PPWR for Canadian brands selling into the EU
CETA lowers tariffs; it does not exempt Canadian packaging from Regulation (EU) 2025/40. From 12 August 2026 every packaging type you place on the EU market needs a declaration, and a representative in the EU must hold your file.
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.
Canadian specifics
Canada's provincial EPR programmes (Ontario, Quebec, BC) generate material data you can reuse in the technical file, but they do not produce the declaration. Quebec producers exporting to France: a French-language declaration is required; the same file serves both.
Data collection and document tooling. Not legal advice. The declaration is signed by the manufacturer's legal representative, who remains responsible for it.