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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New measures regarding the packaging law in France

Today we report on the latest developments in France, as related decrees ensured by the French government have been officialised during the first weeks of January. Targeting to tackle the struggle of ever increasing waste and paving the way towards a circular economy (AGEC), the following overview will provide you the main changes implemented.

Please find below the latest updates, as related decrees ensured by the French government have been officialised during the first weeks of January. Targeting to tackle the struggle of ever increasing waste and paving the way towards a circular economy (AGEC), the following overview will provide you the main changes implemented:

Penalty on the Green Dot starting from the 1st April 2021

Signs and markings that may lead to confusion about the instructions for sorting waste become subject to a penalty. The Green Dot is included in this measure. Starting from the 1st April 2021, the Green Dot will be subject to a 100 % penalty, a so-called malus. However, all the packaging produced with a Green Dot before the 1st January 2022 and distributed in both France and at the same time in other EU countries where the Green Dot is mandatory (e.g. Spain and Cyprus), are exempt of the penalty until the 31st December 2022. Products packaged or packaging manufactured in or imported into France before the 1st April 2021 benefit from an 18-month transition period from this date.

The substitution of the Triman logo by the crossed-bin is still allowed until the 1st January 2022

Starting from 1st January 2022, the Triman logo cannot be replaced by the crossed-bin anymore and has to be displayed on all packaging, not only the one associated with an efficient take-back system. This means, the Triman will become mandatory on all types of packaging.

Measures considering the info-tri

By the 1st April 2021, Citeo will have developed a harmonised guideline for the info-tri (sorting info), which will have to be approved by the French government. The new harmonised guidelines will be compulsory for all packaging starting from the 1st January 2022.

Measures considering plastics

The French government has decided to prohibit all single use packaging by 2040. This objective will be reached step-by-step. For now, the interdiction concerns only very specific kinds of plastic produced for single-use. Please find the list below:

  • Straw, except the one for medical use
  • Plastic confetti
  • Steak spades
  • Disposable glass lids
  • Plates, other than kitchen plates for the table, including those with plastic film
  • Cutlery
  • Mixing sticks for drinks
  • Expanded Polystyrene (EPS) containers or receptacles intended for on-site or nomadic consumption
  • EPS bottles for drinks
  • Support rods for balloons and their mechanisms


In addition, oxo-degradable plastics are prohibited. These plastics are not considered environmentally friendly since the micro particles remain in the environment and are carried along by river water to end up in the oceans. The marketing of products made of oxo-degradable plastics is now prohibited.

We will keep you informed on the upcoming decisions, which could further impact your obligations as a producer of packaging in France.

Should you wish to register in France as a producer of WEEE, batteries, packaging, textiles or furniture, please do not hesitate to contact our Consulting Department via beratung@take-e-way.de or +49/40/750687-0.

For solutions on EU product or packaging labelling requirements and especially disposal labelling, please contact the trade-e-bility consulting team via beratung@trade-e-bility.de or +49/40/75068730-0.

For more information on our international compliance services related to the placing on the market of electronic equipment, batteries/accumulators and packaged products or packaging, please click here: 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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