How to resolve failing risks in your PPWR conformity scores

Last updated: June 9, 2026

Your PPWR conformity score is calculated from your questionnaire responses. Each risk control reflects a specific packaging compliance requirement. Within some controls, individual KPIs provide a more granular breakdown of what is passing or failing. This article explains each control, what causes it to fail or stay pending, and how to resolve it.


Risk 1: Substances of concern (SoC)

Checks whether your organization has taken active steps to reduce substances of concern in packaging materials, as required under PPWR Article 6.

KPI 1: SoC actions

Your questionnaire response indicates that your organization has not yet taken sufficient steps to minimize the presence of substances of concern in packaging materials. This typically means no active SoC reduction program has been confirmed.

How to resolve

Update your operations and the questionnaire to confirm that your organization has an active SoC minimization program. Supporting evidence such as a material restrictions list or chemical management policy will strengthen your score.

Survey path

Packaging assessment survey > Substances of Concern > General


Risk 2: PFAS restrictions

Assesses whether your packaging materials comply with PFAS concentration limits and whether test documentation is on file. Two KPIs are evaluated independently.

KPI 1: PFAS threshold

One or more of the three regulated PFAS concentration thresholds have been exceeded in your packaging materials.

The thresholds are as follows:

  • Step 1: Total fluorine must not exceed the 50 mg/kg. If your packaging is below this threshold you are passing the assessment. If not you must move to step 2.

  • Step 2: Total organic fluorine must not exceed the 50 mg/kg. If your packaging is below this threshold you are passing the assessment. If not you must move to step 3.

  • Step 3: Highest PFAS type must not exceed the 25 µg/kg and the sum of all PFAS must not exceed 250 µg/kg.

How to resolve

Identify which threshold is exceeded in your test results and work with your suppliers to reformulate or replace affected packaging components. Update your questionnaire once compliant materials are in use.

Survey path

Packaging assessment survey > Substances of Concern > PFAS > PFAS volume thresholds

KPI 2: PFAS test reports

Either no PFAS test report has been provided, or the questionnaire response indicates a report exists but no file was attached.

How to resolve

Obtain a PFAS test report from an accredited laboratory and upload it to the questionnaire. If a report already exists, re-open your submission and attach the file in the PFAS test question.

Survey path

Packaging assessment survey > Substances of Concern > PFAS > PFAS test results


Risk 3: EN13430 compliance

Verifies that your packaging has been assessed against EN13430, the European standard for packaging recoverable through material recycling, and that supporting evidence is attached.

KPI 1: EN13430 assessment

This control fails for one of two reasons: no EN13430 compliance assessment has been carried out for your packaging, or the questionnaire indicates compliance was assessed but no document was attached.

How to resolve

If no assessment has been done, commission one against the EN13430 standard. If an assessment already exists, re-open the questionnaire and attach the compliance document in the specific question.

Survey path

Packaging assessment survey > Recyclability > General


Risk 4: Document completeness

Evaluates whether all required packaging documentation has been provided. Five KPIs are assessed independently. A packaging entry can fail on one or more of these simultaneously.

KPI 1: Harmonisation

No information on harmonisation has been provided for this packaging entry. Add the relevant harmonisation data in your questionnaire response.

Survey path

Packaging assessment survey >Harmonisation standards & specifications > Harmonisation standards

KPI 2: Specifications

No packaging specifications have been provided. Complete the specifications fields in your questionnaire or attach the relevant specification document.

Survey path

Packaging assessment survey >Harmonisation standards & specifications > Common specifications

KPI 3: Design documents

No design documentation has been provided for this packaging. Upload design files or drawings for the packaging entry in the questionnaire.

Survey path

Packaging assessment survey > Materials, design and diagrams > Conceptual design

KPI 4: Technical documents

No technical documentation has been provided. Attach the relevant technical files (e.g. material data sheets, compliance certificates) to your questionnaire submission.

Survey path

Packaging assessment survey > Materials, design and diagrams > Technical drawings

KPI 5: Component breakdown

One or more packaging items contain components for which no component-level information was provided. Each component within a packaging entry must be documented individually.

Survey path

Packaging assessment survey > Materials, design and diagrams > Components per material type (e.g., Glass, Textile)

How to resolve
Each KPI above is scored independently. Upload the evidence on each relevant questions to complete the data collection needs.


Risk 5: Heavy metals restrictions

Checks compliance with heavy metal concentration limits in packaging materials and verifies that test documentation is available. Two KPIs are evaluated independently.

KPI 1: Heavy metal threshold

The heavy metal threshold have been exceeded in your packaging materials. The total heavy metals threshold should not be exceeding 100 mg/kg for the total packaging type.

How to resolve

Work with your suppliers to reformulate or replace affected packaging components. Update your questionnaire once compliant materials are in use.

Survey path

Packaging assessment survey > Materials, design and diagrams > Components per material type (e.g., Glass, Textile) > Heavy metal concentration column

KPI 2: Heavy metal tests

Either no heavy metals test report has been provided, or the questionnaire response indicates a report exists but no file was attached.

How to resolve

Obtain a heavy metals test report from an accredited laboratory and upload it to the questionnaire. If a report already exists, re-open your submission and attach the file in the heavy metal test question.

Survey path

Packaging assessment survey > Substances of Concern > Heavy metals > Heavy metals test results