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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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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WEEE Germany: Obligation to take back on delivery! Check your logistics if you sell electrical appliances >50 cm

With the impending amendment to the Electrical and Electronic Equipment Act as of 1 January, 2022, an actually minor tightening for “obliged distributors” has fallen somewhat under the radar, but it certainly has a major impact on existing practice: When selling appliances with an edge length of more than 50 cm (this can already apply to commercially available microwave ovens), as well as when selling television sets and refrigerators, the purchaser must be actively asked whether he/she wishes to return a corresponding old appliance completely free of charge.

With the impending amendment to the Electrical and Electronic Equipment Act (ElektroG = German WEEE conversion) as of 1 January, 2022, an actually minor tightening for “obliged distributors” has fallen somewhat under the radar, but it has a major impact on existing practice: When selling appliances with an edge length of more than 50 cm (this can already apply to commercially available microwave ovens), as well as when selling television sets and refrigerators, the purchaser must be actively asked whether he/she wishes to return a corresponding old appliance completely free of charge.

So please check urgently whether your logistics or those of your service provider are capable of doing this if the customer also expresses this wish.

Here are a few practical examples:

A 32” TV set is shipped by parcel service. Can the parcel carrier also take back an old appliance (for example, a valve TV set) from the customer?

You deliver a new stove to the customer’s curb by a freight forwarding service. Can the forwarding agent take back an old stove from there, too?

Apart from the logistical challenge (Is there enough space for old equipment inside the delivery vehicle? How many people are needed to carry this old equipment?), the legal aspect must also be taken into consideration. At least a notification according to Section 53 or permission under Section 54 of the German Circular Economy Act (KrWG) is necessary as well as unfolding the so-called “A sign” (A for “Abfall” = waste in German) when transporting such equipment.

If you have any questions or need support for your logistics, please do not hesitate to contact us:

Wolfgang Obermeyer from take-e-way will be glad to assist you. Please send an e-mail message to take-e-back@take-e-way.de or call +49/40/750687-146.

Incidentally: For electrical appliances with an edge length of less than 50 cm, operators of online shops with a storage floor space of >400 sqm are required to continue offering a return option at a reasonable distance from the customer. This is where our nationwide system www.take-e-back.de provides a practicable and cost-effective solution for affected distributors.

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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