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.

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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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On 1 March: The OPEN Foundation officially became the umbrella organisation for WEEE in the Netherlands

Since 1 March 2021, the OPEN Foundation has been the only organisation in the Netherlands that can implement the obligations for producers of electrical and electronic equipment. Therefore, these producers are obliged to join the OPEN Foundation and pay the disposal fees to it.

On 18 February 2021, the Dutch Ministry approved the application for a generally binding declaration (NL.: Avv), which means that on 1 March 2021 the OPEN Foundation officially became the umbrella organisation for WEEE collection and recycling in the Netherlands. We last informed you about this on 28/09/2020.

What has changed?

Since 1 March 2021, the OPEN Foundation has been the only organisation in the Netherlands that can implement the obligations for producers of electrical and electronic equipment. Therefore, these producers are obliged to join the OPEN Foundation and pay the disposal fees to it.

Important: Quantity reporting on behalf of resellers not allowed!

The OPEN Foundation explicitly points out that non-Dutch producers are only obliged to report quantities sold directly to end users in the Netherlands. In the case of sales from abroad to Dutch resellers, these resellers are legally obliged to register and report the imported quantities under their own registration. According to the OPEN Foundation, non-Dutch producers cannot report under their own registration any quantities on behalf of Dutch resellers!

What else is important?

There is a minimum annual fee of € 175 per manufacturer. This includes € 100 as a fee to the National Register and € 75 as a minimum disposal fee. If producers exceed the € 75 with their annual disposal costs, they will be required to pay more. Furthermore, producers whose average disposal costs reach at least € 100 per month receive monthly advance invoices based on the previous year’s quantity report or alternatively on planned quantities. These advance payments are offset against the actual quantities at the beginning of the following year.

Exception: Lamps

An exception are producers of lamps (not luminaires). Until 31 December 2022, these manufacturers will be members of the LightRec Foundation, as a separate decision has been made for them. From 2023, producers of lamps will become members of the OPEN Foundation.

If you have any questions about the OPEN Foundation, please do not hesitate to contact Alina Eggert via international@take-e-way.de or via +49/40/750687-166.

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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