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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When will RFID blocker cards fall within the scope of the Electrical and Electronic Equipment Act?

Whether the blocker cards are electrical devices as contemplated by the Electrical and Electronic Equipment Act (ElektroG) depends on their internal structure. Blocker cards with chips or aerials are electrical devices and fall under category 6. In contrast, RFID blocker cards that contain neither a chip nor an aerial, but only a metal foil to shield an electromagnetic field, do not fall under the ElektroG.

As a rule, RFID protection cards (RFID blockers, blocker cards) are the size of a credit card and are intended to prevent unauthorized reading of credit and giro cards as well as identification documents (e.g. carried in a wallet) – which are now usually equipped with Near Field (NFC) technology.

Whether the blocker cards are electrical devices as contemplated by the Electrical and Electronic Equipment Act (ElektroG) depends on their internal structure. RFID blocker cards with an integrated chip are active cards that send meaningless signals to readers. RFID blocker cards with an integrated aerial are passive cards that are supposed to interfere with readers using the built-in aerial. Both types of Blocker cards, cards with chips or aerials, are electrical devices and fall under category 6.

In contrast, RFID blocker cards that contain neither a chip nor an aerial, but only a metal foil to shield an electromagnetic field, do not fall under the ElektroG as they do not constitute electrical devices.

If you have any questions on the ElektroG, please do not hesitate to contact the take-e-way GmbH consultants by calling +49/40/750687-0 or by sending an e-mail message to beratung@take-e-way.de.

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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