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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Packaging Act Germany: Free riders become more apparent quicker

An interface now allows retailers and marketplaces to use the taxpayer reference number of producers and online retailers to quickly determine whether they are listed in the register. Free riders become more apparent quicker.

According to the German Central Agency Packaging Register (ZSVR), more and more packaging from abroad is reaching Germany and more and more goods are being sold via electronic marketplaces. This means a lot of packaging. Yet international producers and retailers are often unfamiliar with the German legal provisions governing them. To date, this has often led to illegal conduct on the part of international firms.

Since 3 July 2021, the German Packaging Act (Verpackungsgesetz) will allow international producers and online retailers to appoint an authorized representative in Germany to assume all of the obligations for the party actually under obligation. This ensures that there is a party familiar with German legislation that can also be held accountable in Germany.

The authorized representative reports the data required to the LUCID Packaging Register. For this to happen, the LUCID software had to be reprogrammed extensively.

There is another small change with major impact that will also bring significantly more transparency: instead of an e-mail address, it will be the taxpayer reference number that will now be published. This will make it easier for retailers and marketplaces to identify the parties under legal obligation. The packaging of producers not registered in the LUCID Packaging Register is not permitted for sale in Germany. They are banned from distribution.

An interface now allows retailers and marketplaces to use the taxpayer reference number of producers and online retailers to quickly determine whether they are listed in the register. Free riders become more apparent quicker.

Distributors of packaging subject to licensing without a branch office in Germany can be represented by an authorised representative and transfer essential manufacturer obligations to this person.

As your authorised representative, get-e-right also offers you a convenient and digital service.

If you have any questions on the Packaging Act, the take-e-way consultants will be pleased to assist you. Call +49/40/750687-0 or send an e-mail to beratung@take-e-way.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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