Need to Prepare Before December 31, 2026

The credibility of any recycled-content certification system depends on one fundamental question: can the organization demonstrate that the material entering the certified recycling supply chain was genuinely reclaimed material?

Once material has entered a certified supply chain, transaction certificates, production records and chain-of-custody controls can help track its movement. But the point at which waste or reclaimed material first enters the certified system presents a different challenge.

This may involve waste collectors, industrial scrap suppliers, aggregators, municipalities, material recovery operations or other suppliers that are not themselves certified to a Textile Exchange standard.

Without consistent documentation at this stage, traceability can become fragmented.

GRS 5.0 therefore strengthens the way information about reclaimed materials is captured at the beginning of the supply chain. These changes are intended to improve data collection and tracking while also helping mitigate the risk of fraudulent reclaimed-material claims.

For buyers and brands, this provides greater confidence that a certified recycled-material claim begins with documented reclaimed material rather than simply appearing later in the manufacturing process

What Is the Reclaimed Material Declaration Form?

At the center of GRS 5.0 is the Reclaimed Material Declaration Form, or RMDF.

The RMDF is a standardized Textile Exchange document used to record reclaimed materials entering certified recycled-material supply chains.

It captures structured information relating to areas such as material composition, feedstock type, whether material is classified as pre-consumer or post-consumer, and material origin.

The RMDF was introduced before GRS 5.0 and became available for use in 2025. Under the updated framework, however, it becomes mandatory from December 31, 2026 for GRS and RCS certification.

This means organizations currently relying on older reclaimed-material supplier documentation need to transition their systems.

Key Change 1: The Previous Reclaimed Material Supplier Form Is Replaced

One of the most visible changes under GRS 5.0 is the removal of references to the previous Reclaimed Material Supplier Form.

The updated standard and implementation manual instead align with the new RMDF.

This is more than a document-name change. The revised RMDF is designed to standardize data in a format that can be more consistently collected, reviewed and integrated into Textile Exchange traceability systems.

For organizations, this means existing procedures, templates, supplier instructions and internal responsibilities should be reviewed.

Continuing to use outdated forms after the mandatory transition date could create gaps during certification or transaction-certificate processing.

Key Change 2: Greater Clarity on the First Certified Organization

GRS 5.0 also clarifies the responsibilities of the first certified organization within the recycling supply chain.

This organization is commonly the recycler, although a certified collector or concentrator may also occupy this position.

Current Textile Exchange requirements specify that the RMDF must be completed by the first certified organization. A separate RMDF is required for each supplier, and forms are to be submitted monthly for periods in which reclaimed-material shipments are received. The completed information is provided to the organization’s certification body.

This places a significant responsibility on the first certified entity. It cannot simply rely on a supplier invoice stating recycled material or waste.

The organization needs a systematic process for collecting, checking, consolidating and maintaining reclaimed-material information.

Key Change 3: Reclaimed Material Becomes More Explicitly Integrated into Certification

GRS 5.0 clarifies that certification applies to reclaimed material, which is considered equivalent to claimed material for the relevant certification requirements.

This strengthens the link between reclaimed-material sourcing and subsequent recycled-material certification.

For suppliers and recyclers, it reinforces the importance of correctly establishing whether input material qualifies as reclaimed material and whether it is appropriately classified.

This distinction matters particularly where companies handle a mixture of production waste, post-consumer waste, virgin material, rework, by-products or other recovered streams.

Not every material described commercially as waste, scrap or recovered will automatically qualify for a recycled-content claim. The classification must be supported by appropriate evidence and the applicable Textile Exchange definitions and guidance.

Key Change 4: Monthly and Supplier-Specific RMDF Controls

One of the most operationally important changes is how RMDF information needs to be managed.

Textile Exchange states that a separate RMDF is required for each reclaimed-material supplier and calendar month in which shipments are received.

This means a recycler purchasing reclaimed PET, textile cutting waste or other eligible feedstock from numerous suppliers may need a significant number of RMDF records.

The organization therefore needs to integrate the requirement into normal procurement and material-receipt processes rather than trying to reconstruct the information immediately before an audit.

A practical system should connect supplier identification, RMDF data, goods receipt, weight records, invoices, material classification and stock entries.

The objective should be straightforward: an auditor should be able to understand who supplied the material, what the material was, when it was received, how it was classified and how it entered the certified recycling system.

Key Change 5: Better Connection With Digital Traceability

The RMDF also supports Textile Exchange’s wider move toward digitized traceability.

Textile Exchange explains that RMDF information integrates with Trackit, improving structured data availability and supporting more scalable traceability. It can also improve information available for Transaction Certificate processing.

This is an important direction of travel.

Recycled-material certification is increasingly moving away from disconnected paper declarations toward structured information that can follow material through the supply chain.

Suppliers should therefore focus not only on having documents but also on ensuring that the underlying information is consistent across different records.

For example, supplier name, material type, weight, dates and material classification should not conflict between the RMDF, purchase invoice, goods receipt and internal stock system.

