PPWR compliance audit: how to choose a consultancy firm
What should the diagnostic cover?

The European packaging regulation, known as the PPWR (Packaging and Packaging Waste Regulation), nowhere mentions an audit. It requires the manufacturer of each packaging type to assess its conformity itself (Annex VII), without a notified body, before placing it on the market, then to sign an EU declaration of conformity (Annex VIII). What is called a "PPWR audit" is therefore a consulting service, which each consultancy defines in its own way.

The useful service therefore depends on the question asked, and each question calls for a different profession. This article deals with the first case, the conformity diagnostic of a packaging portfolio, and refers to the others. If the question is still whether the company is affected, our test PPWR: am I affected? comes first.

1What does a PPWR compliance audit cover?

A conformity diagnostic answers a single question: which requirements of the Regulation apply to each of my packaging items, and from when? It starts from the real inventory of packaging, component by component, and ends with a list of gaps ranked by deadline.

The company's role, packaging item by packaging item

The Regulation attaches its obligations to roles, not to companies. The manufacturer is the party that has the packaging designed or manufactured under its own name or trademark, even if it produces nothing itself (Article 3). A retail chain that sells own-brand products is therefore the manufacturer, as is a distributor that modifies packaging to the point of compromising its conformity (Article 21).

The same retail chain is distributor of the brands it resells and importer of what it buys from outside the Union. The manufacturer draws up the technical documentation, the importer checks that it exists, and the distributor checks the labelling and the producer's entry in the register (Articles 15, 18 and 19). The producer, liable for extended producer responsibility (EPR), is a different notion, which does not always designate the same company. For a micro-enterprise, these obligations may fall to its supplier, a case detailed in our article for micro-enterprises.

What a diagnostic is not

4 neighbouring services are sold under the same name, and a quotation must say which of them it includes:

• The review of supplier evidence, document by document, checks that a composition declaration or a test report covers the right component, the right site and the right period, as detailed in our article on the PPWR technical file.
• The laboratory test measures heavy metal or fluorine content on an identified sample, and only the laboratory that carried it out signs the report.
• Certification of recycled content by a third-party body, already required for recycled plastic in contact with food, is presented in our article on auditing recycled content.
• Legal advice on a disputed role, a supplier contract clause or a penalty is a matter for a lawyer, whom the technical consultancy must know how to bring in at the right time.

2Do you need to have your packaging audited?

No: no Article requires an audit, a consultant or a third party. The Regulation requires a result and the proof of it. Since 12 August 2026, the manufacturer places on the market only compliant packaging, and draws up for each type the technical documentation and the EU declaration of conformity. It keeps them for 5 years, or 10 years for reusable packaging, and provides them to the authority within 10 days of a reasoned request (Article 15).

What has applied since 12 August 2026

A diagnostic carried out in 2026 first assesses what is already enforceable:

• The limit of 100 mg/kg for the sum of lead, cadmium, mercury and hexavalent chromium applies to all packaging and to each of its components, from the body to the label (Article 5).
• The PFAS thresholds apply to packaging intended to come into contact with foodstuffs, with the method detailed in our article on PFAS in food packaging.
• Recyclability and the reduction of weight and volume are still assessed under the requirements of the 1994 directive and its standards, such as EN 13430, pending the criteria of the Regulation (Commission guidance).
• The packaging bears a type or batch number, and the manufacturer's name and postal address, on the packaging or through a QR code (Article 15).

Missing, incomplete or erroneous documentation is a formal non-compliance, which the Member State requires to be corrected and which, if it persists, can lead to withdrawal of the packaging (Article 62). National penalties must be laid down by 12 February 2027 at the latest (Article 68). In France, the competent authority is the Directorate-General for Risk Prevention (in French). No text yet sets the penalties: the bill adapting French law to EU law (in French) that provides for them, adopted by the Senate on 18 February 2026, is still awaiting its vote in the National Assembly.

What is still awaiting the Commission

For 2030, the Regulation sets the obligations but leaves the method for calculating them to Commission acts. Recyclability classes are awaiting delegated acts due by 1 January 2028 at the latest, and will apply only from 1 January 2030, or 24 months after those acts if they are published later (Article 6). The method for recycled content is due on 31 December 2026, that for the empty space ratio on 12 February 2028. The formats banned in 2030, by contrast, are listed in the text (Annex V) and can be identified today.

