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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Consumer products: Stricter rules for use of pthalates as of 7 July 2020

Please ensure that your suppliers have already checked the products for substances in the prohibited list according to Annex XVII of REACh. Moreover, we recommend that you arrange for your suppliers to sign a declaration of chemical harmlessness. Also ensure for production that none of the phthalates mentioned can “creep in” unnoticed.

Pthalates, substances also known as plasticisers, have been regulated more strictly since 18 December 2018. The four plasticisers DEHP, DIBP, BBP and DBP are henceforth included in Annex XVII of the REACh Ordinance. This applies in particular to toys and baby articles. In 2019, by early May more than 50 articles had already been withdrawn from the market, e.g. because of excessive DEHP content (source: RAPEX). A further amendment will take effect on 7 July 2020, which will then extend to include additional consumer products. The new threshold limit is 1,000 ppm or 0.1%.

Affected manufacturers and distributors must comply with the 1000 ppm limit for DBP, BBP and DEHP for toys and children’s articles, as well as for DINP, DIDP, DNOP and other toys and children’s articles that can be placed in their mouths.

Our recommendation: Please ensure that your suppliers have already checked the products for substances in the prohibited list according to Annex XVII of REACh. Moreover, we recommend that you arrange for your suppliers to sign a declaration of chemical harmlessness. Also ensure for production that none of the phthalates mentioned can “creep in” unnoticed.

Trade-e-bility GmbH will help you to comply with the chemical limit values of your products and to render their documentation compliant. We also offer you coordinated test plans to minimize your laboratory costs. If you have any questions, please do not hesitate to call trade-e-bility on +49/40/75068730-0 or send an e-mail message to beratung@trade-e-bility.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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