The audit system

The overall idea is to provide reliable data about the circularity aspects of the product. The entry of data into the standardized PCDS template is under the full responsibility of the issuer of the document (i.e. the manufacturer of the product). Thus, a third-party verification scheme does dramatically increase the level of confidence in the provided data and is a significant added value. It also protects the manufacturer from unintentional errors in providing the market with data on e.g. product recyclability.

The PCDS verification process

The PCDS verification process can be applied to SMEs as well as to large manufacturers. Therefore, the PCDS verification scheme considers 5 different assurance mechanisms, as shown below, in order to balance credibility and cost-accessibility.

The PCDS can be issued without being verified, but this non-verification needs to be transparently communicated. The audit provides an additional level of confidence for companies and their customers.

The audit of the PCDS management system will be lighter for ISO 9001 certified manufacturers, as it already guarantees a certain product consistency due to the implemented quality management system and the availability of related documentation.


There is a clear market need to keep the cost of this verification scheme as low as possible, as the PCDS system aims at engaging all actors throughout the supply chain from producers of raw materials to final product manufacturers. In order to save costs, the PCDS verification could be combined with regular audits. The basic auditing scheme will remain accessible to SME’s.

Accredited auditors

PCDS auditors are required to undergo specific training required to understand the structure and content of a PCDS. A particular focus is on the guidance document and the taxonomy as it is critical for the evaluation.

The independence of the verifiers is a key. In addition, the organizations allowed to perform PCDS audits need to be accredited.