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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Amendments to the Packaging Act as of 3 July 2021

The Packaging Act (VerpackG) took effect in Germany on 1 January 2019. Already now, about 2 years later, the legislature has introduced amendments to the Packaging Act of relevance to you, which will come into force step by step, taking account of transition periods from 3 July 2021 to 1 January 2029.

The German Packaging Act (VerpackG) took effect on 1 January 2019. Already now, about 2 years later, the legislature has introduced amendments to the Packaging Act of relevance to you, which will come into force step by step, taking account of transition periods from 3 July 2021 to 1 January 2029. 

Amendments as of 3 July 2021

  1. Foreign obliged parties now have the option of appointing an authorised representative (Section 3 (14a), Section 9 (2), Section 35 of the Packaging Act 2)
     
  2. New responsibilities for electronic marketplaces and fulfilment service providers (Section 3 (14b); Section 3 (14c); Section 7 (7); Section 9 (5)
     
  3. Extension of registration obligation (Section 7 (2) sentences 2 and 3; Section 9 (3)), valid from 3 July 2021 / 1 July 2022: “Manufacturers” of service packaging will be required to register even if they purchase the product registered by the previous distributor.
     
  4. Extension of take-back and recycling obligations (Section 15 (3) sentence 3; Section 15 (3) (new: (5)), valid as of 3 July 2021: Proof of compliance with the take-back and recycling requirements for transport packaging must be provided; as of 1 July 2022, manufacturers of transport packaging must also sign up with the Central Agency Packaging Register (ZSVR)
     
  5. Provision of financial and organisational resources (Section 15 (4)): Manufacturers or downstream distributors of packaging or single-use beverage containers in the supply chain, as well as systems and industry solutions, are required to maintain appropriate resources for management, including separate collection and the provision of sorting and treatment processes.

If you have any questions on the Packaging Act, the take-e-way consultants will be pleased to assist you. Call +49/40/750687-0 or send an e-mail 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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