From 12 August 2026, PPWR audits become a reality: market surveillance authorities, customers, and trading partners will systematically check whether your packaging is compliant - and whether your documentation actually proves it.

The PPWR (Regulation (EU) 2025/40) entered into force on 11 February 2025 and will apply directly in all EU Member States from 12 August 2026.

In this step-by-step guide, you will learn:

  • which documents you need in a PPWR audit,
  • how to structure your audit documentation (including an audit checklist at document level),
  • how digital document management can get your team audit-ready without extra Excel spreadsheets.

You can find a detailed introduction to PPWR requirements from 2026 in this PPWR 2026 guide.

The focus is on FMCG companies with extensive packaging portfolios - teams that will face particularly intense data and evidence pressures from 2026 onwards.

Prerequisites: What you should clarify before preparing for the audit

Before you start preparing for the audit, you should have these basics in place:

  • Role under PPWR for each packaging/product
    • Are you a Producer (placing on the market), Manufacturer, Importer or Distributor/Retailer?
  • Scope of your portfolio
    • Which sales, grouped, transport, and e-commerce packaging do you place on the EU market?
  • Central responsibility
    • Who is internally responsible for the Declaration of Conformity, technical documentation, and audit coordination (e.g. Packaging, QA, Regulatory)?
  • System landscape
    • Where are specifications, supplier data, and certificates currently stored? In ERP, PIM, Excel, email, or already in digital packaging management such as with Packa?

The clearer these points are, the more efficiently you can set up your audit checklist for documents.

Step 1: Clarify roles, scope, and packaging inventory

1.1 Understand roles under PPWR

PPWR distinguishes the following roles: Producer (placing on the market), Manufacturer, Importer, and Distributor/Retailer. Your obligations for compliance and documentation depend on your role.

  • Producer: Places packaging or packaged products on the EU market for the first time, usually the brand owner.
  • Manufacturer: Produces packaging or components and provides technical data.
  • Importer: Brings goods from non-EU countries into the EU and secures the documentation.
  • Distributor/Retailer: Sells products already available in the market and is responsible for labelling and supporting documents.

You can find more information on the roles in the following article: Roles under PPWR.

Tip: Create a matrix ("product line × role"). This will show you where you need to create Declarations of Conformity (DoCs) yourself and where you need to retain supplier documents in an audit-proof way.

1.2 Compile a complete packaging inventory

A PPWR audit always starts with the question: Which packaging is in scope?

  • Capture all packaging types: primary, secondary, tertiary, and e-commerce packaging.
  • Group them by material, function, and intended use.
  • Assign each group a unique ID, which will later be used in the Declaration of Conformity.

This creates the basis for linking your Declaration of Conformity (DoC), technical documentation, and audit documentation.

Step 2: Understand which documents are checked in a PPWR audit

From 2026 onwards, you will need to provide two main document blocks: Declarations of Conformity and technical documentation - supplemented by supplier evidence and reporting documents.

From 12 August 2026, every piece of packaging placed on the EU market must be covered by a PPWR Declaration of Conformity (DoC).

2.1 Declarations of Conformity (EU Declaration of Conformity)

The PPWR Declaration of Conformity is the key document in an audit. It confirms that a packaging type meets the requirements of Articles 5-12 of the PPWR.

At a minimum, as specified in Annex VIII, it must include:

  • a unique DoC identification number,
  • full manufacturer/company details,
  • clear identification of the packaging type (material, format, application),
  • a formal statement of conformity with the relevant PPWR Articles,
  • references to the technical documentation and applied standards/methods,
  • date, name, role, and signature of an authorised signatory.

Variants with different materials, sizes, or design changes each require their own Declaration of Conformity.

You can find more details about the DoC in this article.

2.2 Technical documentation

The DoC is only as robust as the technical documentation behind it. This includes all evidence demonstrating that PPWR requirements are fulfilled.

Typical contents:

  • detailed material and layer constructions (including coatings, adhesives, additives),
  • drawings, bills of materials, article and variant overviews,
  • test reports on recyclability and material minimisation,
  • evidence of compliance with substance restrictions (e.g. heavy metals, PFAS),
  • documentation of design specifications (e.g. void-space limits in e-commerce),
  • traceability information along the supply chain.

