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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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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Does the SCIP database for substances of concern go too far?

The FDP parliamentary group has submitted a so-called minor enquiry in the German Bundestag as to whether the transmission of information via the SCIP database does not go beyond what is required by law. If you place articles containing SVHCs on the EU market, you should follow this development.

The European Chemicals Agency (ECHA) has been operating the SCIP database since last year. Since 5 January 2021, each supplier in the EU market is obliged to submit information about an article containing a substance of very high concern (SVHC) to the ECHA. This is planned to be done by entering the relevant data in the SCIP database. However, the type of data transmission is not yet specified by the German implementation of the EU Waste Framework Directive, the Chemicals Act.

Now, the FDP parliamentary group has submitted a so-called minor enquiry in the German Bundestag (19/31860) as to whether the transmission of information via the SCIP database does not actually go beyond what is required by law. An answer is still outstanding.

If you place articles containing SVHCs on the EU market, you should keep track of this development. The SCIP database has been used millions of times since January and has established itself as an information channel to ECHA; trade-e-bility will keep you up to date in this regard.

The consultancy team from trade-e-bility will be pleased to assist you. Please call +49/40/75068730-0 or send an e-mail 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

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