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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Authorised representative in Austria required

These changes concern companies without a registered office in Austria that import packaging and single-use plastic products into Austria. For all deliveries to end users, it is mandatory to appoint an authorised representative in Austria; for deliveries to sellers in Austria, pre-licensed imports can be made with an authorised representative based in Austria, but only for companies based within the EU. This regulation has been in force since 1 January 2023.

Our partner Altstoff Recycling Austria AG (ARA) has reminded its customers of the changes in the Austrian Waste Management Act and the Packaging Ordinance, which came into force on 1 January 2023 (VerpackVO 2021 § 16a). The background to this is that a large number of sellers and producers who were previously active on the Austrian market are still not registered with an authorised representative. take-e-way had already informed about the new obligations as early as September 2022.

In these cases, it is already mandatory by law that the declaration for 2023 be made by an authorised representative domiciled in Austria. You cannot submit a declaration for 2023 without a duly registered, authorised representative. Please note that this means that goods you deliver to your Austrian customers are no longer licensed as required by Austrian law.

You can find more information on this topic and on the appropriate authorised representative solution from our get-e-right Austria GmbH (Vienna) branch at https://www.get-e-right.at/en/authorised-representative-packaging

Our consultancy team will be pleased to assist you. Please call +49/40/750687-0 or send an e-mail to info@get-e-right.at.

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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