PPWR Compliance: Do You Need an Authorised Representative, and How Do You Choose One?
| Direct answer: If you manufacture, import, or sell packaged products into the EU, the Packaging and Packaging Waste Regulation (Regulation (EU) 2025/40, “PPWR”) applies to you from 12 August 2026, regardless of what’s inside the packaging. Most businesses need to prepare a Declaration of Conformity and technical documentation for their packaging. If you’re a manufacturer based outside the EU, you separately need to appoint an EU-based Authorised Representative under Article 17 to hold that documentation, and if you don’t have your own entity in a given member state, you likely also need a separate Article 45(3) representative to handle extended producer responsibility registration in that country. These are two different obligations, not one, and providers who blur them together are worth double-checking. |
Do you actually need this, and who’s responsible for what
The PPWR applies to all packaging placed on the EU market, regardless of material. Plastic, paper, glass, metal, wood, and composite packaging are all in scope, there’s no exemption based on what the packaging is made of. It also applies regardless of what’s inside the packaging, so this sits alongside whatever product-specific regulation already applies to your goods (GPSR, cosmetics regulation, and so on), it doesn’t replace it.
Who counts as responsible depends on your role in the supply chain:
1. Manufacturers carry the primary obligations: conducting the conformity assessment against Articles 5 to 12, and preparing the Declaration of Conformity under Article 39.
2. Importers (Article 18) must verify that packaging from outside the EU already meets Articles 5 to 12 before it’s placed on the market, and can’t pass that responsibility upstream.
3. Distributors (Article 19) have a “due care” duty: checking that the producer is registered, that labelling is present, and that manufacturer contact details are correct, before making packaging available.
4. Fulfilment service providers (any business handling at least two of warehousing, packaging, addressing, or dispatching without owning the goods) must ensure the packaging they handle meets Articles 5 to 12, and are expected to stop handling packaging that doesn’t.
5. Online marketplaces have their own due-diligence obligations under Article 45, including checking that sellers are properly registered before allowing their listings.
If you’re a non-EU manufacturer, two separate representative appointments can apply, and they’re easy to conflate:
• Article 17: an optional, EU-wide product-conformity representative who holds your technical documentation and Declaration of Conformity, and responds to market surveillance authorities on your behalf. One appointment covers the whole EU. By law, this representative cannot write your technical documentation for you, they hold and defend it, you (or your compliance provider’s tooling) still has to produce it.
• Article 45(3): a separate, mandatory extended producer responsibility (EPR) representative, required in each individual member state where you place packaging and don’t have your own entity. This one handles registration in that country’s national packaging register, reporting packaging volumes and materials, and paying into that country’s producer responsibility scheme. You keep the underlying legal responsibility either way, appointing a representative doesn’t transfer liability, it delegates the operational work.
What you actually have to do
• Substance restrictions (Article 5): heavy metals (lead, cadmium, mercury, hexavalent chromium) capped at a combined 100 mg/kg in packaging or packaging components. PFAS in food-contact packaging capped at 25 ppb for any single PFAS substance, 250 ppb for total PFAS, and 50 ppm for polymeric PFAS. These apply from 12 August 2026.
• Recyclability (Article 6): packaging must be designed to be recyclable, with detailed design-for-recycling criteria expected to firm up around 2028, worth checking current Commission guidance closer to that date.
• Recycled content (Article 7): plastic packaging must contain a minimum share of recycled content, 10 to 35% depending on packaging type from 1 January 2030, rising further (50 to 65% for certain categories) from 1 January 2040.
• Minimisation (Article 10): packaging (including e-commerce packaging specifically) must avoid unnecessary empty space and excess weight or volume.
• Labelling (Article 12): material composition pictograms, manufacturer or importer name and address, identification numbers, and (for certain categories) QR codes linking to disposal instructions. This phases in, some elements apply from 2026, with fuller harmonised labelling requirements following in 2028, confirm the current phase-in schedule before relying on a specific date for your packaging category.
• Declaration of Conformity (Article 39): manufacturers must prepare a DoC following the Annex VIII model, incorporating the Annex VII (Module A, internal production control) conformity assessment. No notified body is required, this is a self-assessment, not third-party certification. The DoC must be kept continuously updated, translated into the language of each member state where the packaging is placed on the market, and held on file for market surveillance purposes (not submitted to any central registry). Retention is 5 years for single-use packaging and 10 years for reusable packaging.
• EPR registration (Article 45(3)): where required, registration in the relevant national packaging register, ongoing reporting of packaging volumes and materials, and fee payments into that country’s producer responsibility scheme.
• HORECA restrictions (Article 25(1) and Annex V): certain single-use packaging formats are banned in the hospitality sector from 1 January 2030.
