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

Amazon informs retailers about the Market Surveillance Regulation

According to reports from take-e-way customers, Amazon is currently informing its merchants regarding the EU Regulation on Product Safety (known as “Regulation (EU) 2019/1020 on Market Surveillance and Conformity of Products”), which will take effect on 16 July 2021. Owing to the large number of requirements, we recommend that you should already take action right now. In this respect, you will not be left on your own, because we can actively support you with our solutions regarding the Market Surveillance Ordinance.
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The “Green Dot” in France – current information and background details

With the kind permission of Duales System Deutschland GmbH (DSD), we would like to inform you regarding DSD’s assessment of the use of the Green Dot in France. The “Green Dot” is a symbol that has been particularly well known for 30 years now. It signals to consumers that the producer of the labelled packaged product is participating in the financing of an authorised national system for the collection and recycling of packaging and is thus clear evidence of producer responsibility. To ensure the free movement of goods within the EU, 31 European organisations under the PRO Europe umbrella have agreed on the Green Dot as a valid symbol. According to DSD. “information letters” are currently in circulation concerning the continued use of the “Green Dot” trademark in France. From DSD’s perspective, much of this information is factually incomplete, partly incorrect and confusing. DSD would therefore like to provide you with some facts.
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Labelling of packaging in Scandinavia

With the many different types of packaging, it is difficult for consumers to keep track of what belongs in which recycling bin. To facilitate waste sorting, Denmark developed a voluntary pictogram system in 2016, which is now also being implemented in Finland, Norway, Sweden and Iceland. This flexible but uniform colour, terminology and symbol system has already been introduced in over 90 % of Danish municipalities, not only in recycling centres, recycling stations and residential areas, but also on packaging materials. Do you place packaging on the market in the Scandinavian countries? You can then use these pictograms free of charge and thus create a visual link for consumers between the empty packaging and the correct recycling container. As such you can make a valuable contribution to the circular economy.
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Selling devices, batteries and packaging worldwide with legal certainty

The rule of thumb is that the first economic operator placing an electrical/electronic device, packaging or a battery on the market is responsible for proper registration of the product and participation in country-specific take-back systems. The complexity of national legislation, as well as of the offerings of individual compliance systems, is immense. Both country-specific legislation and system performance are subject to constant change and must be continuously monitored and adapted to changing framework conditions. The consultants from take-e-way’s “International Compliance” team can provide guidance here.
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Video: international consultancy regarding sales based on legal certainty

In this video, our colleague Florian Spreu introduces the “International Compliance” team and the services rendered by take-e-way concerning international sales of electric equipment, packaging and batteries subject to legal certainty.
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Differentiation of battery types according to the German Batteries Act

Industrial batteries, by definition, are all batteries that are not automotive or device batteries. In this context, automotive batteries are defined as batteries intended for the starter, lighting or ignition of vehicles, but not for their propulsion. In contrast, device batteries are encapsulated batteries that can be held in one hand. This leaves a large delta between device batteries and automotive batteries, which belong to the category of industrial batteries. These include, for instance, batteries for electric vehicles and e-scooters, but also for other technical devices, provided that they cannot be “held in one hand” (Section 2 No. 6. Batteries Act (BattG)). Industrial batteries are also required to be registered with the EAR foundation (German WEEE registration board). At the time of registration, a declaration must be submitted to the effect that a return facility has been set up, as well as information on how last owners entitled to a return can access the return facility. Accordingly, manufacturers are tasked with creating a sustainable and comprehensive return option or facility. We offer a solution of this kind with our new contract for registration and return of industrial batteries.
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New measures regarding the packaging law in France

Today we report on the latest developments in France, as related decrees ensured by the French government have been officialised during the first weeks of January. Targeting to tackle the struggle of ever increasing waste and paving the way towards a circular economy (AGEC), the following overview will provide you the main changes implemented.
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Energy label – lamps to be entered in the EPREL database as of 1 May 2021

take-e-way had recently reported that in the first two weeks of March (1 – 18 March 2021), traders would need to replace labels for mains-operated refrigerators with direct sales function, mains-operated refrigerators between 10 and 1,500 litres in volume, mains-operated household dishwashers, television sets, monitors, certain signage displays, washing machines and washer-dryers. As of 1 September 2021, all E-labels for light sources must also be changed accordingly. However, the entry in the EPREL database (from which the energy labels are generated) is required from as early as 1 May 2021. Uncertainties currently exist in the market regarding the deadlines for relabelling since it is not always clear which requirement needs to be applied when reading the underlying legislation (Delegated Regulation 2019/2015/EU and Framework Regulation 2017/1369/EU). For the reasons specified above, it is advisable to deal with this topic in good time.
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take-e-way supports with Environmental Audits: Looking back at 2020

In spite of the pandemic, both the authorities and take-back schemes have been persistent in checking the compliances of companies regarding the national implementation of the WEEE (2012/19/EU), Battery (2006/66/EG) and Packaging (94/62/EG) Directives. In 2020 we were keen to participate, coordinate and support many of our clients in numerous audits. We would like to present to you a retrospect of the audits done in some countries last year and share the lessons we have learned so far. Through these experiences, we gained greater understanding of the subject to better support you.
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Packaging Act Amendment: Online marketplaces are required to verify registration under the German Packaging Act

According to the German Federal Ministry for the Environment, on 21 January 2021 the Federal Cabinet adopted a resolution on a proposal by Federal Environment Minister Svenja Schulze to amend the Packaging Act. Key content of the legislative amendment: In future, online marketplaces and fulfilment service providers will need to verify that manufacturers of packaged goods on their platform are listed with the German Foundation Central Agency Packaging Register (ZSVR) and comply with the Packaging Act. According to our latest information available, the Act is to take effect on 3 July 2021.
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