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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Brand description "no brand" is no longer accepted

With immediate effect, the "EAR" foundation will not be going ahead with any brand registration for producers or equipment under the Electrical and Electronic Equipment Act with the description "no brand".

The reason for this decision is that according to case law of Ansbach Administrative Court in Bavaria, which is the only first instance responsible for decisions of the "EAR" Foundation in Germany, registration with the brand description "no brand" and comparable descriptions (e.g. "without", "none", "no-name") would be unlawful and is therefore not permitted. On the contrary, the manufacturer must always be registered with a brand description that clearly identifies the manufacturer.

In addition, a manufacturer must clearly mark electrical and electronic equipment if no brand is illustrated. The electrical and electronic equipment must be marked with wording (e.g. company name) or a figurative mark registered with the DMPA. Electrical or electronic equipment cannot be marked merely with the registration number and the crossed out dustbin. The manufacturer must certainly be identified in plain text, so that this can then be used as brand during registration.

Please do not hesitate to contact the take-e-way team if you need any more information or have any further questions.

Phone: +49(0) 40-750687158, e-mail: info@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

Services & Contact
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