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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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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trade-e-bility News and Press Releases

REACH: SVHC List of the ECHA extended yet again

On 19 January, the SVHC List (SVHC = Substances of Very High Concern) was extended by 2 candidates to a current total of 211. The SVHCs are governed by the REACH Regulation (EC) No. 1907/2006. Materials that the listed candidates contain must be reported to the purchasers of the materials. Since the beginning of the year, this notification has been mandatory throughout Europe via the ECHA’s SCIP database. The new SVHCs are used e.g. in Li-Ion battery technology (entry 210) or in adhesives (entry 211). Other uses are rather unspecific. Manufacturers or importers of products should evaluate the new candidates and decide whether a material analysis is required. In the event of a positive finding, an entry would then need to be made in the SCIP database. trade-e-bility can support manufacturers and importers of products in the EU in this regard.
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UK Declaration of Conformity & Marking

Since 1 January 2021, it has been possible for goods placed on the market in the United Kingdom (UK, comprising England, Scotland, Wales and Northern Ireland) and covered by certain product legislation to bear the UKCA mark (and from 1 January 2022, this will be mandatory). Persons with product responsibility should obtain information on the differences between UKCA and the EU CE legislation at an early stage; trade-e-bility can provide assistance with preparing the product documentation.
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REACH – EU project finds harmful substances in sports articles

The EU project AskREACH raises awareness of so-called “substances of very high concern” (SVHCs) in products amongst the general public, trade and industry circles throughout Europe. According to the German Federal Environment Agency, sports articles were tested for harmful substances via the project. 82 samples from 13 European countries were tested for SVHCs. These include some plasticizers, flame retardants, heavy metals and alkylphenols, amongst others. Products such as gymnastic balls, yoga mats, dumbbells, skipping ropes, swimming equipment, water bottles and gymnastic shoes were tested. Our recommendation: Obtain an overview of the chemical ingredients of your products in good time.
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Children’s masks must be free of toxic chemicals

Children also want to be protected in corona times. Poorly fitting FFP2 or medical masks often provide worse protection than specially adapted fabric masks (referred to as community masks). For masks made of textiles, however, care should be taken to avoid exposure to toxic chemicals; this applies in particular to children. Just last December, aniline was found in the dye of a community mask at a well-known drugstore chain. Anilin is considered carcinogenic and poses a great danger, especially to children. Our recommendation: The relevant safety standards should be observed in the manufacture of children’s masks and documented accordingly.
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Compliant sale of FFP2 masks

The “FFP2” label alone is not sufficient. In addition to the four-digit CE mark, the manufacturer’s address and all the contents required by the EN 149 standard must likewise be listed. Moreover, importers of FFP2 masks must ensure that there is adequate documentation for masks and that further information is provided in the instructions for use and on the packaging. trade-e-bility supports importers in compiling the documentation and in complying with the statutory requirements for product labelling.
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SCIP – more than five million notifications already received

The ECHA (European Chemicals Agency) reports that companies have already submitted more than five million notifications for inclusion in the database. The ECHA will start publishing the data on its website in the coming months, and this feature will be further developed. If you have Substances of Very High Concern (SVHCs) with a concentration above 0.1 mg/kg per material in your products, you are required to report this since 5 January 2021 by entering the concentrations, the components and the test documents in the new SCIP database. In Germany, at present there is only an informal obligation to report to the ECHA pursuant to Section 16f of the Chemicals Act (ChemG), which does not include the obligation to actually use the SCIP database. It remains to be seen how long this German path can be maintained. If you wish to set up your business in a future-proof way or sell your products to other EU countries, you will probably not be able to avoid using the SCIP database.
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EPREL – Energy labels must be replaced by 18 March 2021

In the first two weeks of March (1 – 18 March 2021), retailers must replace labels for mains operated refrigerators with direct sales function, mains operated refrigerators between 10 and 1500 litres in volume, mains operated household dishwashers, television sets, monitors, certain signage displays, washing machines and washer-dryers. This concerns both the products in shops and products offered on the Internet. Before that, only old energy labels may be shown, and afterwards only new ones. Missing labels must be requested from the relevant suppliers. If there is no new label, then the equipment affected must be sold off by 1 December 2021. Please bear in mind that the new labels must have corresponding test reports that must be placed in the EPREL database. If these are lacking, then new labelling is not possible. Preparing a test report is time-consuming, so please act promptly.
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SCIP: As of 5 January 2021 articles containing SVHC must be reported

If you have Substances of Very High Concern (SVHCs) with a concentration above 0.1 g/kg per material in your products, you are required to report this as of 5 January 2021 by entering the concentrations, the components and the test documents in the new SCIP database. In Germany, at present there is only an informal obligation to report to the ECHA, the European Chemicals Agency, pursuant to Section 16f of the Chemicals Act (ChemG), which does not include the obligation to actually use the SCIP database. It remains to be seen how long this German path can be maintained. If you wish to set up your business in a future-proof way or sell your products to other EU countries, you will probably not be able to avoid using the SCIP database.
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SCIP database already contains 50,000 notifications

As reported by our partner VFI/German Importers, the SCIP database already contains more than 50,000 notifications one month after activation. Seven per cent of attempted registrations in the database are reported to have been unsuccessful due to the validation rules. These included e.g. multiple filings of a product by the same company or attempted registrations of companies outside the European Union.
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SCIP – public authorities can see that your products contain SVHCs

Are your products SVHC-free? You will only know this once you have valid test documents in hand. However, many products can already be seen to contain SVHCs. The new transparency of the publicly accessible SCIP database is a real invitation to establish whether such products are on record in the database. Both market participants and regulatory authorities can give you cause for concern when you take this path.
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