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Free Claim CheckFrequently asked questions
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.
A flustix certification is independent evidence of a single, measurable product property, assessed against a published certification programme and confirmed by an accredited body. The result is a certificate with a licence number, a public entry in the certification database and the right to carry the corresponding trustmark.
flustix issues the trustmarks and writes the programmes but does not test itself. Laboratory analyses run through laboratories accredited to ISO/IEC 17025, the conformity assessment through certification bodies accredited to ISO/IEC 17065. That separation is why the trustmark works as evidence towards third parties.
After the enquiry a quotation follows within two to three working days; the assessment itself takes four to twelve weeks depending on the programme. Costs consist of the one-off testing effort and the ongoing licence fee; the fee structure with all packages is openly available in the download centre. The full route is set out on the page about the certification process.
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.
How long a trustmark certification takes is determined by three things: the type of testing, how complete the documentation is, and laboratory capacity. A laboratory analysis of individual substances can be done in weeks. A supply chain audit, as recycled content or chain of custody require, takes longer because upstream suppliers have to produce evidence of their own. Missing data sheets or formulations push everything back, whoever issues the trustmark.
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.
With any trustmark certification the cost has two parts: the one-off testing effort and the ongoing licence fee for using the mark. The testing effort depends on whether assessment runs through a laboratory or a supply chain audit and how many products are involved. The licence fee depends on the extent to which the trustmark is used and in which markets.
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.
The licence fee structure with all packages and the services they include is openly available in the download centre. We deliberately do not quote single prices as line items there, because they depend heavily on how many certifications come together: from the second trustmark onwards, the effort per piece of evidence drops considerably.
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.
There is no official list of accepted trustmarks, and no retailer keeps one. What retailers check is something else: whether the claim on the pack holds up, and whether the supplier can produce the evidence for it.
The EmpCo directive answers the question. A sustainability label may only be used towards consumers if it is based on a certification scheme or was established by a public authority. Self-awarded logos drop out. For retail that means the label has to be verifiable: a published programme, an independent assessment, a licence number and follow-up checks.
Because liability sits with them. The duty to check falls on the company displaying the label, not on the label owner. With own brands the retailer is the brand owner and therefore the party making the claim. An assurance from the supplier does not discharge that.
Anyone with a substantiated answer to all four is in the conversation. Anyone with only a logo is not.
Every certificate carries a licence number and can be looked up in the public database, the certification programme is published, testing runs in laboratories accredited to ISO/IEC 17025 and assessment follows ISO/IEC 17065. Through the sub-licence system the evidence can be passed along the supply chain so the retailer can take it into their own file.
That depends on what the existing certification covers, and on whether you want to claim anything towards consumers.
A chain-of-custody or mass-balance certificate documents the route of the material, not the property of the individual product on the shelf. Schemes such as ISCC PLUS, GRS or RCS are built to make flows and origin traceable across several stages. That is a different question from: does this particular pack contain the share printed on the front?
A claim on the packaging needs evidence whose subject is exactly that claim. A chain-of-custody certificate therefore does not replace a consumer trustmark, and a consumer trustmark does not replace a chain of custody.
When you make no claim towards consumers. Anyone documenting recycled content only for business customers, or substantiating it for a quota, is fine with the evidence they have. EmpCo bites where something is asserted towards consumers, including through a mark, a symbol or a design.
When the claim is to go on the pack, into the shop or into advertising. What counts then is whether the mark meets the requirements for a certification scheme and whether a consumer can verify it.
Where a certification already exists, the chain does not have to be rebuilt. The flustix sub-licence system transfers existing evidence onto the specific product under defined conditions. Existing test reports and analyses are credited, as far as scope, method, accreditation and currency fit.
To the flustix sub-licence system
Copy link to this questionThere is no exhaustive list, but there is a useful ordering: labels differ less in how strict they are than in their subject, that is in what they actually assess.
The list shows the pattern: most well-known marks assess a product group or a method of production. They are not built for a single measurable material property of the kind EmpCo and the PPWR require.
Since 27 September 2026 there is a legal benchmark for this. A sustainability label may only be used towards consumers if it was established by public authorities or is based on a certification scheme that makes its conditions public and meets four criteria: open to all companies on non-discriminatory terms, requirements drawn up with experts, procedures for non-compliance up to withdrawal, and compliance monitored by an independent third party.
