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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Flame retardants on ECHA list

If a substance is on this list, companies may not use it unless they apply for authorisation and the European Commission approves its continued use. Importers and producers of articles must inform ECHA within six months of a substance being added to the candidate list (27 June 2024) whether their article contains such a substance.

The chemical bis(α-dimethylbenzyl)peroxide, which was added to the candidate list by the European Chemicals Agency ECHA on 27 June 2024, is toxic to reproduction and is used as a processing aid, e.g. as a flame retardant.

ECHA's Member State Committee (MSC) has confirmed the inclusion of this substance on the candidate list. The list now contains 241 entries - some are groups of chemicals, so the total number of chemicals concerned is higher. This substance may be added to the Authorisation List in the future. If a substance is on this list, companies are not allowed to use it unless they apply for authorisation and the European Commission approves its continued use.

According to REACh, companies have legal obligations if their substance - either as such, in mixtures or in articles - is included in the Candidate List. If an article contains a Candidate List substance in a concentration of more than 0.1% (by weight), suppliers must provide their customers and consumers with information on the safe use of the substance. Consumers have the right to ask their suppliers whether the products they buy contain substances of very high concern. Importers and producers of articles must inform ECHA within six months of a substance being added to the candidate list (27 June 2024) whether their article contains such a substance.

EU and EEA suppliers of Candidate List substances supplied either on their own or in mixtures must update the safety data sheet they provide to their customers.

According to the Waste Framework Directive, companies must also notify ECHA if the articles they produce contain substances of very high concern in a concentration of more than 0.1% (by weight). This notification is published in ECHA's database for substances of very high concern in articles (SCIP).

Attention fines for SCIP notification: Incorrect or omitted SCIP notifications of articles containing SVHC are penalised with a fine of up to 10,000 euros per case.

You sell SVHC-containing articles and are not yet registered in the SCIP database? Find out more about our SCIP database registration service. Get it done quickly in the "SCIP Fast Lane"! Simply request our non-binding SCIP database service here or our training so that you can handle SCIP yourself:

Use SCIP Fast Lane now!

Our consulting team will be happy to support you with solutions to ensure your sales success in the area of ECHA / REACh and SCIP database: +49/40/750687-300 or beratung@trade-e-bility.de

Contact us now!

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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