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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ElektroG applies to e-cigarettes, tobacco tax law for liquids

E-cigarettes require three registrations: As applicable, a WEEE or ElektroG registration is required for the vaporiser, a battery registration for the rechargeable battery, and a packaging law registration and licence for the packaging. The regulations under tobacco tax law regarding mandatory packaging, the prohibition of packaging and tying, as well as the use of tax stamps also apply without restriction to substitutes for tobacco products (liquids).

The EAR foundation (German WEEE and battery registration board) points out that e-cigarettes and disposable e-cigarettes are battery-powered electrical appliances that must be disposed of properly at the end of their life: “E-cigarettes, like any other electrical appliance, must be disposed of properly. Under no circumstances do they belong in the household waste, in the yellow (recycling) bag or in public waste bins, but should be disposed of free of charge as electronic waste at recycling centres or within the trade.”

E-cigarettes: WEEE, the Batteries Act and Packaging Act must be observed

E-cigarettes (small appliances as contemplated by the Electrical and Electronic Equipment Act/ElektroG) require three registrations: A WEEE or ElektroG registration is required for the vaporiser, a battery registration for the rechargeable battery (device battery within the meaning of BattG; now permanently installed in disposable e-cigarettes), and a registration under the Packaging Act and a licence for the packaging.

Customs and excise: Tobacco tax law also applies to liquids

As the retail trade association Bundesverband des Tabakwaren-Einzelhandels e.V. (BTWE) reported, the regulations under tobacco tax law regarding mandatory packaging, the prohibition of packaging and tying, as well as the use of tax stamps also apply without restriction to substitutes for tobacco products (liquids). In recent weeks, the customs administration has received an increasing number of enquiries regarding the correct handling of substitutes for tobacco products, which are to be considered as tax objects under tobacco tax law as of 1 July 2022. The problems reported bore testimony that there is still a great deal of uncertainty, especially among those partly confronted with tobacco tax law for the very first time, how to proceed in accordance with the law. In order to enable all parties involved to have equal access to the information, the Directorate General of Customs has published a specialist notification to this effect at www.zoll.de. In principle, it should be noted that according to Section 1b sentence 1 of the Tobacco Tax Act, the provisions of the latter as well as the implementing regulations issued in connection therewith also apply to substitutes for tobacco products, unless otherwise stipulated.

The take-e-way consultancy team is at your disposal via +49/40/750687-0 or beratung@take-e-way.de for your questions regarding WEEE, the Electrical and Electronic Equipment Act, the Batteries Act, Packaging Act and the EPR and provides assistance with registration/licensing.

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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