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How does a certification work, what does it cost, what evidence do the PPWR and EmpCo require, and why do we not certify bioplastics? Here are the answers, gathered for businesses and consumers.
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Verifiable product properties are more than a sustainability topic today. They decide regulatory conformity, monetary advantages in tax and bonus schemes, market access in tenders, and what you are still allowed to claim at the point of sale.
An independent flustix certification delivers robust third-party evidence for defined product properties such as recycled content, recyclability, plastic reduction, microplastic-free status or PFAS-free status. This evidence works in four areas at once: regulatory compliance and market access, monetary advantages from tax and bonus schemes, tenders and supplier qualification, and credible, compliant environmental communication. The difference from a self-declaration lies in the burden of proof: whoever claims a product property themselves has to substantiate it themselves if challenged.
Requirements for verifiable environmental and material properties keep rising. Companies increasingly have to substantiate how high the recycled content of a product is, whether packaging is recyclable, or whether defined requirements on plastic reduction, microplastics or PFAS are met.
An independent certification translates these product properties into traceable third-party evidence that holds up towards customers, retail, authorities, contracting bodies and other market participants. Self-disclosure does not shift the risk; verified evidence does.
Certified evidence can represent an immediate monetary advantage, because several European countries link taxes, bonuses and EPR fees directly to verified recycled content.
In Spain, the plastic tax is levied on the non-recycled plastic share of certain non-reusable plastic packaging. The rate is 0.45 euros per kilogram of non-recycled plastic. For the recycled content to be deducted for tax purposes, Spanish law requires evidence from an accredited certification body on the basis of UNE-EN 15343 or a successor standard.
In France, financial bonuses for the use of plastic recyclates have been granted since 2026. Depending on the origin and application of the recyclate, these are generally 450 or 550 euros per tonne. For certain hard-to-recycle plastics in contact-sensitive packaging applications, the scheme provides for even higher premiums.
The Netherlands also rely on financial incentives: in the Verpact scheme, the use of recyclate is credited in 2026 at 0.20 euros per kilogram of packaging. From 2027 the tariff structure is to be expanded further: the higher the recycled content, the greater the financial advantage. The concrete conditions are currently being finalised.
The direction is clear: wherever taxes, bonuses, reduced EPR fees or other advantages are tied to specific material properties, robust and, where regulation requires it, accredited certification evidence decides whether companies can actually use those advantages. The evidence comes from flustix RECYCLED.
As at August 2026
Since 12 August 2026 the European Packaging and Packaging Waste Regulation (PPWR) has applied directly across the European Union. It considerably tightens the requirements for packaging and introduces binding rules step by step, among others on recyclability, recycled content, packaging minimisation as well as technical documentation and conformity assessment.
Particularly relevant for brand companies is the question of who has to provide the evidence. In its current PPWR guidance, the European Commission makes clear that the “manufacturer” within the meaning of the PPWR is not necessarily the company that physically produces the packaging. Where packaging or a packaged product is made and placed on the market under a company’s own name or brand, the brand owner is in principle to be regarded as the manufacturer. The guidance also stresses that there is in principle only one manufacturer within the meaning of the PPWR along the supply chain.
That manufacturer carries the legal responsibility for the conformity of the packaging. Suppliers have to provide the necessary information and documents, but responsibility for the conformity assessment, the technical documentation and the proof of conformity stays with the responsible manufacturer. The Commission expressly describes the brand owner as the economic operator carrying legal responsibility for the compliance of the packaging.
A pre-certification of the packaging or material supplier therefore does not transfer that responsibility to the supplier. It can be an important component of the evidence, but it does not replace the product- and brand-specific compliance of the party placing the goods on the market. This is exactly where flustix offers a pragmatic route: for materials or packaging already certified at the plant, the flustix sub-licence model can transfer an existing certification to the brand owner or their specific product under defined conditions. A downstream brand therefore does not have to rebuild the entire certification chain, yet obtains the certification evidence relevant to its own responsibility. More on our PPWR page.
Yes, but under one clear condition. From 27 September 2026 the requirements of the EU directive “Empowering Consumers for the Green Transition” (EmpCo) apply. Sustainability labels may then in principle only be used if they are based on a certification scheme or were established by a public authority. At the same time, generic or insufficiently substantiated environmental claims are restricted further.
For companies this means that a mere self-declaration increasingly becomes a regulatory and commercial risk. Infringements of European consumer protection rules can be penalised with fines; in cross-border cases the maximum amount must reach at least 4% of the company’s annual turnover in the member states concerned.
All flustix trustmarks are based on defined certification programmes with independent conformity assessment and can be verified in the public certification database. An environmental claim thereby becomes a substantiated claim. More under green claims.
Verifiable environmental and material properties keep gaining importance in public tenders, supplier qualification and professional procurement. Environmental criteria, recyclability, recycled content and further sustainability requirements can form part of award criteria and technical specifications.
Independent certificates offer a structural advantage here: required product properties do not have to be asserted by the supplier itself, but can be demonstrated traceably and independently towards procurement, clients and business partners. Supplying the evidence shortens the review process on the customer side.
