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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WEEE: The German Electrical and Electronic Equipment Act (ElektroG)

The WEEE is the regulation of the European parliament and the council over electric and electronic devices. Amongst others, they say that the producers and quasi producers of electric and electronic devices have to take back old devices in the scope of product responsibility and carry out disposal or recycling of them.

The return and recycling responsibility of the producers are carried out through the national conversion, the Electrical and Electronic Equipment Act (ElektroG) of the EU regulation (WEEE) which are controlled and steered through a central coordination centre. The taking over of the end users old equipment will probably be carried out through a communal collection of electronic scrap by the respective public waste disposal authorities. The collected old equipment is then prepared for collection by the producers at a certain transfer location, which is determined by the communities. Herewith, the producers are informed of the transfer location for the old devices (collecting point of the community) through the coordination centre (EAR), according to a system which still has to be described and is undefined (probably the coincidence principle). All other organisational interests are obligations of the producers.

The scale of frequency for the collection and disposal contracts for the individual market placement of electric and electronic devices is based on the share of the inner German market. For example, if the producer has a market share of 2 % , then he/she becomes an assignment relationship of 2 % collection and disposal contracts inside the Federal Republic of Germany.

Additionally, every individual producer is obliged to take back a certain amount of old and orphan* devices according to their market share independent on whether the device originates from their production or import.

*One speaks of orphan devices if the producer does not exist any more or is not able to be identified.

CONTACT

take-e-way GmbH
Schlossstr. 8 d-e
22041 Hamburg
Germany

Phone: +49 40 750687 - 0
E-Mail: beratung@take-e-way.de

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