Three things make that checkable in practice: is the programme publicly available? Is the assessing body accredited, usually to ISO/IEC 17065? Can the individual certificate be looked up, for example by a licence number in a public register?
Which trustmark fits which claim is set out in the trustmark overview.
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 the Packaging Directive 94/62/EC. It governs packaging across the entire life cycle: substances, recyclability, recycled content, reuse, packaging minimisation, labelling and extended producer responsibility.
A directive had to be transposed into national law by every member state, which produced 27 readings. A regulation applies directly: the same requirement word for word in Berlin, Barcelona and Bucharest. National rules such as the German packaging act are being adapted but do not change that direct application. For companies this shifts the work from national adaptation to evidence: no longer “what does this market require?” but “what do I substantiate it with?”.
The core material requirements arrive in stages, and several dates are lower bounds: if the corresponding legal act comes later, the date moves with it. Harmonised labelling of material composition from 2028 at the earliest, design-for-recycling criteria with performance grades and the first minimum recycled content for plastic packaging from 2030 at the earliest, the additional assessment of recycling at scale from 2035 at the earliest, only grades A or B from 2038, and the second quota stage from 2040.
The regulation distributes the duties; it does not distribute the evidence. Central responsibility for conformity sits with the producer, in practice often the brand owner, even where packaging or product were developed or manufactured by third parties. Suppliers have to provide the information and documents needed for that. Extended producer responsibility is a separate question: who counts as producer there depends on who first makes the packaging available in a given member state.
The text is in the Official Journal. Which requirement applies when, and who is responsible for it, is set out in detail on the PPWR page.
The PPWR has applied since 12 August 2026. It entered into force on 11 February 2025; after a transition period of 18 months it became applicable. The individual requirements arrive in stages.
Some of these are not fixed 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 that means the requirements are settled while the start date of individual details may move back. Plan against the earlier date: anyone who waits for the legal act has no lead time left.
The deadlines from 2030 look distant but are not. Packaging that has to reach performance grade C in 2030 is being developed, signed off and tooled today. Decisions on material, multi-layer structure, label, adhesive and ink determine the later recyclability, and tools are not replaced every year.
What is immediate is this: check whether the substance limits under Article 5 are met and evidenced, clarify the three PFAS limits where there is food contact, and build the technical documentation for the requirements that already apply. The deadlines and duties in detail are on the PPWR page.
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 producer’s formal statement that a packaging item meets the PPWR requirements applicable to it. The template is in Annex VIII, and the underlying evidence belongs in the technical documentation under Annex VII.
The declaration is drawn up by the producer and may rely on information and evidence from suppliers. Legal responsibility stays with the producer. An assurance from someone else does not discharge it.
What matters is which requirements already apply at the time. The basic requirement in 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 in place, however, the Commission does not yet require a conformity assessment under Article 38 and Annex VII for recyclability. The minimum recycled content under Article 7 likewise applies only later.
An EU declaration of conformity should therefore not sweepingly certify compliance with all requirements of Articles 5 to 12, but reflect accurately the requirements that actually apply at that point. A declaration claiming more than has been assessed creates precisely the risk it is meant to avert.
Annex VII requires a general description of the packaging and its use, information on material and composition, design and manufacturing documents, and the test reports and assessments on which conformity rests. In practice: one source per requirement, and that source has to be presentable.
Nobody can issue the declaration on the producer’s behalf. Two different things can be supported, and they come from different places:
The second part is what holds up in a dispute. Which four kinds of evidence flustix provides is set out on the PPWR page.
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.
The Single-Use Plastics Directive names no figure. It asks whether plastic acts as a main structural component and leaves the assessment to the individual case. That is precisely the point of contention: paper and board always contain polymer-based additives such as sizing and wet-strength agents, without which they would not have their properties.
Six technical sources average 0.93 per cent of dry weight as the technically necessary polymer content. Adding the scientifically recognised trace allowance of 0.1 per cent gives a derived overall threshold of 1.03 per cent. These additives are functionally necessary and do not form a plastic matrix of their own.
Without a threshold it remains open, four years after the directive took effect, whether a fibre-based cup falls under it. The flustix LESS PLASTICS PRODUCT mark works with 0.75 per cent and therefore sits below the derived value. The full derivation with all six sources is set out in the scientific derivation.
