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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Filament bulbs and visible fee in Czech Republic

In the Czech Republic the absence of an environmental fee on the invoice is supposed to indicate that the product has not yet been reported in accordance with the requirements of the WEEE Directive. Free riders are thus recognisable at first glance. Commercial buyers, for their part, inevitably become producers acquiring undeclared products and will have to fulfil the corresponding obligations. Additionally, you have to report filament bulbs in the Czech Republic (unlike in all other EU states) since 01.01.2021.

Through more transparency, the Czech legislative authority aims for increased awareness and compliance with environmental protection obligations. With the legal act on end-of-life products 542/2020, it was decided to oblige producers to disclose the costs of collection, treatment and environmentally sound disposal (visible fee) in invoices. Although this possibility is explicitly mentioned in Article 14 of the EU Directive 2012/19/EU, the "visible fee" is voluntary in many EU countries and even prohibited others (including Germany).

In the Czech Republic, disclosing of costs was voluntary until 2020. Since 1st January 2021, the legal act 542/2020 has been in force and with it the obligation of the visible fee. The Ministry reasons, as follows:

Even before the new legal act came into force, the possibility of the visible fee was used by some producers, which led to confusion in the market. Buyers were uncertain whether the product had been reported in conformity with the law when invoices did not show disposal costs. Now, the absence of an environmental fee on the invoice is supposed to indicate that the product has not yet been reported in accordance with the requirements of the WEEE Directive. Free riders are thus recognisable at first glance. Commercial buyers, for their part, inevitably become producers acquiring undeclared products and will have to fulfil the corresponding obligations.

In addition, it is intended to create transparency of the disposal prices of the take-back systems. Take-back systems are obliged to offer all their customers the same price for collection, treatment and environmentally sound disposal of electronic equipment.

Last but not least, end-users are to be made aware that separate collection of waste equipment is necessary for the protection of the environment and thus it shall not be disposed in municipal waste.

In the same legal act 542/2020, filament bulbs are no longer excluded from the scope of WEEE-regulations. You therefore have to report filament bulbs in the Czech Republic (unlike in all other EU states) since 01.01.2021.

If you sell products to the Czech Republic or would like to know more about designated disposal costs in the EU, Rebekka Schwarber will be happy to assist you at international@take-e-way.de  or via +49/40/750687-150.

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