Our registrar wrote a minor in an audit b/c my company did not have ppap packages on file from our steel suppliers. In the PPAP 3rd Edition book it does state that for bulk, raw or indirect material, it is the Procurring Division's decision whether ppap is required. Wouldn't this fall into that clause?
Para F.2 infers that when an OEM approves a PPAP for a bulk material then you do not need approval for the material when used in other products.
Also see F.4, contact your customer about the need for a PPAP.
Your auditor is correct in issuing a minor; you did not have documented evidence that a PPAP was not required.