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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Lead, RoHS and REACh: As at 21 July 2021, some exemptions from the RoHS Directive are set to expire

As at 21 July 2021, some exemptions from the RoHS Directive are set to expire. In particular, lead-containing components and materials such as high-current connections on printed circuit boards, brass and aluminium alloys are also included. Distributors of products containing materials with more than 0.1 per cent lead should keep an eye on the decision of the EU Commission. Should any exemptions be withdrawn, then there will probably be a twelve-month transition period to replace the materials in question.

As at 21 July 2021, some exemptions from the RoHS Directive are set to expire. In particular, lead-containing components and materials such as high-current connections on printed circuit boards, brass and aluminium alloys are also included. In the past, content values of more than 0.1 per cent by weight were permitted within narrow limits. At this stage, however, it has not been clarified which exemptions will actually expire. Although there are alternatives for some materials proposed by the Öko-Institut, the coordination process with the market participants is still under way.

Distributors of products containing materials with more than 0.1 per cent of lead should keep an eye on the decision of the EU Commission. Should any exemptions be withdrawn, then there will probably be a twelve-month transition period to replace the materials in question. Attention should also be paid to the fact that exceedances of 0.1 per cent of lead by weight in a material fall under the REACh SVHC Regulation, are reportable and require an entry in the ECHA’s SCIP database.

trade-e-bility supports distributors in complying with RoHS and REACh requirements and in entering relevant materials and components in the SCIP database.

Our consultancy team will be pleased to answer any questions you may have: Please call +49/40/75068730-0 or send an e-mail to beratung@trade-e-bility.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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