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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German WEEE legislation (ElektroG): Please check your registered categories - take your chance to use the period of crisis to revise and update your WEEE-compliance matters

Check your assortment of registered products concerning some possible gaps in compliance. take-e-way will be delighted to assist you. For example: According to German ElektroG legislation, electric products are classified as six different categories. For consumer products (products for private use), it happens quite often and unintentionally, that electronic products are not classified correctly according to the electro-legislation. After the crisis, the competent authorities are likely to impose fines and audits. Currently the Federal Environmental Agency in Germany is hiring additional enforcement officers in the sections of WEEE (ElektroG), Batteries Act and Packaging Act. Moreover, please note that in the field of competition law, competitors and associations specialized in warning letters are taking any chance to detect gaps in compliance.

At present, all daily business is strongly influenced by the coronavirus pandemic. According to statements from our members and clients, there is currently room left for issues that are naturally a little time consuming and, therefore, usually are having to wait for completion. Therefore, take-e-way recommends taking your chance during the crisis to check your assortment of registered products concerning some possible gaps in compliance. take-e-way will be delighted to assist you.

For example: According to German ElektroG legislation, electric products are classified as six different categories. For consumer products (products for private use), it happens quite often and unintentionally, that electronic products are not classified correctly according to the electro-legislation. This is, for example, happening when selling Small Electric Appliances (of maximum 50 cm edge/diameter) and a new item that is measuring more than 50 cm is added to the product range.

The new product has got the same function as the WEEE-registered small items but according to its measurements, this new item is WEEE-classified as “Large Electric Appliance”. In this case, registering an additional category is mandatory and, in the monthly data submission, this item measuring more than 50 cm has to be declared as “Large Electric Appliance”.

After the crisis, the competent authorities are likely to impose fines and audits. Currently the Federal Environmental Agency in Germany is hiring additional enforcement officers in the sections of WEEE (ElektroG), Batteries Act and Packaging Act. Moreover, please note that in the field of competition law, competitors and associations specialized in warning letters are taking any chance to detect gaps in compliance.

If you recognize a discrepancy in your WEEE-registration and your assortment of electric products or if you have any questions about the categories of your range of electric products, please do not hesitate to contact us. By working collaboratively with you, we will find out your needs of registering additional categories.

In case of questions please contact Elisabeth Westermann and the take-e-way consulting team as follows: +49/40/750687-0 or e-mail: beratung@take-e-way.de

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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