For the first testing step yes, as the sole piece of evidence no. Where total fluorine stays below 50 mg/kg (50 ppm), the sample counts as compliant under the stepwise approach recommended by the European Commission, and targeted PFAS analysis is not required. Above that, organically and inorganically bound fluorine have to be distinguished and the further limits evidenced individually.
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.
Yes. Trifluoroacetic acid (TFA, CAS 76-05-1) is part of the target panel of the flustix PFAS-FREE certification scheme, explicitly as an ultra-short-chain PFAS. Perfluoropropionic acid (PFPrA) and the modern replacement substance ADONA are included as well.
Many test panels cover the classic long-chain compounds, so PFOA, PFOS and their relatives. Ultra-short-chain PFAS with two or three carbon atoms slip through, even though they are precisely what fluorinated chemistry degrades into. The flustix panel deliberately goes beyond looking at legacy substances alone.
For the individual target substances: a product meets the analytical requirement when they stay below the limit of quantification documented for the method, as a rule 10 to 25 ppb per substance or stricter. On top of that comes the fluorine sum parameter for the relevant product group. It is the two together that carry the statement, not either one alone. The full list of target substances is in Annex A of the certification scheme, the limits per product group are on the page about flustix PFAS-FREE.
Yes. Textiles and textile products are a product group of their own in the flustix PFAS-FREE certification scheme, including clothing, home textiles, technical textiles and coated or finished textile materials.
Testing focuses on impregnations, coatings and water-, oil- or soil-repellent finishes. That is where fluorinated functional chemistry sits, if it was used at all. Target substances have a limit of quantification of as a rule 10 to 25 ppb per substance, the fluorine sum parameter is at most 40 ppm.
Raw and intermediate materials can be certified where they are a certification object in their own right or can be clearly assigned to a later one. A finisher or coater can therefore have the fabric tested before it becomes a finished product. The limits for all eight product groups are on the page about flustix PFAS-FREE.
None. The PPWR does not provide for verification by a third party. The manufacturer as defined by the regulation assesses conformity itself, documents it technically and issues an EU declaration of conformity. Whoever places packaging on the market under their own name or brand is that manufacturer, even when they do not produce it.
For individual requirements of the regulation there are tested proofs, and those come from accredited bodies. Recycled content under DIN EN 15343 and ISO 22095, recyclability with performance grades, PFAS-free status, plastic content. Such proof does not replace the declaration of conformity, it supports it: the technical documentation then rests on tested data instead of self-declarations from the supply chain.
It rests on a published certification scheme, conformity is assessed by a body accredited to ISO/IEC 17065, the analysis runs through laboratories accredited to ISO/IEC 17025, and the individual certificate can be looked up by number. Providers calling themselves “PPWR certifiers” usually offer consulting or software, not the testing of a material property. Which four proofs flustix supplies is set out on the PPWR page.
From 1 January 2030, minimum shares of post-consumer recyclate apply to plastic packaging:
From 2040 the figures rise to 50 %, 25 %, 65 % and 65 %.
The figure is an average per manufacturing plant and year, not per individual pack. That is a considerable relief and at the same time a documentation task: anyone relying on the average has to account for the year’s material flows in a verifiable way.
Only post-consumer recyclate counts. Post-industrial recyclate from production waste does not, however high its share.
Exempt are, among others, plastic components making up 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. Anyone relying on an exemption today should keep that review in view.
2030 sounds distant but is not: sourcing recyclate, qualifying the material, adapting tools and sign-offs all need lead time, and the market for food-grade PCR is tight. Three steps pay off early:
There is a commercial argument on top: in Spain and France a substantiated recycled content feeds directly into the plastic tax.
PCR stands for post-consumer recyclate, material from waste that has already reached the end consumer. PIR stands for post-industrial recyclate, material from production waste that never reached a consumer. Only PCR counts towards the minimum recycled content quotas under Article 7 of the PPWR.
Many suppliers report both together as “recycled content”. Packaging with 30 % PIR and 10 % PCR does not meet a 30 per cent quota; it sits at 10 %. Evidence that does not separate PCR and PIR cannot be used for Article 7 at all, no matter how high the combined figure is.
This cuts both ways: counting PIR overstates the quota, while reporting only part of the actual PCR out of caution gives away material that has already been paid for.
