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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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: Unique Identification Number (UIN)

We would like to inform you about the latest developments concerning Extended Producer Responsibility in France. For producers placing products on the French market, the introduction of the Unique Identification Number (UIN) in 2022 will be highly relevant.

What is the Unique Identification Number (UIN)?

As stated in the article L541-10-13 within the law n° 2020-105 of the 10th February 2020, which enters into force on the 2nd January 2022, the French government has decided to issue a Unique Identification Number to every producer placing particular products on the French market. This UIN will be issued for every waste stream subject to Extended Producer Responsibility (EPR) in France. Please note that EPR in France is not limited to WEEE, batteries and packaging. There are more waste streams concerned (among others paper, furniture, textiles incl. shoes, tyres, household chemical products). take-e-way is working on supporting you in these areas in the future and will inform you separately after successful implementation.

The UIN at a glance:

  • The UIN will be issued by the French authorities in January 2022.
  • One UIN will be issued per waste stream. If a producer is registered with three different take-back schemes (e.g. WEEE, batteries, packaging), the producer will receive three different Unique Identification Numbers.
  • The UIN is an addition to the take-back scheme membership number.
  • The UIN proves that a company is registered with a take-back scheme in France and complies with its EPR obligations for one specific waste stream.
  • The UIN has to be displayed on the producers’ websites and in the general terms and conditions or, if the latter is not available, in any other contractual document.

How will the UIN affect market places?

As stated in the article L541-10-9 within the law n° 2020-105 of the 10th February 2020, the French authorities can hold a market place responsible for every online seller not complying with their EPR obligations when selling products to French end-users via their platform. The market place will not be held responsible if they can prove to the French authorities that the sellers comply with their EPR obligations. In that case, the market places will have to provide to the French authorities a list of their sellers’ UIN on a regular basis.

For this reason, certain platforms have already started to inform their sellers in order to receive their UIN as early as possible.

How will the UIN affect market place sellers?

Starting from 2022, every producer concerned by EPR selling in France might be asked by the respective market place to provide their Unique Identification Number(s) to prove compliance with the French law.

How will you receive your UIN?

If you are not yet registered in France but place products on the market that are subject to registration, we will be happy to assist you with the necessary steps. Within the scope of our services, we ensure your legally compliant sale and issue you with your personal UIN after successful registration with the competent authorities.

If you have any questions in this regard and would like a non-binding offer, please do not hesitate to contact Mr Sebastian Siebert (+49/40/750687-151) via

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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