PPWR for Swiss brands selling into the EU
Switzerland is not bound by Regulation (EU) 2025/40, so Swiss producers are third-country manufacturers for EU sales. The bilateral agreements do not cover it. Every packaging type sold into the EU needs the declaration and the 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.
Swiss specifics
Swiss packaging ordinances and the Swiss EPR schemes do not replace the EU declaration. Selling into Germany, France, Italy and Austria means German, French and Italian versions of the declaration. Many Swiss brands already have an EU-established entity for other regulations; check whether it can hold the Art. 17 mandate.
Data collection and document tooling. Not legal advice. The declaration is signed by the manufacturer's legal representative, who remains responsible for it.