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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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: Depending on their contents, envelopes are packaging items that require system participation

The German Central Agency Packaging Register (ZSVR) classifies envelopes as subject to system participation. Evidently the decisive factor is their contents. If only notices and information such as invoices were sent, these would not be packaging items requiring mandatory system participation. If, however, in addition to an invoice, advertising flyers, brochures, leaflets and other printed advertising materials are sent, then the envelope is considered to be packaging filled with merchandise and is therefore subject to mandatory system participation. This applies irrespective of the envelope selected and concerns padded and classic envelopes featuring a window if they contain “merchandise”.

The German Central Agency Packaging Register (ZSVR) responded with a declaratory ruling to the enquiry by an insurance association as a distributor of letters with different contents. The insurance association wanted to obtain confirmation that the envelopes used, which had different contents, were not packaging items subject to mandatory system participation and that no licence fees were payable.

The ZVSR assesses this differently and classifies the envelopes as subject to mandatory system participation, adding that the decisive factor is their contents. If only notices and information such as invoices were sent, these would not be packaging items requiring mandatory system participation. If, however, in addition to an invoice, advertising flyers, brochures, leaflets and other printed advertising materials are sent, then the envelope is considered to be packaging filled with merchandise and is therefore subject to mandatory system participation. This applies irrespective of the envelope selected and concerns padded and classic envelopes featuring a window if they contain “merchandise”.

Further information in this regard is available on the website of the EUWID.

If you have any questions on the German Packaging Act, please do not hesitate to contact the take-e-way GmbH consultants by calling +49/40/750687-0 or by sending an e-mail to beratung@take-e-way.de.

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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