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.

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.

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.


B2B take-back obligation, take-back concept and information obligation under Section 7a ElektroG3

Under the German Electrical and Electronic Equipment Act (ElektroG3) to be amended on 01/01/2022, producers of B2B equipment will be obliged in the course of registration to submit a take-back concept (cf. Section 7a ElektroG3) to the EAR foundation (Stiftung Elektro-Altgeräte Register) and also to inform the users of their equipment about the disposal channels set up.

For registrations already existing on 01/01/2022, this concept will need to be subsequently submitted by 30/06/2022.

This regulation was drawn up in order to specify the take-back obligations of the producers of B2B equipment under Section 19 ElektroG and to encourage the producers to deal with their take-back obligation.

The good news is that take-e-way has created such a take-back concept and will make it available to its customers within the framework of the existing B2B contracts without any additional costs. take-e-way customers will receive more detailed information in this regard.

Are you not a take-e-way customer? Then feel free to subscribe to our newsletter for more information.

Should you need such a solution for an existing registration or if you wish to newly register: We have prepared everything for you.

This is how it works: Your customer or owner of one of your products can conveniently complete an online questionnaire which will determine the costs for collection. After approval, the devices are collected, professionally recycled and the quantities reported to the EAR foundation.

Section 7a ElektroG
“(1) Every producer or, in the case of authorisation under Section 8, every authorised representative, is obliged to submit to the competent authority a take-back concept for the take-back and disposal of electrical or electronic equipment in respect of which the person in question can satisfy himself or herself that the equipment is used exclusively in households other than private households or that such equipment is not normally used in private households.
(2) The take-back concept must contain the following information, depending on each type of equipment:

  1. a declaration that the producer or, in the case of an authorisation under Section 8, the authorised representative has set up return possibilities that meet the requirements Section 19 (1) sentence 1.
  2. in the event that a third party is commissioned: name and address of such third party,
  3. the possibility for end-users to access the return possibilities referred to in point 1.

(3) Changes to the take-back system must be reported to the competent authority without delay by the producer or, in the case of authorisation under Section 8, by the authorised representative.”

Section 19
“(1) Every producer or, in the case of authorisation under Section 8, every authorised representative shall be obliged to provide a reasonable possibility for the return of electrical or electronic equipment from users other than private households as from the dates referred to in Section 3 item 4 [...].”

Section 19a
“Every producer or, in the case of authorisation under Section 8, every authorised representative must inform the end-users of electrical or electronic equipment from users other than private households of the obligations under Section 10 (1). The person in question must also inform end-users of

  1. the possibilities it has created for the return and disposal of waste equipment,
  2. the end-users’ own responsibility with regard to the erasure of personal data on the waste equipment to be disposed of, and
  3. the meaning of the symbol shown in Annex 3.”
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