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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UK: DTS for a further three years

Manufacturers of B2C electrical appliances in the UK are affected. Current DTS members will be given until 31 March 2024 to either rejoin the DTS and/or set up their own take-back schemes.

As you may be aware, membership of the current Phase 6 of the DTS (Distributor Take-Back Scheme, take-e-way reported), which producers of B2C electrical products in the UK can join to fulfill their take-back obligation towards UK end-users, ended on December 31, 2023.

take-e-way has now been informed by the DTS that Phase 7, which runs from 01/01/2024 to 31/12/2026 (for 3 years), has been approved with some important changes. Current DTS members will be given until March 31, 2024 to either rejoin the DTS and/or set up their own take-back schemes.

Defra (Department for Environment, Food and Rural Affairs) and OPS&S (Office for Product Safety & Standards) confirm that all current Phase 6 members will be considered DTS members until Phase 7 registration is possible.

The criteria for Phase 7 remain the same as for Phase 6, i.e. retailers selling more than £100,000 worth of electrical goods in a UK store will no longer be able to participate in the DTS and will have to offer their own take-back.

Please note that vapes are also now exempt from the DTS, which means that all stores selling vapes are now required to offer in-store take-back to customers purchasing vapes in accordance with the WEEE Regulations. This applies regardless of their turnover relating to vape sales. This does not prevent these stores from joining the DTS in respect of other sales of electrical goods if they fall below the £100,000 threshold for membership.

Subject to the above DTS exclusion for vapes, manufacturers can join Phase 7, i.e. membership until Dec. 31, 2026, if they have at least one physical store and sell less than 100,000 pounds per year worth of electrical equipment (EEE), or if they are an online-only or distance seller, regardless of size.

take-e-way will be happy to answer your questions about WEEE, the Electrical and Electronic Equipment Act, the Batteries Act, the Packaging Act/packaging subject to system participation and the EPR on +49/40/750687-0 or beratung@take-e-way.de and will help you with registration/licensing.

For information on our international compliance services in connection with the placing on the market of electronic devices, batteries/rechargeable batteries 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

Services & Contact
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