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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Amazon blocks offers from 15 June 2022

If you sell on Amazon.de, please enter your LUCID number for the “Packaging” category. Otherwise, you will risk having your offers blocked by Amazon starting 15 June 2022.

As FBA Realtalk vividly shows in its new Youtube video (starting at minute 5:00), Amazon.de requires its sellers using the dashboard to provide the LUCID number for the “Packaging” category. It literally states: “Action required: Extended Producer Responsibility (EPR) for Germany: If you sell on Amazon.de, please enter your LUCID number for the “Packaging” category. Otherwise, Amazon will as of 15 June 2022, block offers that do not meet the guidelines.”

Further on in the video, starting at minute 6:00, the following information can be seen: “This applies to both primary packaging (i.e., the product packaging itself) and secondary packaging (i.e., transport packaging, including shipping by Amazon). For this reason, the last possible date for submitting your LUCID registration number […] is 14 June 2022.”

This procedure results from the amendment to the Packaging Act, according to which not only online dealers are required to prepare for stricter controls. The marketplaces have their own direct inspection obligations and must check whether their online retailers are complying with packaging law obligations. From July 2022, fulfilment service providers are also required to ensure that their principals behave in a legally compliant manner. In future, they will no longer be allowed to offer their services to customers who violate the Packaging Act. This is also what Amazon itself writes (see above video starting at minute 05:40): “As of 1 July 2022, Amazon is required by law to verify that you are compliant in Germany and, if necessary, suspend your non-compliant offers.”

Whoever is not yet registered with LUCID and does not want to be blocked must act immediately.

The take-e-way consultancy team will be glad to answer any questions you may have on the Packaging Act. Please call +49/40/750687-0 or send an e-mail to beratung@take-e-way.de.

This is where you will find useful EPR services for your sales via Amazon and similar providers.

Sebastian Siebert
Contact

Sebastian Siebert
Head of Advisory services

Phone: +49 40 750687-0

beratung@take-e-way.de

Christoph Brellinger
Contact

Christoph Brellinger
Head of Marketing & Public Relations

Phone: +49 40 750687-0

presse@take-e-way.de

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