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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Photovoltaics fall under eco-design legislation

The Commission perceives the need to present the comparability of photovoltaic products in terms of energy efficiency, durability and carbon footprint on the basis of universally applicable standards. In addition, modules and inverters have so far been difficult to repair and recycle, a state of affairs that is to be significantly improved. However, the aim is also to make the products easier to use for the end consumer.

The EU Commission has launched a new initiative to regulate photovoltaic products. In effect, this will make competition for efficiency and environmental impact much more transparent. The Commission perceives the need to present the comparability of photovoltaic products in terms of energy efficiency, durability and carbon footprint on the basis of universally applicable standards. In addition, modules and inverters have so far been difficult to repair and recycle, a state of affairs that is to be significantly improved. However, the aim is also to make the products easier to use for the end consumer.

The implementation is to take place within the framework of the legislation Ecodesign Directive 2009/125/EC and the Energy Consumption Labelling Ordinance (EnVKV) (EU) 2017/1369. This means that minimum requirements for PV products are defined, as well as a classification into efficiency classes. The latter then requires the registration of the products in the EPREL database already known for other products such as lamps and ‘whiteware’ appliances.

Affected or interested parties can still give their opinion until 16 December 2022 within the scope of a public consultation here. The adoption of a draft legal act is planned for the second quarter of 2023. Affected economic actors should find out at an early stage which testing requirements they will be facing. trade-e-bility keeps its customers up to date on changes in product legislation and develops possible solutions for relevant requirements.

The example shows that optimal legal monitoring is necessary as an existential risk precaution in order to protect you under product law. If you have any questions, the trade-e-bility advisory team will be happy to help you via beratung@trade-e-bility.de or +49/40/75068730-0.

"The new Ecodesign Regulation: From Directive to Regulation / The Digital Product Passport” is also the topic of our seller event “The Future of Product Responsibility” at the Tipi am Kanzleramt theatre in Berlin on 8 November 2022. Further particulars and registration details are available here.

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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