PIR is not inferior material, quite the opposite: it is usually single-grade and well documented. It does not count towards the Article 7 quota, but it certainly counts for a recycled content claim, provided the claim names the type. The mistake is not using PIR, it is failing to declare it separately.
It must declare PCR and PIR separately, make the origin traceable and account for the material flows in a verifiable balance. The standards for this are DIN EN 15343 for traceability and DIN EN ISO 22095 for chain of custody. The flustix RECYCLED trustmark therefore states the recyclate type explicitly, and its certification programme refers to both standards.
One practical question to the supplier separates usable figures from useless ones: what is the content, and which share of it is post-consumer? Anyone without a substantiated answer has a number, not evidence.
Through an audit of the supply chain, not through a single laboratory analysis. Recycled content cannot be reliably determined analytically on the finished part, because recycled and virgin polymer are chemically identical. What is verified is therefore the route of the material and the mass balance, back to the waste source.
An enquiry is usually answered with a quotation within two to three working days. The documents are then reviewed, a qualified auditor assesses the supply chain, and an independent certification body assesses conformity to ISO/IEC 17065. Depending on the programme and the product this takes four to twelve weeks. The certificate is then published in the public database.
It states the verified percentage, the recyclate type and the scope, that is which product exactly is covered. It rests on a published programme referring to DIN EN 15343 for traceability and DIN EN ISO 22095 for chain of custody. And it is verifiable by third parties, usually through a licence number.
A figure that comes only from a supplier data sheet does not meet this. It is the starting point of the assessment, not its result.
Three things, in this order.
“Made from recycled material” is not a verifiable claim. It becomes verifiable once it is settled what it refers to (product, packaging or only one component), how high the share is and which type is meant, post-consumer or post-industrial. If the claim covers the whole pack while only the cap contains recyclate, it has been prohibited since 27 September 2026 regardless of any evidence.
A supplier declaration is not enough for this: it is a self-declaration and does not shift liability. What is needed is evidence from a certification scheme with published requirements, an audit of the supply chain and a conformity assessment by an independent body.
This is where it stalls in practice. The retailer needs something for their own file, because the duty to check falls on the company displaying the label, and with own brands that is the retailer. A certificate with a licence number they can look up in a public register meets that. A PDF without a register does not.
Where the supplier already holds a certification, it can be transferred onto your product through the sub-licence system instead of rebuilding the chain. And if it is unclear whether the wording is permissible at all, the free claim check assesses up to five claims before you enter certification.
These systems compete less than it looks. They answer different questions, and in many supply chains two of them make sense at the same time.
If the point is to make flows and origin traceable across several stages, a chain-of-custody system is the right tool. If the point is to put a figure on the packaging that a consumer must be able to verify, what counts is evidence whose subject is exactly this product and exactly this figure.
That is not a contradiction. An ISCC PLUS certified material stream and a consumer trustmark on the finished product do not exclude each other, they prove different things. Where evidence already exists, we credit it instead of repeating the assessment.
There only post-consumer recyclate counts. Evidence that does not separate PCR and PIR is useless for Article 7, whichever system sits behind it.
The performance grades classify the recyclability of packaging by the share that can actually be recycled: grade A from 95 %, grade B from 80 %, grade C from 70 %.
The grade is therefore not a distinction but a threshold for market access. Packaging at grade C can be placed on the market from 2030 and no longer from 2038.
From 1 January 2035 a further assessment is added: the packaging must also be recycled at scale. What is meant is not theoretical recyclability in the laboratory but whether functioning collection, sorting and recovery exist for this material in sufficient volume. Packaging can therefore be well designed for recycling and still be affected if no real recovery route exists for it.
It is decided in the design, not in the test. Typical losses come from material combinations that cannot be separated, full-body labels and sleeves, adhesives that do not release during washing, barrier layers, colouring, and closures made of a different material from the container. Anyone who measures the grade shortly before 2030 no longer has any way of influencing it, because tooling and sign-offs are fixed by then.
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. The result feeds into the technical documentation as verified evidence and can be used well before 2030 to back up design decisions.
One side effect pays off earlier than the deadline: in several member states recyclability already feeds into the fees under extended producer responsibility.
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 on the basis of their technical documentation, not for third-party certification. Whoever places packaging on the market under their own name or brand is that producer, even if they do not manufacture it themselves.
