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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France / packaging act – latest developments

Following the suspension of the execution of the decree of 30th November 2020, the French Council of State has decided to put the prohibition of the Green Dot as well as the penalty for using the Green Dot on hold. The topic requires further discussion among the French government. At present, we are waiting for the French Council of State’s decision on whether the Green Dot prohibition and penalty for using the Green Dot will be maintained or not. The final decision is expected within the next 6 to 18 months.

Following our previous newsletter article sent on 22 February 2021, please find below the latest updates regarding the French packaging regulation, as new information and a related court order have recently been released.

Release of the new sorting information guideline delayed

The French government has not yet achieved any agreement on the new harmonised guideline for the sorting information (Info-tri).

Due to this delay, the new sorting information will not be released in April 2021 but is expected to be released instead in July 2021. Producers will still have to implement the new sorting information by 1st January 2022. However, the French government is considering prolonging the transition period by additional 6 months due to the unexpected delay.

Prohibition of the Green Dot postponed to 1st January 2022

On 15th March 2021, the French Council of State released an order to suspend the execution of the decree of 25th December 2020. This order states that the prohibition of the Green Dot will not come into effect by 1st April 2021 as previously announced, but is instead scheduled for 1st January 2022. One of the reasons behind is that the time frame of implementation of the decree was too short.

Suspension of the Green Dot prohibition and penalty for using it

Following the suspension of the execution of the decree of 30th November 2020, the French Council of State has decided to put the prohibition of the Green Dot as well as the penalty for using the Green Dot on hold. The topic requires further discussion among the French government. At present, we are waiting for the French Council of State’s decision on whether the Green Dot prohibition and penalty for using the Green Dot will be maintained or not. The final decision is expected within the next 6 to 18 months.

We will keep you informed on the upcoming decisions, which could further impact your obligations as a producer of packaging in France.

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 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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