Choosing a recyclate certificate is not merely a matter of choosing a specific logo. It is a choice of the markets in which a given certification will be recognized. In some markets, certification translates directly into business benefits, while in others its value may be limited or even nonexistent.
A good example is Spain, where EN 15343 certification is already required. It must be issued by a certification body accredited in accordance with ISO 17065. In France, starting in January 2026, recycled material certification that takes into account the Annex Eco Modulation will be required. The United Kingdom, on the other hand, is moving toward mandatory ISCC PLUS certification, scheduled to take effect in April 2027. Germany and the Netherlands currently do not impose a formal requirement for recycled material certification. At the same time, ROP systems may offer incentives for recycled material whose origin and composition have been properly documented. In the U.S. and Asian markets, however, GRS plays a significant role.
The decision to choose a certification scheme is a business decision that impacts opportunities for expansion and growth.
21.08.2026
Changing the certification scheme is not a decision that can be finalized in a single quarter. If it is to cover the entire supply chain, it affects the recycler, the compounder, the converter, and the manufacturer. Each link in the chain must prepare for the new requirements. This involves, among other things, audits, changes to documentation, mass balance rules, and building a reliable data history. For a chain comprising four or five links, such a process can take 12–18 months. Therefore, when you choose a certification scheme, you are, in effect, making a strategic decision regarding the growth of your business.
Meeting today’s requirements is only one side of the coin. The other side is about maintaining access to markets in the future.
We already know that choosing the right certification scheme depends largely on the target market. The table below shows which certifications for recyclate are important in specific markets and what factors may influence their selection.
| Certificate | Spain (Ley 7/2022) | France (CITEO) | Great Britain (PPT) | Germany / The Netherlands | USA / Asia |
| RecyClass RP / Traceability (accredited CB) | ✅ EN 15343 + 17065. | ✅ Required by CITEO (Annex Eco Modulation). | 🔎 Probably. | ⚠️ No formal requirement. | 🔎 Less recognizable. |
| RecyClass RP / Traceability (recognised CB) | ⚠️ Not directly. | ⚠️ Requires verification with CITEO. | 🔎 Probably. | ⚠️ No formal requirement. | 🔎 Less recognizable. |
| EN 15343 (np. EN 15343 Certification Program by Silk Road Certification) | ✅ Directly complies with Ley 7/2022. | ⚠️ EN 15343 recognised as a recycler certificate within RecyClass. | 🔎 Probably. | ⚠️ No formal requirement. | 🔎 Less recognizable. |
| ISCC PLUS (mass balance) | ❌ No (no EN 15343, mass balance). | ❌ Brak Annexu Eco Modulation. SD nie zawiera proximity/yield. | ✅ Indicated (from Apr 2027 for chem. rec.) | ✅ Widely used. ⚠️ No formal requirement. | ✅ Recognizable. |
| GRS | ❌ No (no EN 15343). | ❌ Does not meet CITEO requirements | ⚠️ Lack of a clear position. | ⚠️ No formal requirement. | ✅ Dominant (textiles, retail). |
| ISCC PLUS + Add-on EN 15343 | ❌ Explicitly excluded by the ISCC (CBs are not accredited under EN 15343). | ⚠️ EN 15343 recognised as a recycler certificate within RecyClass. | ⚠️ To be verified. | ✅ Possible. | 🔎 Less recognizable. |
| EmpCo 2024/825 (since IX 2026) | Applies (Prohibition on making general environmental claims without certification). | Applies (Prohibition on making general environmental claims without certification). | Not applicable (outside the EU). | Applies (Prohibition on making general environmental claims without certification). | Not applicable (outside the EU). |
The table may look simple, but there are specific requirements behind it. Every “yes,” “no,” or “unsure” corresponds to a specific regulation, deadline, or financial consequence. So let’s take a closer look at what exactly each answer means.
RecyClass currently works with two types of certification bodies. The first are “accredited” bodies – that is, those accredited in accordance with ISO/IEC 17065 by a national accreditation body that is a signatory to the EA/MLA. The second are “recognized” bodies – that is, those recognized by RecyClass that are still in the process of accreditation.
