Recycling and traceability

RecyClass Module I: when do closed-loop requirements apply?

Module I in Recycled Plastics Traceability Certification adds requirements for controlling relevant material loop systems. It concerns closed loops for all plastics and, for certain post-consumer PVC streams, controlled-loop requirements as well.

Updated:

October 5, 2026

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min read

PREPARED BY

Almaland technical editorial team

Resources prepared from official RecyClass documentation, EU legislation and other primary sources, with reference to audit and certification practice.

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SOURCE STATUS

Translation of the Polish original, whose sources were editorially reviewed on 28 September 2026. Translation prepared on 5 October 2026; no independent expert approval.

Read in another language:

Polish German

AT A GLANCE

Not every material return automatically constitutes a closed loop. Module I requires clearly defined system boundaries and traceability. In certain PVC applications it also covers controlled-loop requirements linked, among other factors, to lead content.

Module I extends Recycled Plastics Traceability Certification

Module I: Loop Requirements is an additional scope of Recycled Plastics Traceability Certification. It verifies systems in which recycled material circulates within a clearly defined loop and its origin and subsequent use can be reliably traced.

A closed loop for plastics

For plastics, Module I applies the definition of a closed loop. In practice, this means demonstrating which products and materials belong to the system, who manages them, where they are collected and processed, and how they return to a subsequent application.

A controlled loop for certain PVC streams

The current Module I also includes controlled-loop requirements for certain recovered post-consumer PVC whose lead content falls within the range specified by the applicable legislation and scheme documentation. In such cases, additional restrictions on use, lead content monitoring and full material traceability are important.

Not every material return qualifies

Internal production regrind, the return of transport packaging or the collection of waste from a customer should not automatically be described as a closed or controlled loop. The Module I requirements and the actual system boundaries must be checked first.

What needs to be documented?

the system boundaries and participants;
the material and product type;
material ownership and flow;
collection and reverse logistics;
the recycling process and subsequent use;
quantities and reconciliation;
documentary traceability;
rules for handling material from outside the system;
additional requirements for a controlled PVC loop, where applicable.

Key point

Module I is not a label for any material circulation system. Its application should be based on a clearly defined system, actual flows and current RecyClass documentation.

HOW TO USE THIS ARTICLE

Practical guidance grounded in source documents

Use the current scheme documentation and the actual scope of your activities when making decisions about a specific process. Check the dates and sources below.

CHECK THE DATE

Scheme requirements and regulations change. Publication and update dates show which version of the requirements the article reflects.

CHECK THE SOURCE

For RecyClass requirements, consult the current scheme documentation; for legal requirements, the applicable legislation; and for accreditation status, official PCA documents.

APPLY IT TO YOUR PROCESS

The same requirement may have different implications depending on the process, site, material, product, module or scheme version. An article does not replace an individual assessment of the scope.

SOURCES AND REFERENCES

Editorial source review of the Polish original: 28 September 2026.

Primary source: Recycled Plastics Traceability Certification.

Supplementary source: Module I: Loop Requirements, v1.0.

Before applying the requirements to a specific process, check the current edition of the relevant documents, the scheme scope and any subsequent updates.