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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Repairability of products – what are the next requirements?

So far, the EU has already issued regulations for several appliance groups, such as refrigerators, dishwashers, washing machines, tumble dryers and vacuum cleaners, which stipulate the availability of spare parts for up to 10 years; for the first 3 groups, this legislation has also been in force since as early as March of last year.

As the TV programme tagesschau.de reported on 25 January 2022, Consumer Protection Minister Lemke intends to make the service life of products more transparent. A “Repairability Index” is intended to provide guidance. So far, the EU has already issued regulations for several appliance groups, such as refrigerators, dishwashers, washing machines, tumble dryers and vacuum cleaners, which stipulate the availability of spare parts for up to 10 years; for the first 3 groups, this legislation has also been in force since as early as March of last year.

However, the repairability of a device also takes account of factors such as the availability of repair instructions, the ease of replacing spare parts or the price of such spare parts. The following example shows how something like this can be implemented: A repair index ranging from 0 to 10 has already existed in France since January 2021. The higher the index, the easier the repair work. This index is provided when a product is purchased and is intended to influence the purchase decision.

It remains to be seen whether the Ministry for Consumer Protection will focus on a national index for Germany or tackle the issue on a pan-European scale.

At any rate, the economic operators affected, such as manufacturers, importers and fulfilment service providers, are bound to face fresh challenges. Careful monitoring of legislative initiatives is advisable.

trade-e-bility informs you in good time of amendments to legal product requirements and assists you to implement them in line with your particular needs.

If you have any questions in this regard, our team of consultants will be pleased to assist you. Please call +49/40/75068730-0 or send an e-mail message to beratung@trade-e-bility.de.

Sebastian Siebert
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Sebastian Siebert
Head of Advisory services

Phone: +49 40 750687-0

beratung@take-e-way.de

Christoph Brellinger
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Christoph Brellinger
Head of Marketing & Public Relations

Phone: +49 40 750687-0

presse@take-e-way.de

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