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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Obligation to provide proof for transport packaging

From 1 January 2022 onwards, producers of transport packaging have also been required to be able to provide proof that the take-back and recovery requirements have been fulfilled. Until that date, only packaging items subject to mandatory system participation and packaging with hazardous fillers were subject to this obligation, but now it has been expanded to include all packaging types.

By 15 May each year, all packaging which has been put on the market, returned and recycled must be documented in verifiable form and submitted to the federal state authorities where requested.

Suitable self-monitoring measures must be set up. The documents do not require uploading (e.g. to the packaging register), but rather must be kept ready to be shown to the correct authorities upon request.

What are “suitable self-monitoring measures”? (the following is for illustrative purposes only and does not represent all the possible measures)

  • Prepare company guidelines and check regularly they are being complied with (e.g. “We have defined a series of guidelines and objectives, and provide regular feedback on compliance with them”.)
  • Independent actions
  • Regular information on the areas involved
  • Active inclusion of all stakeholders
  • Understandable, clear communication

Our take-e-way services for your transport packaging

Are you a producer who regularly puts the packaging on the market? take-e-way provides expert solutions:

  • take-e-way can provide support with take-back and reporting obligations, as well as mandatory registration and the obligation to provide proof.
  • Simple, secure reporting in conformity with the law for all products brought to market via the take-e-way customer portal
  • Cost-efficient compliance with the legal regulations of the German Packaging Act
  • Reporting for all volumes of packaging, electrical equipment and batteries in Germany and the EU as a whole in an online portal
  • Comprehensive advice on the classification of packaging, recycling-friendly packaging, etc.

Request information on transport packaging according to the German Packaging Act

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