d1e705-1-1__para__5
COMMISSION NOTICE Guidance document for Regulation (EU) 2025/40 on packaging and packaging waste · European Union
Because a branch lacks separate legal personality, it cannot qualify as an importer under the PPWR. The requirement of being ‘established’ refers to a natural or legal person incorporated in the EU, not merely a branch office. A branch may become a separate legal entity (i.e., a subsidiary) when it is incorporated under the law of a Member State, has its own legal personality, rights and obligations, and can own assets, sue and be sued independently.
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Source: EUR-Lex (Cellar) · retrieved 2026-09-07 · Text as adopted (Official Journal); later amendments are not incorporated in this text.