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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Packaging Act: Starting in June 2022, marketplaces will be able to check LUCID registration automatically

The marketplaces will be directly subject to this obligation as of 1 July 2022. They are required to check whether the online retailers or sellers who offer their packaged goods on their platform have implemented the registration requirements and system participation. If the traders violate the statutory provisions, the marketplaces may no longer allow them to distribute their goods.

As reported by the Packaging Register Foundation (ZSVR) in its current newsletter, from June 2022 the ZSVR will make an XML file available to electronic marketplaces, fulfilment service providers and other interested parties daily by register retrieval via a defined interface. This enables the marketplaces to automatically check whether their traders are listed in the LUCID Packaging Register.

If this is not the case, then online retailers should act quickly to avoid fines and distribution bans. After all, while the testing and verification requirements for electronic marketplaces are novel, the registration and system participation requirements for merchants who sell their goods there are not.

The ZSVR has already been engaged in intensive dialogue with operators of electronic marketplaces for some time. And there is a specific reason for this: As of 1 July 2022, the marketplaces will be directly subject to this obligation. They are required to check whether the online retailers or sellers who offer their packaged goods on their platform have implemented the registration requirements and system participation. If the traders violate the statutory provisions, the marketplaces may no longer allow them to distribute their goods.

The take-e-way consultancy team will be glad to answer any questions you may have on the Packaging Act. Please call +49/40/750687-0 or send an e-mail message to beratung@take-e-way.de.

This is where you will find useful EPR services your sales via Amazon and similar providers.

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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