Until recently, both types of bodies were authorized to issue RecyClass certificates. As of July 2026, these rules have changed.
According to the document “RecyClass Certifications 2026: Questions & Answers” (pp. 6–7), new requirements regarding the authorization of certification bodies will take effect as of the dates indicated below.
This means that after the deadline, RP and RC certificates may only be issued by: an accredited CB (ISO/IEC 17065) or a recognized CB that meets the conditions of the transition period. Therefore, before commissioning a RecyClass RP or RC audit in the second half of 2026, check the following three things:
Remember that a certificate issued by an unauthorized body is invalid; therefore, do not accept it as proof of the supplier’s compliance.
For the Spanish plastic tax (Ley 7/2022) this situation has two implications. Ley 7/2022 requires a certificate issued by a body accredited under ISO 17065. If the certificate is issued independently by a “recognized” certification body (even if it was issued before the deadline), it will not meet the requirements. The RecyClass list of certification bodies, broken down into “accredited” and “recognized,” is publicly available on the RecyClass website
| Silk Road Certification is an accredited certification body for RecyClass Recycling Process and RecyClass Recycled Plastics Traceability (ISO 17065 accreditation since 19.12.2025). The accreditation status of SRC for the individual RecyClass schemes (RP, RC) can be verified on the RecyClass website. Silk Road Certification also operates its proprietary EN 15343 Certification Programme, which is likewise covered by ISO 17065 accreditation.: |
Under France’s Extended Producer Responsibility (EPR) system, the producer placing packaging on the market pays a fee (éco-contribution) to a producer responsibility organisation — a PRO (Producer Responsibility Organisation, in French: éco-organisme). For consumer packaging, the main PRO is CITEO The second is Léko. For professional (B2B) packaging a future PRO is expected to apply the EPR bonus from January 2027.
Arrêté du 5 septembre 2025 (published in the Official Journal of the French Republic, effective January 1, 2026) amends the specifications (“cahier des charges”) for individual PROs. It also introduces harmonized eco-modulation criteria for the use of post-consumer recycled content in plastic packaging. Under this decree, CITEO requires companies benefiting from the ROP bonus to obtain mandatory certification for both the recycler and the converter in the supply chain. RecyClass is designated as the certification scheme that provides the appropriate methodology, evidence, and credibility.
CITEO bonuses for recycled material:
The key requirement is the proximity criterion (proximité). Article 8 of the decree requires that recycled material be collected, sorted, processed, and incorporated within a maximum distance of 1,500 km from the center of France, within the EU27+3, which is why RecyClass has developed a dedicated tool for this purpose. Annex Eco Modulation. is an optional appendix to the RP and RC audit reports. Among other things, it documents the ROP destination country, the origin of the recycled material, the percentage of recycled material, tonnage, proximity criteria, and the recycling process yield. This appendix is required by CITEO to receive the bonus.
The Sustainability Declaration contains the recyclate percentage and the chain of custody model but no data on geographic proximity or process yield. A company exporting to the French market with an ISCC PLUS certificate is unable to document compliance with CITEO criteria in the required format.
As a result, the ISCC PLUS certificate alone does not provide the exporter with all the information needed to demonstrate compliance with the CITEO criteria. Therefore, a company exporting recycled material to the French market may need additional documentation. This is true even if the company holds a valid ISCC PLUS certificate. Starting January 1, 2026, the French system will impose specific conditions for receiving a premium for the use of recycled materials.
This is a thread companies often overloo. At the same time this is the one that determines whether a supply chain can be certified at all.
RecyClass Recycled Plastics Traceability has specific rules regarding the eligibility of input materials. This scheme currently recognizes only RecyClass certificates (SP, RP, RC) as supplier certificates. Temporary exception: During the first year of certification, up to 34% of inputs may be certified under EN 15343. However, for food-contact materials, 100% must be RecyClass-certified from day one.
As far as ISCC PLUS is concerned, the supply chain is based on certificates issued under the ISCC system. This means that a certificate from another scheme is not automatically recognized by ISCC PLUS.
