Track material sent to a subcontractor by date, destination, grade, quantity and batch. Check the subcontractor's certification, retain the link to returned output and account for additions, waste and losses. Apply the requirements of the relevant RecyClass scheme.
Does sending material to an external subcontractor break the traceability chain?
Not necessarily, but outsourcing does not remove responsibility for traceability. Under RecyClass Recycled Plastics Traceability Certification, material sent for subcontracted processing must be properly recorded, and the processing included in the calculation must take place at certified facilities. Processing at non-certified companies is excluded from the recycled content calculation under this scheme.
1. Subcontracting takes an operation outside your facility
A company may outsource storage, compounding, converting, grinding, washing or another operation. Traceability gains an additional stage in which material changes location and is handled outside the applicant's direct control.
Documentation must therefore show not only dispatch and return, but also the material's status while it is with the subcontractor.
2. RPT requires basic dispatch data
In its subcontracting section, RecyClass requires records of at least the dispatch date of Recycled Input, the name and address of the organisation performing the processing, and the material grade and tonnage.
These minimum data connect a specific flow to an organisation and quantity. Batch numbers, transport documents and identification of the returned product are also useful in practice.
3. The subcontracted facility must hold certification
Audit Scheme v2.2 requires subcontracted processing to take place in certified facilities and copies of the subcontractors' certificates to be provided as evidence.
The scheme adds that processing at non-certified companies is not included in the recycled content calculation. This is significant when designing a supply chain.
4. Material ownership matters to the definition
RecyClass defines subcontracted processing as an arrangement in which the applicant retains ownership of the output from an operation performed by an external organisation.
This distinguishes subcontracting from purchasing a finished product from a supplier. The latter may be assessed as a supplier relationship rather than a subcontracted operation.
5. Batch identity should survive dispatch
Ideally, dispatched material has an unambiguous batch number or transaction code appearing on transport documents, subcontractor receipt records and the returning material.
A subcontractor can use a different internal code only if there is a clear mapping between the original and new identifiers.
6. Quantity reconciliation must include the external stage
If 20 tonnes are sent to a subcontractor and 17 tonnes of product plus 2 tonnes of waste return, the company should be able to explain the remaining difference.
Subcontracting must not leave an unexplained gap in volume reconciliation. Losses, waste, additives and other materials must be accounted for according to the actual process.
7. Recipe changes at the subcontractor affect recycled content
If the subcontractor adds virgin plastics, masterbatch, filler or another ingredient, the company needs data allowing it to calculate the actual share of Recycled Input after that stage.
Knowing how much recycled material was dispatched is insufficient. The company must know what was produced and in what quantity.
8. The subcontract should support audit requirements
It is useful to agree requirements for record retention, batch traceability, quantity data, notification of process changes and maintenance of the required certification.
The auditor assesses the available evidence; lack of access to outsourced-process data may prevent substantiation of the claim.
9. Sorting Process has its own subcontracting requirements
Sorting Process contains a separate subcontracting section for input waste and plastic waste. Every RPT detail should not automatically be transferred to the sorting scheme.
The shared principle is that an external operation must preserve traceability and be controlled under the applicable certification scheme.
10. A common mistake: excluding an outsourced operation from the assessment
If outsourcing forms part of the material flow supporting certified recycled content, it cannot simply be omitted because another company performs it.
Establish whether the operation is a supplier relationship, subcontracted processing, a separate site or another part of the chain of custody, then apply the relevant requirements.
FAQ
Does every subcontractor need RecyClass certification?
In RPT, subcontracted processing included in the recycled content calculation must take place at certified facilities. Always check the applicable scheme and the type of operation.
Is an invoice from the subcontractor sufficient?
No. Data must connect the material, quantity, process and result to the specific batch.
Is an external warehouse subcontracted processing?
It may form part of the external chain, but classification depends on what actually happens to the material and which scheme requirements apply.
Can the subcontractor change the batch code?
Yes, provided unambiguous mapping allows the material history to be reconstructed.
Can outsourcing be covered by a product family?
A product family concerns a group of products, rather than the subcontracting relationship. Both may occur within one scope, but address different questions.