Module A can accompany RP or RC. A1 covers final preparation of the input for decontamination, while A2 covers the relevant decontamination scope. A2 excludes novel technologies. Certification does not replace a legal food-contact compliance assessment.
Module A in Recycling Process and Recycled Plastics Traceability
Module A adds requirements to the relevant RP or RC certification, depending on the organisation's operations. The RecyClass Q&A 2026 states that the module is mandatory when it applies to the assessed process and products intended for the food-contact chain. It cannot be obtained as a standalone certificate without the scheme's general requirements.
The A1 and A2 scopes
Current RecyClass documentation distinguishes between A1 and A2, which relate to different process stages. A1 covers the relevant final preparation of material before decontamination, while A2 concerns the decontamination process itself within the appropriate scheme scope.
Suppliers and novel technologies
For RP or RC with Module A2, the Q&A requires suppliers of the relevant input to hold valid certification with Module A1. Module A2 does not apply to novel technologies. For these technologies, the Q&A describes the possibility of a general scope in EU27+3 and A1 requirements for inputs; any derogation must follow from the relevant dossier and be clarified with RecyClass.
Why is the distinction between stages important?
Sorting, pre-processing and decontamination serve different functions. Material can be well prepared for a subsequent process, but preparation alone does not mean that it meets the requirements for the final food-contact application.
What can be assessed?
Depending on the relevant scope, important factors include material origin, input control, process parameters, traceability, operational records, output quality and compliance with the module's additional requirements.
Module A is not a legal authorisation
A RecyClass certificate should not be presented as independent proof that a material fully complies with food-contact legislation. In the European Union, relevant processes and applications are subject to Regulation (EU) 2022/1616 and other applicable legislation.
How should you prepare for the module?
- clearly define the process stage within the scope;
- document the origin and control of input material;
- identify critical process parameters;
- ensure batch traceability;
- retain quality control results;
- distinguish scheme requirements from the operator's legal obligations.
Key point
Module A strengthens verification of a specific process, but the safety and legality of the final application require a full review of the applicable legislation and technical documentation.