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.


WEEE, ElektroG & ElektroStoffV – Important information for our customers and members

take-e-way and VERE learned from some manufacturers that the Foundation EAR is planning to remove the LEDs from the collection group 4 (gas discharge lamps) and to assign them to the collection group 5 (small household appliances) this year.

Dear take-e-way customers, dear VERE e.V. members,

As we already reported to you a few weeks ago, the administrative practice for lamps was amended as of March 1st and with a transitional period as of September 1st, 2013 given by the Foundation EAR.

Since that time it is also necessary to register light sources (illuminants) with firmly connected luminaires (bodies, housings) provided that such illuminants are not equipped with a filament.

Against this background we learned from informed circles of the industry that illuminants (except for gas discharge lamps) with firmly connected luminaires shall be assigned to the collection group 5 (small household appliances); we are welcoming this fact. However, there will be no further differentiation between LEDs and gas discharge lamps (energy-saving lamps/fluorescent tubes) from the point of view of the industry in the future.

This will result in the fact that the environmental friendly LEDs will be collected together with the gas discharge lamps in the collection group 4 further on. We think that this practice is questionable since in this way the LEDs will not be rewarded for their environmental friendliness. Instead, they shall bear the considerably higher disposal and warranty cost of the gas discharge lamps which currently amount to € 1'300 instead of 119 Euros/t.

However, we learned from some manufacturers that the Foundation EAR is planning to remove the LEDs from the collection group 4 (gas discharge lamps) and to assign them to the collection group 5 (small household appliances) this year. In this way, the manufacturers of LEDs would also profit from the lower disposal and warranty cost of 119 Euros/t.

We expressively welcome this suggestion of the Foundation EAR and will energetically support the realization in the interest of our members in order to remedy the still existing disadvantage of manufacturers and distributors of LEDs as quickly as possible.

We will get in touch with you again as soon as specific innovations are available.

2) Implementation of the new WEEE directive

The amended WEEE directive which was passed in Brussels in 2012 provides that the number of appliance categories will be reduced from 10 to 6 categories from 2018 on.

We hope for your understanding that we inform you about this amendment already now. Since the option which seems to be a simplification at the first glance reveals to be a way with lots of obstacles when taking a closer look at it.

The most important factor is the differentiation indicated in the directive which distinguishes small appliances from large appliances according to their edge length.

Based on our information today's merchandise planning and control systems cannot process product parameters such as for instance the edge length.

Therefore, considerable additional investments in the field of EDP are to be expected for all concerned manufacturers.

Please inform us if you also encounter problems with this directive.

We will try to correct this directive which is stipulated in the European law in cooperation with the industry on the European scale.

If you need any further information, please do not hesitate to contact us.

3) ElektroStoffV (Ordinance on the restriction of the use of certain hazardous substances in electrical and electronic equipment)

As we already reported to you the ordinance on the restriction of the use of certain hazardous substances in electrical and electronic equipment (ElektroStoffV) was put into power on the 9th of May.

Several members contacted us on how the formal guidelines for the CE declaration of conformity will read.

After checking up with the Ministry of Environment we were informed that the implementation of this ordinance would be a matter of the individual state and that no corresponding form is available.

The VERE Association will now write to the federal states and ask them to make an agreed form available to you which you may also send to your suppliers.

Unfortunately it once again happened that legal ordinances were passed without providing the necessary tools to the concerned parties which would allow them to fulfill their obligations.

We hope that we will soon be able to support you and remain with

Kind regards,

Your team of take-e-way and the VERE Association

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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