The Commission itself plans to propose these implementing acts and delegated acts within 2 to 3 years of its guidance document of 10 June 2026. A consultancy can already position each packaging item against these requirements and identify those that will need to be redesigned. It cannot guarantee their compliance before the criteria exist.

3How do you choose the right consultancy?

The Regulation reserves the engagement to no profession and approves no consultant. The choice therefore rests on demonstrated competence, in 3 steps: what is non-negotiable, the questions that set candidates apart, and the promises that should give pause.

What is non-negotiable

The consultancy must be able to read both the Regulation and a packaging item. It reads the text Article by Article, with its conditional dates and the Commission guidance, and the packaging component by component, with its materials, inks, adhesives and transport packaging. A requirement is often assessed on a single component. A plastic part of less than 5% of the mass is exempt from recycled content (Article 7), the cardboard box falls outside the reuse targets (Article 29), and medicine packaging has its own exemptions.

It must also separate the conformity of the packaging, which follows placing on the Union market, from EPR in each country of sale (in French) (in French), which has its own registers, producer responsibility organisations (PROs, éco-organismes in French) and deadlines. The 2 are prepared together, but a quotation that confuses them does not say who does what. Finally, a consultancy that designed a redesign does not review its own evidence, the rule that also applies to a critical review of a life cycle assessment (LCA) (in French) (in French).

The questions to ask

5 questions separate 2 or 3 consultancies in a single meeting:

• How do you establish our role, manufacturer, importer or distributor, for each product reference, including our own-brand products and our purchases from outside the Union?
• Will your deliverable be a reference-by-reference matrix, with the Article, the date and the evidence expected, or a list of obligations valid for a whole sector?
• How do you handle a requirement whose Commission act has not been published, and how will the diagnostic be updated when it is?
• Who, by name, will read our technical data sheets and our supplier declarations, and what experience of packaging materials does that person have?
• What is excluded from the quotation: tests, the full review of evidence, a life cycle assessment, legal advice, EPR procedures abroad?

Warning signs

Some offers promise what the Regulation does not yet make it possible to deliver:

• A complete "PPWR compliance" project in a few weeks, when the recyclability criteria and the recycled content method are not published.
• A sector-wide grid of obligations, identical for all references, with no component, no supplier and no date of application.
• A diagnostic that overlooks transport packaging and e-commerce parcels, which are covered in 2030 by the empty space ratio and by the reuse targets.
• A life cycle assessment proposed from the outset for every reference, when the Regulation requires none and it mainly serves to choose between 2 redesigns.

4How does a diagnostic work, and at what price?

A full diagnostic follows 5 steps, the third of which produces the main deliverable:

• The inventory of the packaging types placed on the market, with their components, materials, suppliers, volumes and countries of sale.
• The attribution of the company's role for each reference, and that of the producer liable for EPR in each country of sale.
• The applicability matrix, which crosses each packaging item with each requirement, its date and the evidence expected.
• The statement of the evidence already available and of the gaps, ranked by date of application and by the time needed to close them.
• The roadmap, which separates what must be corrected now from what must be prepared for 2030, including redesigns and supplier changes.

The deliverable: a matrix, reference by reference

The example below is constructed for this article: 5 packaging items of a grocery brand sold in store and online, crossed with 6 requirements of the Regulation, as a diagnostic would present them.

The matrix shows what a generic grid hides. The bottle and the pouch do not have the same recycled content rate to reach. The glass jar is exempt from this requirement, because its only plastic weighs less than 5% of the unit, and the cardboard parcel falls outside the reuse targets that the pallet film must prepare for, even after the exemption granted in 2026.

The quotation, the lead time and the price

No public price list exists for a PPWR compliance diagnostic. At Celsius, the audit and inventory of a portfolio cost €15,000 to €30,000 excl. VAT, over about 3 months, as our PPWR support offer states. The workload follows the number of packaging types and components, much more than turnover: 30 references that share 3 formats are handled faster than 10 references with 10 formats. The lead time depends mainly on how quickly suppliers send their documents.