The flustix trustmarks make independently certified product properties directly visible: on products and packaging, in online retail, at the point of sale and in B2B communication. Companies can clearly differentiate their actual performance from competitors and credibly communicate verified properties such as plastic reduction, microplastic-free status, recycled content, recyclability or PFAS-free status.
flustix thereby connects the areas that belong together for companies today: regulatory compliance, financial advantages, market access and credible marketing. Independently certified. Robustly evidenced. Safely communicated.
flustix certifies products, packaging, components, semi-finished goods and raw materials made of plastic, paper, board, cardboard, metals including aluminium, and glass. Which certification programme applies depends on the property you want to substantiate:
Several programmes can be combined for the same product. If you are unsure which evidence fits, we clarify that in a few minutes in a free initial consultation.
The process involves three steps: enquiry and quotation, independent testing, certification and issue of the trustmark. We usually respond to your enquiry within two to three working days with an individual quotation. The testing itself takes four to twelve weeks depending on the programme and the product.
Depending on the evidence, testing takes place in the laboratory or via a supply chain audit. Laboratory analyses run through laboratories accredited to ISO/IEC 17025; the conformity assessment is made independently to ISO/IEC 17065 by accredited certification partners. After successful certification you receive your certificate, your licence number, the trustmark files and the public entry in the flustix certification database.
Costs depend on the programme and the testing effort and are always calculated individually. Four factors determine the price: the chosen certification programme, the number and complexity of the products or materials to be tested, the type of testing (laboratory analysis or supply chain audit) and the licence scope, that is in which markets and to what extent the trustmark is used.
Two things noticeably reduce the effort: existing test reports and prior certifications are recognised where they meet the requirements of the certification programme. And via the sub-licence model, downstream brands can build on an existing certification without going through the full process again.
You can obtain a concrete quotation via the online questionnaire, in a free initial consultation or by email to contact@flustix.com.
Yes. Existing test reports, analyses and prior certifications are recognised where they meet the requirements of the respective flustix certification programme. You therefore do not have to start from scratch if your material or product has already been tested.
What matters is the scope of testing, the test method, the accreditation of the laboratory and how current the data is. We review existing documents in advance and tell you which of them are usable and where additional testing is required. In many cases this considerably reduces cost and time.
A test report confirms a measurement result at a point in time on a submitted sample. A certification additionally assesses conformity with a defined programme, monitors continued compliance and governs which claim may be made at all.
The two levels interlock and are accredited differently:
| Accredited testing laboratory (ISO/IEC 17025) | Certification body (ISO/IEC 17065) |
|---|---|
| Confirms a measurement result | Assesses conformity with a programme |
| Relates to the sample submitted | Relates to the product within a defined scope |
| A snapshot in time | Ongoing surveillance, recertification |
| No statement on the permissible claim | Governs the permissible claim and its labelling |
| Not publicly verifiable | Publicly verifiable via certificate and database |
For internal technical documentation a test report can be sufficient. As soon as it becomes a claim towards customers, retail or consumers, it generally is not. In the flustix programmes, laboratories accredited to ISO/IEC 17025 carry out the testing; the conformity assessment is made independently to ISO/IEC 17065.
A flustix certificate is valid for six years. Within that term, ongoing conformity checks take place to ensure that the certified property continues to be met.
If the formulation, material, supplier or production process changes, this has to be reported to flustix, because a certification is always tied to a defined scope. The current status of every certificate can be viewed at any time in the certification database.
Yes. flustix expressly certifies raw materials, semi-finished goods and components as well, not only finished consumer goods. Suppliers of plastic recyclates, compounders, film and packaging manufacturers and material suppliers can have their goods certified and make origin, recyclate type (PCR, PIR or MIX) and recycled content transparent for their customers.
For suppliers this is increasingly a sales argument: European customers have to provide evidence under the PPWR and EmpCo and request it along the supply chain. Supplying verified evidence makes you the easier decision. Via the sub-licence model, downstream customers can build on this certification without your supply chain being disclosed.
The sub-licence model transfers an existing certification to a downstream market participant under defined conditions. The supplier has the material tested once; its customers receive their own licence number and their own entry in the public database on that basis. Without repeat laboratory testing and without duplicated audit costs.
This solves exactly the problem the PPWR creates: legal responsibility sits with the party placing the goods on the market, the verified data sits with the supplier. The sub-licence closes that gap without disclosing the supply chain to third parties. Important: a sub-licence does not extend the scope of the parent certification and remains tied to its validity.
Details under flustix sub-licence system.
flustix certified products are on the market in more than 28 countries. Certification runs through an international network of accredited certification bodies and testing laboratories with auditors in Europe, the Americas and Asia.
For manufacturers outside the EU this is particularly relevant, because testing can take place in the country of origin and the evidence can then be used across Europe. The underlying standards such as DIN EN 15343, DIN EN ISO 22095 and DIN EN 13430 are internationally recognised. More under EU market access.
Every valid flustix trustmark carries an individual licence number. Using that number, the corresponding certificate can be called up in the public flustix certification database, including product, licence holder, certified property and validity.
Trustmarks without a licence number or without a findable database entry are not valid. If you notice unauthorised use of a flustix trustmark, you can report it to us via our contact form. We follow up on every report.
No. Products and packaging made of bioplastics are not certified as plastic-free by flustix. flustix treats bioplastics made from renewable raw materials (for example bio-polyethylene) or from degradable materials (for example PLA) like petroleum-based plastics. The German Federal Environment Agency and BUND also classify PLA, as it occurs for instance as an exfoliating agent in personal care products, as microplastic.
