Certifiying Recycled Contet: How to Provide Reliable Proof

What does it mean to have a recycled content percentage certified?

The statement “contains 30 percent recycled plastic” may seem clear at first glance. However, a percentage stated on a data sheet is not sufficient for reliable verification. 

As part of the certification process, an assessment is conducted to determine 

• the origin of the recycled material, 
• whether it is pre-consumer or post-consumer material, 
• how material quantities are recorded and calculated, 
• how material flows are tracked through purchasing, storage, and production, 
• whether certified and non-certified materials are processed separately or together, and 
• whether the resulting calculations and conclusions are accurate and verifiable. 

Certification, therefore, is not limited to verifying a single percentage. The focus is on the processes, data, and control mechanisms on which a company bases its recycled content reporting. 

Depending on the certification system and chain-of-custody model, the claim that can ultimately be made about the product may also differ. It should therefore be clear before the audit what evidence is required and how the company intends to communicate the claim to customers and other stakeholders. 

Five Steps to Certified Recycled Content 

Step 1: Define the product and the desired claim

The first step is not to select a standard, but to ask: What exactly needs to be verified? 

Possible claims include: 

• The plastic product contains a specific percentage of post-consumer recycled material. 
• The recycled content of a product was calculated based on traceable material flows. 
• A specific amount of circular raw material has been allocated to a given quantity of product using a mass balance method. 
• The circular raw materials used come from a certified supply chain. 
• The plastic packaging has been assessed for its recyclability. 

Companies should therefore first determine which product, location, and time period the verification applies to. Equally important is whether the verification is needed to meet customer requirements, support sustainability reporting, substantiate product claims, or demonstrate regulatory compliance. 

Step 2: Analyze Materials and the Supply Chain 

The second step involves examining how the recycled material enters the company and how it is incorporated into the product. 

• The following factors are relevant: 
• the type of plastic, 
• the recycling process used, 
• the origin of the input waste material (the raw material at the beginning of the supply chain), 
• the number of suppliers and locations involved, 
• the blending of recycled material with virgin material or other raw materials, 
• the traceability of material quantities, and 
• the available supplier and material documentation.

For mechanically recycled plastics, the path from waste through the recycled material to the end product is often relatively easy to trace. In chemical recycling processes, however, circular and fossil-based raw materials may be processed together in complex production facilities. In such cases, a mass balance approach may be used. 

The more complex the supply chain, the more important it is to have consistent data, unambiguous material designations, and clearly defined responsibilities. 

Step 3: Select the Appropriate Certification Standard 

Which certification approach is appropriate depends on the specific use case. Key factors include the product, the recycling process, the structure of the supply chain, and the message to be communicated to customers or other stakeholders. 

Both RecyClass and ISCC PLUS support the traceability of recycled plastics, but they take different approaches.  

RecyClass: Focus on Plastic Products and Specific Recycled Content  

The RecyClass Recycled Plastics Traceability Certification is specifically aimed at companies in the plastics value chain. It verifies the traceability of recycled materials and confirms the calculated percentage of recycled plastic in products. The system uses a controlled-blending approach and is based, among other things, on EN 15343 and ISO 22095. 

RecyClass is particularly suitable when 

• a specific recycled content in a plastic product needs to be verified, 
• mechanically recycled materials are used, 
• a distinction needs to be made between pre-consumer and post-consumer fractions, 
• there is a clearly defined plastics value chain, or 
• customers require product-specific confirmation of recycled content.  

The certification is intended for chemical companies, plastics processors, manufacturers, and distributors. 

ISCC PLUS: Focus on Complex and Circular Supply Chains 

ISCC PLUS is a voluntary certification system for the circular economy and bioeconomy. It covers recycled and renewable raw materials and offers various chain-of-custody approaches, including physical segregation, controlled mixing, and mass balance.

ISCC PLUS is particularly suitable when 

• an international or multi-stage supply chain is to be certified, 
• chemically or mechanically recycled raw materials are used, 
• circular and fossil-based raw materials are processed together, 
• different sustainable or alternative raw materials are incorporated into the supply chain, or 
• a mass balance allocation is required. 

The ISCC PLUS base system sets requirements for traceability and the handling of certified material flows along the supply chain. If, in addition, the recycled content of a plastic product is to be verified in accordance with the requirements of EN 15343, ISCC PLUS can be supplemented with the corresponding EN 15343 add-on. This add-on contains additional requirements for the identification, traceability, and verification of recycled plastic materials and is intended for mechanically recycled plastics subject to physical segregation. 

For companies that are already certified under ISCC PLUS, the add-on can be a way to expand existing certification structures to include specific verification of recycled content. The additional effort involved depends on the scope of application, the material flows, and the processes already in place. 

While ISCC PLUS is designed to span multiple industries and raw materials, RecyClass focuses more specifically on plastic products and plastics value chains. Which certification approach is appropriate therefore depends primarily on the desired verification, the recycling process used, and the structure of the supply chain. 

