non-certified material is physically mixed, and separation occurs solely at the bookkeeping level.
There is, however, a caveat:
Not every product from an ISCC PLUS-certified company contains recyclate.
Only products accompanied by the Sustainability Declaration. A product sold without an SD (even from a facility with a valid certificate) is a conventional product. The SD is the only document that confirms the recycled content of a specific delivery. For this reason, it should be retained together with a valid certificate. The entity drawing up the PPWR declaration of conformity should store both documents as part of the supporting technical documentation.
This creates practical difficulty:
ISCC PLUS v3.4+ includes a section entitled “Additional Requirements for Recycling according to EN 15343”. It is a supplementary requirements for recyclers that wish to demonstrate compliance with the European standard for plastics recyclate traceability.
This distinction is particularly important when assessing the credibility of declared recycled content. EN 15343 is based on physical traceability and controlled blending, rather than on mass balance. A recycler holding ISCC PLUS with the EN 15343 module is closest to what the PPWR expects from mechanical recycling. It confirms physical traceability under EN 15343, together with process control and recyclate calculations based on physical inputs and outputs. The identification of recyclate percentage for subsequent links in the chain works as described above (via the SD accompanying each delivery.)
Therefore, the level of assurance provided by the ISCC PLUS system depends on whether the EN 15343 module is included. The difference can be summarized as follows:
The EN 15343 module under ISCC PLUS is voluntary. Not every recycler holds it. It is worth verifying this in the scope of the supplier’s certificate — especially now that the regulatory direction is becoming clearer.
Under the RecyClass Traceability system, the certificate is issued per site, valid for 12 months. Recycled content is confirmed per product (per Recycled Output), linked to a specific material name. But not every product from a RecyClass-certified company contains recyclate. Cross-verification of the certificate is essential:
If the material name on the invoice does not match the name on the certificate, you cannot rely on that certificate for that batch.
RecyClass uses a controlled blending model, based on physical traceability of materials. Recyclate is physically mixed with other materials in a known proportion. The ratio of input (recyclate) to output (finished product) is known, documented and verified through an on-site audit. The certification scheme is developed in line with EN 15343:2007 and the controlled blending model under ISO 22095:2020. If a RecyClass Traceability certificate confirms 30% recyclate for a given product — that 30% is physically present in that product.
As always, the devil is in the detail, bercause not every product sold by a RecyClass-certified company contains recyclate. The certificate, just as with ISCC PLUS, covers the facility and the process. That is why merely holding a RecyClass certificate from your supplier is not enough. Confirmation of recycled content for the next link in the chain is the result of cross-verification. Only this verification provides a basis for entering recycled content in the PPWR technical documentation. In practice, materials with and without recyclate should be marketed under different trade names within the certified company. This ensures that the next link in the chain can identify the correct material without ambiguity, even if recyclate feedstock is temporarily unavailable.A real-life scenario, worth anticipating in procedures.
The practical advantage of this model is its simplicity. A PPWR declaration can be supported by just two documents: a certificate identifying the material by trade name and a purchase invoice for that material. The certificate confirms the declared recycled content and the use of controlled blending. The invoice confirms that the certified material was actually purchased. Together, they provide sufficient evidence for the PPWR technical documentation.
Important point: the recycler supplying the raw material must hold a RecyClass Recycling Process certificate (valid for 12 months, with an annual monitoring audit) or equivalent EN 15343 certification recognised by RecyClass. SRC has its own EN 15343 Certification Programme (accredited from 19 December 2025), which meets this requirement.
The Global Recycled Standard (GRS) is an international, voluntary standard developed by Textile Exchange. It is used to verify the recycled content of end products. It covers the entire supply chain and requires compliance with stringent social (ILO) and environmental criteria. In addition, it imposes restrictions on the use of certain chemicals.
GRS requires a minimum of 20% recycled content for a product to be certified. Furthermore, at least 50% recycled content is required to use the GRS logo on the product. The Global Recycled Standard is based on the ‘physical segregation / identity preserved’ model. This represents the most stringent supply chain control model.
The certification comprises two key elements:
It is therefore a comprehensive standard. However, there are certain limitations to GRS in the context of the PPWR: GRS is not based on the EN 15343 standard! Consequently, its standing is weaker under the PPWR. This is particularly true when compared with systems such as RecyClass, which are based on EN 15343.
