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: Final approval of the harmonised sorting information guidelines

This July, the French packaging take-back schemes submitted to the French authority a proposal concerning the sorting information guidelines. The French government gave their approval to validate this proposal on the 9th September 2021. This decision will allow the take-back schemes to release their definitive version of the harmonised sorting information, together with a user hand book and all necessary technical specifications. The information will be released shortly.

This July, the French packaging take-back schemes submitted to the French authority a proposal concerning the sorting information guidelines. The French government gave their approval to validate this proposal on the 9th September 2021. This decision will allow the take-back schemes to release their definitive version of the harmonised sorting information, together with a user hand book and all necessary technical specifications. The information will be released shortly. We will provide you with all the elements you need in order to adjust your packaging, as soon as we receive it.

Transition period

As explained in our previous newsletter, the obligation to display the Triman logo together with the sorting information enters into force on 1st January 2022 and has to be fulfilled by 9th March 2022 at the latest. However, in order to give the producers time to adapt, a transition period of one year following the release of the sorting guidelines by the French government is granted. This means, the sorting information will become compulsory on all packaging starting from the 9th September 2022. An extension of the deadline until the 15th June 2023 is granted to all packaging produced or imported before the 9th September 2022 for producers serving one additonal waste stream (WEEE or batteries). For producers only serving the packaging waste stream the deadline will be the 9th March 2022.

Overview of the sorting information provided by Citeo

Citeo (French take-back scheme for packaging) has provided an overview of the upcoming sorting information guidelines. This information guideline has to be displayed on all the household packaging and has to include the Triman logo. The overview represents two examples of packaging which offer three versions the producer can choose to display on their packaging.

According to Citeo, these versions offer different advantages for the producer:

1) The version that informs the best the customers
2) The most explicit version
3) The most simple version in order to avoid translation.

The third version is especially interesting for all foreign producers using the same packaging for their product everywhere in Europe. Since this version does not have any text, it will not require additional translation efforts.

Additional sorting information guidelines for other EPR schemes in France

In order to align with the latest regulations, the other take-back schemes dealing with extended producer responsibilities (EPR) in France will have to release their own sorting information as well. We are awaiting the definitive version of the harmonised sorting information guidelines. The information will be released shortly. As usual, we will update you about any further development.

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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