GRS
The GRS system bases traceability on its own certification system and requirements. All companies in the supply chain must be GRS-certified for the material to continue to be presented as GRS-certified.
| Practical note: A certificate recognized in one system may not be accepted in another; therefore, if your supplier holds an ISCC PLUS certificate and you wish to obtain RecyClass Traceability certification, their certificate alone will not suffice. The supplier will need to obtain the appropriate RecyClass certification so that their material can be used in a certified supply chain. This also works the other way around. A RecyClass certificate does not automatically replace the certification required by ISCC PLUS. |
In March 2026, ISCC formally launched the ISCC PLUS Add-on EN 15343 (v1.1). This is a separate document that extends the scope of ISCC PLUS certification to include the requirements of the EN 15343 standard. This add-on applies exclusively to mechanical recycling and requires either a physical segregation or controlled blending model. The updated Sustainability Declaration (SD v4.0) now includes the information required by EN 15343.
This brings ISCC PLUS with the EN 15343 Add-on closer to the RecyClass model (physical traceability at recycler level). But there is one important caveat: ISCC explicitly states that the EN 15343 Add-on cannot be used in Spain to demonstrate compliance with Ley 7/2022. This is because Spanish law requires the certification body to be accredited under EN 15343, and ISCC bodies do not hold that accreditation. In countries where alignment with EN 15343 is sufficient without formal accreditation the add-on may be used.
Holding a recyclate certificate does not automatically grant the right to display the logo on a product. Each system sets its own requirements regarding communication and the use of labels. These requirements vary, among other things, in terms of the minimum percentage of recycled content required to use the logo or make a declaration to consumers.
For RecyClass, the product must contain at least 10% recycled content. ISCC PLUS requires at least 20% certified material. GRS sets a minimum threshold of 50% recycled content to use the GRS logo on a product. However, the GRS certificate itself can be obtained with as little as 20% content of material that meets the standard’s requirements. Therefore, before using the logo, it is important to check not only the validity of the recyclate certificate. You must also verify the required level of recycled content and the rules for using a specific label to avoid misleading the customer or consumer.
Starting September 27, 2026, another layer of regulation will be introduced. This is Directive (EU) 2024/825 (known as ECGT or EmpCo). The directive strengthens the consumer’s position, including by restricting the use of general environmental claims without adequate justification. This applies to terms such as “eco,” “green,” “environmentally friendly,” and other similar terms.
At the same time, Directive 2024/825 restricts the display of ecolabels without an appropriate basis. This refers to labels not based on a certification system or another required verification mechanism. For this reason, the method of verifying the information provided to the consumer also becomes significant.
A company stating “contains recycled material” on its packaging must have a basis for such a claim. Simply having recycled material will not always be sufficient. The certification scheme used (such as RecyClass, ISCC PLUS, or GRS) may be a key factor.
In the event of a violation, penalties may amount to up to 10% of the business’s annual turnover. It is worth distinguishing EmpCo from the Green Claims Directive. The latter envisaged more far-reaching requirements for the verification of environmental claims; however, work on its publication has been suspended for the time being. The European Commission has withdrawn its proposal for the Green Claims Directive. As a result, EmpCo remains the key instrument for combating greenwashing in the EU.
This is where a key connection between EmpCo and the RecyClass accreditation rules comes into play. EmpCo does not explicitly require ISO 17065 accreditation for every certification system. However, it does require that the system be sufficiently credible. Sustainability labeling must be based on a certification system. The system should provide for independent third-party verification. It should also ensure objective monitoring of compliance. Meanwhile, RecyClass has established its own requirements for certification bodies.
For RP, the accreditation requirement takes effect on June 12, 2026. For RC, the deadline is July 23, 2026. After these dates, the certificate must be issued by a body with the appropriate authorization. A certificate issued by a body that does not meet the requirements is not valid in the RecyClass system. This affects the ability to use such a certificate in environmental communications with consumers. A claim based on an invalid certificate may be deemed to lack proper justification. Additionally, displaying a label based on an invalid certification may lead to further consequences.
