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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Billions for sustainability bureaucracy

Annual costs of around 1.58 billion euros are expected for the economy from the 2028 financial year. In addition, one-off costs of around 846 million euros will be incurred, mainly for the customisation of products, manufacturing processes and the introduction of digital processes.

As reported by the Bundestag, the German government has presented a draft law to implement the EU directive on sustainability reporting by companies (trade-e-bility reported: CSRD implementation act published). This draft obliges large companies as well as small and medium-sized capital market-oriented companies to carry out sustainability reporting and have it audited. The aim is to promote sustainable consumption and production patterns and thus contribute to the achievement of Goal 12 of the UN 2030 Agenda. Implementation requires amendments to the German Commercial Code, the Securities Trading Act and the Auditors' Code.

Once the reporting obligations have been fully introduced, there will be considerable costs: the economy is expected to incur annual costs of around 1.58 billion euros from the 2028 financial year. These costs are mainly made up of bureaucratic expenses for information obligations. In addition, one-off costs of around 846 million euros will be incurred, mainly for the adaptation of products, manufacturing processes and the introduction of digital processes.

For the federal government, this results in additional annual expenditure of around 4.9 million euros, while one-off costs for the introduction of the regulations amount to around 2.3 million euros. In contrast, the federal states and local authorities are only marginally affected by the new regulations.

Even if companies are not directly affected by the legal requirements, the complexity increases with rising customer requirements and specifications. These requirements are often passed on from customers to small and medium-sized enterprises, which leads to an indirect impact.

Is your company affected by the CSRD? Take precautions now in good time: The trade-e-bility management consultancy will work with the responsible employees in your company to set up a sustainability management system in small steps so that you are prepared for the new requirements by the time they are introduced.

Christopher Blauth and Jens Haasler will be happy to answer your questions.

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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