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Terms of Use

L’Authorize Authorized Representative and Packaging Compliance Support Service for PPWR Manufacturers

Last updated: 22/04/2026

These Terms of Use govern the use of the L’Authorize Authorized Representative and Packaging Compliance Support Service provided by Lovat Compliance LTD (“Lappa”, “we”, “us”, “our”).

By ordering, subscribing to, or using the Service, you (“Customer”, “you”, “your”) agree to these Terms.

1. Who this Service is for

This Service is intended only for customers acting as a manufacturer of packaging under the EU Packaging and Packaging Waste Regulation (PPWR). Under the Commission’s guidance, the manufacturer is the economic operator responsible for the packaging’s compliance with the sustainability and labelling requirements, and there is only one manufacturer EU-wide for that purpose. In many cases, that is the brand owner or the party that has the packaging or packaged product designed or manufactured under its own name or trademark, rather than the business that physically produces the packaging.

If you are not acting as the manufacturer for PPWR purposes, this Service is not intended for you unless we expressly agree otherwise in writing. The guidance also distinguishes the manufacturer from the producer, which is the role linked to EPR financing in the Member State where packaging is first made available and expected to become waste.

2. Scope of the Service

The Service covers packaging only.

It is limited to support relating to the packaging obligations of the manufacturer under the PPWR, including packaging sustainability, packaging labelling, declarations of conformity for packaging, supporting packaging documentation, and related administrative compliance support. The Commission guidance states that the manufacturer must ensure that the packaging complies with the sustainability and labelling requirements in Articles 5 to 12 before it is first made available on the Union market.

The Service does not cover the product itself.

This means, by way of example, that the Service does not include advice or responsibility relating to:

  • product safety;
  • product formulation or composition;
  • product claims;
  • product performance;
  • product certification;
  • product-specific labelling unrelated to packaging;
  • customs, VAT, product-marketplace rules, or other non-packaging compliance areas unless separately agreed in writing.

3. What is included in the subscription

Unless expressly agreed otherwise in writing, the subscription includes only recurring services relating to the Customer’s packaging obligations as a PPWR manufacturer.

This may include:

  • Authorized Representative service, where applicable;
  • collection and review of packaging-related documents;
  • support with packaging compliance administration;
  • support with preparation of packaging declarations of conformity;
  • notifications about packaging-related legal or labelling changes within the scope of the Service;
  • standard administrative support related to the Service.

The subscription does not include unlimited project work, bespoke consulting, or product compliance review.

4. Initial onboarding

Initial onboarding is not included in the subscription fee and is billed separately.

Initial onboarding includes the initial review and setup of the Customer’s packaging compliance file, including:

  • all initial checks for conformity of the packaging;
  • review of existing packaging documentation;
  • review of existing packaging labels and markings;
  • identification of missing packaging documents, laboratory tests, or technical information;
  • identification of gaps that need to be addressed before or during the Service.

Onboarding relates to packaging conformity only and does not include conformity checks for the product itself.

We may delay or refuse activation of the ongoing Service until onboarding is completed and the onboarding fee has been paid.

5. Consulting is not included

Consulting is not covered by the subscription and is charged separately.

Unless expressly agreed in writing, the subscription does not include:

  • bespoke consulting;
  • legal advice or legal opinions;
  • technical product assessments;
  • packaging redesign work;
  • remediation projects;
  • supplier coordination beyond routine administrative support;
  • extensive declaration of conformity drafting or redrafting;
  • laboratory testing or third-party verification.

Any consulting, advisory, or project-based work requested by you will be quoted and billed separately.

6. Appointment as Authorized Representative

To enable Lappa to act as your Authorized Representative, you must issue to us a valid power of attorney and/or written mandate in the form reasonably required by us.

Lappa will act only within the authority expressly granted in that mandate.

Our appointment as Authorized Representative does not make Lappa the manufacturer, importer, producer, owner, designer, or tester of your packaging or products.

7. Declarations of conformity

Lappa may assist with the drafting or preparation of declarations of conformity relating to packaging, where this is included in the Service or separately agreed.

However:

  • Lappa does not sign declarations of conformity on your behalf;
  • you must review, approve, and sign all declarations of conformity in your own name;
  • you remain solely responsible for the accuracy, completeness, and legal validity of every declaration of conformity.

