PPWR: EU Packaging Regulation

Our retailer asks for proof of our recycled content claim. What do we need?

Three things, in this order.

1. Establish what is actually being claimed

“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.

2. Obtain the evidence that carries exactly that claim

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.

3. Deliver it in a form the retailer can adopt

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.

What shortens the route

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.

Sources: German Unfair Competition Act (UWG) · ISO/IEC 17065 (requirements for certification bodies)

Editorial responsibility: Malte Biss, CEO & Founder of flustix