PPWR for UK brands selling into the EU
Since 12 August 2026 every packaging you place on the EU market under your brand needs an EU declaration of conformity. As a UK-established business you are a third-country manufacturer: the full obligations apply, plus an EU authorised representative.
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.
UK specifics
UK packaging EPR and the UK's own labelling rules do not satisfy PPWR. Northern Ireland businesses are treated as EU-established for goods placed on the NI/EU market under the Windsor Framework — check with your adviser. Many UK wine and spirits brands sell into Ireland, France and Germany: that is three market languages on the declaration.
Data collection and document tooling. Not legal advice. The declaration is signed by the manufacturer's legal representative, who remains responsible for it.