The Commission guidance states that the declaration may be drafted by the manufacturer or by an authorised representative acting under written mandate, but the manufacturer remains the sole economic operator bearing legal responsibility for the packaging’s compliance.

8. Your document and information obligations

You must cooperate fully and in a timely manner with Lappa.

You agree to:

  • upload all documents we request;
  • provide complete, accurate, and up-to-date information;
  • provide laboratory tests for packaging where requested;
  • provide packaging specifications, technical documentation, supplier declarations, and supporting evidence where requested;
  • inform Lappa promptly of any changes to packaging materials, packaging design, packaging structure, labels, markings, suppliers, or other packaging-related matters;
  • upload updated documents whenever you make any changes to the packaging or its labelling.

If you do not provide the requested documents or information, we may suspend or limit the Service.

9. Regulatory and labelling updates

Lappa will inform you of packaging-related legal, technical, or labelling changes that, in our reasonable view, you need to follow in order to remain compliant within the scope of the Service.

This includes notifying you of changes affecting packaging rules and harmonised packaging labelling. The Commission guidance says the packaging labelling regime under Article 12 is fully harmonised in scope, and that Member States will not be allowed to keep national sorting labels next to EU harmonised labels after the applicable transition deadline.

You remain responsible for reviewing those notifications, implementing the required changes, updating your packaging and documentation, and meeting all applicable deadlines.

10. Your responsibility for packaging quality and compliance

You bear full responsibility for:

  • the quality of your packaging;
  • the accuracy of the information and documents you provide;
  • the conformity of your packaging with applicable law;
  • all packaging changes made by you or your suppliers;
  • the content of declarations of conformity and supporting records;
  • the use of compliant packaging and compliant packaging labels on goods placed on the market.

You also remain fully responsible for the quality, safety, legality, and compliance of the product itself. The Service does not shift any responsibility for the product or for packaging quality from you to Lappa.

Lappa does not manufacture, design, test, certify, or control your packaging or your products and does not assume responsibility for their actual conformity, safety, quality, or performance.

11. Fees and payment

You agree to pay:

  • the separate onboarding fee;
  • the annual subscription fee;
  • any separately quoted consulting or additional service fees;
  • any applicable taxes, duties, bank charges, or governmental fees.

Annual subscription

The subscription is billed one year in advance.

For each renewal term, payment must be made no later than 10 calendar days before the start of the next subscription year.

If payment is not received on time, Lappa may suspend the Service, suspend acting under the Authorized Representative mandate, withhold deliverables, or terminate the Service.

12. Suspension or refusal of Service

Lappa may suspend, limit, or refuse the Service if:

  • you fail to pay fees when due;
  • you fail to provide the required power of attorney or written mandate;
  • you do not provide requested packaging documents, packaging laboratory tests, or updated information;
  • you provide inaccurate, incomplete, or misleading information;
  • you fail to notify us about packaging or packaging labelling changes;
  • continued provision of the Service may expose Lappa to legal, regulatory, or reputational risk.

13. No guarantee of market access

Lappa does not guarantee that your products or packaging will be accepted by any authority, customs office, marketplace, retailer, or other third party.

Compliance and market access depend on many factors outside our control, including your implementation, supplier performance, packaging changes, testing results, and regulatory developments.

14. Limitation of liability

To the fullest extent permitted by law, Lappa shall not be liable for:

  • indirect or consequential losses;
  • lost profits, lost sales, or lost business opportunities;
  • fines, penalties, recalls, or enforcement actions arising from your packaging, products, labels, or documents;
  • losses caused by inaccurate, incomplete, or outdated information provided by you or your suppliers;
  • losses resulting from your failure to implement required changes.

Lappa’s total liability in connection with the Service shall not exceed the amount of subscription fees actually paid by you to Lappa for the 12 months preceding the event giving rise to the claim.

Nothing in these Terms excludes liability that cannot be excluded under applicable law.

15. Governing law

These Terms are governed by the laws of England and Wales, unless otherwise required by mandatory law.

Any dispute arising out of or in connection with these Terms shall be subject to the exclusive jurisdiction of the courts of England and Wales, unless otherwise required by law.

16. Contact

If you have questions about these Terms or the Service, please contact:

Lovat Compliance LTD

United Kingdom, Bayes Centre, 47 Potterrow, Edinburgh, EH8 9BT
info@lappa.org
lappa.org