The reason: bioplastics remain controversial, because they too can contain harmful chemicals. In addition, not all bioplastics are recyclable and they are usually incinerated. If bioplastic is mistakenly disposed of in the organic waste bin, it is not composted but sorted out and also ends up in the incinerator. The additional sorting effort leads to higher energy consumption.
Yes. From 2019 until the end of 2025, the flustix RECYCLED DIN-geprüft mark was awarded together with DIN CERTCO, on the basis of the DIN CERTCO certification scheme “Products from recycled material”.
During that cooperation the scheme was developed further on an ongoing basis and adapted to new regulatory and market requirements. Among other things, first extended requirements for the traceability of recyclates and first elements of DIN EN 15343 were added alongside the requirements of DIN EN ISO 14021.
Regulatory requirements in Europe keep developing. Markets such as Spain and France, and likewise the Netherlands, Belgium, Poland and Italy, increasingly follow standards-based systems with traceability requirements under DIN EN 15343 and a chain of custody under ISO 22095.
Against that background, an expert panel developed the standalone flustix RECYCLED Certification Programme. It was published on 28 November 2025. Since mid-December 2025, flustix RECYCLED has been licensed exclusively on that basis, through several mutually independent certification bodies that are internationally recognised for this scope. Existing licences were transferred into the new system during the annual surveillance audit in 2026.
The flustix RECYCLED Certification Programme is thereby aligned with the present and future regulatory requirements of the European market. It creates the basis for international recognition and for use in regulatory applications, for example in connection with EPR systems or national plastic taxes.
PPWR, EmpCo, recycled content quotas, PFAS limits: European regulation increasingly demands evidence instead of claims. The key requirements at a glance.
The PPWR is Regulation (EU) 2025/40 on packaging and packaging waste. It has applied directly in all EU member states since 12 August 2026 and replaces Packaging Directive 94/62/EC. It governs packaging across its entire life cycle: substances, recyclability, recycled content, reuse, packaging minimisation, labelling and extended producer responsibility.
The decisive difference from the previous directive lies in its legal form. A directive has to be transposed into national law by each member state, which led to 27 different interpretations. A regulation applies directly: the same requirement applies word for word in Berlin, Barcelona and Bucharest. National rules such as the German Packaging Act are being adapted, but this does not change the direct applicability of the regulation itself.
The PPWR has applied since 12 August 2026. It entered into force on 11 February 2025 and became applicable after an 18-month transition period. The individual requirements take effect in stages:
Several of these dates are lower limits rather than binding calendar dates. The design-for-recycling criteria, for example, apply from 1 January 2030 or 24 months after the corresponding delegated act enters into force, whichever is later. For companies this means the requirements are settled; the exact start date of individual details may still shift.
Responsibility for product conformity lies with the manufacturer within the meaning of the PPWR. That is not necessarily the company that physically produces the packaging. Anyone who has packaging or a packaged product designed or made under their own name or brand is generally the manufacturer themselves.
In its PPWR guidance the European Commission makes clear that for sales and grouped packaging the manufacturer is regularly the party carrying out the final processing steps and filling the product. That is often also the brand owner. Within a supply chain there is generally only one manufacturer within the meaning of the PPWR.
This manufacturer bears the legal responsibility for the conformity of the packaging. Under Article 16, suppliers must provide the necessary information and documents. Responsibility for assessing conformity nevertheless remains with the manufacturer. An exception applies to microenterprises: if a microenterprise has packaging made under its own brand and the packaging supplier is located in the same Member State, the supplier is generally regarded as the manufacturer.
The EU declaration of conformity under Article 39 is the manufacturer's formal statement that a packaging meets the requirements of the PPWR applicable to it. The template is set out in Annex VIII. The underlying evidence is documented in the technical documentation under Annex VII. The declaration is drawn up by the manufacturer and may rely on information and evidence from suppliers. The legal responsibility remains with the manufacturer.
What matters is which requirements are already applicable at the relevant point in time. The basic requirement under Article 6(1) that packaging must be recyclable has applied since 12 August 2026. Until the harmonised design-for-recycling criteria under Article 6(4) are available, however, the Commission does not yet require a conformity assessment under Article 38 and Annex VII for recyclability. The minimum recycled content targets under Article 7 likewise apply only at a later date.
An EU declaration of conformity should therefore not certify blanket compliance with all requirements of Articles 5 to 12, but reflect correctly the requirements actually applicable at that time.
Since 12 August 2026, food-contact packaging may not be placed on the market if it reaches or exceeds any of the following limits:
Total fluorine content is not the same as PFAS content. If total fluorine exceeds 50 mg/kg, it must be possible to demonstrate on request which share of the measured fluorine is attributable to PFAS and which to non-PFAS.
What counts is the food-contact packaging at the time it is placed on the market. The guidance expressly notes that sales and grouped packaging is regularly placed on the market only after filling, when final processing steps such as sealing can affect conformity.
Under the current PPWR guidance, a total fluorine analysis can be sufficient as a first testing step. The European Commission recommends a stepwise testing approach as long as no harmonised EU test method for PFAS in food-contact packaging is available.
If total fluorine content is below 50 mg/kg, or 50 ppm, the sample can be regarded as compliant within this approach recommended by the Commission. According to the data currently available to the Commission, samples that passed this first step also passed the subsequent steps.
