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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Green Dot now legal in France

The Green Dot can now be used in practice. Nevertheless, it is likely that the French government will present a well-worded ban to the Commission.

take-e-way had reported in detail in 2021 on current and background details on the use of the Green Dot and the latest developments of the Packaging Act in France. Today we want to inform you about the latest developments on the subject.

As reported by the law firm Produktkanzlei, the two 2020 Ministerial Decrees were annulled by the Court essentially on procedural grounds, which classified or sanctioned Green Dot as confusing in terms of sorting rules (see CE, 30 June 2023, Nos. 449.872 - 450.134 - 450.158). The Conseil d’Etat’s reasoning is based on Directive (EU) 2015/1535, which requires the European Commission to be informed of any draft “technical regulation” that Member States intend to adopt (see Art. 5 of the Directive).

The Green Dot can therefore be used in practice. Nevertheless, it is likely that the French government will present a well-worded ban to the Commission. In view of the current situation, it is advisable to have own product or packaging labelling checked if there is any uncertainty about the use of the Green Dot.

For solutions on the subject of EU product labelling or packaging and, in particular, disposal labelling, the trade-e-bility consulting team is at your disposal via beratung@trade-e-bility.de or +49/40/75068730-0.

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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