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.

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.


Single-Use Plastic Fund Act entry into force

On 15 May 2023, the new Single-Use Plastics Fund Act (EWKFondsG) was published in the German Federal Law Gazette and has thus come into force step by step since 16 May 2023. Affected products include plastic carrier bags, balloons and tobacco products.

The new Single-Use Plastic Fund Act (EWKFondsG) supplements the already existing Single-Use Plastic Prohibition Ordinance (EWKVerbotsV) and the Single-Use Plastic Labelling Ordinance (EWKKennzV) of 2021 and serves to implement the EU Single-Use Plastics Directive (EU 2019/904) of 5 June 2019, the aim of which is to reduce the impact of certain plastic products on the environment. 

It is aimed at all companies that make certain single-use plastics available on the market for the first time on a commercial basis in Germany or sell them directly from abroad by means of distance communication to private households or other users in Germany. 

From 1 January 2024, manufacturers of the single-use plastic products listed below will be required to register in advance with the Federal Environment Agency (UBA) in the future Single-Use Plastics Register and, depending on the type and mass of single-use plastic products made available or sold on the market for the first time in the respective preceding year, to make payments to the Single-use Plastic Fund from 2025 (cut-off date: 15 May). The amount of this so-called single-use plastic levy will be defined in the future Single-Use Plastic Fund Ordinance (EWKFondsV). 

Entitled public authorities and other legal persons under public law who wish to claim reimbursement of their collection, cleaning and sensitisation costs for single-use plastic waste are likewise required to register with the German Federal Environment Agency (Umweltbundesamt). The disbursement from the Single-Use Plastic Fund to those entitled to it is made on a calendar-year basis according to a points system. 

From 2025 onwards, it will be mandatory for foreign manufacturers without a branch in Germany to appoint an authorised representative before commencing their activities.  

Operators of electronic marketplaces and fulfilment service providers may only provide their services to registered manufacturers. 

Overview: List of single-use plastic products (Annex 1 EWKFondsG) 

  1. Food containers, i.e. containers, such as boxes with or without lids, for foodstuffs
    a. intended to be consumed immediately, either on the spot or as a take-away dish,
    b. are usually consumed out of the container
    c. without further preparation such as cooking, boiling or heating; beverage containers, beverage cups, plates as well as bags and film packaging, such as wrappers, with food content are not food containers in this sense;
  2. bags and film packaging made of flexible material, such as wrappers, with food content that is
    a. intended to be consumed directly from the bag or foil package, and
    b. do not require any further preparation;
  3. beverage containers with a filling volume of up to 3 litres, i.e. containers used to hold liquids, such as beverage bottles with and without containers and composite beverage containers, including their closures and lids; beverage containers made of glass or metal with closures, lids, labels, stickers or wrappings made of plastic are not beverage containers in this sense;
  4. beverage cups including their closures and lids;
  5. lightweight plastic carrier bags, i.e. plastic carrier bags with a wall thickness of less than 50 micrometres, with or without a handle, offered to consumers at the point of sale of the goods or products;
  6. Wet wipes, that is, soaked wipes for body and household care;
  7. balloons; except balloons for industrial or commercial use and applications not supplied to consumers;
  8. tobacco products with filters as well as filters intended for use in combination with tobacco products.  

From 2027, this list will be supplemented by fireworks. 

take-e-way will keep you further informed on the EWKFondsG. 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 for any questions you may have on packaging as contemplated by the German 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 or +49/40/75068730-0.

This is where you will find useful EPR services your sales via Amazon and similar providers.

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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