RecyClass: what the result lets you claim
RecyClass produces four different outputs, and they are not interchangeable. A technology approval, a letter of compatibility, a design-for-recycling certificate and a recyclability certificate carry four different sets of claim rights.
Only the last one lets a brand say the pack is recyclable and put the certification mark on it. One of them prohibits the logo outright. The difference is not a formality: it is the difference between a statement about a structure and a statement about what happens to that structure in a given country.
This page sets out the four outputs and what each permits. It covers why designed for recycling is not the same claim as recyclable, why a film supplier’s document is not a claim a brand can print, and which of two legal regimes governs the wording once it reaches the pack.
The four RecyClass outputs and what each permits
The RecyClass Use of Claims Guidance sets out separate rules for each output, and splits them again into business-to-business and business-to-consumer communication.
| Output | What is assessed | What may be claimed |
|---|---|---|
| Technology Approval | A specific technology or packaging feature, such as a multilayer film or a label-and-glue combination. It can cover either semi-finished or finished packaging. | Full, limited or no compatibility with a given recycling stream. The result may be communicated business-to-business in the exact terms of the approval letter, with every condition listed. It is not a certification of a final product and must not be communicated to consumers. |
| Letter of Compatibility | Semi-finished packaging: the body or main component without its final elements, so without labels and artwork. | An intermediate class, business-to-business only. The certification mark is prohibited at this stage. Claims are allowed if they state that this is a pre-evaluation, that changes in design, print, materials or product residue may change the outcome, and that the score does not consider national collection systems. |
| Design-for-Recycling Certification | A finished pack against the guidelines, without looking at any particular country’s collection and sorting. | With a grade between A and C, that the pack is designed for recycling. The certificate and mark may be used business-to-business and in off-product consumer communication, with the required disclaimers. Not on-product, and not as a recyclability claim. |
| Recyclability Certification | The same pack, plus whether it is effectively recycled in the specific geographic area assessed: collection schemes, sorting and recycling infrastructure. | Recyclability, with the certification mark, on-product included. The claim is limited to the geography the certificate covers. |
Below grade C, the RecyClass scheme closes the question
A result below C closes the question. The guidance states that certification results below grade C are not considered recyclable. No contradicting message claiming the packaging is designed for recycling may be used either, because the design presents fundamental flaws affecting the quality of the output material. Recyclability claims are not allowed in those cases, in order to avoid greenwashing.
Designed for recycling is not the same claim as recyclable
The two certifications sit one step apart, and the step is geography.
The design-for-recycling assessment ranks how well a pack suits a recycling stream, based on the sorting and recycling technologies available in Europe. The guidance is explicit that this assessment does not consider the collection, sorting and recycling specificities in a given country.
The recyclability assessment adds that missing half. It checks that the pack is designed for recycling and is effectively recycled in the specific geographic area for which the assessment is conducted. That means verifying that selective collection schemes exist there, and that the sorting and recycling infrastructure does too.
That is why a recyclability certificate is country-specific and a design-for-recycling certificate is not. The same pouch can be designed for recycling within the European scope of that assessment, and recyclable in only some of the countries it is sold in.
The four conditions behind the word
RecyClass defines recyclability by four cumulative conditions. The product is made with plastic that is collected for recycling, with market value or a legislatively mandated programme behind it. It is sorted and aggregated into defined streams. It can be processed and reclaimed with commercial recycling processes. And the recycled plastic becomes a raw material used in new products.
The guidance then adds the sentence most summaries leave out: meeting all four does not automatically designate a product recyclable. Recyclability is a conclusion drawn from evidence, not a property read off a datasheet.
Why a film supplier’s RecyClass document is not a claim you can print
A converter supplies film and laminates. In RecyClass terms that is semi-finished packaging: the packaging body or main component without its final elements. Labels and artwork are among the elements missing.
The output for semi-finished packaging is a Letter of Compatibility, and the template carries its own instruction: at that stage the use of the RecyClass logo is prohibited, and claims on the recyclability of the semi-finished product are not supported. To use the logo, the final packaging has to be submitted for certification. It is the final packaging, with its decorative elements and its product residue, that enters the recycling system.
The document travels, the claim does not. A supplier’s Letter of Compatibility is evidence about the semi-finished packaging it covers. It does not certify the customer’s finished pack. A RecyClass claim or mark for the finished pack requires certification of that finished pack, under the scheme’s own claim rules. Separately, and on a different legal basis, the Regulation decides which operator is the manufacturer that owes the conformity file: the supplier owes information under Article 16.
Which company is the manufacturer, and so owns both file and claim, is set out on the page about PPWR compliance and who carries the obligation.
How the RecyClass ladder maps onto the PPWR timeline
The split between design and geography is not a RecyClass invention. The Regulation uses the same one, spread across two dates.
| Question | RecyClass | PPWR |
|---|---|---|
| Is it built so it could be recycled? | Design-for-Recycling Certification | Design for recycling criteria, grades A, B and C, from 2030 |
| Is it actually recycled where it is sold? | Recyclability Certification, per geography | Recycled-at-scale assessment, added from 2035 |
The thresholds match too. RecyClass adapted its recyclable-content bands to the ones in the Regulation. It also cut its scheme from six classes to three, removing D, E and F and reclassifying them as non-recyclable. Grade A sits at 95 per cent or above, grade B at 80, grade C at 70.
