PPWR for US brands selling into the EU
If your product reaches EU consumers with your brand on the label, you are the manufacturer of its packaging under EU law, wherever the packaging was made. The regulation applies from 12 August 2026 with no sell-through period.
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.
US specifics
State PFAS-in-packaging laws (Maine, Minnesota, California and others) create useful evidence: supplier statements prepared for those laws often carry the data PPWR needs, but the EU limits and the declaration format are different. FDA food-contact compliance is not evidence of PPWR conformity on its own. Amazon EU and other marketplaces are beginning to request the declaration from sellers (Art. 20).
Data collection and document tooling. Not legal advice. The declaration is signed by the manufacturer's legal representative, who remains responsible for it.