For individual requirements of the regulation there is verified evidence, and it comes from accredited bodies:
Such evidence does not replace the declaration of conformity, it supports it: the technical documentation then rests on verified data instead of self-declarations from the supply chain.
Providers selling “PPWR certification” are as a rule offering consultancy, software or a document template, not the testing of a material property. Three questions settle it quickly:
Which four kinds of evidence flustix provides, and how they feed into the technical documentation, is set out on the PPWR page.
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 PPWR requirements also apply to packaging and packaged products from third countries as soon as they are placed on the Union market. What matters is market access, not where the company is established.
Product conformity. The packaging has to meet the requirements, and someone has to assess, document and declare that. Who that is depends on the route to market: it can be the producer in the third country, it can be the importer in the EU.
Extended producer responsibility. Here the PPWR determines the responsible “producer” for each member state by who first makes available the packaging or packaged product there. In direct sales to end users in another member state the foreign seller can itself be the producer for EPR purposes. In classic supply chains through an importer or distributor in the EU, responsibility can sit with that European operator instead.
For certain cross-border distance sales, Article 45(3) as it currently stands requires an authorised representative for extended producer responsibility in the member state concerned. For producers from third countries, member states may require such an appointment on top of that.
Three points decide whether a shipment into the EU goes through:
Evidence that rests on a published certification programme, tested in laboratories accredited to ISO/IEC 17025 and assessed under ISO/IEC 17065, travels internationally and can be passed along the supply chain through the sub-licence system.
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 is not a free-standing regulation but amends two existing directives: the Unfair Commercial Practices Directive (2005/29/EC) and the Consumer Rights Directive (2011/83/EU). It was adopted on 28 February 2024, had to be transposed by 27 March 2026 and applies from 27 September 2026.
The name sounds like consumer information. In practice EmpCo is competition law. Germany transposed it by amending the Unfair Competition Act, promulgated in the Federal Law Gazette of 19 February 2026. Six new entries now sit on the blacklist in the annex to section 3(3) of that act. What stands there is prohibited towards consumers in all circumstances, with no balancing of interests and no case-by-case assessment.
From that follows the most important practical difference to regimes such as the PPWR: there is no authority that reviews anything in advance, and no approval procedure. Enforcement runs through competitors, consumer associations and qualified entities, that is through warning letters and litigation after the fact. The evidence is not requested before publication but after a complaint, and then at short notice.
Three changes in the operative text apply case by case and are often overlooked. Environmental and social characteristics as well as circularity aspects such as durability, reparability and recyclability now expressly count among the main characteristics of a product. Forward-looking claims about future environmental performance are misleading unless they rest on clear, objective, publicly available and verifiable commitments. And comparison services must disclose their method.
The directive does not regulate the composition of products, only how they are presented to consumers. It covers every commercial practice towards consumers: packaging, label, website, online shop, social media, catalogue, trade fair stand and point of sale. Images, symbols and brand names count too. Pure business-to-business communication is outside its scope, but any statement that travels from a data sheet or a sustainability report into consumer advertising is not.
Inventory every environmental claim, assign each to one of the six numbers, and for the critical ones either obtain robust evidence or make the wording specific enough that it is no longer a generic environmental claim. Packaging artwork first, because prepress, sign-off and selling off stock run one after another. Everything on EmpCo, and the free claim check assesses up to five claims.
Everything on green claims and EmpCo
Copy link to this questionEmpCo applies from 27 September 2026. That is not a date from which something can be applied for, it is the day the new prohibitions start to apply towards consumers.
The implementing act provides for no general transition or sell-off period. What counts is the commercial practice towards consumers, not the date of printing. The rules therefore expressly also cover packaging manufactured, ordered, distributed or placed on the shelf before the application date.
In June 2026 the national authorities in the European Consumer Protection Cooperation Network (CPC) published a common understanding on this. Enforcement may be phased where old stock gives rise to genuine and specific transitional difficulties, and practical constraints such as packaging cycles, stock volumes, orders already placed and long shelf lives may be taken into account. What is expected in return are all reasonable and proportionate efforts, evidenced by records showing what was done and when. That is not a sell-off period, and the paper is not binding either.
