The Eco-modulation Annex applies to both Recycling Process and Recycled Plastics Traceability. For CITEO, the RecyClass guidance identifies certification of both the recycler and the converter. Eligibility for a bonus depends on the relevant EPR organisation’s conditions, rather than certification alone.
CITEO Eco-modulation Annex in RecyClass Recycling Process and Recycled Plastics Traceability
The Eco-modulation Annex applies to both RecyClass Recycling Process Certification (RP) and Recycled Plastics Traceability Certification (RC). In the guidance, RC means Recycled Plastics Traceability, not Recyclability. This additional scope is used to organise and verify the data required by extended producer responsibility (EPR) fee modulation schemes, particularly the French CITEO system.
In practice, recycling process certification may provide one of the pieces of evidence used when applying for a bonus or fee reduction for incorporating recycled plastics. The final award nevertheless depends on the current rules of the relevant EPR organisation.
Eco-modulation in Recycling Process and Recycled Plastics Traceability
Correct allocation
The Eco-modulation Annex is optional and can be prepared during an RP or RC audit. It enables information on material origin and traceability to pass to subsequent supply chain participants. The RecyClass guidance states that, for CITEO, both the recycler and the converter should be certified; the requirements of the particular scheme must be checked before applying for a bonus.
An annex is not a certification module
Using Recycling Process as an example, a distinction can be made between general requirements, modules and additional annexes:
- General requirements — the Recycling Process audit scheme, which provides the basis for certification of the recycling process.
- Modules A, B, C and D — additional requirements covering, among other matters, food contact, cosmetic and household applications, corporate social responsibility and PVC.
- Additional annexes — documents serving particular reporting or market needs, such as eco-modulation or other mechanisms requiring additional verification of data.
The Eco-modulation Annex does not replace the general requirements of the relevant RP or RC scheme. It documents additional information required by a particular EPR system; it does not create a standalone certificate or automatic entitlement to a bonus.
Why do recyclers and converters need this annex?
Extended producer responsibility systems may vary fees according to compliance with specific environmental criteria. CITEO includes mechanisms relating to the use of recycled material and requires reliable evidence of the origin and content of recycled material.
Recycling Process Certification independently verifies the origin of Input Plastic Waste, process traceability and Recycled Output. The additional eco-modulation scope can organise the information required to use certification as evidence in a specific EPR system.
Recycler
The process and Recycled Output are audited against the Recycling Process requirements.
Converter and the downstream RC chain
The converter retains information about earlier sorting and recycling stages and documents the incorporation of recycled material into the product. The annex may also be useful to intermediaries when the end market is not yet known.
Party placing the product on the market
According to the guidance, the bonus beneficiary is the party placing the product on the market and paying the EPR fee. The recycler or converter supplies evidence but does not automatically receive a bonus merely by being certified.
Certification body
The certificate and additional documentation should reflect the actual audit scope, verified data and current certification scope.
EPR system
The final award of a bonus or fee reduction follows the rules of the relevant system, such as CITEO, rather than simply the possession of a RecyClass certificate.
Which data should be consistent?
Always check the precise set of fields in the current form or instructions for the particular eco-modulation mechanism. From an audit perspective, the information should be consistent with the certification scope and process documentation.
- Identification of the organisation, site and relevant RP or RC scope.
- Type and origin of Input Plastic Waste and the appropriate pre-consumer/post-consumer classification.
- Description of the recycling process and scope of certified Recycled Outputs.
- Verified input and output quantities and Volume Reconciliation.
- Connection between Recycled Output and the data covered by the audit.
- Consistency of additional information with the certificate, audit report and current process scope.
- Additional data required by CITEO or another relevant EPR organisation.
Origin data and yield in the annex
The guidance identifies data on the locations of earlier sorting and recycling operations and the stage at which recycled material is incorporated into the product. The yield field relates to the recycling process for the material concerned. Even in a converter’s annex, it should not be replaced with the yield of the converter’s own manufacturing process.
For the French bonus mechanism, check the proximity rules, PCR eligibility and traceability of the entire chain. Article 8 of the French Order of 5 September 2025 sets out a 1,500 km radius rule together with additional territorial conditions and exceptions. Identifying an EU country alone does not establish eligibility.
RecyClass also explains that a Sorting Process certificate is not a condition of the CITEO bonus itself, although information on the sorting location is still needed. This does not remove separate requirements for the food-contact materials supply chain.
How should you approach the audit?
- Identify the intended use. Confirm the system and mechanism for which the customer requires additional verification of data.
- Check the relevant RP or RC scope. The material and process covered by the additional verification must match the actual certification scope.
- Verify the data. Additional information should be reproducible from audit documentation, production records and the process balance.
- Check consistency. Additional documentation, the Audit Report and the certificate should not contain conflicting information.
- Maintain the independence of certification. Documentation is linked to the assessment conducted by the relevant certification body.
- Check current CITEO rules. Bonuses or fee reductions are awarded under the current conditions of the EPR organisation.
Which concepts should be kept separate?
Recycling Process
Certifies the recycling process, waste origin and traceability of Recycled Output.
Recycled Plastics Traceability
Covers downstream participants using certified recycled material, as well as traceability and calculation of recycled content in products.
Eco-modulation
Is an EPR fee mechanism. Certification may supply evidence used by such a system, but it does not replace the rules of the organisation responsible for calculating fees and bonuses.
The Eco-modulation Annex and PPWR
The CITEO mechanism should not be equated with PPWR rules. PPWR develops its own provisions on extended producer responsibility and fee modulation, while national and sectoral EPR mechanisms operate under their own rules. These subjects are related, but they are not the same requirement.
Frequently asked questions
Does the Eco-modulation Annex apply to Recycled Plastics Traceability?
Yes. The RecyClass 2026 guidance describes the Eco-modulation Annex for RP and RC: Recycling Process and Recycled Plastics Traceability. RC should not be excluded from this scope.
Does every Recycling Process certificate automatically qualify for a CITEO bonus?
No. A certificate may be one piece of evidence documenting the origin and content of recycled material. Compliance with the conditions for a bonus or fee reduction depends on the current CITEO rules.
Is Eco-modulation one of Modules A–D?
No. Certification modules and additional annexes serve different purposes.
Can the requirements change?
Yes. EPR scheme rules and documentation requirements may be updated independently of the RecyClass audit scheme itself. Check the current requirements before using the documentation.