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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Energy label – lamps to be entered in the EPREL database as of 1 May 2021

take-e-way had recently reported that in the first two weeks of March (1 – 18 March 2021), traders would need to replace labels for mains-operated refrigerators with direct sales function, mains-operated refrigerators between 10 and 1,500 litres in volume, mains-operated household dishwashers, television sets, monitors, certain signage displays, washing machines and washer-dryers. As of 1 September 2021, all E-labels for light sources must also be changed accordingly. However, the entry in the EPREL database (from which the energy labels are generated) is required from as early as 1 May 2021. Uncertainties currently exist in the market regarding the deadlines for relabelling since it is not always clear which requirement needs to be applied when reading the underlying legislation (Delegated Regulation 2019/2015/EU and Framework Regulation 2017/1369/EU). For the reasons specified above, it is advisable to deal with this topic in good time.

take-e-way had recently reported that in the first two weeks of March (1 – 18 March 2021), traders would need to replace labels for mains-operated refrigerators with direct sales function, mains-operated refrigerators between 10 and 1,500 litres in volume, mains-operated household dishwashers, television sets, monitors, certain signage displays, washing machines and washer-dryers.

As of 1 September 2021, all E-labels for light sources must also be changed accordingly.

Uncertainties currently exist in the market regarding the deadlines for relabelling since it is not always clear which requirement needs to be applied when reading the underlying legislation (Delegated Regulation 2019/2015/EU and Framework Regulation 2017/1369/EU).

This results in scope for interpretation ranging from only 14 days for the relabelling of e.g. display stands and online displays to 18 months which, according to the Framework Regulation, applies only to labels printed on the packaging, for instance.

However, the entry in the EPREL database (from which the energy labels are generated) is required from as early as 1 May 2021. Traders are required to be supplied with the appropriate E-labels as of that date.

For the reasons specified above, it is advisable to deal with this topic in good time.

Evaluation and/or preparation of test reports

Please bear in mind that the new labels must have corresponding test reports that must be placed in the EPREL database. If these are lacking, then new labelling is not possible. Preparing a test report is time-consuming, so please act promptly. trade-e-bility can support you in the evaluation of your test documents. If you have any questions, please do not hesitate to call trade-e-bility on +49/40/75068730-0 or send an e-mail message to beratung@trade-e-bility.de.

Registration and entry in the EPREL database

The registration in the EPREL database had to be carried out 4 months before 1 March 2021, i.e. before 1 November 2020. Since 1 November 2020, suppliers have had to include both the old and the new label. If you need support with the registration and entry of your products or the entry of your data and documents into the EPREL database, the take-e-way GmbH consultants will be pleased to assist you. Please call +49/40/750687-0 or send an e-mail to beratung@take-e-way.de.

You can find our services on the subject of EPREL at: https://www.take-e-way.com/services/eprel-database-service/

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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