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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Bulgaria: Packaging labeling obligation

Under Extended Producer Responsibility (EPR), distributors are responsible for the collection and treatment of waste from their products. This applies to foreign companies in particular if they distribute products to end-users in Bulgaria. A fine of BGN 10000 (€ 5000) to BGN 50000 (€ 25000) shall be imposed on any infringement.

As Italy and France did (take-e-way reported on this), Bulgaria renewed the Packaging Ordinance with due date 8 January 2021. Under Extended Producer Responsibility, distributors are responsible for the collection and treatment of waste from their products.

This applies to foreign companies in particular if they distribute products to end-users in Bulgaria. Duties such as waste collection, official reporting and information campaigns can be transferred to a take-back-scheme. With the quantity reporting and payment of disposal costs, these obligations are fulfilled for producers. The obligation remains to minimise the packaging itself and its hazardous substances, to provide the required declarations of conformity and to label the packaging with disposal instructions.

According to the newest version of the Packaging Decree, the labelling obligation applies to all packaging placed on the market in Bulgaria for the first time from 1 January 2022.

Like the Italian decree, the Bulgarian Packaging Ordinance requires the alphanumeric codes of EU Decision 97/129/EC to identify the packaging material. The code must be placed in the middle of the three arrows symbol of Möbius loop (see Annex 3, VerpVO). Also the tidyman must be clearly legible and permanently affixed to the packaging component with the largest weight or to a label (see Appendix 4, VerpVO).

A fine of BGN 10000 (€ 5000) to BGN 50000 (€ 25000) shall be imposed on any infringement.

Should you wish to register in Bulgaria as a producer of WEEE, batteries, packaging, textiles or furniture, please do not hesitate to contact our Consulting Department via beratung@take-e-way.de or +49/40/750687-0.

For solutions on EU product or packaging labelling requirements and especially disposal labelling, please contact the trade-e-bility consulting team via beratung@trade-e-bility.de or +49/40/75068730-0.

For more information on our international compliance services related to the placing on the market of electronic equipment, batteries/accumulators and packaged products or packaging, please click here: https://www.take-e-way.com/international-compliance/

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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