On 28 December 2022, the new packaging act was published in the Spanish Official Gazette. On 20 June 2022, we already informed about planned changes and the VERE association's statement on the draft legislation.
Labelling
In the interest of its members, the VERE e.V. association, together with others, was able to avert the requirement of detailed instructions for sorting packaging waste according to instructions of the take-back systems on the packaging, as well as the explicit ban on the use of the Green Dot. On household packaging, however, there is an obligation to indicate the waste fraction or the correct collection container.
Registration Obligation
With the definition of product producer, this new legislation widens the scope of obligated parties. This also includes packers, importers, brand owners, distributors, parcel services and platform operators. For household packaging as well as for commercial and industrial packaging, they are obliged to register in the public producer register and to ensure the separate collection of packaging waste via a take-back system. The registration number must show up in official documents throughout the supply chain and is controlled by authorities. Foreign producers have to appoint an authorised representative.
Disposal costs
In agreement among trading partners, the financing of the disposal can be taken over by a buyer or seller based in Spain. Anyone who therefore voluntarily joins a take-back system thus assumes the full responsibility of a producer. The contribution paid to a take-back system for disposal must be shown visibly on invoices to the customer.
If you would like to be registered in Spain as a producer of WEEE, batteries or packaging or have any questions about Extended Producer Responsibility (EPR), please contact our consulting team via beratung@take-e-way.de or +49/40/750687-0.
The trade-e-bility consulting team is at your disposal for solutions on the subject of further information regarding labelling via beratung@trade-e-bility.de or +49/40/75068730-0.
For further particulars on international compliance services related to placing electronic equipment, batteries/rechargeable cells and packaged products or packaging on the market, please click on this link: International Compliance (take-e-way.com)
