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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Triman France Update

The EU Commission opened an infringement proceeding against France on 23 February 2023. In this proceeding, the Commission argues that the French Triman regulation represents an impediment to the internal market and to the principles of the free movement of goods, as the additional labelling leads to increased material requirements and thus to more waste.

As reported by our partner law firm Reuschlaw, France has also violated its own notification requirement, as the law has cross-border effects, about which the Commission should have already been informed in the draft phase. “Despite this procedure, however, it should be noted that the obligation to affix the Triman logo remains in force as long as the French national legislator does not repeal the regulation. Therefore, the French market surveillance authorities will continue to monitor compliance with the Triman regulations and impose sanctions, if necessary.“, Reuschlaw continues.

Apart from the outcome of the infringement proceeding, the legal regulation of the affixing of the Triman logo can only be altered by the French legislature, so that affixing this labelling remains required until the national regulation is abolished. In Reuschlaw’s view, however, this is not seriously to be expected.

For solutions on the subject of EU product labelling or packaging and, in particular, disposal labelling, the trade-e-bility consulting team is at your disposal via beratung@trade-e-bility.de or +49/40/75068730-0.

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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