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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Energy consumption labelling warning

In October, the ECJ ruled that the obligation for sellers to refer to the energy efficiency class and the range of efficiency classes in their visually perceptible advertising or technical promotional material arises directly from Regulation 2017/1369.

The shop operator blog “warning radar” reports on warnings due to a lack of energy consumption labelling for products for which labelling is mandatory. Regulation (EU) 2017/1369, which has been in force since 1 August 2017, authorises the European Commission to adopt new delegated acts for the energy labelling of certain electrical appliances. These legal acts have been in force for specific product groups since 1 March 2021 and for light sources since 1 September 2021. In October, the European Court of Justice (ECJ) ruled that the obligation of retailers to refer to the energy efficiency class and the range of efficiency classes in their visually perceptible advertising or technical promotional material arises directly from Regulation 2017/1369. If no new delegated act has yet been adopted, the range must be indicated in accordance with the delegated act still in force.

A breach of the information obligations for energy-related products may not only be anti-competitive, but may also constitute an administrative offence pursuant to Section 8 EnVKV in conjunction with Section 15 (1) EnVKG. A fine of up to 50,000.00 euros may be imposed.

The trade-e-bility consulting team will be happy to advise you via +49/40/750687-300 or beratung@trade-e-bility.de about solutions to ensure your sales success in the area of energy consumption labelling.

If lawyers and competitors are targeting your product, the labelling of your products and packaging is always the first port of call. With the images of your products on online marketplaces, you yourself provide the basis for warnings and fines. In addition, incorrect labelling is an indication of illegal products. With just a few clicks, you can commission our inexpensive labelling check in the Fast Lane, from one country to EU-wide. Request a non-binding quote 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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