Inside a Free PPWR Audit: The Three Things We Always Find on Day 1

Over ninety free PPWR audits across the last four quarters, three Day-1 findings appear in roughly seventy-three per cent of portfolios. They are not dramatic. They are not difficult to resolve. They are simply the three places where audit-grade documentation reliably fails, and where teams who have not been through a real inspection do not yet know to look.

This piece walks through the three findings — what each one looks like in the wild, why they recur, and the twenty-four-hour fix sequence that closes all three.

Why Day 1 finds the same things

The repeatability is not coincidence. Day 1 of an audit is a documentation review, not a substantive review. The auditor opens the dossier, picks a sample of SKUs, and checks the attached evidence against the regulatory clauses cited. The three findings below are the three places where documentation typically lags behind operational reality.

Teams that have been through a real inspection close these gaps automatically. Teams who have not — and that is most teams entering PPWR enforcement this year — discover them on audit day, which is the wrong day to discover them.

Finding 1 — The unsigned PFAS attestation

A supplier has provided a written statement confirming the absence of PFAS in a food-contact SKU, but the document lacks a signature, a date, an authorised signatory's role, or all three. Sometimes the statement exists only as an email body, with no attachment.

Why it recurs. Suppliers issued these informal statements for years before the October 2025 amendment, and they were accepted. Most teams have not refreshed the format because no audit has yet challenged it.

Fix. Request a new dossier-grade attestation referencing the 100 ppb threshold per Annex II. Median response time when asked specifically: four to eleven days. Cost: zero (suppliers reissue at no charge).

Finding 2 — The unverified PCR claim

The recycled content percentage is stated on the SKU sheet (commonly “30% PCR” or “30% recycled”), but no certificate from a recognised certifying body is attached. The figure may be correct; an auditor cannot verify it.

Why it recurs. PCR percentages are often entered into the ERP at SKU creation and updated as supplier confidence increases, but the underlying certificates are stored in email folders, shared drives, or supplier portals. The link between the figure on the SKU sheet and the certificate behind it is implicit.

Fix. Attach the supplier's RecyClass, EuCertPlast, ISCC PLUS, or equivalent certificate directly to the SKU record. If the certificate is older than twelve months, request a renewal. Median time to refresh: seven days.

Finding 3 — The sub-grade mismatch

The SKU is labelled Grade B in the system, but the underlying recyclability data — pulled from an older assessment — supports only Grade C. This is the most subtle of the three findings and the most common: it appears in roughly forty per cent of audited portfolios.

Why it recurs. Grade letters are often inherited from previous compliance frameworks (Italian decree, German VerpackG, voluntary EPR schemes) and copied forward without re-derivation against PPWR Annex VI. The methodologies differ. A unit that earned Grade B under VerpackG may earn Grade C under PPWR.

Fix. Re-grade the SKU against PPWR Annex VI directly, citing RecyClass v2.4 as the methodology. If the new grade is lower, update the label and disclose the change in the audit trail. Median re-grade time per SKU: two to five minutes once the methodology is loaded.

Of the three findings, the sub-grade mismatch is the most expensive to leave undetected. It carries the largest gap between presumed compliance and actual compliance — and it is invisible to the team until an auditor pulls the supporting evidence.

The 24-hour fix sequence

All three findings can be closed within twenty-four hours of detection, provided the team runs the sequence in the right order. The sequence below is calibrated for a 200 to 400 SKU portfolio.

1. Hours 0 to 4. Run a portfolio re-grade against PPWR Annex VI. Identify all sub-grade mismatches. This closes Finding 3 for the SKUs where the regrade confirms the existing label, and flags the rest for relabelling.
2. Hours 4 to 12. Send dossier-grade attestation requests to every supplier with a food-contact SKU. Use the specific six-property template (see our PFAS field report). This starts the four-to-eleven day clock on Finding 1.
3. Hours 12 to 20. Attach all existing PCR certificates to their SKU records. Identify expired or missing certificates and request renewals from suppliers. This closes Finding 2 for SKUs with valid certificates and starts the seven-day clock on the rest.
4. Hours 20 to 24. Document the audit trail. For every change made in the previous twenty hours, log the regulatory clause it addresses, the methodology used, and the responsible signatory. This is the most under-invested step and the single best protection against repeat findings.

Twenty-four hours of focused work closes the three findings substantively. The supplier responses arrive over the following two weeks. By the end of week three you have a portfolio that survives Day 1 of any subsequent audit.