Lappa Supports
Cancarb
with EU PPWR Compliance
Authorized representation and packaging conformity support for a Canadian carbon black manufacturer supplying EU markets exclusively through local importers and distributors.
With Lappa, Cancarb has been able to:
Fulfil PPWR Manufacturer obligations as a non-EU exporter without taking on EPR Producer responsibilities
Appoint an authorized representative in the EU to act on behalf of Cancarb in packaging compliance matters
Prepare the required technical documentation and Declaration of Conformity under the Packaging and Packaging Waste Regulation
About Cancarb
Cancarb is a Canadian manufacturer of Thermax® carbon black, a high-purity thermal carbon black used in industrial applications worldwide. The company exports its products to EU markets through local importers and distributors, who take on responsibility for placing the packaged goods on the market in their respective member states.
Website: cancarb.com
Headquarters: Medicine Hat, Alberta, Canada
Industry: Industrial Materials / Chemical Manufacturing
Exporter, Not Producer — A Different Set of EU Obligations
The EU’s Packaging and Packaging Waste Regulation draws a clear distinction between the Producer — the entity that first places packaged goods on the EU market — and the Manufacturer, whose obligations relate to packaging conformity, technical documentation, and regulatory representation. For Cancarb, whose EU distributors and importers assume full EPR Producer responsibility at the point of market entry, the compliance task was different: meeting the PPWR Manufacturer requirements as a non-EU exporter with no direct presence in the bloc.
This meant identifying the correct scope of obligations, preparing a Declaration of Conformity, ensuring technical documentation met EU standards, and appointing an authorized representative capable of acting on Cancarb’s behalf with EU authorities — without conflating these duties with the EPR reporting and eco-fee obligations that sit with the importers.
Why Lappa
Cancarb needed a partner who understood the boundary between PPWR Manufacturer and EPR Producer obligations and could handle the non-EU exporter scenario without overreach.
Key strengths included:
- Clear scoping of PPWR Manufacturer obligations versus EPR Producer responsibilities held by EU importers
- Appointment of an EU authorized representative for packaging compliance purposes
- Support with Declaration of Conformity preparation and technical documentation requirements
- Guidance tailored to an export-only business model with no direct EU market presence
- Ongoing compliance support as PPWR implementation timelines develop across member states
Results & Impact
PPWR Manufacturer obligations correctly identified and separated from EPR Producer scope
EU authorized representative appointed to act on Cancarb's behalf
Declaration of Conformity and technical documentation prepared to EU standard
Compliance structure in place without disrupting existing distributor relationships across EU markets
What’s Next
Cancarb continues to supply EU markets through its network of local importers and distributors. Lappa remains the authorized representative and compliance partner for PPWR Manufacturer obligations, ready to adapt as the regulation’s requirements are further defined and enforced across member states.