The nearest public price is that of the Diag Écoconception (in French), an eco-design diagnostic funded by ADEME (the French Agency for Ecological Transition) and operated by Bpifrance (the French public investment bank) for SMEs: 18 days of support over 10 months, or €18,000 excl. VAT before subsidy, life cycle assessment included. After the ADEME subsidy, an SME pays €5,400 or €7,200 excl. VAT depending on its size. The scheme concerns the eco-design of a product, not the conformity of a portfolio, and our article on financing the Diag (in French) (in French) details its conditions.

5What should you prepare before approaching consultancies?

A useful first meeting is prepared with 5 items:

• The list of references sold in the Union, with their annual volumes, countries of sale and channels, in store or online.
• The bill of materials of each packaging item, from the body to the closure, the label, the inks and the adhesives, through to the transport carton and film.
• The list of packaging and material suppliers, with their sites, and the documents already received, such as technical data sheets, composition declarations or test reports.
• The expected role for each reference: own brand, resale, import or manufacture entrusted to a subcontractor.
• The decisions coming up, such as a redesign, a change of supplier, a listing with a retailer or the opening of a new country.

Suppliers must provide the manufacturer with all the information and documentation necessary (Article 16). Approaching them before the diagnostic saves the weeks that collection would otherwise take. The EU declaration of conformity that results is then signed, packaging type by packaging type, and the full PPWR timeline says what comes after 2030.

For us, at Projet Celsius, the useful question to put to a consultancy is "which requirement applies to which component, and on what date?" A diagnostic that answers it line by line makes it possible to correct now what is already enforceable, namely substances, PFAS and documentation, and to launch the 2030 redesigns with full knowledge. This is how we run our PPWR support, with the engineers who write our guides to the Regulation, referring to a laboratory, a certification body or a lawyer whatever falls within their remit.

6Key takeaways

• No text defines the PPWR audit, and the manufacturer assesses conformity alone, without a notified body or a certificate.
• The role is set packaging item by packaging item, and the same company can be a manufacturer, a distributor and an importer.
• Since 12 August 2026, substance limits, PFAS, technical documentation and the declaration of conformity have been enforceable.
• The 2030 criteria are awaiting Commission acts, which a consultancy can prepare for without being able to guarantee the result.
• The deliverable to demand is a matrix that crosses each packaging item, each requirement, its date and the evidence expected.

To compare this approach with that of an environmental claims audit, see how to choose an EmpCo provider, and to train the teams who will produce the evidence, our article on PPWR training.

Further resources

Frequently asked questions

1Is a PPWR audit mandatory?

No. Regulation (EU) 2025/40 requires no audit, consultant or third-party body for packaging. It requires the manufacturer to assess the conformity of each packaging type itself, to draw up technical documentation and to sign an EU declaration of conformity, since 12 August 2026. A diagnostic by a consultancy is one way to achieve that, not an obligation.

2Is there an approval scheme for PPWR consultancies?

No. The Regulation reserves the engagement to no profession and provides for no approval of consultants, nor any certificate of conformity for the company. The choice rests on demonstrated competence: knowing how to establish the company's role for each packaging item, reading the text Article by Article and assessing packaging component by component.

3How much does a PPWR compliance audit cost?

There is no public price list. At Celsius, a PPWR compliance diagnostic costs €15,000 to €30,000 excl. VAT, over about 3 months. The workload depends on the number of packaging types and components, the number of suppliers and countries of sale, and the documents already gathered. To compare, ask 2 or 3 consultancies for a quotation on the same inventory, with the same deliverable and the same exclusions (tests, full review of evidence, legal advice).

4Does a distributor have to have its packaging audited?

It has no obligation to, but before selling it must check the labelling and the producer's entry in the register (Article 19). If it sells products under its own brand, it becomes the manufacturer within the meaning of the Regulation and then bears the technical documentation and the declaration of conformity for that packaging (Articles 3 and 21).

5Can you achieve PPWR compliance before the Commission publishes its acts?

In part. Substance limits, PFAS thresholds for food contact and technical documentation have applied since 12 August 2026. Recyclability classes, the recycled content method and the empty space ratio method depend on acts due between the end of 2026 and 2028: you can prepare for them, but not yet demonstrate compliance.

6What is the difference between a PPWR audit and a declaration of conformity?

The EU declaration of conformity is a mandatory document, signed by the manufacturer for each packaging type, following the model in Annex VIII. The audit, or diagnostic, is an optional service that helps establish which requirements apply and which evidence is missing, before signing that declaration.

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