How does a packaging audit prepare a company for the requirements of the PPWR? Case Study

The PPWR packaging audit enables a company to check whether its packaging is compliant with the European Union’s new requirements regarding recyclability, recycled content, weight minimisation, labelling and documentation. It is not merely a review of cartons, films or labels. A well-conducted audit highlights which packaging poses legal risks, which increases costs, which can be simplified, and which requires redesign before the next stages of the PPWR come into effect.

The PPWR, or Regulation (EU) 2025/40, covers all packaging and packaging waste, regardless of material or origin. The European Commission states that the new regulations are intended to reduce packaging waste, increase recyclability, promote reuse and reduce the consumption of virgin raw materials.

The case study below illustrates how a packaging management audit can prepare a manufacturing company for PPWR, whilst also helping to optimise packaging costs. This example has been anonymised and is based on an actual implementation — the specific percentage figures should be adjusted to reflect the company’s actual performance.

What is a PPWR packaging audit?

The PPWR packaging audit is a systematic analysis of the packaging used by a company in terms of compliance with new EU packaging regulations, costs, documentation and opportunities for optimisation. In practice, it covers unit packaging, collective packaging, transport packaging, dispatch packaging, labels, films, fillers, trays, closures, dividers and other components used in the supply chain.

The EKOPRO GROUP describes PPWR audit as a comprehensive assessment of the company’s readiness to meet the new requirements, including an analysis of packaging in terms of its design, composition, recyclability, and environmental and legal compliance.

The PPWR packaging audit does not merely answer the question of whether the packaging complies with the law. It also reveals whether the company is overpaying for weight, materials, unnecessary components and unnecessarily complex solutions.

This is important because PPWR combines regulatory compliance with material efficiency. Packaging that is difficult to recycle, too heavy, overly complex or poorly documented can generate costs not only in procurement, but also in reporting, EPR, BDO, logistics and B2B customer relations.

Why should manufacturing companies carry out an audit before implementing the PPWR?

Manufacturing companies often use several types of packaging simultaneously: retail packaging, bulk packaging, transport packaging, pallet packaging, protective packaging and export packaging. In such a structure, the risk of non-compliance rarely lies in just one area.

Most often, the problem arises in several areas at once:

– the packaging is too heavy in relation to its function,
– multi-material packaging that is difficult to recycle,
– no information on the composition of the components,
– no confirmation of the recycled content,
– packaging designed for marketing purposes, but without an assessment of its recyclability,
– inconsistencies in data between purchasing, the warehouse, BDO and reporting,
– the absence of a person responsible for the overall management of packaging,
– overseas sales without a full EPR analysis.

The European Commission points out that the PPWR is intended to cover requirements relating to the production, composition, reuse and recovery of packaging. This means that a company cannot limit its analysis to post-production waste alone — it must consider packaging from the design stage and the procurement of materials.

Case Study: A manufacturing company prior to the audit

A manufacturing company in the B2B sector produced goods packaged in individual units, master cartons, protective film and transport packaging on pallets. The company sold its products in Poland and on selected EU markets. Until now, packaging had been treated primarily as a procurement and logistics cost.

Before the audit, the situation was typical of many manufacturing companies:

– the purchasing department selected packaging on the basis of price and availability,
– the production department assessed, above all, the convenience of the packaging,
– the marketing department approved the design of the individual packaging,
– the warehouse was responsible for transport security,
– the accounts and compliance departments received data on packaging weights with a delay,
– no one in the company had a single complete list of packaging types.

At first glance, the process seemed to be running smoothly. Products were reaching customers, complaints were at an acceptable level, and packaging costs were within budget. The problem only became apparent following a PPWR analysis: the company was unable to quickly identify which packaging was recyclable, which contained plastic components, which was subject to recycled content requirements, and which accounted for the largest mass in its reporting.

The greatest risk was not a single error in the packaging, but the lack of centralised knowledge about which packaging the company was actually putting on the market.

