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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ElektroG: EAR again reduces the fees by 15 to 18 percent

The fourth regulation modifies the ElektroGKostV (= The Cost Ordinance on the Electrical and Electronic Equipment Act – ElektroG).

Berlin/Hamburg/Fürth (Germany) – On December 14th, 2011, the Bundesministerium für Umwelt, Naturschutz und Reaktorsicherheit (BMU) (=The Federal Ministry for Environment, Conservation and Nuclear Safety) has enacted the fourth regulation to modify the ElektroGKostV (= The Cost Ordinance on the Electrical and Electronic Equipment Act – ElektroG). This fourth regulation was announced on December 30th, 2011 and came into force on December 31st, 2011. With the new regulation, the fees of the Stiftung Elektro-Altgeräte Register (Foundation EAR) will be reduced at an average of 15 to 18 percent. For comparison: The EAR fee for the basic registration including warranty check (fee-rated matter No 1.01 and 1.04.b) will now cost a total of 182.00 euros (formerly 218.00 euros) and has thus been reduced by 36.00 euros. The repeated reduction of the rates of charges is welcomed by take-e-way and the VERE Association and is valued as another step in the right direction.

However, take-e-way and VERE consider that the relation among the individual rates of charges might have a tendency to adversary effects on small and medium sized companies (SMEs). Thus, the relatively high fees for the basic registration including the guarantee review (fee-rated matters No 1.01, 1.04.a, 1.04.b and 1.04.f) represent a considerable financial obstacle for small suppliers or when selling smaller quantities, whereas the fees for e.g. disposal orders are in contrast considerably lower and thus prove to be an advantage for those suppliers, who burden the system with larger quantities. Precisely the high entry fees often prevent small companies from behaving in conformity with the ElektroG (free-riders) – to the disadvantage of all manufacturers acting in compliance with the law.

The VERE Association already pointed out this problem in advance. VERE holds the view that a load-oriented fee structure would be suitable for all market participants. Therefore, VERE and take-e-way will commit themselves further on towards an equitable treatment of the SMEs.

Below you can download the text of the regulation, the draft of the current regulation as well as the corresponding justification of the BMU. Please contact us if you need an overview of the actual fees of the Cost Ordinance on the Electrical and Electronic Equipment Act in english language. Of course, the team of take-e-way will be at your entire disposal for any further questions under the phone number +49/40/750687-111 or under info@take-e-way.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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