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EU Authorized Representative
for Packaging Manufacturers

Lappa helps non-EU manufacturers meet EU packaging compliance through L’Authorize — covering Authorized Representative appointment, declaration of conformity, and compliance coordination. Legal responsibility remains with the manufacturer.

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EU AR service
Appoint an EU-based Authorized Representative
DoC drafting support
Help with the EU declaration of conformity
Packaging compliance
Prepare packaging for EU sustainability and labelling requirements

We help non-EU manufacturers make packaging compliant for the EU market

Packaging compliance under the PPWR is not the same as EPR. The manufacturer is the operator responsible for ensuring conformity with the packaging sustainability and labelling requirements, while the producer is the operator responsible for EPR in the Member State where packaging is first made available and expected to become waste. Lappa’s AR service is built for the manufacturer side of that framework: appointing an EU-based representative where needed, organizing compliance documentation, and supporting the declaration of conformity and packaging-readiness work.

Complete packaging AR service with L’Authorize

  • EU Authorized Representative appointment support for non-EU manufacturers
  • Review of your market-entry model and first placing on the EU market
  • Help determining who is the manufacturer and who is the producer
  • EU declaration of conformity drafting support
  • Coordination of technical documentation and supplier information
  • Practical guidance on packaging sustainability and labelling readiness
  • Support for making packaging compliant before EU market entry
  • Centralized document handling and communication through L’Authorize

This offer is designed around the manufacturer’s compliance role under the PPWR, not around local EPR producer financing workflows.

L’Authorize packaging compliance
features

EU Authorized Representative appointment

Declaration of conformity drafting support

Manufacturer vs producer role mapping

Packaging compliance document management

Supplier documentation coordination

Sustainability and labelling requirement review

EU market-entry readiness support

Ongoing expert assistance

How packaging AR support from Lappa works

1
We review your business model Assess who qualifies as the manufacturer under PPWR, where products enter the EU market, and whether you need an EU subsidiary or Authorized Representative (a branch alone doesn't resolve the establishment requirement).
2
We define the AR mandate Prepare the representative scope, set up the operating model, and align with manufacturer obligations. The AR can draft the declaration of conformity under written mandate, while legal responsibility stays with the manufacturer.
3
We support the declaration of conformity and documentation Gather supplier data, organize technical records, and draft the declaration to support compliance with Articles 5–12.
4
We help make the packaging compliant Prepare your packaging and packaged products for EU sustainability and labelling requirements before market placement.

Core elements of packaging compliance support

Authorized Representative service

Manufacturer role assessment

Declaration of conformity drafting support

Technical documentation coordination

Supplier information collection

Packaging sustainability readiness

Packaging labelling readiness

EU market-entry compliance support

Packaging compliance support
across EU

Lappa helps manufacturers manage packaging compliance from one service layer instead of coordinating separate legal, technical, and operational workstreams manually. With L’Authorize, you get one process for AR appointment, documentation handling, and declaration support, built around the manufacturer’s role under the PPWR. The Commission guidance distinguishes that role from the producer role used for EPR allocation in the Member State where packaging first becomes waste.

 

 

L’Authorize
by Lappa

L’Authorize is Lappa’s service layer for representative and compliance support. For packaging manufacturers, it is focused on the questions that matter most before EU market entry: who is the manufacturer, whether an AR is needed, what documentation is required, and how to prepare the declaration of conformity and packaging compliance file.

Authorised Representative Services photo 1

Why choose L’Authorize for packaging AR support

  • Built around the PPWR manufacturer role
  • AR appointment plus documentation support in one service
  • Practical declaration of conformity drafting help
  • Clear separation between manufacturer compliance and producer/EPR obligations
  • One structured process for EU market-entry readiness

The distinction between manufacturer and producer is central here: the manufacturer is one economic operator EU-wide for conformity purposes, while the producer is identified for EPR purposes based on first making available in the relevant Member State.

Learn more about Packaging EPR

PPWR compliance for brands: manufacturer obligations

Six practical steps for brand owners selling in the EU under the PPWR — label planning, declaration of conformity, and how to separate packaging conformity work from EPR obligations.

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Country-by-country EPR guides covering registration, reporting, and compliance requirements across the EU, UK, US, and Asia-Pacific markets — in one place.

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Packaging Label Manager by Lappa

L'Tag helps e-commerce sellers organize EPR packaging data, generate QR codes linked to packaging metadata, and track packaging waste throughout the product journey.

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Packaging AR made easy

Appoint an EU AR, draft your declaration of conformity,
and enter the EU market compliant.

Contact us

FAQ about Packaging AR

What is the difference between a manufacturer and a producer under the PPWR

The manufacturer is the operator responsible for conformity of the packaging with sustainability and labelling requirements. The producer is the operator relevant for EPR in the Member State where the packaging is first made available and expected to become waste. They are not always the same operator.

Who is the manufacturer if the packaging carries a brand name

The guidance says two things matter: who had the packaging or packaged product designed or manufactured, and whose name or trademark it bears. Where packaging is designed or manufactured under a company’s own name or trademark, that company is generally treated as the manufacturer.

Can an Authorized Representative draft the EU declaration of conformity

Yes. The guidance says the EU declaration of conformity must be drafted by the manufacturer based on supplier information, or by an authorized representative appointed by the manufacturer by written mandate. The manufacturer remains legally responsible for the packaging’s compliance.

Does a non-EU company’s branch in the EU solve the problem

Not by itself. The Commission guidance says a branch is not a separate legal entity for these purposes. Where a non-EU manufacturer has only a branch in the EU, it may need to incorporate a subsidiary in the EU or appoint an authorized representative where required.

Do manufacturers need an AR in every Member State

This page is written as a single EU AR offer, but the legal trigger in the Commission guidance is tied to the Member State where packaging or packaged products are first made available. That means the right setup still depends on the manufacturer’s actual distribution model and where first placing on the market happens.

What does Lappa help with

Lappa helps non-EU manufacturers appoint an EU Authorized Representative, organize technical documentation, support declaration of conformity drafting, and prepare packaging for EU compliance before market entry.