Stage 1 of the audit: mapping of packaging and material flows

The first step was to carry out an inventory of packaging. The audit team gathered data on all types of packaging used by the company: from individual packaging to pallet securing devices.

The analysis covered:

– the name of the packaging,
– material code,
– a supplier,
– unit mass,
– the predominant material,
– additional components,
– the intended use of the packaging,
– sales market,
– annual volume,
– documentation from the supplier,
– reporting procedures in environmental management systems.

The first business benefit became apparent at this stage: the company discovered that some similar products were being packaged in different formats simply because they had been purchased at different times. This was not due to technological considerations or product protection, but to a lack of standardisation.

Conclusion of the audit: before a company begins to implement the PPWR, it must know how much packaging it has, what it is made of and where it ends up.

Stage 2 of the audit: assessment of PPWR risks

The second stage involved assigning packaging to risk categories. Highest priority was given to high-volume packaging, plastic packaging, multi-material solutions and items that are difficult to document.

The audit identified four main categories of risk.

The first group consisted of multi-material packaging. In several cases, the combination of paper, plastic and adhesive created a composition that was difficult to assess in terms of recyclability. Such solutions require special analysis, as the PPWR shifts the focus from material declarations to the actual feasibility of sorting and recycling. In such cases, a separate analysis is helpful multi-material packaging.

The second group consisted of packaging that was overweight. The company used the same cardboard boxes and dividers for several product groups, even though some of the products did not require such extensive protection.

The third group consisted of documentation gaps. Suppliers did not always provide information on the composition, weight of components, recyclability or recycled content.

The fourth group comprised environmental data. The information required for BDO, EPR and fee analyses was scattered across different departments, which increased the risk of reporting errors.

Stage 3 of the audit: optimising the weight of packaging

One of the most significant outcomes of the audit was the identification of packaging whose weight could be reduced without increasing the risk of product damage. This is a typical area where a packaging audit combines compliance with the PPWR with financial savings.

The analysis covered:

– bulk cartons,
– dividers and inserts,
– stretch film,
– individual packages,
– corner protectors,
– palletised packaging,
– labels and ancillary items.

In several cases, it transpired that the packaging was oversized in relation to its actual protective function. The company used a single standard for products of varying weights and durability, which simplified the purchasing process but increased the weight of the packaging materials.

The following implementation recommendations were made:

– standardisation of formats,
– a reduction in the number of unnecessary spacers,
– a change in the grammage of selected cardboard sheets following transport tests,
– minimising the use of plastic sheeting where alternative protection was possible,
– introducing rules for selecting packaging for a product group,
– updating procurement specifications.

Optimising packaging costs is not simply a matter of buying the cheapest material. It involves removing excess weight, unnecessary components and solutions that serve no real purpose.

Stage 4 of the audit: documentation and compliance data

The PPWR places greater emphasis on technical documentation. A company must be able to demonstrate what the packaging is made of, its composition, weight, function and recyclability, and whether it contains components requiring further assessment.

In the case study, one of the main problems was the lack of a standardised packaging data sheet. The data was available, but scattered: some was held by the purchasing department, some in the warehouse, some in suppliers’ files, and some in BDO’s records.

Following the audit, it was recommended that a single package insert be created, containing:

– the name and code of the package,
– a supplier,
– main material,
– gross weight,
– the mass of the components,
– the proportion of plastics,
– information about recycled material,
– an assessment of recyclability,
– documents from the supplier,
– sales market,
– integration with BDO and EPR systems,
– the date of the last update.

Such a document is useful not only during audits. It makes shopping, negotiations with suppliers, the design of new products and environmental reporting easier.

Stage 5 of the audit: BDO, EPR and sales in the EU

A PPWR packaging audit should not be limited to the packaging unit itself. If a company sells products in Poland and abroad, it must integrate PPWR with its obligations under BDO, EPR, LUCID and other national schemes.

The EKOPRO GROUP states that it supports businesses in launching products and packaging on the EU and Polish markets, as well as in meeting environmental obligations such as those relating to BDO, KOBiZE and reporting.

