Inside a Free PPWR Audit: Three Gaps That Show Up on Day 1

A free PPWR audit is short and specific. A regulatory engineer walks one bill of materials with you and checks the evidence behind each component against the PPWR article it supports. The same three gaps come up often. They are not dramatic and they are not hard to fix. They are the places where documentation lags behind what the team actually knows, and where teams that have not yet answered an authority’s request for documents do not know to look.

This piece walks through the three gaps: what each one looks like, why it recurs, and a four-step sequence that closes them in the right order.

Why the same gaps come up first

The repetition is not coincidence. The first look at a file is a documentation review, not a test programme. For each component, the question is simple: does the file hold evidence that matches the PPWR requirement it claims to meet? Article 15(2) requires the manufacturer to draw up the technical documentation in Annex VII before placing packaging on the market, and Article 16(1) requires suppliers to provide the information the manufacturer needs for it. The three gaps below are where that chain tends to break.

Under Article 15(10), a national authority can ask for that documentation, and you have 10 days to provide it. Teams that have answered such a request tend to close these gaps early. Others often find them only when the request arrives, which is the wrong time to find them.

Gap 1: An informal PFAS statement instead of evidence

A supplier has confirmed in writing that a food-contact material contains no PFAS. The statement may be unsigned or undated, or it may exist only as an email. It does not say which limits it addresses, and there is no test report behind it.

Why it recurs. Informal “PFAS-free” statements were common before the PPWR limits applied, and many files still carry them. Article 5(5) changed the question. Since 12 August 2026, food-contact packaging cannot be placed on the market if it contains PFAS at or above 25 ppb for any single PFAS, 250 ppb for the sum of PFAS, or 50 ppm for all PFAS including polymers. A general statement does not show which of these limits was checked, or how.

Fix. Ask each supplier of a food-contact material for a total fluorine test report and a written confirmation that no PFAS are intentionally added. The Commission’s guidance (C(2026) 3702) suggests starting with a total fluorine test: below 50 mg/kg, the sample could be considered compliant. Above it, Article 5(5)(c) lets you ask the chemical supplier for proof of how much of the fluorine is PFAS. Record the laboratory, method and limit of quantification in the technical documentation (Annex VII, points 2(d) and 2(f)). See our Article 5 guide.

Gap 2: A recycled-content figure with no evidence behind it

The recycled content is stated on the product sheet, often as “30% PCR” or “30% recycled”, but nothing in the file shows where the figure comes from. The figure may be correct. Nobody reading the file can check it.

Why it recurs. Recycled-content figures are often entered into the ERP when a product is created and updated later. The certificates and supplier declarations behind them sit in email folders, shared drives or supplier portals. The link between the figure and its evidence lives in someone’s head. The minimum shares in PPWR Article 7 apply from 1 January 2030 at the earliest, so many teams treat the evidence as a later problem. Under Article 7(6), compliance will have to be shown in the technical documentation under Annex VII, and the calculation and verification method is due in an implementing act by 31 December 2026 (Article 7(8)).

Fix. For each supply batch, attach the supplier’s post-consumer share, the certification scheme and certificate number, and the collection and recycling location to the product record. Schemes such as ISCC PLUS, EuCertPlast and REDcert² are useful evidence today, but no scheme is yet recognised under PPWR. Keep the data behind the certificate as well. See our Article 7 guide.

Gap 3: A recyclability grade that is not a PPWR grade

The product sheet shows a recyclability letter, say grade B, and the team reads it as the PPWR grade. On a closer look, it comes from an industry design guide, a national EPR scheme or an older assessment. PPWR does define grades A, B and C (Article 6(3), Annex II Table 3), but the criteria that produce them are not adopted yet. This is the least visible of the three gaps.

Why it recurs. Grade letters are often inherited from earlier frameworks or voluntary tools and copied forward. The methods differ, and the PPWR method does not exist yet: the Commission must adopt the design-for-recycling criteria in delegated acts by 1 January 2028 (Article 6(4)). The grade requirement applies from 1 January 2030, or 24 months after those acts, whichever is later. Any PPWR grade you calculate today is an estimate.

Fix. Label every inherited grade as an estimate and record its source, method and date. Use guideline scores, such as RecyClass, as a planning signal, not as the legal grade. Until the design-for-recycling condition applies, the Commission’s guidance points to the recyclability requirement of Directive 94/62/EC and the harmonised standard EN 13430:2004. See our Article 6 guide.

A grade on a product sheet is only as good as the method behind it. Until the Article 6(4) criteria are adopted, the honest PPWR grade is an estimate, and the file should say so.

A four-step fix sequence

All three gaps can be closed with work you control, plus supplier responses you need to start early. The order matters: begin with what depends on others.

1. Step 1. Send supplier requests. Ask every supplier of a food-contact material for a total fluorine test report and a statement that no PFAS are intentionally added. Ask recycled-content suppliers for the post-consumer share, the scheme, the certificate number and the collection and recycling locations. Article 16(1) requires suppliers to give you the information you need for the technical documentation.
2. Step 2. Attach what you already hold. Link existing test reports, certificates and supplier declarations to the product records they support. List what is missing or out of date, and track it against the requests from Step 1.
3. Step 3. Relabel inherited grades. Mark every recyclability grade that does not come from the PPWR criteria as an estimate, with its source, method and date. This closes Gap 3 for now and makes the later re-assessment easier.
4. Step 4. Log every change. For each change, record the PPWR article it addresses, the evidence used, who approved it and the date. Keep the technical documentation and the EU declaration of conformity for 5 years after single-use packaging is placed on the market, and for 10 years for reusable packaging (Article 15(3)). This step is easy to skip, and it does the most to stop the same gap from coming back.

The internal steps take days, not months. Supplier responses take longer, which is why they start first. If you want a second pair of eyes, a free PPWR audit walks one bill of materials with a regulatory engineer. You leave with the evidence gaps and the article behind each.