In this edition, we continue to offer our subscribers specialized information on EPR compliance.
If you have any questions, our experts are available for personal consultation.
Today's topics at a glance
Spain: Labelling Requirement for Packaging from 2025
Germany: Single-Use Plastics Fund Act
EU: EU Battery Regulation: New Obligations from August 2024
EU: The Digital Product Passport
EU: New Energy Label for Smartphones and Tablets from 2025
Webinar Invitation
Fresh Up - Reminders / Dates
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Deutsche Recycling
Spain: Labelling Requirement for
Packaging from 2025
Since 28 December 2022, new regulations on packaging law have been in force in Spain, known as the "Royal Decree on Packaging and Packaging Waste".
Labelling will be mandatory from January 2025. All packaging must be clearly and legibly labelled with a pictogram indicating the intended disposal container.
What do companies have to do?
In addition to these new obligations, the following regulations will apply from 2023:
Registration obligation: Manufacturers must register in the packaging register and register the packaging placed on the market (household, commercial, trade and industrial packaging).
Licensing requirement: A packaging licence is required for household packaging placed on the market. From 2025, the licensing requirement will be extended to commercial and industrial packaging.
Recycling organisation: Companies that sell household packaging must already join waste management organisations.
NIF number: The Spanish Ministry of the Environment requires foreign companies that are subject to registration in the packaging register to have a Spanish tax number for non-resident companies. This number is known as the NIF number. A foreign VAT ID is therefore not accepted by the Spanish authorities.
Non-resident companies in Spain must provide a Spanish Tax Identification Number (NIF=Número de Identificación Fiscal). This requirement is an important prerequisite for smooth business operations in Spain.
Deutsche Recycling offers you a full-service packagefor this. You will receive your NIF number with us in no time.
The Single-Use Plastics Fund Act (EWKFondsG) and the Single-Use Plastics Fund Ordinance (EWKFondsV) have been in force since 1 January 2024.
The EWKFondsG obliges manufacturers of single-use plastics to pay a levy. This levy is used to cover the costs of collecting and disposing of single-use plastics in public areas. This relieves the financial burden on public waste disposal organisations.
In addition, the EWKFondsV specifies how high these levy rates are and how the payment system for the fund works.
What manufacturers must do!
Registration: Manufacturers who started their activities before 1 January 2024 must register on DIVID, theGerman Environment Agency's single-use plastic fund platform, by 31 December 2024.
Foreign companies that supply their products directly to private or commercial users in Germany must also register. From 2025, they must appoint an authorised representative to fulfil their obligations.
Reporting: Manufacturers of single-use plastics must report their quantities annually by 15 May (for the first time in 2025).
Watch out online retailers!
From 1 January 2025, the operators of electronic marketplaces and fulfilment service providers will also be explicitly held responsible.
Operators of electronic marketplaces (such as Amazon or eBay) and fulfilment service providers may not offer single-use plastic products from manufacturers that are not registered in the Single-Use Plastic Fund. This means that only registered manufacturers may sell their products on these platforms.
Sanctions for non-registered manufacturers
Ban on offering: From 1 January 2025, single-use plastic products may only be offered if the manufacturer is registered in the Single-Use Plastic Fund.
Fines: If a manufacturer offers its products without registration, it may face a fine of up to 100,000 euros.
Anti-competitive behaviour: A violation of this regulation is considered anti-competitive.
If you are unsure what obligations your company faces or need support in complying with the EWKFondsG, Deutsche Recycling Service GmbH is a trustworthy partner at your side.
Click on the button below now to make a free enquiry and receive support.
The new Battery Regulation has been in force throughout the EU since 18 February 2024.
New obligations will come into force for battery producers, importers and distributors from 18 August. Here are some of the most important changes.
The new obligations for producers
Conformity assessment: Producers must ensure that their batteries have undergone a conformity assessment procedure and have an EU declaration of conformity.
CE labelling: Batteries must be CE-labelled.
Labelling: Batteries must be labelled with model identification, batch number and producer identification (name, trademark, postal address).
Operating instructions and safety instructions: These must accompany the batteries.
The new obligations for importers
Control obligations: Importers must ensure that the batteries have the required conformity assessments and labelling.
Importer labelling: Importers must affix their own details (name, address) to the batteries if the producer is located outside the EU.
Retention of documentation: Importers must retain relevant documents and be able to present them if required.
Remedial action/recalls: Importers must take action if batteries do not meet the requirements.
The new obligations for distributors:
Inspection obligations: Distributors must ensure that batteries are correctly labelled and have the required conformity assessments.
Sales bans: Retailers must not sell batteries that do not comply with the regulations.
Duty to co-operate: Retailers must co-operate with the authorities and other market players to ensure compliance.
Talk with an Expert
Are you a producer, importer or distributor of batteries and have questions about the new obligations?
Do you need support in complying with the EU Battery Regulation?
We will be happy to help you. Simply get in touch with us by e-mail, contact form or telephone. We will answer your enquiry within 24 hours.
The digital product passport (DPP) is a digital identity of a physical product. It contains all relevant information about the product, from its origin and composition to its entire life cycle.
What information should be provided?
The DPP should contain comprehensive information about the product, including its components, materials, ingredients and, where applicable, chemical substances. In addition, the DPP provides information on the reparability, spare parts and proper disposal of the product.
The information in the EU product passport varies depending on the product. A product passport is already known from the amendments to the EU Battery Regulation 2023. Information on the capacity, performance, service life and chemical composition of the battery must be available via the QR code. Similar to the battery passport, the EU's digital product passport sets out product-specific obligations that determine what information manufacturers must provide.
The digital product passport is to be gradually introduced into the economy. It is currently planned that the obligation will initially be extended to textiles, cars and electrical appliances from 2026. From 2027, it will be mandatory for all products imported into the EU.
Find out more about the digital product passport in our blog article:
It's important for your company to prepare for the upcoming changes now. Our experts will be happy to help you if you need support. Click on the button below now to make a free enquiry.
EU: New Energy Label for Smartphones and Tablets from 2025
From 2025, a new energy label for smartphones and tablets will be introduced in the EU, which will include a reparability index. This label rates the repairability of devices on a scale from A to E and is intended to help consumers make informed purchasing decisions.
Extensive standardisation work is required to implement the new EU directive. Technical consultations have begun and the first results are expected in the course of 2024. The aim of this work is to standardise the assessment of reparability.
Objectives of the new label
The new energy label is intended to provide consumers with clear information on the repairability of appliances, which can help them choose more durable products. This could also increase the demand for easily repairable appliances and encourage manufacturers to improve repairability.
A step towards more sustainable consumption
The label is part of the EU strategy to promote sustainable consumption habits and support the circular economy. It enables greater transparency and supports consumers in making environmentally conscious purchasing decisions. From 2025, the label will be introduced on the market, which will potentially shift the focus towards more durable, repair-friendly products.
Deutsche Recycling offers a legal monitoring service that provides relevant information and supports implementation. Our advisory team is available to answer any questions.
We cordially invite you to our exclusive webinar "New EPR regulations in the EU" on Tuesday, September 10, 2024 at 10:30. In this webinar, our expert Rolf Andreas will specifically address our English-speaking audience and provide valuable information on complying with EPR guidelines and the new regulations.
Denmark - EPR packaging: As an obligated company for the EPR in Denmark, you must report your planned packaging consumption by 30 September 2024 at the latest.
Germany - Single-Use Plastics Fund Act: In accordance with the Single-Use Plastics Fund Act, foreign companies that supply their products directly to private or commercial users in Germany have been able to register on the DIVID platform since the beginning of August.
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