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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Proposal for EU Packaging Regulation published

To encourage reuse or refilling of packaging, companies must offer consumers a certain percentage of their products in reusable or refillable packaging, e.g. eCommerce deliveries. Moreover, some packaging formats are standardised, and clear labelling of reusable packaging is prescribed. To decisively address unnecessary packaging, certain packaging is prohibited.

As the EU Commission reports, Europe produces on average almost 180 kg of packaging waste per capita and year. Packaging materials use the most primary raw materials, as 40% of plastics and 50% of paper consumed in the EU are for packaging materials. This is why on 30 November 2022, the Commission proposed a Revision of EU legislation on packaging and packaging waste. The proposals are important building blocks of the Circular Economy Action Plan announced in the European Green Deal and its aim to make sustainable products standard practice.

The proposed revision has three main objectives. The first is to avoid creating packaging waste in the first place by reducing the amount, limiting unnecessary packaging and promoting reusable and refillable packaging solutions. Secondly, to promote a high-quality closed-loop recycling system by ensuring that all packaging on the EU market can be commercially recycled by 2030. Thirdly, to reduce the demand for primary raw materials and create a well-functioning market for secondary raw materials by increasing the share of recycled plastics in packaging materials through binding targets.

The overall target is to reduce packaging waste by 15% per EU member state per capita by 2040 compared to 2018. This is done both by reuse and also by recycling.

To promote the reuse or refilling of packaging, companies must offer consumers a certain percentage of their products in reusable or refillable packaging, e.g. takeaway drinks and meals or e-commerce deliveries. Furthermore, some packaging formats are standardised and clear labelling of reusable packaging is prescribed.

To decisively address unnecessary packaging, certain packaging will be banned, e.g. single-use packaging for food and beverages consumed in restaurants and cafés, single-use packaging for fruit and vegetables, miniature shampoo bottles and other miniature packaging in hotels.  

Numerous measures are aimed at making packaging fully recyclable by 2030. This includes prescribing criteria for the design of packaging, introducing mandatory deposit systems for plastic bottles and aluminium cans, and specifying which very few types of packaging must be compostable for consumers to be able to throw them into organic waste.

In addition, there will be mandatory recycled content that manufacturers must include in new plastic packaging. This will help to make recycled plastic a valuable raw material, as the example of PET bottles in the context of the Single-Use Plastics Directive shows.

The proposal of the Packaging and Packaging Waste Regulation will now be discussed by the European Parliament and the Council under the ordinary legislative procedure.

The advisory team of take-e-way will be pleased to assist you. Please call +49/40/750687-0 or send an e-mail to beratung@take-e-way.de for any questions you may have on the Packaging Act.

For solutions on the subject of EU product labelling or packaging and, in particular, disposal labelling, the trade-e-bility consulting team is at your disposal via beratung@trade-e-bility.de or +49/40/75068730-0.

For further particulars on our international compliance services in connection with placing electronic equipment, batteries/recharegable cells and packaged products or packaging, please click on this link: https://www.take-e-way.com/international-compliance/

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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