New registration obligation for packaging in Spain

The Spanish packaging law obliges producers to register their packaging. Distributors from abroad must also register through an authorised representative if they sell packaged products in Spain.

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Document titled GPSR with a magnifying glass placed over a warning sign
General Product Safety Regulation (EU) 2023/988 obliges
GPSR Risk Analysis Required

Mandatory for almost every product: According to the GPSR, producers must draw up technical documentation for the products they place on the market. The technical documentation must be based on an internal risk analysis.

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General Product Safety Regulation requires Responsible Person
EU Responsible Person Service for the GPSR and more

Since 16 July 2021, it is against the law to sell products with CE marking without a Responsible Person in the EU. In addition, a Responsible Person must also be specified in accordance with the General Product Safety Regulation (EU) 2023/988.

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Personal EU Batteries Regulation Training
Ready for the new Batteries Regulation (EU) 2023/1542

Find out which obligations the EU Batteries Regulation places on you and how to deal with them in your specific case. Receive comprehensive information on how to implement your obligations with regard to labelling, battery passport, EPR and due diligence obligations in the supply chain.

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take-e-way News and Press Releases

One third of all admonitions attributable to Packaging Act violations

“In May 2021, one third of all admonitions made known to the merchants’ association ‘Händlerbund’ were due to violations of the Packaging Act,” reported the Channelpartner portal on 7 July 2021. This finding is based on an assessment by the Händlerbund and features at the top of its list.
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France packaging act – latest developments

Following our previous newsletter article published on the 23rd March 2021, please find below the latest updates regarding the French packaging regulation, as a new related decree has recently been released.
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Pursuit of freeriders in Belgium

All producers placing portable, industrial and automotive batteries and/or accumulators on the Belgian market are legally obliged to collect used batteries and to provide further treatment for them. Bebat is actively searching for freeriders on the market aiming at convincing them to comply with their legal obligations.
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WEEE Switzerland: Public list of non-system participants

The SENS Foundation publishes a list of non-system participants on its website. The alternative to being publicly classified as a non-system participant is to join a voluntary system and make a financial contribution to the disposal structure in Switzerland.
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Bundesrat approves supply chain law

On June 25, 2021, the Bundesrat approved the Act on Corporate Due Diligence in Supply Chains by waiving a conciliation procedure. It can now be forwarded to the Federal President for signature and pronounced in the Federal Law Gazette. It will largely enter into force on January 1, 2023 – and for individual provisions already on the day after its pronouncement.
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Equipment and batteries: Are you fulfilling your legal obligations in the USA?

Not only in Europe, but also in the USA, you need a registration for the sale of electronic products and batteries. Producers are subject to registration if they sell computers (desktops, laptops, tablets, etc.) or televisions and their peripherals (monitors, printers, DVD players, game consoles, etc.).
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WEEE Germany: Questionable cover letters in circulation concerning registration under the Electrical and Electronic Equipment Act

On 15 June 2021, the take-e-way consulting department was informed by one of our foreign customers about a questionable e-mail cover letter with the subject “Elektrogeräte Registrierung“ (Electrical equipment registration), which originated from a German company based in Neuss. If you receive a letter regarding the registration of your products and are unsure of the current status, our advisors will be pleased to assist you.
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WEEE Germany: Damages payable due to failure to register under the Electrical and Electronic Equipment Act

Competitors can assert far-reaching claims for information and damages due to missing ElektroG registration. Businesses are therefore well advised to avoid such violations through proper registration.
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Video: The Authorised Representative under the Packaging Act

The new Packaging Act (VerpackG2) is scheduled to take effect in Germany on 3 July 2021. An important amendment is the newly created function of the authorised representative, who can relieve certain manufacturers of many duties. In our latest Compliance Talk, we explain exactly which manufacturers will benefit from the new option in terms of which obligations. The video is available for viewing here (YouTube):
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Italy: Transitional period of environmental labelling obligation for all packaging extended to 1 January 2022

Amendments to Legislative Decree No. 41 of 22 March 2021, the so-called "Decreto Sostegni", were approved during its conversion into law. These amendments include, inter alia, the suspension of the environmental labelling obligation for packaging, as well as the possibility of trading products already placed on the market without the new environmental labelling requirements, until stocks are exhausted.
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