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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Printer cartridges with electrical or electronic functions are subject to the ElektroG

Printer cartridges which require electrical currents or electromagnetic fields in order to fulfill their functions are subject to the Electrical and Electronic Equipment Act (ElektroG).

The statement that it would not be necessary to qualify printer cartridges as electrical devices was made regarding the field of application of the Electrical and Electronic Equipment Act (ElectroG/WEEE) in the FAQ of the commission and the original notes of the German Federal Ministy for the Environment, Nature Conservation and Nuclear Safety. From the point of view of the Foundation EAR (=German national registration board) this statement is no longer applicable in this way.

Furthermore, printer cartridges are available on the market which are equipped with electrical or electronic functions. Such cartridges are equipped with a chip, a sensor, an RFID chip or an LED status display (as the case may be also a combination of these items) – depending on the type. In this case, the printer cartridge requires electrical currents or electromagnetic fields in order to fulfill their functions.

Therefore, in these special cases the Foundation EAR assumes that such printer cartridges come under the field of application of the Electrical and Electronic Equipment Act (ElektroG). Of course, in order to be sure in cases of doubt, manufacturers can make an application for assessment at the Foundation EAR.

The team of take-e-way will be glad to support you, if you are concerned with it and will support you in registering your items according to the Electrical and Electronic Equipment Act (ElektroG). We are looking forward to your call: +49 / 40 / 21 90 10 - 65.

Source: Foundation EAR/Stiftung Elektro-Altgeräte Register (EAR Insight Newsletter 03/2012, October 1st, 2012).

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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