If total fluorine content is above 50 mg/kg, further investigation is required, in particular to distinguish between organic and inorganic fluorine and, where relevant, to assess the other PFAS limits.
The guidance is an aid to interpretation, and no harmonised EU test method exists to date. The testing approach behind flustix PFAS-FREE deliberately goes beyond this regulatory minimum and is correspondingly more robust as evidence.
From 1 January 2030, minimum shares of post-consumer recyclate apply to plastic packaging: 30% for contact-sensitive packaging with PET as the main component, 10% for contact-sensitive packaging made of other plastics, 30% for single-use plastic beverage bottles and 35% for all other plastic packaging. From 2040 the figures rise to 50%, 25%, 65% and 65%. The calculation is an average per manufacturing plant and year.
Exemptions include plastic components accounting for less than 5% of the total weight of the packaging unit, compostable plastic packaging and certain packaging for medicinal products, medical devices and dangerous goods. The Commission reviews the list of exemptions by 1 January 2028.
PCR stands for post-consumer recyclate, that is material from waste that has already been with the end consumer. PIR stands for post-industrial recyclate, that is material from production waste that never reached the consumer. Only PCR counts towards the minimum recycled content quotas of the PPWR under Article 7.
This has practical consequences: many suppliers report both together as “recycled content”. Packaging with 30% PIR and 10% PCR does not meet a 30 percent quota, but sits at 10%. Evidence that does not distinguish between PCR and PIR cannot be used for Article 7. The flustix RECYCLED trustmark therefore states the recyclate type explicitly.
The performance grades classify the recyclability of packaging: grade A from 95%, grade B from 80%, grade C from 70%. From 1 January 2030, packaging that does not reach the grade C threshold may no longer be placed on the market. From 1 January 2038, grade C is dropped and only A and B remain permissible.
From 2035 a second dimension is added: the packaging must additionally be recycled at scale. flustix RECYCLABLE assesses recyclability on the basis of the minimum standard under Section 21(3) of the German Packaging Act, DIN EN 13430, ISO 15270 and the PPWR criteria, and states the result as a performance level.
Yes. Producers’ financial contributions under extended producer responsibility are modulated in line with the recyclability performance grades. Easily recyclable packaging is therefore treated more favourably than packaging that is hard to recycle. The Commission sets the precise framework by legal act.
For planning this means the performance grade becomes a cost issue before it becomes a market access issue. Packaging development runs in cycles of three to five years, so the material decision for 2030 is being taken today.
There is no such thing as PPWR certification. The regulation provides for a declaration of conformity by the producer based on its technical documentation, not for certification by a third party.
Independent certifications do however supply robust building blocks for that documentation, for example on recycled content, recyclability, PFAS-free status or plastic content. Anyone holding such evidence bases their declaration on verified data rather than on self-disclosure.
A supplier declaration can form part of the technical documentation and can be an important basis for demonstrating conformity. Article 16 expressly obliges suppliers to make available to the manufacturer the information and documents needed to demonstrate conformity. The European Commission confirms that the manufacturer's EU declaration of conformity may be based on this supplier information.
What matters is therefore not merely whether information comes from a supplier declaration, but whether it robustly and sufficiently substantiates the requirement in question. Responsibility for that assessment, and for the conformity of the packaging, remains with the manufacturer.
Independent testing or certification can reliably underpin that evidence, particularly where product characteristics are to be demonstrated to customers, retailers, authorities or consumers. It is not a mandatory requirement of the PPWR, but it is considerably more robust than a self-declaration from the supply chain.
Yes. The requirements of the PPWR also apply to packaging and packaged products from third countries as soon as they are placed on the Union market. Which obligations fall on the company outside the EU itself, and which on an importer, distributor or other economic operator within the EU, depends on the specific route to market.
The distinction between product conformity and extended producer responsibility is particularly important. For EPR, the PPWR determines the responsible "producer" per Member State according to who first makes the packaging or packaged product available there. In direct sales to end users in another Member State, the foreign seller may itself be the producer for EPR purposes. In classic supply chains via an importer or distributor in the EU, responsibility may instead lie with that European economic operator.
For certain cross-border direct sales, Article 45(3) currently requires an authorised representative for extended producer responsibility in the Member State concerned. Member States may also require such authorisation for producers from third countries.
The PPWR governs the packaging, EmpCo governs what you may say about it. Both apply side by side, cover the same products and have different key dates.
Regulation (EU) 2025/40 on packaging and packaging waste concerns the item itself: the substances it contains, material use, recyclability, recycled content, reuse, packaging minimisation and labelling. Being a regulation, it applies directly in every member state without national transposition. Whoever places packaging on the market has to assess its conformity and document the evidence in a technical file. More on this on the PPWR page.
Directive (EU) 2024/825 concerns not the product but the claim made about it. It sets the conditions under which companies may advertise environmental and sustainability claims or sustainability labels to consumers. Being a directive, it works through national law; in Germany through six new entries on the blacklist in the Annex to section 3 (3) of the Unfair Competition Act. It is enforced not by an authority but by competitors and consumer associations. More on this under Green Claims.
At the packaging on the shelf. The PPWR determines which property a packaging must have and be able to prove, EmpCo determines whether that property may be printed on the pack and how it has to be worded. Recycled content that meets the PPWR requirement is not yet a permissible advertising claim; conversely, a carefully worded claim does not make a packaging compliant.
