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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FORMALDEHYDE REMAINS IN FOCUS

Regulations on the emission of formaldehyde in consumer products remain in a state of flux. ECHA is currently consulting on the introduction of a Europe-wide limit value of 0.124 mg/m³, measured according to EN ISO 717-1. An inclusion in the REACh Annex XVII list is then to be expected.

Clothing, other textiles that come into contact with the skin and footwear listed in Regulation (EU) 2018/1513 are to be excluded. (It has already been decided that the limit value will be set at 300 mg/kg from the first of November 2020 and then lowered to 75 mg/kg in 2023. Biocides according to Regulation (EU) 528/2012 are excluded).

The regulation proposal corresponds to the “old” limit value for wood-based materials in the [German] Chemicals Prohibition Ordinance (ChemVerbV) until 31 December 2019. As is commonly known, this will be determined as of 1 January 2020 according to the new EN 16516 method and will lead to a further reduction in formaldehyde emissions.

Formaldehyde will also be newly included in the Toys Directive. The amendment governs the limits for materials intended to be placed in the mouth. Limit values are specified for polymers, textiles, leather, paper and other materials. The requirements of standard EN 71-9 are thus partially tightened.
Parties concerned: Manufacturers
Requirements: Compliance with limit values will become mandatory; amendments to follow as of 1 January 2020 and later.
Recommendation: The projects are not yet legally binding. However, please make sure that your suppliers already have products that meet the above requirements or prepare them for stricter rules to be introduced. In order to keep costs under control, also with regard to further restrictions on pollutants, risk-based test management is recommended.

TMK offers you appropriately optimized test planning.

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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