In the case under review, the company sold some of its products to overseas customers. The audit revealed that the data on packaging weights could not be easily broken down by market. This made it difficult to assess EPR obligations in individual countries.

The recommendation was clear: any change to packaging should be assessed not only by the production and procurement departments, but also by the person responsible for environmental matters in the sales markets.

Companies operating across borders should consider compliance with packaging obligations in EU markets, and also when selling to Germany LUCID audit.

The results of the audit: what has changed within the company?

Following the audit, the company did not replace all the packaging at once. Instead, it drew up an action plan divided into three stages.

The first stage involved quick fixes: organising the data, collecting missing declarations from suppliers, standardising packaging names and improving the flow of information between the procurement and compliance departments.

The second stage involved material optimisation: reducing excess components, changing the formats of several cardboard boxes, cutting back on some filler materials, and standardising packaging for selected product groups.

The third level comprised strategic measures: the redesign of high-risk PPWR packaging, the updating of procurement specifications, the implementation of packaging data sheets, and the linking of data to BDO and EPR obligations.

This resulted in a reduction in the risk of future charges and penalties, better preparation for the PPWR, and greater control over packaging costs. In the client’s publication, it would be worth including specific figures here, for example:

– a percentage reduction in the weight of selected packaging,
– the number of SKUs analysed,
– the number of packaging items to be redesigned,
– an estimated reduction in the cost of purchasing materials,
– a reduction in the weight reported in environmental systems,
– the number of suppliers subject to the new documentation requirements.

How does an audit help you avoid charges and costs?

A packaging audit does not automatically guarantee that no charges will be incurred, as specific obligations depend on regulations, weights, materials and sales markets. However, it can significantly reduce the risk of costs arising from incorrect data, excess packaging weight or delayed changes.

The key cost-saving measures are:

– reduction in packaging weight,
– minimising unnecessary components,
– reducing the number of formats,
– packaging that is better suited to the product,
– updating data for BDO and EPR,
– a lower risk of reporting errors,
– earlier detection of packaging that is difficult to recycle,
– avoiding a costly last-minute redesign.

The environmental audit offered by EKOPRO includes, amongst other things, an analysis of operational and production processes, taking into account the flow of materials, packaging and waste, as well as the identification of areas for optimisation and the reduction of waste generation at source.

Packaging management audit and the circular economy

The PPWR packaging audit ties in well with the circular economy. The circular economy is not solely about recycling. It is about designing processes to minimise the use of raw materials, extend the life of materials, reduce waste and improve the efficiency of the entire system.

In the case study, the company changed its approach to purchasing decisions following the audit. Previously, the question had been: „Which packaging is cheaper?”. Following the audit, the question changed to: „Which packaging fulfils the required function, has a lower weight, better documentation, a lower risk of product liability claims and a lower cost over its entire life cycle?”.

This is precisely the difference between simply saving money on purchases and a circular economy strategy. In this area, it is worth making use of GOZ package and EKOPRO’s experience in circular economy projects. The circular economy projects page indicates that EKOPRO offers support ranging from potential analysis, through solution design, to project implementation, and also assists companies in preparing grant applications related to the circular economy.

How should a company implement the PPWR following an audit?

An audit should result in an implementation plan. The report alone is not enough unless the company assigns responsibilities, sets deadlines and allocates a budget.

1. Determine the process owner

PPWR cannot be „nobody’s” responsibility. The company should appoint a person or team to be responsible for packaging, data, documentation and liaising with suppliers.

2. Sort the parcels by priority

First, we need to tackle the packaging with the largest volume, the highest weight, the highest proportion of plastic and the greatest risk to recyclability.

3. Set out the requirements for suppliers

Suppliers should provide data on composition, weight, recycled content, recyclability and substances of concern. A lack of documentation should be treated as a procurement risk.

4. Update the packaging specifications

The specification should include not only the dimensions and price, but also PPWR requirements, material, weight, function, documentation and design preferences in line with recycling.

5. Test changes before implementation

Any reduction in packaging weight must not result in damage to the product. Every change should be assessed in terms of quality, transport, complaints and environmental compliance.

