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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Brexit impact on WEEE and your product conformity

On leaving the EU, Great Britain will become a third state, making it difficult for new products to be placed on the market from and to GB.

However, a transitional treaty exists, in terms of which everything is to remain as it stands until the end of 2020. If, contrary to all forecasts, Brexit takes place without this treaty being taken into account, then the role of economic participants in the EU will change as early as February.

The importer of products from GB will then become an importer into the remaining EU-27 and will essentially have the same obligations as an importer of goods from China.

Notified bodies in GB, e.g. under the Personal Protective Equipment Directive or Medical Devices Directive, may lose their status. This means that products certified by them can no longer be assumed to be compliant.

Who is affected?
Affected are dealers who purchase goods from GB as well as importers and manufacturers who have used a notified body in GB for the CE conformity procedure for their products to date.

What is to be done?
Products from GB must comply with a conformity procedure within the EU-27.

Our recommendation
As the expected withdrawal data (31 January 2020) now appears to become reality and the withdrawal regulations are not yet known, the safeguarding of products by notified bodies in Great Britain is not recommended. Until further notice, merchandise from Great Britain should be treated as imported goods.

Our solution for you
We offer you a free initial consultation on the subject of Brexit/product conformity and we will provide you with precautionary resilient hedging concepts: We look forward to your call at +49/40/75068730-0 or an email message to beratung@trade-e-bility.de.

Brexit impact on WEEE, batteries and packaging
The WEEE, Batteries and Packaging Directives do not apply directly in an EU Member State, and manufacturers from EU countries are treated in the same way as manufacturers from third countries. According to our local partner company, the withdrawal as of 31 January 2020 includes a one-year transition period until 31 January 2021. Prior to this, all agreements and regulations will continue to apply. If you have any questions concerning the WEEE, Batteries and Packaging Directives in connection with Brexit, please do not hesitate to contact our affiliate take-e-way by calling +49/40/750687-0 or sending an email message to beratung@take-e-way.de.

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

Services & Contact
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