An independent certification serves both sides: it documents the product characteristic for the technical file and at the same time provides the evidence base that EmpCo requires for communication.
EmpCo is Directive (EU) 2024/825 on empowering consumers for the green transition. It amends the Unfair Commercial Practices Directive and the Consumer Rights Directive and targets greenwashing, opaque sustainability labels and planned obsolescence. The name stands for “Empowering Consumers for the Green Transition”.
It had to be transposed by 27 March 2026 and applies from 27 September 2026. In Germany it lands in the Unfair Competition Act: six new entries on the blacklist in the Annex to section 3 (3), which apply to consumers without exception.
Everything on green claims and EmpCo
Copy link to this questionThe new rules apply from 27 September 2026. Member states had to transpose the directive into national law by 27 March 2026. In Germany this was done by amending the Act Against Unfair Competition (UWG), promulgated in the Federal Law Gazette of 19 February 2026.
Six months lie between the transposition deadline and the date of application, and those are the real window for making changes. No general transition or sell-off period is provided for packaging already printed; what matters is the commercial practice towards consumers, not the date of printing.
As things stand, the implementing act provides for no general transition or sell-off period. Packaging carrying impermissible claims should therefore be changed in good time, because prepress, approval and selling off existing stock all need lead time.
The transposition came as an amendment to the German Unfair Competition Act, promulgated in the Federal Law Gazette of 19 February 2026; the rules apply from 27 September 2026. Anyone planning print production should allow several months: artwork change, internal sign-off, new print run and sell-off of remaining stock happen one after another, not in parallel.
Prohibited above all are generic environmental claims without evidence of recognised excellent environmental performance, claims about the whole product that only apply to one aspect, and product-related climate neutrality claims based on offsetting emissions. Generic environmental claims include “environmentally friendly”, “green”, “ecological”, “climate friendly”, “biodegradable” and “bio-based”.
Six new entries are added to the Annex to section 3 (3) of the Unfair Competition Act in total. They apply per se: unlike with misleading practices, it does not matter whether the claim deceives in the individual case. A claim that names a specific, verified property and supplies the evidence for it remains permitted.
Examples: permitted and prohibited
Copy link to this questionA product-related climate neutrality claim is prohibited if it is based on offsetting greenhouse gas emissions. It remains permissible only if the product is genuinely climate neutral across its entire life cycle. The same applies to wordings such as “CO2 neutral”, “CO2 positive” or “climate friendly”.
The basis is Directive (EU) 2024/825, transposed in Germany as a new entry on the blacklist in the Annex to section 3 (3) of the Unfair Competition Act. It applies without a case-by-case assessment: it does not matter whether the claim misleads in the specific instance. Anyone who still wants to say something verifiable is better served by a measurable product property, such as a stated recycled content.
Examples: permitted and prohibited
Copy link to this questionYes, but only if they were established by public authorities or are based on a certification scheme. Displaying a label that meets neither condition is always impermissible towards consumers. Self-created logos and own labels without independent verification therefore become impermissible, even where the claim is factually correct.
A certification system within the meaning of the rule has to meet four conditions: be open to all companies without discrimination, have developed its requirements with the involvement of experts, provide for sanctions up to withdrawal, and be monitored by an independent body. All four have to be met, not just one.
A certification scheme must make its conditions, including its requirements, publicly available and meet four criteria:
All four must be met. The criteria are set out in Section 2(2)(6) UWG.
The duty to check sits with the company displaying the label. Anyone using a third-party label that does not meet the legal requirements is liable themselves. An assurance from the label owner is not enough; what counts is whether the underlying scheme actually meets the criteria and whether its conditions are publicly available.
Three questions make this checkable: is the certification system publicly documented? Does an independent body accredited for the task carry out the assessment? Can the individual certificate be looked up? At flustix the certification programmes are in the download centre, testing is done by laboratories accredited to ISO/IEC 17025, and every licence number can be viewed in the database.
No, unless they are based on a certification scheme or were established by public authorities. An in-house standard generally does not meet the requirements, because it is neither open to all companies on non-discriminatory terms nor monitored by independent third parties. Existing own labels have to be adapted by 27 September 2026 or may no longer be used towards consumers after that date.
Yes, possibly. The legal definition of an environmental claim expressly covers representations through images, graphic elements and symbols as well as labels, brand names, company names and product names. A graphic element suggesting a positive environmental effect can therefore fall under the same rules as a written claim.
What counts is the overall impression the pack creates, not the single element. Green colouring combined with nature imagery can create the same impression as a written claim and is then subject to the same requirements. Anyone pointing to an environmental benefit visually needs the same evidence as for the sentence beside it.
No. An environmental claim counts as generic if its specification is not given clearly and prominently on the same medium. An explanation that is only reachable via a QR code on a website is not on the same medium and therefore does not cure an unspecific claim on the packaging.
The QR code remains useful for going deeper, but it does not replace the statement on the pack. In practice: the specific property and the reference to the evidence belong right next to the claim, in a legible size. The code then leads to the detail, for instance to the certificate with its licence number.
For cross-border infringements of European consumer protection rules, member states must provide for maximum fines amounting to at least 4% of the company’s annual turnover in the member states concerned.