The following comparison presents three systems: ISCC PLUS, RecyClass, and GRS). It is intended to help answer the question: ISCC PLUS, RecyClass, or GRS? The overview shows the practical differences between these certification schemes and explains which documents are used to confirm recycled content in a product. It also highlights the role of the ISCC PLUS Sustainability Declaration, as well as the ISCC PLUS with the EN 15343 module, which ensures an appropriate level of material traceability.
| ISCC PLUS (mass balance) | ISCC PLUS with the EN 15343 module | RecyClass Traceability | GRS | |
| What confirms % recyclate? | ISCC PLUS Sustainability Declaration per transaction. | ISCC PLUS Sustainability Declaration + physical traceability at recycler. | Certificate with material name + FV. | TC per delivery + SC. |
| Chain of custody model | Mass balance (dominant). | Mass balance + EN 15343 at recycler. | Controlled blending (exclusively). | Physical segregation. |
| EN 15343 compliance | No. ISCC PLUS System Document — own reference standard. | Yes (voluntary module). Recycler confirms EN 15343:2007 compliance. | Yes. Scheme based directly on EN 15343:2007 + ISO 22095:2020. | No. GRS 4.0 (Textile Exchange) — own standard. |
| Recyclate physically in product? | Not necessarily. ISCC PLUS Sustainability Declaration = accounting attribution. | At recycler — yes. Subsequent stages — depends on model. | Yes. Controlled blending guarantees physical presence at every stage. | Yes. Physical segregation. |
| Balance — maintenance | Ongoing (month/quarter). To auditor once a year. | As above + physical inputs/outputs per EN 15343. | Once a year before audit. Physical inputs/outputs for 12 months. | Ongoing. TC per transaction. |
| Brand owner | Not certified (last entity). Receives ISCC PLUS Sustainability Declaration. | As above. | Two pathways: 1) Licence agreement with certified supplier (no audit). 2) Own RC audit and certificate. | Not certified. Receives TC. |
| Min. % for B2C logo | ≥20% certified material (ISCC 208 Logos and Claims v1.3). | ≥20% | ≥10% recycled content (RecyClass Use of Claims Guidance v1.1, April 2025). | ≥50% for GRS logo on-product. |
| Supplier certificates — what does the system accept? | ISCC only (PLUS, EU, DE). Others not accepted. | As above. | RecyClass only (SP, RP, RC). EN 15343 with accreditation — equivalence assessment planned 2027. Transitional: up to 34% from EN 15343 in year 1. Food-contact: 100% RecyClass. | GRS only (SC + TC). |
| Certificate validity and reference standard | 12 months, per site. ISCC PLUS System Document. | 12 months. ISCC PLUS + EN 15343:2007 (voluntary). | 12 months, annual Monitoring Audit. EN 15343:2007 + ISO 22095:2020. | 12 months (SC). GRS 4.0 + CCS (Textile Exchange). |
This is the heart of the problem facing every company drawing up an EU declaration of conformity under the PPWR. Two chain of custody models — mass balance and controlled blending — give fundamentally different answers to the question: “how much recyclate is in my product?”
Recyclate is physically mixed with conventional material in a known, documented and auditable proportion. If the input/output balance confirms 30% recyclate — that 30% is physically present in the product.
Traceability is based on physical material flows at every stage of the chain. The percentage on the certificate reflects physical reality.
Certified and non-certified material is physically mixed, and separation occurs solely at the bookkeeping level. An SD attributing “30% recycled content” does not mean 30% is physically present in the product — it means 30% has been “attributed” to that batch within the mass balance accounting.
This is how mass balance works, not a system error.
Both models have their applications. Mass balance enables the scaling of chemical recycling and the integration of recyclate into complex value chains (e.g. petrochemical crackers), where physical separation of streams is technically impossible. Controlled blending provides physical traceability that is easier to link to regulatory requirements — and closer to what market surveillance authorities may expect as “evidence” of recycled content.
Regulation (EU) 2025/40 (PPWR), Article 7, imposes a requirement for a minimum content of recycled material in plastic packaging components. It sets out specific targets:
However — and this is crucial — the PPWR does not yet specify its own methodology for calculating the recycled content. Article 7(8) empowers the Commission to adopt delegated acts. Deadline: 31 December 2026.
The good news is that the first point of reference has just appeared. On 30 June 2026, the European Commission adopted an implementing act under the Single-Use Plastics Directive (SUPD) — for the first time establishing clear rules for calculating recycled content in PET bottles, including for chemical recycling. The act introduces the “fuel-exempt mass balance” model. It applies at facility level and does not allow transfers of volumes between facilities. It also excludes material used for fuels and process losses. Recyclate from third countries may only be counted from 21 November 2027. It must also meet specific environmental requirements.
For mechanical recycling, the SUPD act does not introduce mass balance. The methodology remains unchanged and relies on the declaration of compliance from Regulation (EU) No 2022/1616 — i.e. physical traceability (controlled blending). This is the same model on which RecyClass schemes and EN 15343 are based.
The SUPD act covers PET beverage bottles only. The PPWR will cover all plastic packaging — and the implementing and delegated acts on recycled content methodology are separate documents, still in preparation.
PPWR Art. 7(8) empowers the Commission to adopt implementing acts on the methodology for calculating and verifying recycled content. Art. 7(9) empowers it to adopt delegated acts on sustainability criteria for plastic recycling technologies. Both deadlines: 31 December 2026. Neither provision determines outright whether mass balance is accepted for mechanical recycling — this will be resolved in the implementing and delegated acts. But the SUPD act sets the direction: mass balance introduced only for processes where physical traceability is not possible.
