Carbonorm collects the supplier evidence behind recyclability, PCR content, separability and PFAS, assembles the Annex VII technical file, and issues the Annex VIII Declaration of Conformity for every SKU — citing every Article clause, with member-state penalty exposure modelled alongside.
Eleven open spreadsheets, 412 SKUs, audit at month-end. Manual reformulation tracking dies on the first material swap.
Who sent which PFAS attestation, in what format, citing which test method? Email threads aren't audit evidence.
12 August 2026 lands during summer holidays. The DoC is a per-SKU document, not a corporate-wide one. Spreadsheets don't scale here.
Carbonorm holds the recyclability evidence for each SKU against the Annex II criteria and flags where the supporting documentation is missing before an auditor asks — so the gap closes on your schedule, not theirs.
One citation engine, every clause named. Auditors see the regulation text next to every flag it raises — nothing unexplained.
PFAS in food-contact packaging is restricted from 12 August 2026 on three thresholds: 25 ppb for any single non-polymeric PFAS, 250 ppb for the sum of non-polymeric PFAS (both by targeted analysis), and 50 ppm total fluorine as an indicator of all PFAS.
↳ Substance checkAll packaging shall be designed for recycling and graded A, B or C under Annex II Table 3. Grade C is the minimum for placing on the market from 1 January 2030; grade B from 1 January 2038.
↳ RecyclabilityPlastic packaging placed on the EU market shall contain a minimum percentage of post-consumer recycled plastic, calculated per unit.
↳ PCRPackaging shall not exceed the minimum weight and volume necessary to ensure functionality — a minimisation duty under Article 10 and Annex IV, applying from 1 January 2030. The separate 50 percent empty-space ratio limit for grouped, transport and e-commerce packaging sits in Article 24.
Manufacturers shall draw up an EU Declaration of Conformity before placing packaging on the market, retain it for 5 years (single-use) or 10 years (reusable), and produce it to authorities within 10 days of request.
Substances of concern (PFAS, BPA in food-contact composites) are restricted under Article 5; the supporting supplier attestations sit in the Annex VII technical documentation, per SKU.
Article 68 leaves penalty calibration to member states with the constraint that they be "effective, proportionate and dissuasive." The published rate cards across our five Wave 1 markets:
Indicative ranges — published rate cards as of Q1 2026. Firmed up as member states adopt implementing acts. Treat as planning ranges, not bonded forecasts.
Member-state EPR schedules (DE/FR/IT/ES/RO) modulated by your Article 6 grade. An A-grade reformulation produces a hard € number — the closing argument your CFO needs.
Drag-and-drop CSV or sync SAP / Odoo. Auto-detects 14 BoM templates.
Match Articles 5, 6, 7 and 10 to the evidence each one requires — recyclability, PCR, separability, PFAS.
Magic-link suppliers for missing dossiers. Track response rate.
Generate the DoC bundle (PDF + XML + audit hash), sign it, and hold it retrievable for the 10-day window.
Don't maintain duplicate data sets. The same supplier dossiers that grade your packaging produce your quarterly CBAM XML — with the audit lineage already attached.
Click through the real workflow on mock data. No login, no demo booking — see the citations, the spec module, the supplier portal, the risk view, and the generated PDF in under sixty seconds.
CSV with sku_code, material, weight_g, recycled_content_pct, pfas_status. We auto-detect 14 ERP templates.
Drag a CSV or sync SAP / Odoo. Auto-detect column mapping, normalise PCR percentages, parse PFAS attestations. 247 SKUs ready in thirty seconds.
Wave 2 (Nov 2026): NetSuite · Sage · Microsoft AX · custom GraphQL
Day-one grading for Germany, France, Italy, Spain and Romania. Each country's recyclability rules, modulated EPR fee schedules and national labelling are loaded into the engine. Austria, Netherlands, Poland, Portugal and Czechia roll out across Wave 1.5.
Article 68 leaves penalty calibration to member states. We model the published rate cards (DE VerpackG, FR CITEO/DGCCRF, ES Royal Decree 1055/2022, IT CONAI) per non-compliant SKU and surface a planning-grade range. Numbers are auditable — every figure is sourced to a citation.
Yes. Annex VIII Declarations of Conformity are produced as PDFs with every clause cited, the Annex VII technical file attached, and a deterministic SHA-256 lineage hash. Each is held for its statutory period: 5 years for single-use packaging, 10 years for reusable.
Drop a CSV or sync directly via REST. We auto-detect 14 BoM templates including SAP MM, Odoo, Microsoft Dynamics and Xero. PCR percentages, material codes and PFAS attestations normalise on ingest — no spreadsheet pre-cleaning required.
EU exclusively. Primary in Frankfurt (eu-central-1), backup in Stockholm (eu-north-1). No US replica, no third-country transfer. DPA available pre-signature, GDPR Article 28 compliant.
Per-country EPR fee estimation ships Sprint H (5 countries). Every SKU's fee exposure is computed from member-state PRO schedules and modulated against its Article 6 grade — so an A-grade reformulation produces a hard € number for your CFO.
A free PPWR audit on your real BoM takes thirty minutes and costs nothing. You get a graded portfolio, a clause-by-clause defence, and a redline of every SKU sitting at or below grade C before the auditor sees it.