What Has Not Fundamentally Changed Under GRS 5.0?

Because GRS 5.0 is being introduced at the same time as Textile Exchange’s broader transition toward the Materials Matter Standard, the two developments can easily be confused.

GRS 5.0 itself is a targeted revision.

The fundamental GRS framework continues to address recycled-content verification and chain of custody along with additional social, environmental and chemical processing requirements. GRS remains more stringent than RCS in these areas.

GRS can currently be used as a business-to-business certification tool for products containing at least 20% recycled content, while product-specific consumer-facing GRS claims generally require at least 50% recycled content, subject to applicable claims requirements.

Organizations should therefore avoid assuming that GRS 5.0 replaces existing requirements relating to chain of custody, social compliance, environmental management or chemical controls. Those systems must continue to be maintained.

How Is GRS 5.0 Connected to Materials Matter?

GRS-certified organizations also need to look beyond the December 2026 GRS 5.0 deadline.

Textile Exchange is transitioning its existing material standards toward the Materials Matter Standard.

Materials Matter was published on December 12, 2025 and becomes effective on December 31, 2026. From December 31, 2027, it becomes mandatory for Tier 4 audits, including applicable recyclers and primary processors currently certified under GRS or RCS.

The RMDF is therefore important in both systems. It supports stronger reclaimed-material traceability under GRS 5.0 while also preparing the foundation for the future Materials Matter framework.

For recyclers in particular, GRS 5.0 should therefore be viewed as part of a broader traceability transition rather than an isolated documentation update.

What Should Recycled Material Suppliers Do Before December 31, 2026?

Companies should use the remaining transition period to strengthen their systems rather than waiting for the next certification audit.

• Review GRS 5.0 and the updated GRS Implementation Manual.
• Identify whether the organization is the first certified entity receiving reclaimed material.
• Map every reclaimed-material supplier and material stream.
• Implement the current RMDF and discontinue obsolete reclaimed-material forms according to the mandatory timeline.
• Establish monthly supplier-specific RMDF controls.
• Train procurement, stores, sustainability and certification personnel.
• Verify consistency between RMDFs, invoices, goods receipts, weighment records and stock records.
• Review pre-consumer and post-consumer material classifications.
• Reconcile reclaimed-material inputs with certified production and output.
• Coordinate with the certification body before the mandatory date.

The most important principle is to integrate GRS traceability into everyday operations. If certification records are created only when the auditor requests them, the risk of quantity mismatches and incomplete supplier evidence increases significantly.

How PQSmitra Supports GRS Certification

At PQSmitra, we support organizations in establishing practical and audit-ready systems for Global Recycled Standard certification and ongoing compliance.

Our GRS support begins with understanding the organization’s product, recycling process, suppliers, material flow and existing certification status.

For companies preparing for GRS 5.0, PQSmitra can support:

• GRS 5.0 Gap Assessment: Reviewing the existing system against updated reclaimed-material and RMDF requirements and identifying implementation gaps.
• RMDF Implementation: Helping organizations establish supplier-wise and monthly processes for collecting, reviewing and maintaining Reclaimed Material Declaration Forms.
• Recycled Material Traceability: Developing practical systems linking reclaimed-material sourcing, goods receipt, production, stock, processing losses, certified output and sales.
• Material Balance and Quantity Reconciliation: Supporting organizations in establishing reliable input-output reconciliation so that certified quantities can be demonstrated during audits.
• Supplier Documentation Review: Reviewing reclaimed-material supplier records, classification evidence, declarations and supporting purchase documentation.
• GRS Documentation and System Development: Supporting required procedures and records relating to recycled material, chain of custody, social requirements, environmental management and chemical controls.
• Employee Training and Implementation Support: Helping procurement, stores, production, compliance and management teams understand their responsibilities under the certification system.
• Internal Audit and Certification Readiness: Conducting pre-assessment reviews, identifying potential nonconformities and supporting corrective actions before the certification-body audit.
• Materials Matter Transition Readiness: Supporting recyclers and primary processors in planning the transition from GRS toward the Materials Matter Standard as the mandatory implementation timeline approaches.

Our objective is not simply to prepare forms. It is to help organizations establish a system where every significant recycled-material claim can be traced back to credible evidence.

Conclusion

GRS 5.0 is a focused update, but its significance should not be underestimated.

The July 2026 revision does not fundamentally rewrite the Global Recycled Standard. Instead, it strengthens one of the most critical points in recycled-material certification: the entry of reclaimed material into the certified supply chain.

The revised RMDF, clearer responsibilities for the first certified organization and stronger supplier-specific data controls represent a move toward more consistent and verifiable recycled-material claims.

For certified companies, December 31, 2026 should therefore be treated as an operational deadline, not simply a documentation deadline.

Organizations that begin updating supplier controls, material traceability, RMDF processes and quantity reconciliation now will be better prepared not only for GRS 5.0, but also for Textile Exchange’s wider transition toward the Materials Matter Standard.

In the future, saying that a product contains recycled material will increasingly be insufficient.

The real question will be: Can your organization prove it?