Converter, brand owner, manufacturer – who certifies recyclate and who signs the PPWR declaration?

In today’s packaging market, a single facility often operates simultaneously as a converter, contract manufacturer, and sometimes also as a brand owner or trader. However, this business flexibility also means operating under several different regulatory and certification frameworks at the same time. Both the PPWR and certification schemes (e.g. RecyClass) now require a precise definition of who is responsible for mass balance, recyclate traceability, and who signs the PPWR declaration of conformity within a given cooperation model. Even a minor change in the order structure or brand ownership can completely alter the scope of responsibilities of individual entities within the supply chain.

That is why we have prepared the following practical guide on the dual role in the plastics value chain.

The problem: one plant, two roles, two legal regimes

A Polish plastics converter carries out typical, everyday operations: in the morning, the production line starts up for an order from a major FMCG brand owner; in the afternoon, it switches to producing packaging sold under its own brand. The same regrind, the same line, the same day.

Yet from a regulatory and certification standpoint, these are two entirely different situations. Handling them incorrectly may mean that neither the recyclate traceability certificate nor the PPWR declaration of conformity will be issued correctly – or at all.

The RecyClass perspective: who is the certification applicant?

Using RecyClass Recycled Plastics Traceability as an example.

The RecyClass Recycled Plastics Traceability audit scheme (based on EN 15343:2007 and the controlled blending model per ISO 22095:2020) distinguishes three main certification models:

Model 1: Converter = manufacturer (production under own brand)

The converter physically controls the raw material, the blending process, and the final product. It places the product on the market under its own brand or unbranded (B2B). In this case, the converter applies for certification, undergoes the audit, and receives the RecyClass Traceability certificate. The mass balance, input and output data relate to its own production.

Model 2: Brand Owner Certification (contract manufacturing)

The brand owner commissions production to a converter and places the product on the market under its own brand, but does not physically control the production process. In this model:

• The certification applicant is the converter – it undergoes the audit and obtains the certificate under the Brand Owner Certification scope.
• The audit takes place at the converter – because that is where the physical blending of recyclate with virgin material takes place (controlled blending).
• The brand owner (FMCG company) signs a Licence Agreement with the converter – and on that basis references the certificate, placing RecyClass certification marks on products entering the market under its own brand.

Model 3: Trader (material trading between divisions or entities)

The role of a trader may also appear in the recyclate supply chain. This applies to situations where material (e.g. recyclate or regrind) sourced by one division of a company is transferred to another division of the same organisation or to another entity within the capital group. The trader does not physically process the material but acts as an intermediary – purchasing from a certified recyclate supplier and reselling to a converter or another entity in the chain. In this model, the trader must ensure full traceability and continuity of documentation: recyclate supplier certificates, invoices, delivery documents, and the mass balance must be consistent at every stage so that the converter (or brand owner) can include this material in its traceability balance.

The trader as both trader and brand owner simultaneously

A special situation arises when a trader stands between the converter and the FMCG company. In such a chain, the converter physically produces the packaging but has no direct relationship with the FMCG company – between them operates the trader, who commissions production to the converter and then delivers finished products to the FMCG company. In this model, the trader combines two roles:

• Trader – acts as an intermediary in the supply chain for materials and finished products, ensuring documentation continuity.
• Brand owner applying for the certificate – it is the trader who obtains the certificate under the Brand Owner Certification scope. The audit is conducted at the converter (where production physically takes place), but the certificate belongs to the trader. The FMCG company signs a Licence Agreement with the trader and on that basis references the certificate when placing products on the market.

In this scenario, the certification chain is as follows:

1. Recyclate supplier (Recycling Process certificate).
2. Converter (audited facility)
3. Trader (holder of the Brand Owner certificate)
4. FMCG company (Licence Agreement)

Mass balance and recyclate traceability must be ensured at every stage of this chain.

The Brand Owner option in both RecyClass schemes

It is worth emphasising that the Brand Owner Certification option is available in both the RecyClass Recycled Plastics Traceability scheme and the RecyClass Recycling Process scheme. In both cases, when the brand owner outsources the process to another entity, it is the entity carrying out the process (respectively: the converter or the recycler) that obtains the certificate under the Brand Owner scope. The FMCG company (brand owner) signs a Licence Agreement with them and on that basis references the certificate when placing products on the market under its own brand.

The dual role: when the converter produces both for itself and on commission

In practice on the Polish plastics converter market, the dual-role situation is the rule, not the exception. Within a single production shift, a company may:

• fulfil an order for brand owner A (contract manufacturing under brand A),
• fulfil an order for brand owner B (different formulation, different brand),
• produce a batch of packaging under its own brand or unbranded (B2B sales).

Each of these orders may have a different recyclate proportion, a different secondary raw material supply chain, and – crucially – a different certification applicant. The controlled blending model on which RecyClass is based makes this possible, but sets a clear requirement: physical inputs and outputs of recyclate must be identified, monitored, and documented on a per-order basis.
This means the converter must maintain a mass balance not only at the facility level but at the order level – knowing how much certified recyclate was used in the batch for brand owner A versus the batch under its own brand. Without this, the percentage of recycled content cannot be attributed to a specific product.