How to choose: match the provider to your situation
| Your situation | What to look for |
| EU-based manufacturer | Confirm your existing quality system can produce Annex VII/VIII-compliant documentation, you may not need an external Authorised Representative at all, just conformity assessment support. |
| Non-EU manufacturer, selling into several member states | Needs both an Article 17 representative (one, EU-wide) and likely Article 45(3) EPR registration in each member state without your own entity, confirm whether one provider covers both or you need two. |
| Importer | Your obligation is verifying Articles 5 to 12 compliance before the packaging enters the EU market, ask any provider exactly what evidence they’ll hand you to prove that. |
| E-commerce seller / marketplace seller | Minimisation rules (Article 10) apply specifically to e-commerce packaging, and marketplaces have their own due-diligence checks on your registration status, don’t assume a generic AR quote covers this. |
When comparing providers, ask directly: does their Authorised Representative service cover Article 17 documentation-holding only, or does it also handle Article 45(3) EPR registration and fee payment in specific member states? Those are genuinely different scopes of work and should be priced and described separately, not bundled into one vague “AR service” line item.
Where Euverify fits
Euverify’s PPWR support is built around a guided wizard: an eight-step flow covering packaging type, materials, substances, and declaration details, with live checks that flag PFAS and heavy-metals issues as you go, and hard stops that prevent you from generating a non-compliant declaration. It produces both the Declaration of Conformity and the Annex VII technical documentation from the same data entry, and stores both for the statutory retention period (5 to 10 years, depending on packaging type) with renewal reminders. The tool is included on every Euverify plan at no separate fee, each packaging type simply counts toward your plan’s product limit alongside your other products.
Euverify also offers an Article 17 Authorised Representative mandate: a single e-signed agreement under which Euverify holds your documentation at authorities’ disposal and responds within the statutory 10-day window. As with any Article 17 representative, this covers documentation-holding, not drafting your technical file for you, that’s what the wizard is for.
Red flags to watch for
• A provider that says you need a notified body for PPWR conformity assessment. You don’t, Annex VII Module A is a self-assessment procedure.
• A provider that talks about “the Authorised Representative service” as one undifferentiated thing, without distinguishing Article 17 documentation-holding from Article 45(3) EPR registration. If they haven’t made that distinction to you, ask directly which one (or both) you’re actually buying.
• A provider that can’t tell you which specific packaging materials or product categories their tool actually checks against the Article 5 substance restrictions.
• No mention of retention periods or renewal reminders for the Declaration of Conformity, this is a “kept continuously updated” obligation, not a one-time document.
• Pricing that isn’t disclosed until after a sales call, for a compliance process that’s fundamentally the same regardless of your industry.
Frequently Asked Questions
All packaging materials are covered, plastic, paper, glass, metal, wood, and composite. There’s no exemption based on material type.
No. PPWR conformity assessment uses Module A (internal production control) under Annex VII, which is a self-assessment procedure, not third-party certification.
Yes. If you sell packaged products to EU customers, PPWR applies, and e-commerce packaging is specifically addressed under the minimisation requirements in Article 10.
Article 17 is an optional, EU-wide appointment covering technical documentation for product conformity, one appointment is enough for the whole EU. Article 45(3) is a separate, mandatory appointment required in each individual member state where a non-EU producer doesn’t have their own entity, covering extended producer responsibility registration, reporting, and fee payments. Many providers don’t clearly separate these two, worth confirming which one you’re actually being quoted for.
The Declaration of Conformity is tied to the packaging type, not the product inside it. If several different products use the same packaging specification, one DoC can cover that packaging type.
Not necessarily. Your obligations depend on your own role, manufacturer, importer, or distributor, under the regulation. Supplier documentation doesn’t automatically replace your own obligations, confirm exactly what your supplier’s documentation covers before assuming it’s sufficient.
Market surveillance authorities can require withdrawal or recall of the packaging from the market, and can issue fines. Penalties are set at the national level, so they vary by member state.
Five years for single-use packaging, ten years for reusable packaging, and the declaration itself needs to be kept continuously updated, not just filed once and forgotten.
12 August 2026 is when the core obligations apply: the Declaration of Conformity requirement, the Article 5 substance restrictions, and the Article 45(3) EPR representative requirement for non-EU producers. Recycled-content targets and full recyclability standards follow from 1 January 2030, with higher recycled-content targets from 1 January 2040. Several secondary labelling and design-for-recycling deadlines fall in 2027 and 2028 and are still being finalised in Commission guidance.
Yes. The regulation requires the declaration to be in the language, or languages, of the member state where the packaging is placed on the market.
