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.

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.

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.


take-e-way News and Press Releases

Notice: Be sure to meet the new reporting and information obligations now

Article 2 of the Implementing Act of the Waste Framework Directive (German acronym: AbfRRL, printed matter 88/20) provides for an amendment to the Electrical and Electronic Equipment Act in Section 18. Accordingly, the status of compliance with the quantitative targets under Section 10 (3) and Section 22 (1) of the Electrical and Electronic Equipment Act must be published annually by manufacturers. The law came into force yesterday.
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The EAR foundation renders the recycling process transparent

What happens to that old hairdryer or the disused refrigerator after it ends up at the recycling yard or at the retail store? The new films produced by the EAR foundation, financed by the fees paid by manufacturers and distributors under the Electrical and Electronic Equipment Act, provide answers and show how key raw materials are obtained without toxic substances endangering the environment and health.
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IT system house faces distribution ban, profit skimming and fine for failure to comply with system participation obligation: Packaging register publishes report

In a case report released on 21 September 2020, the German Foundation Central Agency Packaging Register (ZSVR) describes the case involving an IT system house. Evidently a large group of affiliated IT trading companies with their own direct (IT system house) sales organisation has failed to meet its product responsibility for packaging and has been violating its obligations under packaging law for years now. The ZSVR has notified the competent state enforcement authority that there are concrete indications of regulatory offences having been committed. Possible consequence of such administrative offences include the imposition of fines, profit skimming, as well as monitoring the obligation to participate in the system retroactively for past periods. To the extent that registration and system participation per company is not yet fully in place, a distribution ban on packaging subject to system participation likewise applies by law.
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Waste Framework Directive: Bundesrat approves amendments to the ElektroG, VerpackG and product responsibility of dealers regarding returns

On 9 October 2020, Germany’s upper house (Bundesrat) approved the implementation of the new EU Waste Framework Directive into German law. The objective is to further develop the Circular Economy Act (Kreislaufwirtschaftsgesetz) ecologically in order to improve resource management and resource efficiency in Germany and, in particular, to reinforce and intensify waste avoidance. In this connection, the Bundesrat approved amendments to the Electrical and Electronic Equipment Act (ElektroG), the Packaging Act (VerpackG) as well as product responsibility of dealers regarding returns.
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Green Deal: Commission adopts new chemicals strategy

On 14 October 2020, the European Commission adopted the EU Chemicals Strategy for Sustainability. The strategy is the first step towards the zero-emissions target for a pollution-free environment announced as part of the European Green Deal. The strategy will foster and promote innovative solutions for safe and sustainable chemicals and increase the level of protection of humans and the environment from hazardous chemicals. This includes a ban on the most harmful chemicals in consumer products such as toys, childcare articles, cosmetics, detergents, food contact materials and textiles, unless they can be shown to be essential for the general good or public welfare.
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Packaging Act: Depending on their contents, envelopes are packaging items that require system participation

The German Central Agency Packaging Register (ZSVR) classifies envelopes as subject to system participation. Evidently the decisive factor is their contents. If only notices and information such as invoices were sent, these would not be packaging items requiring mandatory system participation. If, however, in addition to an invoice, advertising flyers, brochures, leaflets and other printed advertising materials are sent, then the envelope is considered to be packaging filled with merchandise and is therefore subject to mandatory system participation. This applies irrespective of the envelope selected and concerns padded and classic envelopes featuring a window if they contain “merchandise”.
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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.
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Recurring errors in “is-input-report” are subject to fines

The EAR foundation (German WEEE registration board) advises to proceed carefully when submitting the notification of the quantity of electrical and electronic devices placed on the market. An incorrectly submitted “is-input-report” (actual input notification) may be punished by the German Federal Environment Agency in the form of a fine for an administrative offence.
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Global supply chains: EU wants corporate due diligence to be enshrined in statute law

At both national and European level, legislators are increasingly seeking not only to intensify market surveillance, but also to make economic operators responsible for their products and production channels (supply chains). In order to prepare you in good time for the Market Surveillance Ordinance and the “Supply Chain Act” (Due Diligence Act), we advise you to take part in our free webinar (in German language) “From Production to the Online Shop – Risk-oriented Supply Chain Compliance in the Non-Food Retail Sector”.
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Battery producers should register with the EAR foundation as of 1 January 2021

Producers of industrial, vehicle and device batteries should have themselves registered with the EAR foundation as of 1 January 2021. Those battery producers who are already correctly registered with the German Federal Environment Agency have a one-year transitional period to register with the EAR foundation; this period expires on 31 December 2021. Accordingly, please ascertain whether your data submitted to the Federal Environment Agency is still correct. New producers who require registration as of 1 January 2021 are also advised to register in advance with the Federal Environment Agency without fail.
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