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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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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Packaging Act: As of 1 July 2022, Amazon merchants must self-report FBA packages

This means that in future, every Amazon seller must be registered with the Central Packaging Register in the LUCID database and must also take part in a disposal system.

As our partner Internetrecht (=Internet law) Rostock reported, a clear regulation will be in place from 1 July 2022 for fulfilment service providers, to which Amazon in particular belongs, if in the context of FBA Amazon the merchandise is dispatched to the customer:

“If the activities of a fulfilment service provider include the packaging of goods in system-participating shipping packages, the distributor of the goods for whom the fulfilment service provider is acting will be deemed to be the manufacturer as far as the shipping packages are concerned.”

This means that in future, every Amazon seller must be registered with the Central Packaging Register in the LUCID database and must also participate in a disposal system. Exceptions, which were previously possible if the sales packaging was registered to the manufacturer, but the seller does not make shipments in any case, are then no longer possible.

Amazon will probably request registration data from the Central Packaging Register (in the LUCID database) from all Amazon sellers using FBA as part of Extended Producer Responsibility (EPR). Distribution without LUCID database registration will then no longer be possible via FBA from 1 July 2022.”

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 message to beratung@take-e-way.de.

Here 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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