Who prepares the PPWR declaration of conformity?

The converter’s dual role also has consequences under PPWR (EU) 2025/40, which from 12 August 2026 requires every packaging placed on the EU market to have a declaration of conformity (DoC) in accordance with Article 39 of the regulation.

PPWR defines the manufacturer (Art. 3) as the entity that manufactures packaging or has it manufactured under its own name or trademark. It is the manufacturer in this sense who prepares the DoC.

Key conclusion

The manufacturer’s role is not fixed – it changes with each production batch depending on whose brand the packaging will enter the market under. A converter that fails to distinguish this risks: incorrect certificate attribution (recyclate declaration made by the wrong entity), missing PPWR declaration of conformity (because neither the converter nor the brand owner prepared the declaration correctly), inability of the brand owner to demonstrate recycled content (because the mass balance does not separate orders).

Caps as a packaging component

Who is responsible for the DoC and who should correctly apply for certification?

In the plastics packaging value chain, it is often overlooked that the final packaging consists of several components – the container, cap/closure, label – which may come from different manufacturers and contain different types of recyclate. The cap is the best example: the bottle may be PET while the cap is HDPE. Each of these materials comes from a different recycling stream, a different supplier, with a different certificate.

PPWR declaration of conformity for packaging with a cap

PPWR (UE) 2025/40treats packaging as a whole, including its integral components such as caps and closures. The PPWR Declaration of Conformity (DoC) is issued by the manufacturer of the final packaging — the entity that manufactures the packaging, or has it manufactured, and places it on the market under its own name or trademark. The manufacturer of the cap as a component does not issue a separate DoC. However, it remains responsible for providing the final packaging manufacturer with the information necessary to prepare the declaration. This includes data on recycled content, compliance with substance restrictions (REACH, PFAS, heavy metals), and the material composition of the cap.

In practice, this means that the brand owner or converter placing the packaging on the market must obtain full material documentation from the cap supplier. If not, DoC for the final packaging will be incomplete.

Mass balance including the cap

Certification such as RecyClass Recycled Plastics Traceability applies to the final product. If the packaging consists of components made from different polymers (e.g. PET bottle + HDPE cap), the mass balance must account for both recyclate streams separately. HDPE recyclate in the cap and PET recyclate in the bottle are two separate inputs to the traceability balance, each requiring its own documentation – including a RecyClass Recycling Process certificate (or equivalent) from the recyclate supplier.

When the cap comes from an external supplier, two scenarios arise:

• The cap supplier holds a certificate – recyclate in the cap can be included in the mass balance of the final packaging. The percentage of recycled content is calculated from the combined mass of both components (bottle + cap), but the source and traceability of the recyclate are documented separately for each material stream.
• The cap supplier does not hold a certificate – recyclate content in the cap cannot be included in the final packaging certificate, even if the supplier declares the use of recyclate. The cap is then treated as a component made from virgin material, which lowers the overall % of recycled content in the final product.

Practical conclusion

The selection of packaging component suppliers (including caps) should take into account their RecyClass certification status. The absence of a certificate such as RecyClass Recycled Plastics Traceability from the cap supplier means that the actual % of recycled content in the final packaging will be lower than assumed – which may have consequences both for the RecyClass certificate and for meeting future minimum recycled content requirements under PPWR.

What to do? Practical steps

1. Map the manufacturer role to the production order – for each product/batch, determine who is the manufacturer under PPWR and who is the Traceability certification applicant.
2. Separate the mass balance by orders – maintain records of recyclate inputs/outputs in a way that allows attributing recycled content to a specific batch and order, not just to the facility.
3.  If decided to obtain a certificate under the Brand Owner scope sign Licence Agreements with FMCG companies – if you produce on commission for a brand owner, you as the converter obtain the certificate under the Brand Owner Certification scope, and the FMCG company signs a Licence Agreement with you. A formal link between the parties is required by the RecyClass scheme.
4. Verify the recyclate supply chain – the recyclate supplier must hold a certificate, i.e. RecyClass Recycling Process. Without it, the recyclate will not be counted in the balance.
5. Clarify who prepares the DoC per batch – for own-brand production – the converter. For contract manufacturing – the brand owner. This is not a one-time decision but an ongoing process resulting from the nature of production.

How can Silk Road Certification help?

Silk Road Certification jest akredytowaną jednostką certyfikującą RecyClass. Wspieramy zarówno konwerterów, jak i Brand Ownerów w całym procesie:

• RecyClass Certification:
  • Sorting Process – coming son!
  • Recycled Plastics Traceability – including the Brand Owner Certification model with Licence Agreement.
  • Recycling Process – for recyclate suppliers (Supplier’s Certificate required).
  • Recyclability – packaging recyclability assessment (classes A/B/C), crucial for EPR fees under PPWR.
• Support in preparing the PPWR Declaration of Conformity, including:
  • verification of the correct roles within the certification chain,
  • compliance with related requirements (REACH, PFAS, heavy metals).