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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Microplastics not banned for decoration

Products, including glitter, that are made of inorganic, natural, biodegradable or water-soluble material are not included in the scope. Beads, sequins and other embellishments intended to be threaded or sewn on are considered articles and are not in scope.

As reported by the European Commission, plastic glitter is not covered by the microplastics ban under Regulation (EU) 2023/2055 if it is contained in technical means to form solid films (e.g. paints, certain inks) or is permanently incorporated into a solid matrix during end use (e.g. glitter glue). Articles with glitter (permanently) attached to their surface do not fall within the scope of the restriction.

Other exceptions that are not affected by the restrictions:

  • Products, including glitter, made of inorganic material (e.g. glass, metal), natural material, biodegradable material or water-soluble material (do not fall within the scope as they are not considered microplastics)
  • Beads and sequins (and other decorations) intended to be threaded or sewn (articles; not in scope)

No time to follow further developments in the field of microplastics in detail? trade-e-bility keeps you up to date with the Legal Monitoring Service. This means you only receive the information that is relevant to you and your product. And we help you with the implementation. The trade-e-bility consulting team will also be happy to provide you with solutions for EU product labelling, packaging labelling and, in particular, disposal labelling via beratung@trade-e-bility.de or +49/40/750687-300.

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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