Anyone planning print production should allow several months. Artwork change, internal sign-off, a new print run and selling off remaining stock happen one after another, not in parallel. Claims online are the opposite case: they can be changed without lead time, which is why they come first in the authorities’ own list.
EmpCo is not the end of the development. The Green Claims Directive is a separate act governing how environmental claims must be substantiated and verified in advance. It is not yet applicable and its timetable is open. Meeting the EmpCo requirements today works in the same direction. Everything on EmpCo.
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.
The rules expressly also cover packaging manufactured, ordered, distributed or placed on the shelf before the application date. In June 2026 the national authorities in the European Consumer Protection Cooperation Network (CPC) published a common understanding on this: enforcement may be phased where old stock gives rise to genuine and specific transitional difficulties, practical constraints such as packaging cycles and orders already placed are taken into account, and in justified cases compliance comes before sanctions. What is expected in return are all reasonable and proportionate efforts, evidenced by records showing what was done and when. That is not a general sell-off period, and the paper is not binding either.
It is not too late, but it is not a free pass either.
The rules apply from 27 September 2026, including to goods manufactured, ordered or distributed before that date. There is no general transition or sell-off period.
In June 2026 the national authorities in the European Consumer Protection Cooperation Network (CPC) published a common understanding on old stock. It states that enforcement may be phased where genuine and specific transitional difficulties exist, and that authorities may take into account a trader’s role, size, available resources and concrete efforts to comply in good faith. As evidence of such efforts the paper expressly names records showing the steps taken and their timing, internal compliance policies, substantiation work and other compliance initiatives.
A process that has been started, with a dated enquiry, laboratory testing commissioned and the conformity assessment under way, is exactly that kind of documented substantiation work. A company visibly pursuing the evidence stands in a different position from one that has done nothing.
A certification in progress does not make an impermissible claim permissible and does not automatically protect against enforcement. The paper concerns old stock and genuine, specific transitional difficulties; it is neither a formal position of the network nor a binding interpretation of the directive, and it does not bind the courts. For packaging newly designed after the application date it does not apply at all.
Correct the claims online first: they come first in the authorities’ own list because they can be changed without lead time. Then promotional and sales materials, then future packaging and new orders. The free claim check assesses up to five claims and shows which of them are critical in the first place.
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 questionIt is not the word that is prohibited but the basis behind it. What is prohibited is a product-related claim that rests on the offsetting of greenhouse gas emissions and states that the product has a neutral, reduced or positive impact on the environment. The same applies to “CO2 neutral”, “CO2 positive” and “climate friendly” where offsetting payments are the basis.
The rule sits as number 4c on the blacklist in the annex to section 3(3) of the German Unfair Competition Act and has applied since 27 September 2026 without any case-by-case assessment. It therefore does not matter whether the claim actually misleads in the individual case, nor whether the offsetting projects are sound.
The claim remains permissible where the product genuinely is climate neutral across its entire life cycle, that is without offsetting. That is the difference between a property and an accounting exercise.
Statements that name and substantiate an actual reduction also remain permissible, for example a quantified cut in emissions against a clearly described baseline. Anyone stating future targets needs clear, objective, publicly available and verifiable commitments; a declaration of intent is not enough.
Climate claims on packaging are often the most convenient way to assert sustainability, and from the application date they are the riskiest. The way out is not a different wording of the same claim but a measurable product property: a declared recycled content, verified recyclability, tested freedom from microplastics or a substantiated plastic content below a threshold. Such statements are verifiable, they rest on a published programme, and they fall under none of the six numbers.
There is no general sell-off period. For goods already on the market the Commission services name covering or correcting the claim and adding supplementary information at the point of sale. Online the claim should go first: there it can be changed without lead time.
Examples: permitted and prohibited
Copy link to this questionYes, but only by two routes: the label must have been established by public authorities or be based on a certification scheme. A label that meets neither may no longer be displayed towards consumers, even where the underlying claim is factually correct.
This covers marks such as the EU Ecolabel or the German Blauer Engel, which rest on a public legal act. One restriction matters here, and the Commission services have stated it expressly: what is meant are authorities in the EU. A label established by an authority outside the EU is prohibited under number 2a unless it is additionally based on a certification scheme.
A certification scheme must make its conditions, including the requirements, publicly available and meet four criteria: be open to all traders on transparent, fair and non-discriminatory terms, draw up its requirements in consultation with experts and stakeholders, provide procedures for non-compliance up to withdrawal of the label, and have compliance monitored by an independent third party. All four must be met, not just one.
