Green Dot Compliance Requirements for Packaging Labeling in Spain
Green Dot compliance requirements in Spain – 5th April 2023 update:
Movements towards the prohibition of misleading symbols on packaging have gained momentum across Europe and in many instances may signify the eventual ban of the Green Dot (an EPR symbol denoting the payment of waste recovery fees) in its current form.
Despite Spain becoming the last EU country to make the Green Dot symbol voluntary, it has not expressly clarified whether the symbol is actually prohibited. In order to ascertain whether the Green Dot will become prohibited rather than voluntary in Spain under Article 21.4 of the Decree, which prohibits EPR symbols that may mislead consumers about a package’s recyclability- Compliance and Risks contacted the Spanish authorities for further information.
Subsequently, the Spanish General Sub-Directorate of Circular Economy responded as follows;
“Considering Article 21.4, which regulates general obligations for extended producer responsibility systems and the measure requiring extended producer responsibility symbols be “clear and unequivocal and not misleading to consumers or users on the recyclability of packaging”, the General Subdirectorate considers that the “Green Dot” symbol can mislead consumers or users about the recyclability of the containers, and in their opinion, the systems who currently use this symbol, should replace it when they submit their request for authorization in accordance with Royal Decree 1055/2022.”
Packaging Labelling Legislation in Europe: A 2023 Regulatory Update
In recent years packaging labelling practices across Europe have undergone dramatic changes, leading to a growing lack of legislative harmony and disruption to market access.
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Green Dot compliance requirements in Spain – 21st October 2021 update:
On 28 September 2021, Spain announced a far reaching Draft Packaging and Packaging Waste Decree to further the development of a circular economy for packaging. Despite the scale of the proposal it remained ambiguous as to whether the use of the Green Dot label (el punto verde) would remain mandatory in Spain.
Compliance & Risks contacted the Spanish authorities for clarity on the status of the Green Dot under the current proposal, and has been informed by the Spanish Subdirectorate General for Circular Economy that the current Draft does not require the mandatory use of the Green Dot label on packaging. However, extended producer responsibility (EPR) schemes such as Ecoembes and Ecovidrio may still request the use of markings on packaging to denote EPR membership.
Although EPR schemes may request the use of packaging labels to symbolize the payment of EPR fees etc. on packaging, the Subdirectorate has stated that this symbol does not have to be the Green Dot label, as it misleads consumers on the recyclability of packaging. Note that Article 21 of the Draft stipulates that EPR symbols must be clear and unambiguous and must not mislead consumers or users about the recyclability of packaging.
The Subdirectorate also clarified that the Draft may be subject to further modification. The deadline for the submission of comments is 28 October 2021 and comments may be submitted via email to firstname.lastname@example.org
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