RecyClass and the PPWR overlap in some areas, but they are different systems. Certification can support specific evidence, while responsibility for legal compliance and the required documentation remains with the economic operator concerned.
RecyClass and the PPWR have different roles
The PPWR is European Union legislation that sets obligations for economic operators. RecyClass is a system of methodologies and third-party certification addressing specific technical characteristics and processes.
Where do their areas overlap?
- designing packaging for recycling;
- data on recycled material content;
- traceability of material origin;
- the recycling process and data quality;
- independent verification of specific information.
RecyClass Recyclability
A RecyClass assessment can provide detailed technical information about a packaging design and its behaviour in the relevant recycling stream. This does not mean that a current RecyClass class is automatically equivalent to a legal PPWR grade.
Recycling Process and Recycled Plastics Traceability
These schemes can support the reliability of data on the recycling process, material origin and recycled content. However, the final legal methodology under the PPWR must be based on the Regulation and the relevant implementing acts.
Technical documentation remains the relevant operator's responsibility
A certificate may form part of the evidence in technical documentation, but it does not replace a full requirements review, conformity assessment or EU declaration of conformity where these are required.
How should certification be communicated?
Instead of stating that “the product complies with the PPWR because it has RecyClass certification”, specify which area was assessed and which data the certificate provides.
Key point
The main value of RecyClass in the PPWR context lies in providing structured technical evidence. Certification does not transfer legal responsibility away from the manufacturer or replace all the Regulation's requirements.