Matching thresholds are not the same as a legal grade. The recyclability performance grade under the Regulation is calculated by the method set in the delegated acts of Article 6(4), due by 1 January 2028. The Commission guidance states plainly that manufacturers do not need to perform the Article 38 and Annex VII conformity assessment for recyclability until those delegated acts enter into force, and that they will then have 24 months to comply. Until then a RecyClass result supports design decisions and voluntary claims. It is not the PPWR grade, and it is not yet a regulatory obligation discharged.
The thresholds, the 2038 cut-off for grade C and the structures that typically land in each band are on the page about the PPWR recyclability grades.
Two legal regimes govern the claim once it reaches the pack
A certificate answers whether the evidence exists. A separate body of law answers whether the wording on the pack is lawful. It is not the same law on both sides of the Channel.
In the European Union
Directive (EU) 2024/825 amends the unfair commercial practices rules. It adds two entries to the blacklist: a generic environmental claim that cannot be substantiated, and a claim about the whole product when it concerns only one aspect of it. Member States apply the national measures from 27 September 2026.
The practical consequence for a recyclability claim is a matter of substantiation. An unqualified recyclable, on a pack whose evidence covers only design and not the local recycling reality, suggests more than the evidence establishes. A claim that names the assessed stream or geography and links to the certificate substantiates better. It still has to be accurate, specific and not misleading; a certificate does not make any wording lawful by itself.
In the United Kingdom
The Directive does not apply. Environmental claims are assessed against the Competition and Markets Authority Green Claims Code, which requires claims to be truthful, clear, complete, relevant to the full life cycle and backed by robust evidence. The policy objective is similar. The legal instrument and the enforcement framework are not.
A brand selling the same pack in both markets therefore has two separate questions. Whether its RecyClass assessment or certification actually covers the geography concerned, since a recyclability certificate is country-specific and should not be assumed to extend to another country. And whether the wording complies with the consumer-protection rules of that market.
RecyClass adds a third layer of its own. Use of the certification mark is governed by the Use of Claims Guidance. Ambiguous use of the mark is not allowed, and claims are expected to be paired with a reference to the certificate. A logo used outside those rules is a problem with the scheme even where the underlying claim is true.
How the same regime treats compostability, and why biodegradable is named in the recitals, is on the page comparing compostable and recyclable packaging.
Frequently asked questions about RecyClass
Can I put the RecyClass logo on my packaging?
Only on the basis of a Recyclability Certification, and only within the geography that certificate covers. A Letter of Compatibility prohibits the mark outright. A Design-for-Recycling Certification allows the certificate and mark off-product, on your website or in press and social communication, with the disclaimer that the score covers Europe and does not reflect national collection systems, but not on-product toward consumers.
My film supplier sent me a RecyClass document. Is my pack certified?
No. A document covering the film covers semi-finished packaging, without labels, artwork or the product residue that the recycling system actually receives. It is useful evidence and it belongs in your technical file. But the finished pack has to be certified in its own right before any claim or mark attaches to it.
Does a RecyClass class give me the PPWR recyclability grade?
Not yet. The thresholds are aligned at 95, 80 and 70 per cent, and RecyClass states that it adapted its bands to the Regulation. The legal grade is calculated by the method set in the delegated acts under Article 6(4), due by 1 January 2028. The Commission guidance adds that manufacturers do not have to perform the Article 38 and Annex VII conformity assessment for recyclability until those acts are in force, and will then have 24 months to comply. A certificate is useful evidence in the meantime, not the grade.
Why is a recyclability certificate country-specific?
Because recyclability, as the scheme defines it, depends on infrastructure that exists in one place and not another. The design-for-recycling assessment deliberately ignores national collection and sorting; the recyclability assessment checks it. A pack can be designed for recycling across the Union and recyclable in only part of it.
What can I say if the result is below grade C?
Nothing that describes the packaging as recyclable. The guidance states that results below C are not considered recyclable, and that contradicting messages are not permitted. Recyclability claims are not allowed in those cases, in order to avoid greenwashing. The result is still useful internally, as the starting point for a redesign.
Can an Online Tool result be used as a recyclability claim?
No. RecyClass describes the Online Tool output as a free self-assessment that gives a first indication only, and states that it may differ from the final result obtained after the audit. A claim of recyclability under the scheme requires third-party certification of the finished pack.
Sources
RecyClass Recyclability and Recycled Plastic Use of Claims Guidance, version 1.1, last updated April 2025, sections 4.1 to 4.4 and the certificate templates in the annexes. RecyClass Packaging Recyclability Methodology, version 3.1, August 2025, the current version of that document; the RecyClass Online Tool is versioned separately and stands at v3.2.1 of 29 June 2026, which clarified alignment with EN 13430. European Commission, Commission Notice on the guidance document for Regulation (EU) 2025/40, C(2026) 3702, on the conformity assessment timing for recyclability. Regulation (EU) 2025/40, Article 6 and Annex II, Table 3. Directive (EU) 2024/825. European Commission FAQ on the PPWR, 2nd edition, August 2026. UK Competition and Markets Authority Green Claims Code. The RecyClass documents cited above are an industry certification scheme, not a source of law; the Commission Notice and the FAQ state the Commission position and are not legally binding. Only Regulation (EU) 2025/40 and Directive (EU) 2024/825 are binding.
Reviewed by Laura Ionescu, VLM Poliplast SRL, on 13 August 2026, against the text of Regulation (EU) 2025/40, Directive (EU) 2024/825 and the RecyClass Use of Claims Guidance. VLM Poliplast SRL holds editorial responsibility for the content of this page. This page is not legal advice.
Related resources
If you are working out what your structure allows you to say, we can go through it against the assessment you already hold.