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.

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.

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.


France: Latest news for producers of all waste streams

With this article, we would like to inform you about current topics that are relevant for you if you sell to France.

Additional sorting information guidelines to be published soon

The sorting information guideline for packaging has been published recently. As mentioned in our news article of 17th September, producers will soon have to display as well the sorting information for other waste streams like electric and electronic products, batteries, textiles and furniture.

In order to raise the consumer’s awareness of the separate waste collection, the French government has issued the decree n° 2021-835 of 29th June 2021. The decree states that the take-back systems shall develop one sorting information guideline for each waste stream falling under Extended Producer Responsibility (EPR). The government is currently validating the propositions of the related take-back systems.

  • Approval and release of the sorting information guidelines expected in December.
  • The sorting information is supposed to be displayed on the product’s packaging. The law indicates the same rules as for the packaging sorting information.
  • In contrast to the packaging sorting information, the other waste streams’ sorting information will look simpler, only requiring minor modifications.
  • Transition period of one year. If for example, the government approves the new guidelines in December, the obligation to display the sorting information starts in December 2022.

As soon as the guidelines are released, we will inform you.

Unique Identification Number (UIN)

In the beginning of 2022, the authorities will issue one UIN per waste stream to each registered producer in France. Please see our news article from 10th November, which contains important information regarding the UIN. The UIN has to be displayed on the producer’s website and in the general terms and conditions or, if the latter is not available, in any other contractual document.

New waste streams falling under EPR as per 2022

Please find below an overview of the waste streams that will become subject to EPR starting from 01st January 2022.

  • Toys
  • Oils
  • Sports and leisure equipment
  • Do-it-yourself and gardening equipment
  • Construction material

Please note that so far, not every waste stream has been assigned to a take-back system. We will inform you as soon as the systems are implemented.

Amendments of the packaging legislation

Following packaging elements will be prohibited as per 2022 according to the Anti-waste Law (AGEC):

  • Plastic packaging and stickers for fruits and vegetables
  • Usage of mineral oils in packaging (Please note: If you cannot remove mineral oil from your packaging yet, it is possible to report mineral oil as part of your packaging. It will result in a malus contribution of 50 percent.)

The ban of the Green Dot

The Council of State has not yet made a decision regarding the ban of the Green Dot in France. The packaging take-back schemes recommend their members not to display the Green Dot. As soon as a decision is communicated, we will inform you.

Should you wish to register in France as a producer of WEEE, batteries, packaging, textiles or furniture, please do not hesitate to contact our Consulting Department via 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 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:

Sebastian Siebert

Sebastian Siebert
Head of Advisory services

Phone: +49 40 750687-0

Christoph Brellinger

Christoph Brellinger
Head of Marketing & Public Relations

Phone: +49 40 750687-0

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