On top of that come the classic consequences of competition law: warning letters, cease-and-desist undertakings, interim injunctions and cost reimbursement, each forcing a rapid change of packaging and advertising material.
The 4 per cent is a floor for the maximum, not a standard penalty. In economic terms competition law usually weighs more heavily in practice: an interim injunction can be issued within days and forces an immediate change while the packaging material is already produced and sitting in the warehouse.
The new provisions address commercial practices towards consumers. In practice the rules reach deep into B2B relationships, because brand owners and retailers have to obtain evidence from their suppliers in order to communicate safely themselves. For suppliers, robust evidence therefore becomes a condition of staying listed.
For suppliers of raw materials and semi-finished goods, holding the evidence becomes a selling point. The flustix RECYCLED certification programme explicitly applies to every actor along the supply chain who takes ownership of the material, including recyclers and intermediaries with or without their own storage.
A supplier declaration is self-disclosure and does not meet the requirements for a certification scheme. It can form part of internal documentation, but it does not shift liability. Responsibility for an environmental claim towards consumers stays with whoever makes the claim.
What does carry the claim is evidence from a certification system: independent testing, conformity assessment by a third party and publicly available terms. At flustix, laboratories accredited to ISO/IEC 17025 do the testing, certification follows ISO/IEC 17065, and every certificate can be looked up by its licence number in the public database.
EmpCo prohibits certain practices and is already transposed law. The Green Claims Directive would additionally govern how explicit environmental claims have to be substantiated and verified in advance. It is not currently in force, but the Commission continues to pursue it as an ongoing initiative.
For planning purposes: EmpCo is what will be measured against from 27 September 2026, the Green Claims Directive is an outlook. Anyone moving to independently verified evidence today satisfies both, because the requirements point the same way: verifiable rather than asserted.
No, where the substance is already prohibited by law for that product category. Presenting legal requirements as a distinctive feature of your own offer is always impermissible.
The claim remains permissible if it goes beyond the legal requirement, for example through a wider test scope or a stricter limit, and that difference is stated.
The difference has to be named and demonstrable, not merely asserted. A broader scope of testing or a stricter limit than the statutory one carries the claim where it follows from the certification programme and the result has been verified on the product itself.
Name a concrete, measurable property instead of a general effect, and point to the evidence. “Packaging with 85% certified post-consumer recyclate” holds; “environmentally friendly packaging” does not. The specification has to appear clearly and prominently on the same medium as the claim itself.
The rule behind it: an environmental claim counts as generic where its specification is not stated clearly and prominently on the same medium. Being specific, measurable and accompanied by the evidence is therefore not a matter of style but a condition. The free claim check assesses up to five claims and returns a written assessment.
Examples: permitted and prohibited
Copy link to this questionWhat counts is the commercial practice towards consumers, not the date of printing. Since no general sell-off period is currently provided for, existing stock carrying critical claims should be planned for in good time and layouts changed early. The assessment in an individual case should be reviewed legally.
A simple order of work helps: first check which claims on the existing artwork are actually affected, then replace the critical ones, and only then schedule the remaining stock. The free claim check covers the first step and assesses up to five claims against EmpCo and the Unfair Competition Act.
An EmpCo assessment report is a document that places one or more environmental claims against Directive (EU) 2024/825 and national unfair competition law. The term is not defined in law. Whoever offers a report decides what goes into it, and that is where the offers on the market differ considerably.
A report that holds up names three things for every single claim: what it rests on, what is missing if anything, and what it was assessed against. An overall score or a traffic light does not do that, because it does not show which claim fails and why.
One page per claim, as a PDF. On it:
Both have their place. A scanner finds conspicuous wording on a website in seconds and suits a first overview of a large stock. It cannot judge whether a piece of evidence supports the claim, because it never sees the evidence.
Where the point is to have proof ready, what counts is who assessed it and against what. That is why the flustix Claim-Check is produced by hand, by an independent certification body, and takes two to three working days rather than three minutes. Up to five claims are free of charge.
„Green claim assessment" is neither a protected term nor a document regulated by law. In practice it covers three different services that come from different bodies and do different things.
The three do not exclude one another, they answer different questions. A legal opinion says whether wording is attackable. A verification says whether the figure behind it holds.
flustix is an independent certification body and works at the second point: we place claims against EmpCo and unfair competition law, and we certify product properties under published schemes. Every certificate is verifiable with its licence number in our public database.
We do not provide legal advice and issue no lawyer sign-off. Where a claim needs a legal assessment, it belongs with a law firm. The free Claim-Check is the way in: up to five claims, a written assessment, two to three working days.
There are three routes, and which one is right depends on what the claim hangs on. Most cases need two of them.
This is the question of substance: is there data, and does it say what the claim asserts? Testing and certification bodies handle this. For material properties such as recycled content, recyclability, microplastics or PFAS it can be substantiated through a published certification scheme, and the proof is then verifiable by third parties.
This is the legal question. EmpCo is not enforced by an authority but through competition law: competitors and consumer associations can issue warnings and sue. Anyone who needs a binding sign-off for a campaign goes to a law firm specialising in competition law.
This is the inventory question. With hundreds of product pages an automated scanner helps to find conspicuous wording. It does not replace the first two steps, it tells you where to apply them.
