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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Slovenia: In future, foreign companies will also be obliged to register the quantities of packaging placed on the market

On 8th April 2021, the Slovenian government published a new decree on Packaging and Packaging Waste Handling, which is an implementing regulation based on the amendment to the Environmental Protection Act and came into force on 24th April 2021. Based on this, all "new" market participants must appoint an authorised representative, who is obliged transfer the adopted obligation to a take-back system within only 30 days.

Thus, all foreign companies selling packaged products by means of distant selling to end users (individuals and households) in Slovenia will have the following obligations in the future:

  • Appointment of an authorised representative in Slovenia
  • Record keeping of the quantities of packaging placed on the Slovenian market based on the following categories:
  • Paper and cardboard
  • plastics other than PVC
  • PVC
  • Wood
  • Iron and steel
  • Aluminium
  • Composites (separated by material type, depending on which material predominates)
  • others (ceramics, textiles, etc.)
  • Quarterly reporting of packaging placed on the market to an authorised representative
  • Payment of advance disposal fees (licensing)
  • Declaration of inclusion in the packaging waste management system on invoices and/or delivery notes (example: For our packaging waste, the handling in accordance with the Ordinance on the Disposal of Packaging and Packaging Waste is ensured by us. The obligations are transferred to name of the authorized representative).

The obligations apply to all foreign companies, regardless of the amount of packaging placed on the Slovenian market. Companies exceeding 15 tons of packaging placed on the market per year are in addition to the advance disposal fees obliged to pay an environmental tax to the Financial Administration of the Republic of Slovenia.

In addition, the role of the authorised representative is described as follows:

  • Report on the quantities of packaging placed on the market to the Slovenian authorities (Financial Administration of the Republic of Slovenia respectively the Slovenian Environmental Protection Agency)
  • Registration principal in the register of the Slovenian Environmental Protection Agency
  • If the authorised representative acts at the same time as a packaging waste disposal company, the authorised representative will take care of the recycling of the reported packaging quantities. If not, it is necessary to conclude a contract with an additional disposal company

In this context, we are in close contact with our Slovenian partner, who acts as both an authorised representative and waste disposal company, and can therefore fully guarantee your legally secure sale in Slovenia.

If you sell products to Slovenia or would like to know more about this new regulation, please contact Florian Spreu via or +49/40/750687-159.

For more information on our international compliance services related to the placing on the market of electronic equipment, batteries/rechargeable batteries 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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