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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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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ElektroG and BattDG under time pressure

The success of both legislative proposals depends on the time remaining in the session and political consensus. A delay could jeopardise the implementation of European requirements - with considerable consequences for sellers, producers and importers.

As Euwid reports, the premature end of the traffic light government is jeopardising several planned waste law reforms. The Battery Implementation Act (BattDG) and the amendment to the Electrical and Electronic Equipment Act (ElektroG) are particularly affected.

BattDG: Urgent adjustments to EU Batteries Regulation

The BattDG is intended to transpose the requirements of the EU Batteries Regulation into German law in order to guarantee both European and national regulations from August 2025. The law is crucial to ensure an orderly transition phase for the take-back and recycling of waste batteries. Without timely adoption, there is a risk of uncertainty as to which EU regulations will apply directly and which German regulations will continue to apply.

Take-back systems are also calling for timely implementation, as otherwise there is a risk of considerable disruption to battery take-back. They are also calling for a joint body for the battery industry, similar to the Packaging Act and the Electrical and Electronic Equipment Act, in order to pool responsibility and avoid bureaucracy.

ElektroG: Opportunities for finalisation, but disposable e-cigarettes a point of contention

The Federal Ministry for the Environment believes there is a chance of finalising the legislative process for the ElektroG in good time. However, one of the Bundesrat's key demands for a ban on disposable e-cigarettes remains controversial. While environmental organisations and disposal companies warn of the risks of improper disposal, the ministry sees no clear scientific link to fires in disposal facilities.

Conclusion

The success of both legislative proposals depends on the remaining time available and political consensus. A delay could not only hinder national regulations, but also jeopardise the implementation of European requirements - with significant consequences for the circular economy, the take-back systems and, above all, the sellers, producers and importers affected.

If you would like to register in Germany as a seller or producer of WEEE / electrical appliances, batteries or packaging or if you have any questions about extended producer responsibility (EPR), please contact our advisory service at beratung@take-e-way.de or +49/40/750687-0.

For solutions relating to the EU Batteries Regulation, EU product labelling or packaging labelling and, in particular, disposal labelling, please contact the trade-e-bility consulting team at beratung@trade-e-bility.de or +49/40/750687-300.

For more information on our international compliance services related to the placing on the market of electronic devices, batteries and packaged products or packaging, please click here: https://www.take-e-way.com/international-compliance/

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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