With the claims that are already printed or about to be. Packaging layouts need lead time, and from 27 September 2026 the new rules apply with no general transition period.
The free Claim-Check covers the first step: up to five claims placed by hand against the six prohibitions, the requirements for labels and the substantiation duty. You receive a written assessment as a PDF within two to three working days.
Enforcement does not run through a supervisory authority but through competition law. Competitors, consumer associations and qualified entities can issue warnings and bring actions. There is therefore no prior review, only a risk after the fact that can be limited by robust evidence.
In practice this means the evidence is not requested before publication but after a warning letter, and then at short notice. Anyone who first has to obtain it at that point does not have it in time. Certification under a published programme is therefore less a marketing question than a question of having your proof ready.
Products, which are completely free of plastics or which have a plastic free packaging or content and which have passed the laboratory test successfully. The flustix RECYCLED trustmark certifies products, components and raw materials that contain recycled plastics or are made completely of them. flustix RECYCLED is issued on the basis of a certification program by our accredited certification partners. Here, an audit process forms the basis for a successful certification. These products are certified with flustix:
The four different flustix PLASTIC-FREE trustmarks distinguish products that do not contain plastic in the entire product, in the packaging and/or product/contents, thus offering consumers security when purchasing. Contamination of the products due to environmental influences or during the manufacturing process, as well as residues that are sometimes technically unavoidable, cannot be completely ruled out. Consumer demand should encourage companies to use the valuable material plastic sustainably in the design and production of goods and/or to replace it with ecologically sensible alternatives – in order to avoid plastic waste worldwide.
The magenta-colored flustix RECYCLED trustmark can be used to label products, components and raw materials that are made entirely or partially from recyclates; more information can be found at flustix RECYCLED. The flustix RECYCLABLE trustmark, which is also magenta-colored, is suitable for recyclable packaging.
All over. The products certified by flustix are sold online and offline through all official sales channels. The flustix RECYCLED mark is also suitable in the B2B area. For example, suppliers of recycled plastic or semi-finished products with recycled material have their goods certified in order to make the origin and the type of recyclate (PCR / PIR / MIX) transparent to their customers.
The flustix initiative was founded in 2016 by Julia and Malte Biss in Berlin in the interests of environmental protection and aims to provide the end consumer with a clear orientation when shopping by clearly marking plastic-free products and / or low-plastic products. In its creation, the sustainability label flustix has received support in the form of discussions and discussions from the Federal Ministry for the Environment, Nature Conservation, Building and Nuclear Safety and the Federal Environment Agency in the development of the basic concept. Further we receive continous support from our testing laboratory partner, the WESSLING GmbH. We are working closely with our independent and reputed partners in awarding the flustix trustmark, controlling compliance with all standards, and fighting abuse. We flustix founders, Julia and Malte Biss, are not yet plastic-free with our three children. This is almost impossible nowadays – that’s why we are aiming for a constructive environmental protection which, through innovative products, extends the plastic-free offer, and we can develop towards plastic freedom. We try to avoid plastic where possible and useful. The material plastic finds in many areas, such as research, medicine, safety and transport, quite meaningful and vital use and is now indispensable. With our initiative, we want to grow into a plastic-free future. Until then we promote a responsible use at state of the art. This is our approach to deal with the genius and everlasting material: plastic.
flustix verifies and certifies with its accredited partners in the basis of ECHAs definition (incl. ISO/TR 21960:2020 Plastics – Environmental aspects – State of knowledge and methodologies), which is so far the only internationally respected and followed definition of microplastic. It refers to solid, water-insoluble plastic particles which are smaller than five millimetres, based on the longest dimension of the plastic particle, as well as solid, water-insoluble plastic particles which are smaller than five millimetres, based on the diameter of the plastic particle fiber. For flustix this also includes so-called bioplastics, obtained from renewable resources. Following the ECHA definition, liquid and water-soluble plastics are not considered, because they are hardly detected analytically in a qualitatively or quantitatively binding manner according to the current state of technology and therefore a legally binding claim can’t be guaranteed yet. As soon as research on this topic has been optimized, flustix will also include these materials in its certification programs.
To MICROPLASTIC-FREE certification
Copy link to this questionIn everyday use the four words are interchangeable. None of them is legally protected, and none of them says on its own who did the assessing. There is still a difference in emphasis.
Ecolabel is the narrowest term. It usually means the state-backed marks such as the Blue Angel or the EU Ecolabel, which assess a product across its whole life cycle.
Environmental label and sustainability label are umbrella terms for any mark confirming an environmental or sustainability property. A single attribute such as a recycled content falls under them too.
Quality mark is not limited to the environment. It also covers safety, as with the German GS mark, origin, or how an online shop handles a purchase.
Test seal stresses that an assessment took place. The word does not say who assessed. A manufacturer testing its own product can put such a mark on the pack as well.
The ISO 14020 series is sounder than the vocabulary:
Type I under ISO 14024. A programme with published criteria, assessed and awarded by a body that does not itself sell the product. The Blue Angel and the EU Ecolabel belong here.
Type II under ISO 14021. A self-declared claim by the manufacturer, for example „recyclable“ on its own packaging. This is exactly what the EmpCo Directive restricts from 27 September 2026.
Type III under ISO 14025. An environmental declaration with life-cycle figures, without judging whether those figures are good or bad. Known as an EPD in construction.