The Commission’s PPWR guidelines — C(2026) 2151 of 30 March and C(2026) 3702 of 5 June 2026 — do not address the methodology. They confirm that the Commission is working on a package of measures. Companies using mass balance for mechanical recycling of other polymers should monitor how the PPWR delegated acts address this question — the PET scenario may well set the benchmark.
The key question to ask right now is: which chain of custody model your supplier uses?
ISCC PLUS allows three models
Mass balance is the most commonly applied in practice. If a recycler or converter uses mass balance for mechanical recycling, and the PPWR delegated acts (expected December 2026) link mechanical recycling to physical traceability, the SD with accounting attribution may not be sufficient evidence. In that case, the documentation chain would need to be restructured or the chain of custody model changed.
By contrast, suppliers using controlled blending or physical segregation under ISCC PLUS are in a stronger position, as these models maintain physical traceability. This is therefore worth verifying now — both on the SD and on the supplier’s certificate — rather than after the delegated acts are published. The estimated time to change the model across the entire chain is 12–18 months.
Certificate with a percentage per product, cross-verifiable with the invoice. Scheme based directly on EN 15343 — the standard that Art. 7(8) PPWR is likely to recognise as the reference (EN 15343 is the only European standard for plastics recyclate traceability). Physical traceability at every stage. This is closest to what the PPWR expects — regardless of the content of future delegated acts.
The strictest model with physical separation. But GRS is not based on EN 15343. If the delegated acts designate EN 15343 as the reference standard, so the GRS TC may require additional validation.
Deadline for the PPWR delegated acts establishing the recycled content calculation methodology: 31 December 2026 (Art. 7(8) PPWR). The SUPD implementing act of 30 June 2026 provides the first reference point — mass balance accepted for chemical recycling (fuel-exempt method), but with restrictions (facility-level, no transfer between facilities, no fuel fraction). The industry expects the PPWR to follow the same path — which strengthens the position of controlled blending (RecyClass, EN 15343) for mechanical recycling.
A company choosing a certification scheme today must factor in this risk — because changing certification across the entire chain (recycler → compounder → converter → producer) takes 12–18 months and significant costs. A decision made today determines costs and flexibility for the next 3–5 years.
EN 15343 is the only European standard for plastics recyclate traceability — and is directly indicated as the basis for RecyClass schemes and the EN 15343 Certification Programme by Silk Road Certification. Controlled blending is the model that delivers physical traceability — closest to what market surveillance authorities may recognise as “evidence” under the PPWR. Mass balance has a strong position in chemical recycling (pyrolysis, gasification) — but for mechanical recycling, its acceptance as PPWR evidence is not assured.
More on warehouse stock and documentation required before 12 August 2026: The PPWR and stock levels.
The differences described above and the contrast between ISCC PLUS, RecyClass and GRS are not just theory. They are the result of our day-to-day experience in different roles.
These two roles require a clear separation — and that is how we treat them. A client we consult on ISCC PLUS / GRS is not our certification client under RecyClass. Impartiality is a condition of accreditation — but for us it is also a condition of the trust we build with every audit and every consultation.
If you want to understand what exactly the documentation from your supplier confirms — and whether it is sufficient for drawing up a credible EU declaration of conformity — get in touch.
This dual experience, with a clear separation of roles, allows us to state directly to companies: your certificate confirms the system. However, what you include in a PPWR compliance declaration must be based on concrete transactional documentation. In the case of ISCC PLUS, this will be the ISCC PLUS Sustainability Declaration (SD), while in RecyClass it will be cross-verification of documentation.
If you want to understand exactly what is confirmed by the documentation provided by your supplier — and whether it is sufficient to prepare a credible EU compliance declaration — feel free to get in touch. Not in order for us to sell you anything, but because it is worth being certain that you fully understand what you are signing.
If you are familiar with the REACH Regulation, you have probably come across the term ‘Only Representative’. This is an entity within the EU that assumes the registration obligations of a manufacturer based outside the EU. The mechanism is simple: a manufacturer from China, the US or Japan cannot register a substance with ECHA on its own, so it appoints a European intermediary to do so on its behalf. The PPWR introduces a similar mechanism for packaging. There is, however, a catch: under the PPWR, there are two types of Authorised Representatives. The first type of Authorised Representative operates under Article 17 of the PPWR. This is an entity appointed by a non-EU manufacturer, which may draw up a Declaration of Conformity (DoC) on the manufacturer’s behalf, maintain the technical documentation and act as the point of contact for market surveillance authorities. The second type of Authorised Representative under the PPWR has a completely different role. Article 45 of the PPWR concerns Extended Producer Responsibility (EPR) and imposes an obligation to appoint an Authorised Representative in each Member State where the packaging is first supplied directly to the end-user.
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