EmpCo does not explicitly exclude RecyClass-recognized entities. Most important is the validity of the recyclate certificate under a specific scheme. If RecyClass does not recognize the certificate, a problem arises at the system level itself. This is followed by a second layer of risk related to communication with consumers. A company using a logo based on an invalid recyclate certificate may therefore face a twofold risk. The first concerns the compliance of the certification with RecyClass requirements. The second concerns the compliance of its communications with EmpCo.
RecyClass and EN 15343 cover plastics only. ISCC PLUS has the broadest scope(plastics, chemicals, fuels, textiles, rubber, glass and over 200 items on the materials list). GRS is for plastics, textiles, glass, leather, metal. If your chain includes anything other than plastics, RecyClass will not suffice.
CEFLEX (raport VI 2026) estimates that meeting the PPWR targets will require approx. 2.5 million tonnes of recyclate from flexible packaging (rPE, rPP) by 2030 and 5.9 million tonnes by 2035. That is 440,000 tonnes of additional recyclate per year. ELV Regulation (agreement XII 2025) introduces mandatory 15% recyclate in plastics in new vehicles (6 years from entry into force) and 25% (10 years). Automotive is the next big market.
As of November 21, 2026, the export of plastic waste from the EU to non-OECD countries will be completely banned. Starting in May 2027, exports to non-OECD countries will be permitted only with the approval of the European Commission.
The EU has not adopted harmonised end-of-waste criteria for plastics. Plastic regranulate may be waste in one Member State and a product in another. A recyclate certificate does not resolve that status. A company needs three layers at once: a certificate + end-of-waste status (national law) + WSR (Waste Shippment Regulation) compliance.
This is of considerable importance when choosing a certification. A recycler processing plastic waste from outside the OECD will lose access to European raw materials after November 2026… even if it holds a valid ISCC PLUS, RecyClass, or GRS certificate. Recyclate certification confirms the traceability system but does not guarantee the legality of the waste source. For PVC, this problem is twofold, because PVC waste is classified as Y48 under the Basel Convention, which means that even transport within the EU requires the full PIC procedure (notification + consent from the authorities of both countries). This entails additional costs and time.
The SUPD (Single-Use Plastics Directive) Implementing Act of June 30, 2026, introduces an additional restriction: until November 21, 2027, only recycled material sorted and processed within the EU/EEA will count toward SUPD compliance. After that date, recycled material from OECD countries will be accepted, provided that the WSR does not prohibit it. Recycled material from non-OECD countries will be acceptable only if it meets equivalent environmental and health protection standards. This SUPD restriction is separate from the WSR (which concerns the transport of waste) as well as from RecyClass Module A1 (which concerns food contact). A company exporting PET bottles to the EU market must satisfy all three layers at once.
In Spain, EN 15343 certification and ISO 17065 accreditation are required. France requires certification for recyclate under the Eco-Modulation Annex and proximity criteria starting in January 2026. The UK is moving toward ISCC PLUS. Germany and the Netherlands have no formal requirements, but eco-modulation of EPR fees rewards documented recycled content. GRS dominates in the U.S. and Asia. The automotive sector is introducing mandatory 15%/25% targets.
Delegated acts under the PPWR regarding recycled content methodologies are to be adopted by the end of 2026. The SUPD implementing act of June 30, 2026, provides the first point of reference (mass balance accepted for chemical recycling in PET bottles), but not for mechanical recycling.
One more thing: recycled content and recyclability are two different PPWR requirements. They are covered by Article 7 and Article 6, respectively. Two different certificates, two different audits. Possessing one does not exempt you from the other.
Selecting a recyclate certification scheme for recycled materials tailored to the target market requires a broader perspective. You need to take into account certification requirements, national regulations, and the requirements of PPWR, SUPD, and even EmpCo. It’s equally important to verify the status of the certification body. It’s also worth assessing the readiness of the entire supply chain. This combination of several areas requires specialized knowledge. Silk Road Certification helps companies navigate this process.
Want to find out which recycled material certification is right for your target market? Do this before scheduling an audit. This will help you avoid costs associated with choosing the wrong scheme or certification body.
How can we help?
Don’t just choose a recyclate certification for today. Choose one with the market you want to sell in in mind.
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