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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No sale despite WEEE registration

If you have not commissioned a battery representative and battery registration, your sale in Germany is not safe if your devices contain unregistered batteries or accumulators.

Since 1 January 2021, anyone who places batteries on the market or produces batteries in Germany, has been required to register them with the EAR foundation (German national register for waste electrical and electronic equipment (WEEE) and batteries; take-e-way informed). It does not matter whether these are small batteries for hearing aids, stationary storage batteries in technical equipment or heavy starter batteries for motor vehicles, because industrial, automotive and portable batteries are all affected.

Please note: Batteries contained in your electrical appliances must already be registered. Therefore, registration under the Electrical and Electronic Equipment Act (ElektroG = German WEEE conversion) is not sufficient for the legal sale of electrical devices in Germany, if these devices also contain batteries.

The EAR foundation also provides information in its latest info letter about a significant change in the new battery law: From 18 August 2025, producers not based in Germany will no longer be allowed to register their batteries themselves: they will need an authorised representative in Germany to carry out the tasks on their behalf.

What this means for you: Batteries cannot be legally sold in Germany without a valid battery registration and without appointing a battery representative. Online marketplaces can suspend the sale of your products due to a missing battery registration or exclude your products from the marketplace.

If you have not commissioned a battery representative and battery registration, your sale in Germany is not safe if your devices contain unregistered batteries or accumulators. If your devices do not contain batteries, they are not affected. Please check your product portfolio for batteries. The new registration at the EAR foundation can take up to 12 weeks. During this time, you are not allowed to place your products on the market. Therefore, we recommend that you take action in good time if you need to.

Request your battery registration now: take-e-way will be happy to take over the function of the battery representative and the battery registration at the EAR foundation for you. Just write us a message to consulting@take-e-way.de to request the necessary documents.

The take-e-way consulting team will be happy to answer your questions on +49/40/750687-0.

Sebastian Siebert
Contact

Sebastian Siebert
Head of Advisory services

Phone: +49 40 750687-0

consulting@take-e-way.de

Christoph Brellinger
Contact

Christoph Brellinger
Head of Marketing & Public Relations

Phone: +49 40 750687-0

pr@take-e-way.de

Services & Contact
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