PPWR for Australian brands selling into the EU
Australian wine is one of the largest non-EU packaging flows into the Union. Each bottle format with its closure, capsule, label and carton is a packaging type needing a declaration in the language of each market you sell in.
What every non-EU seller needs
Technical documentation (Annex VII) and a signed EU Declaration of Conformity (Annex VIII) for every packaging type placed on the EU market under your brand. Evidence from your packaging suppliers on heavy metals (Pb + Cd + Hg + Cr(VI) ≤ 100 ppm) and, for food-contact packaging, PFAS limits. Declarations in the language required by each Member State where the product is sold.
Authorised representative (Art. 17)
A manufacturer established outside the EU must appoint an authorised representative established in the Union, by written mandate, who keeps the declaration and technical documentation available to market-surveillance authorities for 5 years (10 for reusable packaging) and cooperates with them. This is not optional and it is not your importer by default.
Your importer's duties (Art. 18)
EU importers must verify that the manufacturer has carried out the conformity assessment, that the declaration exists, and keep a copy of it. Importers are already asking non-EU suppliers for the document; without it, goods can be held at the buyer's warehouse, not at the border.
Australian specifics
APCO membership and the Australasian Recycling Label do not satisfy PPWR. Screwcap closures are multi-component (aluminium, liner, sometimes tin): request evidence per part. Bulk wine bottled in the EU under an EU importer's brand shifts the manufacturer role to the bottler — check who owns the brand on the label.
Data collection and document tooling. Not legal advice. The declaration is signed by the manufacturer's legal representative, who remains responsible for it.