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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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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Are photovoltaic modules subject to registration?

Photovoltaic modules or panels become electrical devices if they deliver a defined voltage on the output end beside the pure transformation from solar energy to electrical current. This means, if those devices have an integrated electrical additional function which results in a defined current flow (on the output side) they are included in the field of application of the German Electrical and Electronic Equipment Act (ElektroG), independent from their size and intended use.

Dear take-e-way customers, dear VERE e.V. members,

The legal obligations of the revised WEEE directive ("WEEE2") will integrate solar and photovoltaic modules. In this context we received from you lots of requests regarding the currently existing obligation to register solar and photovoltaic devices in Germany after the legal obligations of the German ElektroG. Therefore, we would like to give you a valid answer to your questions with the following definitions:

Photovoltaic modules or panels become electrical devices if they deliver a defined voltage on the output end beside the pure transformation from solar energy to electrical current. This means, if those devices have an integrated electrical additional function which results in a defined current flow (on the output side) they are included in the field of application of the German Electrical and Electronic Equipment Act (ElektroG), independent from their size and intended use. The classification to a type of device is always an individual decision due to the versatile usage of photovoltaic devices.

Limitation: Currently photovoltaic modules or panels are not integrated in the field of application of the ElektroG if they do not have an electrically integrated additional function which generates a defined voltage on the output side.

In any case - with the transformation of the revision of the WEEE2 directive in German law (presumably in 2013) all photovoltaic modules will be subject to registration independent from the above mentioned limitation. We can yet guaranty you comfortable handling of all obligations resulting hereof.

You are also welcome to benefit from the option to receive our personal advice about the changes of the WEEE2 directive with regard to photovoltaic systems:

We are looking forward to welcoming you at our booth (A5.335) at the Intersolar Europe trade fair in Munich. There we will be at your disposal from June 13th to 15th during the opening hours from 9:00 am to 6:00 pm (CET). We will be pleased to answer your questions.

Apart from that, please do not hesitate to call us under the phone number +49/40/ 21 90 10 - 65. With this in mind we remain

with best regards,

Your take-e-way team

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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