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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EPR responsibilities for packaging in Denmark

The registration for packaging manufacturers must already have taken place by 01.01.2024, because the quantities from the previous year must already be reported and collected or recycled when the packaging regulation comes into force in January 2025. The declaration of the planned quantity for 2024 must take place in Q1 2024.

With the Act No. 807 of 09.06.2020 amending the Environmental Protection Act, the extended producer responsibility for packaging will come into force in Denmark on January 1, 2025.

According to the statement on the website of the Danish authority DPA, it says: An act has been passed and adopted, but we are still awaiting the statutory order. The order will detail the provisions about which businesses will be covered by the duty of registration and reporting, financial responsibility, and the distribution of roles among the parties. We expect to the statutory order to be ready during 2023.

All types of packaging are expected to be included, i.e. all packaging regardless of material type (plastic, glass, wood, metal, cardboard, etc.) and use (household, industrial, office, service, etc.) or packaging supply chain (filler, importer, repackager).

There is also discussion about establishing labeling requirements for packaging that manufacturers and importers must follow.

There will most likely be different types of declarations for producers who bring more than 8 tons of packaging waste to the Danish market (by weight and number of pieces per packaging material) and for producers with less than 8 tons. They will still bear the costs of producer responsibility for waste management, e.g. collection and recycling. However, it is not yet known how the obligation for companies below the threshold will be implemented in practice. However, the notification will be less extensive.

In setting the threshold, care was taken to reduce the administrative burden on manufacturers with small packaging volumes, while supporting manufacturers' incentive for environmentally sound design as much as possible.

The registration for packaging manufacturers must already have taken place by 01.01.2024, because the quantities from the previous year must already be reported and collected or recycled when the packaging regulation comes into force in January 2025. The declaration of the planned quantity for 2024 must take place in Q1 2024.

We are pleased to be able to keep you up to date with our Legal Monitoring Service. This means you only get the information that is relevant to you.

take-e-way will be pleased to assist you via +49/40/750687-0 or beratung@take-e-way.de if you have any questions on WEEE, the Electrical and Electronic Equipment Act, Batteries Act, Packaging Act and on EPR with registration/licensing.

For solutions on the subject of EU product or packaging labelling and, in particular, disposal labelling, the trade-e-bility consulting team will be pleased to assist you beratung@trade-e-bility.deor +49/40/75068730-0.

For particulars on our international compliance services related to placing electronic equipment, batteries/rechargeable cells and packaged products or packaging on the market, please click on the following link: 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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