6. Link the data from BDO and EPR

Changes to packaging should automatically update the data used for BDO, EPR, LUCID and other national systems. Otherwise, a company may optimise its packaging but still report incorrect data.

When is a PPWR packaging audit particularly necessary?

An audit is particularly worth carrying out if the company:

– manufactures products in a variety of packaging types,
– uses plastic packaging,
– uses multi-material packaging,
– sells products abroad,
– imports goods in packaging,
– is facing rising costs for packaging materials,
– there is no complete data on the weights of the packages,
– uses a number of suppliers,
– develops new product ranges,
– wants to minimise the risk of charges, adjustments and penalties.

In such situations, an audit is cheaper than rectifying errors after non-compliant packaging has been put into use.

The most common mistakes companies make before an audit

The first mistake is to assume that it is enough simply to ask the supplier whether the packaging is environmentally friendly. The PPWR requires data, not a general declaration.

The second mistake is to analyse only the individual packaging. In manufacturing companies, bulk packaging, transport packaging and pallet securing measures are also of great importance.

The third mistake is the lack of data on weight. Without the weight of the packaging, the company will be unable to assess the costs, reporting obligations or potential for reduction.

The fourth mistake is judging packaging solely on the basis of its purchase price. Cheaper materials can lead to higher costs in terms of reporting, logistics, customer complaints or redesign.

The fifth mistake is postponing the PPWR until 2030. Changing the packaging requires testing, approvals, suppliers and updates to documentation, so the process should begin earlier.

Professional implementation and audit reliability

Case studies and recommendations are important because a packaging audit affects real-world business processes. The company commissioning the audit wants to know whether the consultant understands production, logistics, BDO, EU obligations and operational constraints.

EKOPRO showcases testimonials from customers and partners on its website Customers, where companies highlight their experience, commitment and effectiveness in implementing circular economy strategies.

In the context of the PPWR, this is important because an audit should not merely be a list of regulations. It should lead to decisions: which packaging to change, which to keep, which to document, which to test, and which to withdraw.

FAQ - Frequently asked questions

What does the PPWR packaging audit cover?

The audit involves analysing packaging in terms of its design, composition, weight, recyclability, documentation, environmental obligations and compliance with PPWR requirements. It may cover unit packaging, collective packaging, transport packaging and dispatch packaging.

Can a packaging audit reduce costs?

Yes, an audit can identify packaging that is oversized, too heavy, overly complex or unnecessarily expensive. Reducing weight, standardising formats and selecting materials more carefully can help to cut purchasing and transport costs, as well as reduce environmental obligations.

Does the PPWR audit replace the BDO audit?

No. A PPWR audit does not replace a BDO audit, but it helps to organise the packaging data required for accurate environmental reporting and accounting. It is therefore worth combining a PPWR analysis with a BDO and EPR review.

What data do you need to prepare for the audit?

It is worth compiling a list of packaging, weights, material specifications, supplier details, sales volumes, target markets, information on the BDO, and documents relating to the packaging used in production, storage and dispatch.

When is the best time to carry out a packaging audit?

Ideally, this should be done before changing suppliers, launching a new product range, entering a new EU market or redesigning packaging. Carrying out an audit in advance helps to avoid costly last-minute changes.

Can an audit case study be used in ESG communications?

Yes, if the company has data to support the results, such as a reduction in packaging weight, a reduction in the number of components, improved recyclability or better data control. Such information should be reliable, measurable and verifiable.

Commission an analysis of your packaging

The PPWR packaging audit helps a company move from a reactive approach to packaging to a proactive management of materials, costs and legal risks. A well-conducted analysis highlights where the company is losing money, which packaging may pose a risk, and how to prepare for PPWR requirements without causing operational chaos.

Have your packaging analysed and find out PPWR audit. See also the company’s professional projects and recommendations and make use of Eko-Pro’s comprehensive environmental consultancy services. If you’d like to discuss a specific case, go to the tab Contact Eko-Pro and describe your packaging, volumes and sales markets.