A CMSS is a standardised description of a decontamination installation, its operation, procedures, quality system and compliance monitoring. It is prepared by the recycler and is not a food-grade certificate, a declaration of compliance or a RecyClass audit report.
Is a CMSS a certificate confirming that an installation produces food-grade rPET?
No. The Compliance Monitoring Summary Sheet is a standardised document describing the decontamination installation, its operation, procedures, quality system and compliance monitoring. The recycler prepares it primarily to explain how the actual installation meets the process and regulatory requirements.
1. CMSS follows directly from Article 26
As a general rule, the recycler prepares a CMSS for a decontamination installation under its control using the template in Annex II. For a novel technology, the developer may provide an appropriately adapted form. The specific exemption for qualifying product-loop recycling schemes, described below, must also be considered.
The document should clearly explain the installation, its operation, procedures and documents in a way that demonstrates compliance with the Regulation.
Exception: recycling within a product loop
Article 9(2) provides an exemption from CMSS following notification of production within a recycling scheme, unless column 8 of Table 1 in Annex I requires the document. This exemption does not extend to schemes operating under a novel technology, because Article 10(6) excludes the application of Article 9(2). RecyClass Questions & Answers Certification 2026 also describes, for a qualifying product loop, the exemption from the authority's CMSS-related audit and the requirement to hold the scheme manager's instructions. This does not remove other official controls and is not a rule for any internal recirculation of material. The following sections concern installations subject to the CMSS obligation.
2. CMSS describes a particular installation
One organisation may operate several decontamination installations. Each CMSS should reflect the relevant configuration and the actual place where the process operates.
Copying a generic description across different lines without considering their differences can weaken the documentation's reliability.
3. The document connects technology with the quality system
CMSS includes installation identification, the process diagram, procedures, documents, quality assessment points, critical parameters, records and traceability.
Its purpose is to make it possible to understand how the facility controls recycled plastic production in practice.
4. CMSS must be available at the installation and submitted to the authority
Article 26 requires the recycler to hold the complete document at the installation and submit it to the competent authority.
The provision specifies submission within one month from the start of recycled plastic production at that decontamination installation.
5. Installation notification starts earlier
Under Article 25, the recycler should make the relevant installation notifications at least 30 working days before the planned start of production. CMSS subsequently forms part of establishing and verifying the installation's status.
It should therefore not be treated as a document prepared only for the first audit.
Practical update, 5 October 2026: the European Commission reports that its installation registration and update forms have been offline since 11 September 2026 during a system upgrade, with the replacement expected towards the end of October. The public register remains accessible but is temporarily frozen. Check the Commission's current instructions and contact the competent authority where necessary; the notice should not be interpreted as an automatic extension of legal deadlines.
6. The competent authority verifies the CMSS and installation
The authority assesses the CMSS information and inspects the installation. If compliance cannot be established, it may require changes to the document, the installation's operation or both.
Once compliance is confirmed, the installation's status in the Union Register can be updated accordingly.
7. Missing verification has consequences for registration status
The Regulation provides for changes to an installation's status where compliance has not been confirmed within one year of the start of production. CMSS is therefore part of an operational supervision system, rather than an internal note.
Check the particular installation's status in the current Union Register, taking account of any official notice about updates to the register.
8. CMSS uses quality-system and SOP documentation
Annex II refers to standard operating procedures, quality assessment and GMP documentation. It should be possible to identify the document or record showing how each requirement is controlled.
A useful CMSS acts as a map from requirements to procedures, records and responsibilities.
The GMP amendment introduced by Regulation (EU) 2025/351 requires quality assessment stages for each batch coming directly from a manufacturing stage. The assessment checks compliance with the applicable critical limits and predefined quality criteria. It determines whether the batch may undergo further processing, needs correction, must be discarded or may be used for non-food applications. As a practical consequence, the CMSS description should reflect the corresponding procedures and records at installations subject to the CMSS obligation.
9. Critical parameters must connect to records
Where decontamination effectiveness depends on temperature, time, pressure or flow, for example, CMSS should show how these parameters are monitored and where records are held.
During a control or audit, the authority or auditor can follow the description to a particular batch and inspect the actual process data.
10. CMSS is different from a declaration of compliance
CMSS describes the installation and monitoring system. A declaration of compliance passes down the supply chain with recycled plastic or material containing it.
The first primarily supports installation control; the second communicates product compliance and conditions of use.
11. CMSS is also different from a RecyClass report
A RecyClass audit report documents an assessment against a certification scheme. CMSS arises from legislation and has its own regulatory purpose.
Module A2 may require the organisation to have and correctly maintain a CMSS, but the certification body does not issue it on the recycler's behalf.
12. The document should evolve with the installation
Changes to configuration, parameters, SOPs, records or responsibilities can require a CMSS update. A document that no longer reflects actual operations loses its usefulness for demonstrating compliance.
Change control should therefore assess the impact of changes on CMSS and other regulatory documents.
FAQ
Who prepares the CMSS?
The recycler responsible for the decontamination installation.
Does every installation need its own CMSS?
As a general rule, CMSS concerns a particular installation. The recycling-scheme exemption requires the conditions in Article 9(2) described above and does not cover novel technologies. The scheme manager's instructions still apply.
When must CMSS be submitted to the authority?
Article 26 specifies one month from the start of recycled plastic production at the installation.
Is CMSS sent to every customer?
It does not serve the same purpose as a declaration of compliance. It is primarily a document for the recycler and competent authority.
Can RecyClass replace the authority's CMSS verification?
No. Certification and official verification are separate mechanisms.