The flustix trustmarks are third-party marks. Material analysis is carried out by laboratories accredited to ISO/IEC 17025, and conformity is assessed by certification partners accredited to ISO/IEC 17065. flustix does not assess its own marks. How that works in detail is set out in the certification process. Every certificate carries a licence number and can be looked up in the public database.
An environmental label is a mark on a product, a package or in advertising that confirms a particular environmental property. The term itself is not protected. Anyone may design a mark and call it an environmental label, so the mark alone says nothing about the testing behind it.
Verified third-party labels. An independent body assesses against a published programme, issues a licence number and re-checks. The Blue Angel, the EU Ecolabel and the flustix trustmarks belong here.
Marks run by industries, associations or retailers. Criteria and award sit with a group that is itself active in the market. The requirements can be demanding, but the independence is of a different kind.
Self-awarded company marks. A logo a company designs and grants itself. From 27 September 2026 the EmpCo Directive forbids exactly this: sustainability marks without a certification scheme or a public authority behind them may no longer be used.
1. Who assesses? The label owner itself, or an accredited independent body?
2. What exactly was assessed? The whole product, the packaging only, a single raw material?
3. Can it be looked up? A sound label carries a number and a public database.
4. How long is it valid? Without an expiry date and re-checks, a statement from years ago simply stays on the pack.
The flustix trustmarks name in the mark itself what they refer to, carry a licence number and can be verified in the public certificate database. How an assessment works, who is involved and how long a certificate stays valid is set out in the certification process.
A flustix trustmark means that a particular property of that product has been independently tested and confirmed under a defined certification programme. Which property that is appears in the trustmark itself: plastic-free, plastic-reduced, microplastic-free, recyclable, PFAS-free or with a stated recycled content.
Every trustmark carries a licence number that lets you verify the certificate in the public database. A trustmark is not a general sustainability statement about the company, but evidence for exactly the property named on it.
Not every plastic ends up in the bin. On the beach we lose our flip-flops, in the park we forget the PET bottle or the candy packaging. Sooner or later, this garbage gets into our rivers and seas and is mistaken for food by birds or other animals. The problem: plastic does not rot. Larger plastic parts are a danger to marine life and birds, which are caught in the garbage and die, as you can see it on our doorstep on Helgoland with the basal boobies. Smaller pieces of plastic are confused by the animals with food until they starve to death with a full stomach. In addition, chemicals such as softeners and hardeners from the plastics. These are harmful to humans and animals. Incidentally, not even 45 percent of the plastic waste generated in Germany is recycled (2015 figures) and per capita consumption is still rising. The majority is still used for energy purposes – burned because it is more economical and / or the packaging consists of low-quality mixed plastics.
Packagings
Perhaps the most obvious use of plastic is single-use packaging. These include, among other things, deposit-free plastic bottles, chips or other bags, films and / or other disposable containers. Most of these consist of mixed plastics, which can hardly be recycled at all.
Plastic around and in food
Most foods are packed in plastic. Chemicals such as plasticizers and many other substances dissolve out of the package and enter, e.g. on oily and fatty foods over. Added to this is the microplastic, plastic particles smaller than five millimeters. These drift in the sea, are confounded by seafood and birds with food and eaten. The chemicals in the plastic go into the body of the animals and come back to us. With animals that are consumed as a whole (for example, mussels) or high-quality sea salts and even through drinking water, the plastic waste is now being absorbed directly by us, the human being.
Plastic in cosmetics
At least 500 tons of plastic pass through our German outlets unfiltered into our drinking water cycle every year. Shower gel, toothpaste, shampoos and scrubs mostly contain plastic (microplastic or liquid plastics). Often, the microparticles should enhance the cleaning effect of the products. But also as opacifiers, fillers or as a substitute for vegetable oils, plastics are used in cosmetics and make-up. Here are just a selection of products that use microplastic and liquid plastics:
– Cleaning products: scrubs, toothpaste, shower gel, shampoo, make-up remover
– Skin care products: body lotion, sunscreen, facial, hand and foot cream, shaving cream
– Make-up: lipstick, make-up, eye shadow, mascara
Plastic clothing – fleece, polyester and co.
Also, our clothing contains more and more plastics, including polyester, nylon and elastans. A fleece garment can lose up to 2,000 fibers in each wash, which can be discharged into the drinking water cycle or into the sea via the wastewater without being filtered. Scientists have detected polyester and acrylic fibers in the sand at 80 beaches on all continents. The closer the samples were taken to large cities, the higher was the burden of plastic waste.
The littering of our planet, because plastic lasts forever: if we do not collect it, it remains in nature and scatters. Even in the Antarctic, in the “still” eternal ice, just 30 years old plastic from Germany has just been detected. Most of the lost plastic waste ends up in the sea. Due to the ocean currents, five particularly large garbage strudels have formed worldwide, the so-called “garbage patches”. The biggest is the “Great Pacific Garbage Patch” (four times the size of France). Scientists suspect several million tons of plastic alone in this one whirlpool. Whether in the sea or on land, plastic is increasingly becoming a health threat to humans and animals. Present and future generations are affected by premature puberty, chalk disease, malformations and – in newborns and other as yet incomplete research on diseases directly related to our current inflationary plastic consumption.
Last updated: August 2026
Editorial responsibility: Malte Biss, CEO & Founder of flustix