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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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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Pitfalls in product labelling: School satchels provide protection but do not count as protective equipment?

A school bag or satchel is not considered personal protective equipment (PPE) and may not bear a CE mark based on the PPE Regulation. Incorrectly labelled satchels can sometimes get stuck in customs.

After the summer holidays, corona conditions permitting, there will be plenty of back-to-school traffic. Hopefully, children will then carry satchels that comply with DIN 58124 in terms of visibility and reflectivity. Such a satchel is in line with a protection goal of the Product Safety Act (German acronym: ProdSG). DIN 58124 has also been highlighted by the German Committee for Product Safety (AfPS) as having “presumptive effect” in accordance with the Product Safety Act. Nevertheless, a school bag or satchel is not considered personal protective equipment (PPE) and may not bear a CE mark based on the PPE Regulation. Incorrectly labelled satchels can sometimes get stuck in customs.

Does my product count as protective equipment or not? The answer to this question determines the product’s designation. Importers or fulfilment service providers predominantly source their goods from third countries, and the merchandise is thus inspected by customs. And as of this month, when the new Market Surveillance Regulation takes effect, customs authorities will be granted extended freedom of action. This is one more reason to pay attention to correct product labelling.

Take action now before customs do! trade-e-bility offers comprehensive advice on product labelling to those affected. The trade-e-bility consultants will be pleased to assist you.

Should you wish to register 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 more in-depth advice on product labelling requirements, please contact us via beratung@trade-e-bility.de +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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