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 WEEE registration or termination

As there is always confusion when a WEEE registration is to be terminated in the UK, we wish to provide you with the following background information.

Registrations cannot be cancelled intra-year. They are issued on a calendar-year basis and zero returns are required to be submitted by the respective year-end at which the registration can be cancelled. Companies that no longer exist are excepted.

A distinction is drawn between large-scale (more than 5 tonnes of electrical equipment placed on the market in the previous year or for the first time in the current year) and small-scale WEEE manufacturers (less than 5 tonnes of electrical equipment in the previous year or for the first time in the current year).

Small-scale manufacturers do not pay direct recycling contributions, but the B2C tonnages of small-scale manufacturers are included in the UK market data and therefore also taken into account in the annual UK recycling targets. In order to be considered as no longer committed, the regulations require B2C manufacturers to remain registered as such for a full year and to place zero tonnes of mandatory EEE on the market to prove that they are no longer engaged as manufacturers. In addition, large-scale manufacturers must remain members of a Producer Compliance Scheme (PCS) in the year immediately after the last compliance period in which they placed more than 5 tonnes of EEE on the UK market.

Registration as a WEEE producer for a further year and the zero returns to be submitted for that year applies irrespective of the registration status as a small-scale / large-scale producer. Failure to register would constitute a criminal offence and the manufacturer may face enforcement measures imposed by the Environment Agency.

However, small-scale manufacturers have the option of registering directly through the Authority (NPWD) rather than through a scheme, which can be a helpful option in these circumstances. However, direct registration with the Authority is only possible with a registered office in the UK.

Non-UK based manufacturers: Manufacturers from other countries must either appoint an authorised representative based in the UK or join a UK-approved PCS to register WEEE, although producers with more than 5 tonnes of EEE must in principle join a PCS. Manufacturers from other countries with less than 5 tonnes do not need to join a PCS but do need an authorised representative based in the UK. If you wish to register in the UK as a manufacturer of WEEE, batteries or packaging, please contact our consultancy via beratung@take-e-way.de or call +49/40/750687-0.

For further information on mandatory labelling of products or packaging, the trade-e-bility consultancy team will be pleased to assist you via beratung@trade-e-bility.de or +49/40/75068730-0.

For particulars on our international compliance services related to placing electronic equipment, batteries/rechargeable cells and packaged products or packaging on the market, please click on the following link: 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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