The auditor collects and evaluates evidence at the site. The technical reviewer then checks whether the documented evidence supports the certification conclusion. This is an additional control over quality and impartiality, not a repeat of the audit visit.
Why can an audit report still be checked by another person after the visit?
The audit and technical review address different questions. The auditor collects and assesses evidence directly at the site. The reviewer subsequently checks whether the audit file is complete, logical and sufficient to support the certification conclusion. This adds a layer of quality control and impartiality.
1. Technical review is not a second audit
Technical review does not repeat the site visit. The reviewer mainly works with the audit report, evidence, attachments and records submitted during the process.
Their role is to check whether the material collected by the auditor supports the conformity assessment, rather than replace the auditor.
2. The reviewer sees the report from a different perspective
The auditor knows the context of the discussions and observations. The reviewer primarily sees what has been formally recorded. This can reveal gaps that seemed obvious to the auditor but were never documented.
A useful rule is that if a conclusion cannot be understood without an oral explanation from the auditor, the report needs more detail.
3. Independence from the audit being reviewed matters
RecyClass technical review must be independent of the evaluation activities in the particular audit. The person who conducted the audit cannot provide independent review of their own assessment.
RecyClass packaging certification documentation explicitly describes a model in which a recognised auditor from the certification body, who was not involved in the audit, reviews the report and may then decide to grant certification.
4. The reviewer checks consistency with the scope
A key question is whether the report covers exactly what the certificate will state: the correct location, process, products, materials, modules, levels and assessment period.
Inconsistency between the application form, audit report and draft certificate is a common reason for further questions.
5. The reviewer assesses whether the evidence is sufficient
Marking a requirement “compliant” may be insufficient. The evidence needs to be described: a document, observation, record, result, batch, example or other information supporting the conclusion.
The reviewer may ask the auditor for clarification, further evidence or a report correction where the record does not clearly support the assessment.
6. Non-conformities must be described logically
The reviewer checks whether the non-conformity is linked to a requirement, whether the evidence is clear and whether the client's response addresses the actual problem.
Closure based only on a statement without supporting evidence may be challenged during review.
7. Figures and reconciliations are checked for consistency
For programmes concerning recycled content, the reviewer may revisit percentages, reporting periods, masses, reconciliation results, outputs and product scope.
The purpose is to identify inconsistencies that could lead to an incorrect claim or certificate scope, rather than repeat the entire audit.
8. Review can reveal a conflict between report and certificate
If the report covers a defined product family but the draft certificate includes additional products, the reviewer should stop the process until the difference is explained.
The certificate is the final document communicated externally. Its scope must follow from the audit and approved report.
9. A reviewer's question does not automatically mean the auditor made a mistake
Further questions are a normal part of quality control. Sometimes a description needs clarification or the reviewer needs the location of evidence already included in the file.
A professional system allows verification and technical discussion before the final decision.
10. Technical review also protects the client
Effective review reduces the risk of issuing a document with the wrong scope, an unsupported claim, an error in technical data or a conclusion lacking evidence.
The client receives a more credible certification document that is better able to withstand subsequent scrutiny.
11. Review must not become consultancy
The reviewer also assesses the solutions submitted. They should not design the client's system or prescribe a specific solution that they will later approve.
They may explain that evidence does not meet a requirement or that further clarification is needed.
12. A positive review enables the certification decision
Depending on the programme, review and decision may be performed by the same authorised person or organised as successive functions under the body's procedure. The required separation from evaluation activities must be maintained.
The certificate can only be formally issued once all required stages have been completed successfully.
FAQ
Must the technical reviewer be a recognised RecyClass auditor?
Yes. According to RecyClass Questions & Answers Certification 2026, the technical reviewer must be a recognised RecyClass auditor. For SP, RP and RC, the reviewer must be based in EU27+3. Reviewing Module A also requires the relevant Module A training. Decision-maker competence is addressed separately.
Can the reviewer request further documents from the client?
Communication normally follows the certification process through the auditor or certification body. Further information may be needed where the report lacks sufficient evidence.
Does technical review extend the process?
It is a planned certification stage. Its duration depends in part on the completeness of the report and whether further information is required.
Can the reviewer challenge the auditor's assessment?
Yes. Where evidence does not support the conclusion, the reviewer can challenge it and request clarification or correction under the procedure.
Does the client receive a separate technical review report?
Not necessarily. Review is part of the certification body's internal process, and its documentation depends on the programme and procedures.