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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Packaging Register publishes case reports on own investigations

In addition to ongoing information provided by the German Central Packaging Register to the state enforcement authorities, a further instrument is now being introduced to deal with behaviour infringing administrative regulations: With immediate effect, the ZSVR will also publish case reports. These reports are used to present cases transparently that constitute violations of the German Packaging Act. The take-e-way team will be pleased to assist you if you are concerned that you may not be correctly registered (or not at all) with your packaging.

The German Central Packaging Register (ZSVR - Zentrale Stelle Verpackungsregister) has been operating the LUCID Packaging Register as a public authority for 15 months. The ZSVR analyses the information provided by manufacturers and identifies conspicuous items in the course of its tests and inspections. This corresponds to its statutory mandate. In addition to ongoing information provided by the ZSVR to the state enforcement authorities, a further instrument is now being introduced to deal with behaviour infringing administrative regulations: With immediate effect, the ZSVR will also publish case reports. These reports are used to present cases transparently that constitute violations of the German Packaging Act. The cases published in the reports are already available to the state enforcement authorities at the time of publication on the ZSVR website. This instrument is intended to help manufacturers to identify and remedy their own unlawful behaviour a great deal faster.

According to Section 26 of the German Packaging Act (VerpackG), the ZSVR must forward information on specific indications of administrative offences to the enforcement authorities of the federal state in question along with the evidence obtained. The next step then provides for the relevant authorities to impose fines. Anyone who fails to comply with these obligations must face the relevant consequences.

For further information in this regard (available in German only), see: https://www.verpackungsregister.org/information-orientierung/neuigkeiten-presse/aktuelles/detail-ansicht-newseintraege/news/zentrale-stelle-verpackungsregister-zsvr-veroeffentlicht-fallberichte-zu-eigenen-ermittlungen/

The take-e-way team will be pleased to assist you if you call +49/40/750687-0 or send an e-mail message to beratung@take-e-way.de if you are concerned that you may not be correctly registered (or not at all) with your packaging at the ZSVR.

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

Services & Contact
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