Step 4: Prepare Documentation and Quantity Tracking 

Reliable volume tracking is at the heart of certification. The company must be able to demonstrate the quantities of recycled materials purchased, processed, stored, and sold. 

Typically, the following documents are required: 

• purchasing and sales documents, 
• delivery notes and invoices, 
• material and product specifications, 
• supplier documentation, 
• information on the origin and type of waste material, 
• production records, 
• formulas or bills of materials, 
• inventory levels and inventory movements, 
• recycled content calculations, 
• quantity or mass balances, 
• procedural instructions, and 
• policies regarding responsibilities and internal controls. 

The data in the various systems must be consistent. For example, if the product specification states a recycled content of 40 percent, it must be possible to plausibly trace this percentage through purchasing, production, and inventory data. 

Discrepancies most commonly arise from inconsistent material designations, missing supplier documentation, differing reference periods, or undocumented material losses. A preparatory internal audit can help identify such gaps before the certification audit. 

Step 5: Conduct the Audit and Use Claims Correctly 

During the audit, the certification body verifies whether the company has implemented the requirements of the selected system.

This typically includes: 

• reviewing documented processes, 
• interviewing responsible employees, 
• conducting random checks of purchasing, production, and sales records, 
• verifying quantity calculations, 
• verifying the plausibility of material flows, 
• reviewing supplier documentation, and 
• evaluating the product and sustainability claims used. 

If discrepancies are identified, the company must implement appropriate corrective actions. Upon successful completion of the process, the certificate is issued for the specified scope. 

Claims and logos must comply with the requirements of the respective system. In mass balance approaches, it must remain clear that certified raw material quantities have been allocated within the balance and are not necessarily physically present in their entirety in the individual product. 

Physical Recycled Content or Mass Balance? 

This distinction is particularly important when selecting the certification approach and for subsequent communication. 

With physical segregation, certified materials are stored and processed separately from non-certified materials. With controlled mixing, defined quantities of materials are blended, and the proportion can be calculated based on the actual inputs. 

In a mass balance system, certified and non-certified raw materials can be processed together. The certified quantities used are recorded in the accounts and allocated to specific output products. Overall, no more certified material may be reported than was introduced into the system. 

Mass balance is relevant for facilities where complete physical separation is technically or economically impractical. It allows for a gradual increase in the use of circular raw materials. However, any resulting claims must be formulated precisely. 

The statement “The product contains 30 percent recycled material” is not automatically equivalent to the statement “30 percent circular raw materials have been allocated to the product based on the mass balance.” 

Recycled Content Is Not the Same as Recyclability 

A common misconception is to equate recycled content with recyclability. 

Recycled content describes what percentage of a product is made from recycled materials and how that percentage can be calculated and traced. 

Recyclability, on the other hand, describes whether packaging can be collected, sorted, and recycled using a suitable process after use. Factors such as material combinations, labels, adhesives, inks, closures, and the existing waste management infrastructure all play a role here.

A high recycled content therefore does not automatically make packaging recyclable. Conversely, packaging that is highly recyclable may initially be made entirely from virgin material. 

RecyClass offers various certifications to address these issues. The Recycled Plastics Traceability Certification focuses on the use and traceability of recycled plastics. The Recyclability Certification, on the other hand, assesses the compatibility of plastic packaging with collection, sorting, and recycling, as well as the potential for reuse of the resulting material. 

RecyClass thus offers an additional approach for companies that wish to substantiate not only recycled content but also the recyclability of their packaging. 

PPWR: Why Reliable Proof of Recycled Content Is Becoming More Important 

The EU Packaging and Packaging Waste Regulation (PPWR) establishes a uniform framework for packaging and packaging waste. It includes requirements covering the entire life cycle of packaging, including provisions on sustainability, labeling, recyclability, and the use of post-consumer recycled content in plastic packaging. The EU Packaging Regulation (PPWR) entered into force on February 11, 2025, and has been in effect since August 12, 2026. 

The requirements that apply to a specific company depend, among other things, on the type of packaging, the material, the intended use, and any applicable exemptions.

Checklist: Are You Prepared for the Certification Audit? 

Before engaging a certification body, companies should be able to answer the following questions: 

• For which products or product groups should the recycled content be verified? 
• What specific claim should be used in communications with customers or on the product? 
• Is the material pre-consumer or post-consumer recycled material? 
• Is mechanically or chemically recycled material being used? 
• Is the material physically segregated, controlled-mixed, or allocated via a mass balance? 
• Are all relevant supplier and material records available? 
• Can purchasing, production, inventory, and sales volumes be reconciled with one another? 
• Is the calculation method documented in writing? 
• Are responsibilities and internal controls defined? 
• Do the planned claims comply with the requirements of the certification system?