You've signed.
We check what holds, and plan what comes next.
We audit your declarations and the file behind them the way an authority would. Then we map the next PPWR deadlines for your portfolio: the date, what it depends on, and who in your organisation owns it.
ThePackFlow is an independent PPWR compliance audit practice for FMCG brands and private label operators across Europe. Senior expertise applied directly — no intermediary, no supplier ties.
Since 12 August 2026, every packaging type placed on the EU market requires a valid Declaration of Conformity. Most companies have signed theirs — but a signature and a defensible file are not the same thing.
A declaration is usually prepared by the team that made the original packaging decisions. That team has every reason to find themselves compliant. An independent reviewer has no such bias — and looks at your data the way a regulator would.
We review your documentation, test your assumptions, and flag what could be challenged, while you can still fix it.
PFAS thresholds
Proving 0 ppm is practically impossible — PFAS are present at trace levels and testing has detection limits. For food-contact packaging, Article 5(5) sets three limits: 25 ppb for any single PFAS measured by targeted analysis, 250 ppb for the sum of PFAS — polymeric PFAS excluded from both — and 50 ppm for PFAS including polymeric PFAS. Above 50 mg/kg of total fluorine, you must be able to show on request how much of it is PFAS. The Commission's 2026 guidance sets out a stepwise testing approach. But a threshold is not a defence: we assess whether your testing approach and assumptions would survive scrutiny.
Void space justification
Claiming you cannot reduce empty space requires documented assumptions that are easy to challenge. Most justifications rely on internal estimates that have never been independently tested.
Overdesigned packaging
Many packs are structurally over-specified for valid safety reasons — but cautious engineering is now a compliance problem. "We were being cautious" is not a defensible answer under PPWR.
Private label liability
If your name or trademark appears on the packaging, you are the legal manufacturer (Articles 3(13) and 21) — regardless of who produced it. Your supplier's declaration transfers liability onto you, not away from you. (Added 14 October 2026: one exception — if you are a micro-enterprise and your packaging supplier is established in the same Member State, the supplier is the manufacturer, not you.) The Commission's 2026 guidance also formally distinguishes the manufacturer (product obligations) from the EPR producer — two roles, often two different entities, and a classic source of unowned obligations.
You have signed Declarations of Conformity
A signed declaration stays your responsibility. An independent review tells you what would not survive regulatory scrutiny, while you can still correct it.
You sell private label products
You are legally the manufacturer of record (Articles 3(13) and 21). Your supplier's declaration is your liability — and most private label teams haven't fully registered this yet. (Added 14 October 2026: one exception — if you are a micro-enterprise and your packaging supplier is established in the same Member State, the supplier is the manufacturer, not you.)
You have had regulatory issues before
If your company has received enforcement notices or fines in the past, you already know what non-compliance costs. This audit is the check before an authority does it.
You operate across multiple EU markets
Enforcement will sit with national authorities. Interpretation varies between member states. Multi-market exposure multiplies your risk and requires a broader review.
You sell into the EU from outside it
Article 45(3) requires an authorised representative for EPR in each Member State where you first make packaging available. It applies today: the suspension being discussed in the European Parliament concerns only micro and small producers established in the EU.
Scoping & data intake
Define the perimeter and share your documentation — Declarations of Conformity, supplier data, technical files. We agree on what we are reviewing and what the deliverable looks like.
Independent review
We go through your data with the aim of finding what could be challenged. Every assumption is tested. Every grey area is documented with a clear explanation and a recommended action.
Audit report, roadmap & debrief
A clear report: what holds up, what needs work, what is genuinely ambiguous, and what is coming next, in order, with an owner for each step. We walk you through it and answer questions. You decide what to do next.
Every engagement is scoped around your packaging portfolio. For brands wanting to test the approach first, we offer a pilot audit with a clearly defined perimeter — agreed upfront before any work begins.
Pilot audit
A tightly scoped review — typically a defined set of packaging formats from a limited number of suppliers, within one product category. The perimeter is agreed before we start so the deliverable is clear and the time is bounded.
A starting point, not a substitute for a full review.
Full portfolio audit
Complete independent review of your packaging portfolio against PPWR, labelling obligations, and food contact regulations. Audit report with prioritised action plan.
Private label audit
Specialist review for own-label operators. We assess your exposure as legal manufacturer (Articles 3(13) and 21), review supplier declarations you are legally responsible for, and identify where your liability is concentrated.
PPWR roadmap
The obligations still ahead for your portfolio, each with its date or the Commission act that triggers it, and an owner in your organisation: packaging, regulatory, procurement, co-packers. For example: EPR marking only by QR code or digital means from 12 February 2027, empty space in sales packaging by 12 February 2028, harmonised labelling from 12 August 2028 at the earliest, recyclability grades and recycled content from 2030 at the earliest. A plan your team can run, and update as the dates move.
PPWR — Packaging & Packaging Waste Regulation
Recyclability, recycled content, void space minimisation, harmonised EU labelling. Applicable since 12 August 2026 — where the conformity assessment first covers the substance requirements (Article 5); recyclability grades and recycled-content minimums follow from 2030 at the earliest, later if the Commission acts they depend on are late. Knowing which obligation bites when is half the work.
Labelling & environmental claims
Triman, Info-tri, Green Dot — and "recyclable" or "eco-friendly" claims that require documented justification.
Food contact & safety regulations
Material migration, mandatory mentions, compliance with Regulation (EC) 1935/2004 and related texts.
Ongoing regulatory watch
We monitor EU legislative developments so you stay ahead of upcoming obligations beyond August 2026.
Sandra Schlexer
Founder
"I believe good packaging work always has a positive impact somewhere — whether it's cutting costs (which almost always means fewer resources or fewer lorries), meeting a regulation, or moving to a greener alternative. I'm drawn to complex problems that have simple solutions."
I have over fifteen years of experience in packaging, working across the full value chain — inside major consumer goods companies and on projects spanning food and beverage, household products, and personal care. My background covers both brand and own-label perspectives, which gives me a practical understanding of how packaging decisions are actually made, what constraints teams face, and where the real vulnerabilities tend to sit.
I set up ThePackFlow to offer something the market doesn't have yet: independent compliance audit for packaging, with no supplier ties, no conflict of interest, and no layers between you and the expertise. I work remotely across Europe and travel for plant visits or in-person reviews where the work requires it.
Sectors & contexts
How I work
Remote-first, with travel for plant visits and on-site reviews as needed. Senior expertise on every project — no juniors, no intermediaries.
Once a month, what actually changed in the PPWR: dated, sourced, checked against the text. Published in English on LinkedIn.
Subscribe on LinkedInTell us about your situation
Send us a short message describing your packaging portfolio and what you need reviewed. We will come back to you to discuss whether and how we can help.
Get in touch
