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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Netherlands imposes measures on free riders

The Dutch authorities will enhance actions against freeriding in 2023. If you sell or are planning to sell photovoltaic modules in the Netherlands, but have not registered as producer yet, this new development is of high relevance for you.

Starting from July 1st 2023, Stichting OPEN, the take-back-scheme for WEEE in the Netherlands, will introduce the waste management contribution as a separate line item on PV producers’ sales invoices. Since this fee will be visible on the invoice, it will simplify the control of freeriding, according to the Dutch authorities. Although this new visible fee will only apply to PV producers, it shows the determination of the Dutch authorities against freeriding. In the future, the visible fee could potentially be extended to other electrical and electronic equipment.

Stichting OPEN has also announced that an external service provider will be used to search intensively for free riders and contact them, which may lead to sanctions or legal action. At the same time, Stichting Batterijen, the take-back scheme for batteries in the Netherlands, have also increased dedicated resources, including designated personnel, on the identification and handling of freeriders.

Stichting Batterijen and Stichting OPEN are also joining forces at the administrative and operational level in order to implement and enforce the producer responsibility even more effectively. take-e-way will follow the newest development closely and will inform you when there are major changes that may concern the producers in the Dutch market. 

take-e-way will be pleased to assist you via +49/40/750687-0 or beratung@take-e-way.de if you have any questions on WEEE, the Electrical and Electronic Equipment Act (ElektroG), Battery Act, Packaging Act and on EPR with registration/licensing.

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.

For particulars on our international compliance services related to placing electronic equipment, batteries/rechargeable cells and packaged products or packaging on the market, please click on the following link: https://www.take-e-way.com/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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