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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Digital product passport of the Ecodesign Regulation

There meanwhile are more non-energy-related requirements, e.g. on environmental pollutants, reparability or recyclability. The destruction of unsold products is prohibited. The level of detail of the Digital Product Passport (DPP) can go down to each individual unit if necessary. Especially important: the QR code for the DPP must be readable in the online shop.

The Digital Product Passport (DPP) is introduced as part of the new Ecodesign Framework Regulation (COM(2022)142). Dr. Floris Akkerman from the Federal Institute for Materials Research and Testing (BAM) made some noteworthy observations on this at the German Market Surveillance Conference: Theoretically, all products can be meant, not only "energy-relevant" ones as before. In addition, restrictions from the old Ecodesign Framework Directive 2009/125/EC such as “energy-relevant” and “no vehicle” are dropped and there are more non-energy-relevant requirements, e.g. on environmental pollutants, reparability or recyclability. The destruction of unsold products is prohibited. Registration uses “unique identifiers” for the assignment of the product, the economic operator and the location. The level of detail of the DPP can go down to each individual unit if necessary. Especially important: the QR code for the DPP must be readable in the online shop.

The example of DPP shows that an optimal Legal monitoring is necessary as an existential risk precaution in order to protect you under product law. If you have any questions, the trade-e-bility advisory team will be happy to help you via beratung@trade-e-bility.de or +49/40/75068730-0.

“The new Ecodesign Regulation: From Directive to Regulation / The Digital Product Passport” is also the topic of our panel event “The Future of Product Responsibility” at the Tipi am Kanzleramt theatre in Berlin on 8 November 2022. Further particulars and registration details are available here

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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