Documents are the starting point, but the auditor also checks whether the described system works in practice. Procedures are compared with deliveries, storage, production, quality records, material reconciliation and the traceability of selected batches.
Does a RecyClass auditor mainly check procedures and documents?
No. Documentation is the starting point, but the auditor should check whether the described system actually works at the site. Procedures are therefore compared with deliveries, storage, production, quality records, material reconciliation, the traceability of particular batches and the actual process scope being certified.
1. The audit starts with the certification scope
The first question is what the certificate will cover. The auditor verifies the location, process type, input materials, outputs, chain of custody models, traceability levels and any additional modules.
A scope that is too broad or inconsistent with actual operations creates a problem from the outset. A certificate should not cover a process, product or location unsupported by evidence.
2. Documentation must reflect the actual process
The auditor compares procedures, instructions, process diagrams and forms with operations on the production floor. If a document describes batch segregation but stored material is mixed without identification, the actual situation takes precedence.
The audit does not measure how many documents the company holds. It assesses whether the documented system operates and demonstrates conformity with the applicable RecyClass programme.
3. Input material origin and supplier documentation
Depending on the programme, the auditor may check material status, origin, PCR or PreCR classification, supplier certificates and their scopes, delivery documents and consistency with stock records.
A supplier certificate alone is insufficient if the company cannot show that the purchased material falls within its scope and that the certificate was valid for the relevant period.
4. Traceability is tested using specific batches
A typical audit follows a selected batch from receipt through storage and production to the output, or in reverse. Batch numbers, dates, quantities and documents should form a coherent sequence.
An ERP can help, but is not evidence of conformity by itself. The data must connect to the actual material flow without unexplained gaps.
5. Storage is part of the audit
The auditor may check material identification, batch status, segregation of certified and non-certified material, storage of regrind and protection against accidental mixing.
A separate warehouse is not always necessary. A system must, however, clearly identify material status, quantity and intended use, and demonstrate that its rules are applied.
6. Production reveals whether formulations and records match practice
On the production floor, the auditor may observe material dosing, campaign changes, line identification, handling of out-of-specification material, internal regrinding and assignment of products to batches.
Where the company declares recycled content, the formulation, actual consumption and production records should be consistent. Differences require explanation.
7. Material reconciliation must be reproducible
Volume reconciliation is more than a table prepared for audit day. The auditor checks whether input, production, stocks, waste, losses and sales provide a credible account of material flow.
Unit errors, omitted losses, mismatched periods or differences between accounting and production figures can trigger further questions and a plausibility check.
8. Quality control needs evidence
Depending on the process, checks may cover specifications, test frequency, results, acceptance criteria, handling of non-conforming batches and complaints.
The auditor may request a particular result for a particular batch. If the procedure requires measurement but no records exist, “we always do it” does not replace evidence.
9. Permits and legal requirements affect process eligibility
Recycling processes may require waste management permits, environmental permits or other operating documents. The auditor checks their validity and whether they match the activities within the certification scope.
RecyClass certification does not replace legal requirements. Missing required permissions can affect eligibility to operate the certified process.
10. Employee interviews provide important evidence
The auditor need not rely solely on the quality representative. They may speak to warehouse staff, line operators, purchasing, sales, the production manager or the person responsible for environmental matters.
This helps establish whether the system is implemented across the organisation or understood only by the person preparing the documentation.
11. The auditor gathers evidence without designing the client's solution
The auditor assesses conformity and records findings. They may explain a requirement and identify missing evidence, but should not design the procedure, system or solution they will subsequently assess.
This boundary supports the impartiality and credibility of third-party certification.
12. The visit outcome is not yet the certification decision
After the audit, non-conformity closure, report completion, technical review and a formal certification decision may still be required. A positive closing meeting should therefore not be presented as a certificate issued on the spot.
Separating evaluation, review and decision is an important part of the certification system.
FAQ
Can the auditor select a batch for checking?
Yes. Sampling is intended to assess whether the system works. The auditor may request a batch from another month, a higher-risk supplier or a product whose traceability covers several stages.
Does the absence of an ERP constitute a non-conformity?
No. RecyClass does not automatically require a particular software system. The company must provide effective traceability and reliable records.
Does the auditor physically inspect storage and production?
During an on-site audit, observing the process, storage and material flow is an important source of evidence.
Can the auditor promise a certificate before the process ends?
An opinion following the audit should not be confused with the formal certification decision. Further stages follow the evaluation.
Does every small discrepancy constitute a non-conformity?
Not automatically. The auditor evaluates the finding against the specific requirement, available evidence and rules of the applicable programme.