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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CONSEQUENCES OF BREXIT FOR PRODUCT CONFORMITY

The United Kingdom will become a third country when it leaves the EU, making it more difficult to place new products on the market from and into the UK. If this happens without a relevant agreement being in place, then the role of economic actors in the EU will change. The importer of products from the UK 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 the UK, e.g. under the Personal Protective Equipment Directive or Medical Devices Directive, will lose their status. This means that products certified by them can no longer be assumed to be compliant.

Parties concerned: Dealers who purchase goods from the UK as well as importers and manufacturers who have used a notified body in the UK for the CE conformity procedure for their products to date.
Requirements: Products from the UK must comply with a conformity procedure within the EU-27.
Our recommendation: As neither the date nor the withdrawal regulations are currently known, it is not recommended to arrange for products be covered by Notified Bodies in the United Kingdom. Merchandise from the United Kingdom should be treated as imported goods.

TMK will provide dealers and importers with precautionary, reliable hedging concepts.

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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