By this route established private programmes remain permissible, for example FSC, PEFC or Fairtrade, and by the same route the flustix trustmarks: a published programme, laboratory testing in laboratories accredited to ISO/IEC 17025, conformity assessment to ISO/IEC 17065 by independent certification partners, and a certificate that can be looked up by its licence number in the public database.
Self-created logos, own labels and in-house standards without independent verification. A label whose compliance the company checks itself already fails the fourth criterion. That includes the sustainability marks retail chains run on their own brands.
The duty to check lies with the company displaying the label, not with the label owner. Anyone using a third-party label that does not meet the requirements is liable themselves; an assurance from the label owner is not enough. In practice that means checking three things before use: are the conditions and requirements publicly available? Who monitors compliance, and is that body independent? Is there a defined procedure for withdrawal? Anyone unable to answer those three questions is not looking at a certification scheme.
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.
Responsible is whoever makes the claim towards consumers. That is usually the brand owner or the company placing the product on the market. It stays that way even where the underlying data comes from a supplier and where the label was issued by a third party.
Not an authority, but competitors and consumer associations. In Germany the EmpCo Directive takes effect through six new entries on the blacklist annexed to section 3(3) of the Act Against Unfair Competition (UWG). An infringement can therefore be pursued by way of a formal warning, regardless of whether anyone was harmed. For cases with cross-border relevance, European consumer protection rules additionally provide for fines whose maximum must amount to at least 4 % of annual turnover in the member states concerned.
It does not take the responsibility away, it provides the basis. In a dispute what counts is whether the claim is substantiated. Evidence from an accredited body moves the discussion from “this is what we say” to “this is what was measured”. Which role in your supply chain carries which risk is set out on the page about green claims and EmpCo.
With the flustix Claim Check. Up to five environmental claims are assessed against the EmpCo Directive (EU) 2024/825 and German unfair competition law. Submitting takes about ten minutes, the assessment arrives within two to three working days as a PDF, one page per claim. It costs nothing and commits you to nothing.
Each claim receives one of four ratings: substantiated, substantiable, not substantiable, or outside the scope of the review. Alongside it you get what the rating turns on and, where possible, a suggested wording. The review covers the six commercial practices that are unlawful in all circumstances from 27 September 2026, the requirements for sustainability labels and the duty to substantiate.
A written assessment, not a legal opinion and not sign-off from a lawyer. If you need binding clearance for a campaign, add a law firm specialising in unfair competition law.
Automated scanners search websites and catalogues for conspicuous wording. They find the places but do not assess them: whether the data behind a claim carries it is not something a text scanner can see. For material properties such as recycled content, recyclability, microplastics or PFAS that is the actual question, and it can only be answered through a published certification programme.
Three kinds of provider, and they check different things.
flustix checks up to five environmental claims against the EmpCo Directive and German unfair competition law. You submit the claims exactly as they appear on packaging, label or website; the form takes about ten minutes. Within two to three working days a PDF arrives with one page per claim: substantiated, substantiable, not substantiable or outside our scope, plus what it hangs on and, where possible, a suggested wording.
The result is a written assessment, not a legal opinion and not clearance by a lawyer. It costs nothing and commits you to nothing. To the claim check.
No, unless the logo is based on a certification scheme or was established by public authorities. Since 27 September 2026 this sits on the blacklist of the German Unfair Competition Act, number 2a, and applies towards consumers in all circumstances. The underlying claim may well be factually correct; displaying the mark is prohibited nonetheless.
A certification scheme must make its conditions, including the requirements, publicly available and meet four criteria:
An in-house standard generally fails this: it is not open to other companies, and it is not monitored by an independent third party. A label whose compliance the company checks itself already fails the fourth criterion.
This is not only about small house marks. Retail chains run their own sustainability marks on their own brands, setting the criteria themselves and checking compliance themselves. Towards consumers that is no longer permissible from the application date unless an independent scheme sits behind it. On top of that, the retailer is the brand owner of its own brands and therefore the party displaying the mark. The duty to check lies with the company displaying the label, not with the label owner. Anyone using a third-party label that does not meet the requirements is liable as well; an assurance from the label owner is not enough.
