flustix statement on the UBA study on certification systems for recycled plastics

In August 2026 the German Federal Environment Agency (UBA) published the study “Analysis and assessment of certification systems for recycled plastics” (UBA-TEXTE 130/2026). It assesses a system under the name “flustix RECYCLED DIN-geprüft” and subsequently refers to it in more than 50 places in the shortened form “flustix RECYCLED”.

That assessment does not, however, concern the current flustix RECYCLED certification programme.

UBA reviews the study

After being contacted, the Federal Environment Agency informed flustix that it has initiated a technical review of the matter. The institutes involved in the study are being included in this clarification. The UBA will then decide whether, and in what form, the publication needs to be amended or placed in additional context.

flustix welcomes this step and is available for the further factual review.

What was actually examined in the UBA study?

According to the study, the assessment was based on the document status of October 2024. The material evaluated was in particular:

• the certification scheme “Products from recycled material – flustix V06/24” issued by DIN CERTCO;
• the DIN CERTCO testing, registration and certification regulations;
• the DIN CERTCO conditions for external experts.

This was the basis of the cooperation at the time and of the former combination mark “flustix RECYCLED DIN-geprüft”.

The standalone flustix RECYCLED certification programme, fully revised by a panel of experts, was published on 28 November 2025. Since then, the former combination mark with DIN CERTCO has no longer been awarded.

Today’s flustix RECYCLED certification programme was therefore already publicly available before the study was completed in January 2026, but it was not included in the examination.

Key criticisms in the UBA study concern a superseded version of the scheme

Several substantial criticisms in the UBA study are already addressed in the flustix RECYCLED certification programme that has been in implementation since December 2025. These include in particular:

• the explicit application of DIN EN ISO 22095 for chain of custody;
• specified requirements for the traceability of recyclate origin;
• detailed specifications for material input, material output, material flows and process losses;
• requirements for warehouse management, batch allocation and physical stock controls;
• verifiable mass balancing and plausibility checks;
• consideration of fillers, virgin materials and further product components;
• separate recording and declaration of post-consumer recyclate (PCR) and post-industrial recyclate (PIR);
• further developed requirements for auditing, documentation and conformity assessment.

The current flustix RECYCLED certification programme also works with several independent international certification bodies that are recognised for this scope. The organisational structure of DIN CERTCO discussed in the study therefore cannot remotely be transferred to today’s flustix RECYCLED system.

flustix was not involved in the examination

flustix was neither informed about the examination nor asked for supplementary documents. The preliminary results were not submitted to flustix for review or comment either.

According to the study, only DIN CERTCO was contacted. There, in-depth support was said to be impossible due to a lack of capacity. Elsewhere in the study, however, this is turned into an alleged “lack of willingness to cooperate”.

flustix was ready at all times to contribute to a factual review. No such request reached the company.

The study itself points to its limited significance

The authors state explicitly that the assessment is made subject to reservation because of insufficient depth of information, and that misinterpretations cannot be ruled out.

In addition, no publicly available indications of practical shortcomings, incorrect certifications or breaches by the system examined were identified. The poor ranking therefore rests largely on the assessment of the available documentation and on unanswered points of detail, not on established deficiencies in past certification practice under the combination mark.

Our request to the Federal Environment Agency

flustix has asked the Federal Environment Agency for a prompt clarification and correction. In our view it must be clearly recognisable that:

• the combination mark “flustix RECYCLED DIN-geprüft” has not been awarded since the end of 2025;
• the current flustix RECYCLED certification programme is not the subject of the study;
• the assessment is based on the DIN CERTCO scheme V06/24 and the document status of October 2024;
• flustix was not contacted and not involved in the review of the results;
• the results cannot be associated with the current state of flustix RECYCLED certification;
• the study makes no statement about the present state of flustix RECYCLED certification.

flustix has been and remains available to the Federal Environment Agency and the participating institutes for a full technical review at any time.

Short answers for orientation

Did the Federal Environment Agency assess the current flustix RECYCLED certification programme in the study?
No. What was assessed was the earlier DIN CERTCO certification scheme V06/24 and further DIN CERTCO documents with a document status of October 2024.

Since when has the current flustix RECYCLED programme applied?
The standalone flustix RECYCLED certification programme was published on 28 November 2025.

Does flustix RECYCLED take ISO 22095 into account today?
Yes. The current programme refers explicitly to DIN EN ISO 22095 and DIN EN 15343 and contains corresponding requirements for chain of custody, traceability and material balancing.

Was flustix consulted before the UBA study was published?
No. flustix was neither contacted nor were the questions or preliminary results submitted to the company for comment.

Why did flustix not take part in the study?
flustix was not contacted at any point during the study. flustix only learned of it on the day of publication, through references to the study, and was taken completely by surprise.

Would flustix have worked closely with the institutes carrying out the study?
Yes. Since its foundation in 2017, flustix has always worked closely with the UBA, has left no other institutional enquiry unanswered and has always contributed its full expertise in panels and consortia. That has not changed and will not change now, even after being left out by the UBA: critical exchange with NGOs, institutes and authorities is decisive for constructive progress and for developing trustworthy and recognised systems.

The current flustix RECYCLED Certification Programme as a PDF