Manufacturers must retain technical documentation and DoCs for at least 5 years for single-use packaging and at least 10 years for reusable packaging after it has been placed on the market.

You can find more details about technical documentation in this article.

2.3 Supplier documentation and certificates

Without robust supplier data, your technical documentation will have gaps. You will need, among other things:

  • material specifications and Declarations of Conformity from upstream suppliers,
  • food safety and migration reports (food contact),
  • evidence of PFAS-free materials or compliance with PPWR limit values from 12 August 2026,
  • certificates such as FSC, BRCGS, ISO and recycling or recycled-content certificates,
  • validity/expiry dates of certificates.

Common pitfall: Supplier declarations are requested by email but are not centrally stored or version-controlled. In the audit, you then lack a clear assignment to the relevant packaging batch.

2.4 EPR, registration, and reporting evidence

PPWR links design and documentation obligations with Extended Producer Responsibility (EPR). Relevant for the audit are:

  • EPR registration evidence (e.g. LUCID, national registers),
  • reports and fee statements (potentially including eco-modulation components),
  • internal overviews of reported volumes per material category.

2.5 Internal process and approval documentation

For a complete picture, auditors will also look at your internal processes:

  • approval records for new/modified packaging,
  • change-control documents (what was changed, when, and why?),
  • role and responsibility descriptions,
  • internal procedures for creating and maintaining DoCs and technical documentation.

Step 3: Set up Declarations of Conformity systematically

Your goal is a complete, unambiguous, and maintainable DoC landscape.

  1. Create a DoC master list
    • One line per packaging type (ID, description, roles, status, DoC link).
  2. Standardise the DoC structure
  3. Define responsibilities
    • Who creates, who reviews, who signs? Typically Technical/Packaging, Quality/Regulatory, and possibly Legal.
  4. Establish version control
    • Each DoC version receives its own number and is linked to the reason for the change.

Tip: A digital solution like Packa links DoCs directly to specifications and test reports and enables secure version management.

Step 4: Structure technical documentation so it is audit-ready

Make sure you can quickly provide all evidence for each packaging item if authorities request it.

4.1 Consistent structure for each packaging type

Recommended structure (digital folder or data object):

  1. Master data
    • packaging ID, description, countries of use, roles, linked products,
  2. Material and construction data
    • layer structure, grammages, dimensions, drawings, bills of materials,
  3. Supplier data
    • specifications, Declarations of Conformity, certificates, recycled-content evidence,
  4. Test and assessment reports
    • recyclability, material minimisation, void-space, functional tests,
  5. Substance compliance assessments
    • PFAS assessment, migration reports, further substance restrictions,
  6. Declaration of Conformity (DoC)
    • current version including signature,
  7. History and changes
    • change logs, previous versions.

4.2 Retention periods and access

DoCs and technical documentation must be available for 5 years for single-use packaging and 10 years for reusable packaging after being placed on the market, and must be provided digitally or (on request) in paper form.

Warning: Local drives or individual mailboxes are risky. If a key person is suddenly unavailable, audit traceability is often lost.

Step 5: Collect and maintain supplier data systematically

Many PPWR risks originate upstream - for example, in coatings, adhesives, or printing inks.

5.1 Standardised request packages

Create standardised supplier request packages for each material or packaging group, containing at least:

  • full material composition (including coatings, adhesives, additives),
  • details on recyclability in the relevant collection and sorting stream,
  • PFAS status and, if available, test results,
  • evidence of food-contact suitability,
  • certificates (FSC, BRCGS, ISO etc.) including validity periods.

5.2 Digital supplier communication

Rely on digital workflows instead of individual email requests:

  • standardised forms/portals for structured data collection,
  • automatic reminders when certificates are about to expire,
  • central storage of all responses in a packaging database.

With solutions like Packa, you capture supplier data centrally, validate it automatically, and link it transparently to packaging specifications.

Step 6: Establish digital document management for PPWR audits

From August 2026, PPWR requires detailed, article-level compliance data. Manual reporting through scattered Excel files is inefficient and error-prone.