Existing own labels have to be adapted by the application date or may no longer be used towards consumers after it. For goods already produced or distributed before then, the Commission services name practical routes: covering the mark, correcting the claim or adding supplementary information at the point of sale.
Not every graphic element is a label. A green leaf, a globe or an all-green design is not a sustainability label within number 2a, but it can amount to a generic environmental claim under number 4a where it creates the impression of environmental performance. The line is drawn by the overall impression. The free claim check looks at up to five claims and marks.
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, at least not as a substitute for the statement on the pack. An environmental claim counts as generic where its specification is not provided in a clear and prominent manner on the same medium. An explanation that is only reachable through a QR code on a website is not on the same medium and therefore does not cure an unspecific claim on the packaging.
If the claim is on the packaging, the specification belongs on the packaging. If it is in an advertisement, it belongs in the same advertisement. If it is on a product page in a shop, it belongs on the same page, and placed so that it is perceived together with the claim, not behind a collapsed panel at the bottom.
As depth, not as the proof itself. The specific property and the pointer to the evidence belong right next to the claim and in legible size; the code then leads to the detail, for example the certificate with its licence number or the certification programme.
Not: “environmentally friendly” plus a QR code. Instead: the specific, verified property directly with the claim, for example a declared recycled content with the trustmark beside it, and the QR code leading to the entry in the public certificate database. The claim then stands on its own and the code makes it verifiable.
The difference is not a formality. A generic environmental claim without demonstrated recognised excellent environmental performance sits on the blacklist and is prohibited with no case-by-case assessment. A QR code does not change that; a specific and substantiated property does.
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.
No. A supplier declaration is the supplier’s own statement. It does not meet the requirements for a certification scheme, and it does not shift liability. Responsibility for an environmental claim towards consumers stays with whoever makes the claim.
The typical sequence: the brand owner takes a figure from the supplier’s data sheet, say “30 % recycled content”, and turns it into a claim on the packaging. A technical statement between two companies thereby becomes a commercial practice towards consumers. EmpCo applies to that, and what counts there is not what the supplier assured but what can be substantiated.
If a complaint arrives, the evidence is requested at short notice. Anyone who has to ask the supplier for it at that point does not have it in time.
It can form part of internal documentation and is one building block of the technical documentation under the PPWR. It is the starting point, not the evidence. A claim towards consumers needs proof that comes from an independent body.
Evidence from a certification scheme: published requirements, testing or an audit by an independent body, conformity assessment by a third party, and a result others can verify. At flustix, laboratories accredited to ISO/IEC 17025 carry out the testing, the conformity assessment follows ISO/IEC 17065, and every certificate can be looked up by its licence number in the public database.
One particularity in the supply chain: where the supplier has the material certified, the evidence can be passed on to the customer through the sub-licence system. What then sits behind the figure on the packaging is an assessment, not an assurance.
They are two separate legal acts, and only one of them already applies.
EmpCo, Directive (EU) 2024/825, is transposed and applies from 27 September 2026. It prohibits certain practices: six entries on the blacklist of the German Unfair Competition Act plus three tightenings in the operative text. It requires no procedure before advertising; it creates a risk afterwards, enforced through warning letters and litigation.
The Green Claims Directive is a separate proposal. It would govern how explicit environmental claims must be substantiated and verified in advance, that is with prior verification by independent bodies and a certificate of conformity before the claim is used at all. It is not applicable at present and its timetable is open.
EmpCo says what may no longer be claimed. The Green Claims Directive would say how what is claimed must be proven.
Today the measure is EmpCo. Anyone moving their claims onto independently verified evidence now also meets what the Green Claims Directive would require, because both run in the same direction: verifiable rather than asserted. The work is the same in either case, namely answering for every claim who assessed it and where that can be looked up.
A third act belongs beside them because it is often confused with these two: the PPWR governs packaging itself, that is substances, recyclability and recycled content, not the advertising of it. Meeting a PPWR requirement therefore does not automatically allow you to advertise it; advertising it brings you under EmpCo.
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.
For goods already on the market on the application date, the Commission services name practical options: covering or correcting a claim with a sticker and adding supplementary information at the point of sale. The authorities in the CPC network expect reasonable and proportionate steps that can be evidenced, and are not expected to require destruction or recall in such transitional cases where that would cause disproportionate costs or unnecessary environmental harm.
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