A certificate’s validity period does not permit unrestricted redesign. Assess every change that could affect recyclability and notify the issuing certification body as required. Confirm the approved scope before using the existing claim or mark on a modified pack.
Does a three-year certificate mean packaging can be changed freely during that period?
No. The certificate refers to a particular assessed configuration. A change to the material, label, sleeve, adhesive, closure, colour, printing, barrier or another significant feature can alter the result. Any change potentially affecting recyclability should therefore be assessed before implementation and notified to the certification body where required by the scope and procedure.
1. Certification covers a defined design, not just a product name
The certification documents describe a particular construction, its components and materials, and the variants included in the scope.
If a commercial product retains its name but a significant component changes, the previous result should not automatically be carried over to the new version.
2. RecyClass requires change management
RecyClass methodology and certification documentation require changes affecting the design or assessment outcome to be communicated and reassessed where necessary.
A sound operational approach is to discuss changes with the certification body before introducing them into mass production.
3. A label change can matter
A different label material, coverage, adhesive or printing technology can affect sorting, washing and recyclate quality.
Even a change introduced for marketing or cost reasons can be a technical change for certification purposes.
4. Sleeve changes can affect NIR detection and sorting
A different sleeve material, colour or coverage may alter packaging detection. This is particularly relevant for designs already close to an acceptance boundary.
If the new configuration is not clearly covered by the guidelines, an additional sortability test may be necessary.
5. Adhesive and ink changes can also be significant
Adhesives affect label separation and washing behaviour, while inks can affect colour, the wash bath or the quality of the recovered material.
When changing supplier, functional performance alone is not enough: compare the characteristics relevant to recycling.
6. Colour or pigment changes need assessment
Colour can affect sortability and the value of the final recyclate. The type of pigment matters, rather than only the colour name used in artwork software.
A colour change should therefore be assessed against the current Design for Recycling Guidelines for the relevant stream.
7. Changes to closures, seals and dispensing components
A new cap, pump, valve, liner or multi-material component can introduce another polymer, metal or a part that is harder to separate.
If it affects separation or recyclate quality, the result for the entire design may change even when the body remains unchanged.
8. Changed component proportions may fall outside equivalent packaging
Equivalent packaging can vary within specified conditions, but significant component proportions must remain such that the audit result is unaffected.
For example, a much larger label or a different pack size that changes label coverage may require a separate assessment.
9. Updated Design for Recycling Guidelines also matter
RecyClass updates its guidelines as research and Technology Approvals develop. The applicable version can therefore differ from the one used for an earlier design assessment.
When modifying packaging, check both the previous report and the current guidelines for the relevant stream.
10. A three-year period does not freeze all requirements
A certificate has a defined expiry date, but its proper use requires the product to remain within the approved scope throughout that period. The Quality Management & Procedures document sets the standard initial period at three years minus one day and includes specific timing rules, including for a grace period.
If the product changes in a way that affects the result, the company should not wait until certificate renewal to address it.
11. How internal change control should work
Every planned packaging change should undergo an assessment of its effect on certification. Development, quality, purchasing, marketing and the person responsible for the certificate should be involved.
A useful change form records the changed element, old and new specifications, reason, impact on design for recycling, decision on notifying the certification body and acceptance date.
12. A practical way to group changes
Minor or potentially equivalent: for example, new artwork with unchanged technology and proportions. The certification scope still needs checking.
Significant: changes to material, adhesive, sleeve, barrier, pigment, closure or proportions. These generally require a formal assessment.
Critical or a new design: changes to the main material, recycling stream or fundamental construction. These will usually require a new assessment scope.
13. A reliable practical rule
If the team cannot demonstrate from the documentation that a change leaves the assessment result unaffected, it should not assume the certificate automatically covers the new version.
Discuss the modification with the certification body before using the existing claim or mark for the changed packaging.
Frequently asked questions
Does every artwork change require a new certificate?
Not always. If technology, materials and proportions remain equivalent, the variant may fit the existing scope, but this must be formally checked.
Is a change of adhesive supplier significant?
It can be. Adhesives can behave differently during washing and separation, so recycling-relevant properties need comparison.
Is a certificate valid for three years regardless of product changes?
No. The validity period does not remove the obligation to keep the product consistent with the assessed configuration.
Who should receive the change notification?
Contact the certification body that issued the certificate, following the applicable procedure and assessment scope.