For medium and large FMCG portfolios, a digital packaging management system will be indispensable for handling PPWR audits efficiently.

Such a system should provide:

  • central management of all packaging specifications,
  • structured capture of supplier and certificate data,
  • automatic linking of DoCs, technical documentation, and articles,
  • version control and change logs,
  • real-time visibility of the compliance status of each packaging item,
  • fast, filtered exports for audits and regulatory requests.

You can find more practical guidance on implementing these requirements in Packa's PPWR 2026 guide.

The Packa software digitises specifications, consolidates evidence, and generates audit-ready reports at the click of a button.

Talk to Packa

Practical tip: Time how long it currently takes you to collect all relevant documents (specification, supplier data, test reports, DoC) for one piece of packaging. Target for 2026: under 5 minutes per article.

Step 7: Simulate a PPWR audit and close gaps

Start with an internal trial run before the first real audits.

  1. Define an audit scenario
    • Select 5-10 representative packaging items (different applications and materials).
  2. Simulate document requests
    • For each packaging item, request: DoC, technical documentation, supplier evidence, EPR data.
  3. Measure time and completeness
    • How long does it take to compile the documents? What is missing? Where are there data inconsistencies?
  4. Document and prioritise gaps
    • The result is your concrete audit checklist for data gaps, missing supplier evidence, or process adjustments.
  5. Repeat the simulation after improvements
    • Repeat the exercise after taking corrective measures until processes are reliable.

Common pitfall: The focus is placed solely on filling in the DoC, without checking whether the underlying data are complete and verifiable. Gaps are often only discovered during the audit.

Common mistakes in PPWR audit preparation - and how to avoid them

Experience from projects shows recurring stumbling blocks:

  • Incomplete packaging inventory
    • Transport and e-commerce packaging are overlooked.
  • One-off instead of systematic data collection
    • Supplier data are requested only ad hoc and not maintained systematically.
  • No clear responsibility for DoCs
    • It remains unclear who signs and who maintains them.
  • Excel spreadsheets as the main system
    • No version tracking, no data validation, increased error risk.
  • No simulations
    • Audit gaps only become visible during official inspections.

Addressing these issues early significantly reduces the risk of fines and market exclusion.

Next steps: How to get your PPWR documentation audit-ready

  1. Complete your packaging inventory and role clarification
    • Full list of all packaging types including roles (Producer/Manufacturer/Importer/Distributor-Retailer).
  2. Create a documentation mapping
    • Which DoCs, technical documents, and supplier evidence already exist, and what is missing?
  3. Build your documentation structure
  4. Digitise document management
  5. Work with templates and train your team

This approach turns PPWR audit preparation into a structured, manageable project.

FAQ: Frequently asked questions about PPWR audit documentation

1. How long do we have to retain PPWR documents?

For single-use packaging, the EU Declaration of Conformity and technical documentation must be available for at least 5 years; for reusable packaging, at least 10 years after being placed on the market. These documents must be made available to national market surveillance authorities upon request.

2. In what format do we need to provide documents during an audit?

PPWR allows electronic provision of DoCs and technical documentation; at the authority's request, documents must also be available in paper form. Maintain a digital master version and ensure that relevant information can quickly be exported as a PDF or printed copy.

3. Is one Declaration of Conformity per product family sufficient?

In practice, you need a DoC for each distinct packaging type. If material, size, or design differ in a relevant way, you should issue separate DoCs to avoid confusion and audit risks.

4. Who is the primary point of contact for authorities during an audit?

Formally, the Producer (the entity placing the product on the market) is responsible - i.e. the company that first makes the packaged products available on the EU market. Depending on the situation, however, Importers and Manufacturers may also be required to provide documents. Recommendation: appoint an internal central function (e.g. "Packaging Compliance") to coordinate inquiries and documentation.

5. How often do we need to update PPWR documents?

Whenever there are design- or material-related changes (material changes, new suppliers, altered layer structures, updated test methods), you must:

  • update the technical documentation,
  • check whether assessments such as recyclability and substance restrictions are still valid,
  • create and approve a new DoC version if necessary.

Note: This guide is intended for operational guidance and does not constitute legal advice. For binding assessments and legal opinions, please seek professional legal counsel.