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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WEEE Austria: Audit results uncover frequent fault with LEDs

Official reports from WEEE-audits that proceeded in 2020 are gradually being released this year. It can be observed that the most common finding is the incomplete registration of companies due to the mis-identification and hence the non-reporting of devices that fall under the collection and treatment category gas discharge lamps. In Austria, LED-Light bulbs or LED-Lamps must be reported under the gas discharge lamps category. Such incomplete registration, if no amendments were made, could lead to administrative penalty proceedings.

Official reports from WEEE-audits that proceeded in 2020 are gradually being released this year. It can be observed that the most common finding is the incomplete registration of companies due to the mis-identification and hence the non-reporting of devices that fall under the collection and treatment category gas discharge lamps.

Most of these devices were LED-Light bulbs or LED-Lamps. According to the Annex 3 of the Waste of Electrical Equipment Ordinance (EAG-VO) as well as the electrical equipment list from the Federal Ministry Climate Action, Environment, Energy, Mobility, Innovation and Technology (BMK), LED-Light bulbs or LED-Lamps must be reported under the gas discharge lamps category.

We learned that such incomplete registration, if no amendments were made, could lead to administrative penalty proceedings. With the help of the Austrian authorised representative, the take-back scheme and the eager cooperation of the audited companies, actions were initiated to abate such outcomes.

We urge you to review your portfolio and take into account that LED-Light bulbs and LED-Lamps must be properly reported.

If you sell products to Austria or would like to know more about related audits, Peter Daniel Akut will be happy to assist you via international@take-e-way.de or +49/40/750687-112.

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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