ISCC PLUS New Regulation Deep Dive — Compliance Path for Finished Product with ≥50% Sustainable Materials
1. Introduction: The Biggest Rule Change in ISCC PLUS History
On December 16, 2025, the ISCC (International Sustainability and Carbon Certification) organization implemented the largest rule adjustment since the launch of ISCC PLUS certification. The core change is simple: The sustainable material content of a product must be ≥50%, and the calculation basis has shifted from "individual components" to the "finished product."
This change may seem like a mere numerical adjustment, but it fundamentally alters the rules of the game for ISCC PLUS certification. For Amazon sellers using ISCC PLUS certificates to obtain the CPF Green Label, this means many currently compliant products may become "non-compliant" — and the transition period only lasts until December 31, 2026.
2. Comparison of Old and New Rules
2.1 Old Rules (Before December 15, 2025)
- Only any single component of the product needed to have ≥50% sustainable material content
- Example: For a power bank, if only the outer shell uses 60% recycled plastic, while other components (battery, circuit board) contain no recycled materials, it could still meet ISCC PLUS requirements
2.2 New Rules (From December 16, 2025)
- The overall sustainable material content of the product must be ≥50%
- For the same power bank, the proportion of sustainable materials must be calculated based on the total weight of all components: shell + battery + circuit board + internal cables, etc.
2.3 Mathematical Difference Example
Assume a product's weight composition:
| Component | Weight | Old Rules | New Rules |
|---|---|---|---|
| Plastic Shell | 200g (60% recycled = 120g recycled) | ✅ Single component ≥50% | — |
| Metal Parts | 300g (0% recycled) | Not individually assessed | — |
| Electronic Components | 100g (0% recycled) | Not individually assessed | — |
| Finished Product | 600g | — | 120g recycled / 600g finished product = 20% ❌ |
This product could pass ISCC PLUS certification under the old rules, but under the new rules — the gap is 30 percentage points.
3. Affected Product Categories
| Category | Impact Level | Reason |
|---|---|---|
| Electronics / Electronic Accessories | 🔴 Severe | Electronic components themselves have virtually no recycled materials; meeting the standard for the finished product is extremely difficult |
| Plastic Daily Necessities | 🟡 Moderate | All-plastic products are easier to meet the standard, but mixed-material products containing metal/electronic parts are difficult |
| Textiles | 🟢 Low | The main weight of textiles is indeed fiber, making it relatively easy to meet the standard |
| Packaging Materials | 🟢 Low | Packaging materials are homogeneous, making it easy to meet the standard for the finished product |
| Toys | 🔴 Severe | Toys with electronic components and those made of multiple materials are difficult to meet the standard |
| Household Items | 🟡 Moderate | Depends on material complexity |
4. Seller Response Strategies for 2026
4.1 Strategy 1: Upgrade Products to Meet the ≥50% Finished Product Standard (Recommended)
For products that can potentially meet the standard through material changes:
- Replace more plastic/metal components with recycled material versions
- Prioritize increasing the recycled content ratio of the heaviest components
- For lightweight components that significantly impact certification (e.g., electronic components), explore alternative solutions
Timeline: 3-6 months (supplier switching + certification renewal)
Cost: Depends on the number and scale of component replacements
4.2 Strategy 2: Switch Certification Type
For products that truly cannot achieve the 50% finished product standard, consider switching to other CPF-recognized certifications:
| Original Certification | Alternative | Applicable Scenario |
|---|---|---|
| ISCC PLUS | RCS (Recycled Claim Standard) | Requires only ≥5% recycled materials; threshold is much lower than ISCC PLUS |
| ISCC PLUS | Carbon Neutral | Applicable to all categories; not restricted by material proportion |
| ISCC PLUS | GRS (Global Recycled Standard) | Requires ≥50% recycled materials; ensure compliance is achievable |
| ISCC PLUS | Compact by Design | Free, 3-5 days; emergency transition solution |
4.3 Strategy 3: Tiered Approach (Most Practical)
For sellers with multiple SKUs:
| SKU Tier | Strategy |
|---|---|
| SKUs with finished product recycled material ≥50% | Retain ISCC PLUS; ensure completion of new regulation audit by December 31, 2026 |
| SKUs with finished product recycled material close to 50% (e.g., 40%-49%) | Initiate material upgrades to strive for compliance; simultaneously prepare RCS as a backup plan |
| SKUs with finished product recycled material far below 50% (e.g., <30%) | Immediately switch to RCS or Carbon Neutral certification; do not wait until the deadline |
5. Key Timeline
| Date | Event |
|---|---|
| December 16, 2025 | ISCC PLUS new regulations take effect; new applications follow the new rules |
| January - June 2026 | Existing ISCC PLUS sellers assess impact and develop response plans |
| July - September 2026 | Initiate new certification applications or material upgrades |
| December 31, 2026 | Transition period ends — ISCC PLUS certificates for non-compliant products become invalid |
| January 1, 2027 | CPF Green Labels for non-compliant ISCC PLUS products are removed |
6. Frequently Asked Questions (FAQ)
Q: I am in the process of obtaining ISCC PLUS certification but haven't received it yet. Do I need to follow the new rules?
A: All new ISCC PLUS applications submitted after December 16, 2025, must follow the new rules. If you haven't submitted your application yet, you need to immediately assess whether your product meets the standard under the new rules.
Q: How long will my current ISCC PLUS certificate remain valid?
A: During the transition period (until December 31, 2026), existing ISCC PLUS certificates remain valid, and the CPF Green Label also remains effective. However, the next annual audit on your certificate may need to be conducted according to the new rules.
Q: Is the process of switching from ISCC PLUS to RCS complicated?
A: It is not complicated. The audit requirements for RCS are simpler than ISCC PLUS (only ≥5% recycled materials required, and the audit process is more basic). Most products that have already obtained ISCC PLUS have a foundation in supply chain traceability, so the transition to RCS typically takes 2-4 weeks. GreenArk can assist sellers in achieving a smooth transition from ISCC PLUS to RCS.
About GreenArk (Shenzhen) Certification Co., Ltd.
The impact of the ISCC PLUS new regulations is broad, and the time window is limited. GreenArk has provided new regulation impact assessments and transition plan development services for over 500 ISCC PLUS sellers, including finished product recycled material content calculations, alternative certification recommendations, and supplier material upgrade consulting. Find the best path forward for your ISCC PLUS products before December 31, 2026.
GreenArk (Shenzhen) Certification Co., Ltd.
sui@greenark-sz.com | www.greenark-sz.com
