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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Amazon suspends electronics offers due to WEEE EPR

If you cannot demonstrate to Amazon that you comply with the EPR, Amazon will suspend your non-compliant listings under WEEE on 1 January 2023. This may also affect parts of your WEEE offerings for which there is no valid branded appliance type registration in the EAR foundation’s manufacturer register.

take-e-way customers report to us about letters from Amazon regarding the requirements of Extended Producer Responsibility (EPR) because they sell electrical and electronic equipment (EEE) in Germany. Such a letter with the subject “Action needed - EPR Requirement for EEE” dated 3 August 2022 has been received by take-e-way as an example.

The introduction of the letter begins as follows: “You are receiving this email message because you sell electrical and electronic equipment (EEE) in Germany and are affected by the requirements of the Extended Producer Responsibility (EPR) rules. [...] Therefore, we need to collect your registration number(s) (WEEE Reg. No. DE), validate and check whether your offerings have a valid branded appliance type registration in the EAR Foundation’s register of manufacturers.”

Please note that “manufacturer” is not to be equated with “factory owner”. A manufacturer is the person who first places a product subject to the EPR requirements on the market in Germany. For instance, you are a manufacturer if you offer/introduce electrical appliances that do not originate in Germany for the first time on the German market on a commercial basis or offer them directly to German end consumers via online sales and are not resident or based in Germany.

If you are already registered, you do not need to do anything other than provide Amazon with some information, e.g. whether you are a manufacturer or a reseller, etc. Amazon will inform you when you can submit the registration number(s) (WEEE Reg. No. DE) on Amazon’s collection portal.

If you cannot prove to Amazon that you comply with the EPR requirements, Amazon will suspend your non-compliant listings under WEEE on 1 January 2023. “This may also affect parts of your WEEE offerings for which there is no valid branded appliance type registration in the EAR foundation’s manufacturer register. Please note that Amazon may start enforcing non-compliant listings before the deadline. [...] If you do not start your registration with the EAR foundation by the end of October 2022, you may not have enough time to obtain the registration number(s) (WEEE Reg. No. DE) and registration for branded equipment before the deadline, as the process can take between 7 and 8 weeks,” Amazon advises in its letter.

Important: Irrespective of the obligation to confirm to Amazon that the EPR registrations (WEEE registration, battery registration and packaging registration) are complied with, the corresponding legal requirements already apply at this stage.

The take-e-way consultancy team will be pleased to assist you. Please call +49/40/750687-0 or send an e-mail to beratung@take-e-way.de for any questions you may have on the Electrical and Electronic Equipment Act and the EPR rules and we will help you with the registration.

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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