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Consultancy
Consultancy
Consultancy

Consultancy

At SUN REPACK we provide packaging consulting services to all associated companies as well as providing advice to independent companies that may have doubts or queries in this regard.

All of this, with the aim that all of them can comply with their obligations in accordance with current regulations.

Among the consulting services, we advise companies in the following areas:



1. Application of the non-reusable plastic tax



The Tax on non-reusable plastic containers is a tax of an indirect nature that falls on the use in Spanish territory of non-reusable containers that contain plastic, whether they are empty or presented containing, protecting, manipulating, distributing and presenting merchandise.

The scope of application of the tax is throughout the Spanish territory.

Specifically, the applicable tax rate is 0.45 euros per kilogram of non-recycled plastic contained in the products subject to the tax.

This is a tax that affects all companies that are dedicated to the manufacture, import, intra-community acquisition or irregular possession of products that are part of the objective scope.

From the beginning of 2024, kilograms of non-reusable plastic must be accredited by a certifying entity.



2. Packaging and packaging waste



After the entry into force of Law 7/2022 and RD 1055/2022, of December 27, on packaging and packaging waste, all companies considered as Producers must register in the Registry of Packaging and Waste Product Producers. Packaging from the Ministry of Ecological Transition and Demographic Challenge (MITERD).

The purpose of both regulations is to establish the legal regime applicable to packaging and packaging waste with the aim of preventing and reducing their impact on the environment throughout their entire life cycle.


WHO IS A PACKAGING PRODUCER?


• Packagers or economic agents dedicated to the import or acquisition in other Member States of the European Union of packaged products for placing on the market.

• When, in packaged products placed on the market through distribution brands, the producer of the product is not identified, the owner of the distribution brand based in Spain under which the product is marketed will act as such.

• Likewise, in the case of those products packaged on behalf of a third party who acts as responsible for placing them on the market, the latter will act as producer of the product.

• When packaged products from outside Spain are introduced into the market through electronic commerce platforms and the producer has not designated an authorized representative in accordance with the provisions of article 17.2, said platform will act, subsidiarily, as a product producer. for the purposes of the financial and information obligations, as well as organizational when applicable, regulated in this royal decree, with respect to these containers.


Product Producer Registry


At SUN REPACK we carry out the administrative management that consists of processing registration in the Product Producer Registry on behalf of the companies.

We also notify the communication data report to the Ministry within the established deadlines after reviewing that the data is correct and truthful. To make it easier for companies to know how to communicate, SUN REPACK holds specific webinars and has also developed a step-by-step explanatory guide to make it as simple as possible.


Ecodesign


The following regulations have recently been published regarding packaging and specifically ecological design:

- Regulation of the European Parliament and of the Council, on packaging and packaging waste, amending Regulation (EU) 2019/1020 and Directive (EU) 2019/904, and repealing Directive 94/62/EC .

- Regulation (EU) 2024/1781 of the European Parliament and of the Council, of 13 June 2024, establishing a framework for the establishment of eco-design requirements applicable to sustainable products, amending the Directive (EU) 2020/1828 and Regulation (EU) 2023/1542 and Directive 2009/125/EC is repealed.


This regulation is intended to ensure that manufacturing companies and those that buy from them commit to designing more durable, repairable and easy-to-manage products.

In view of the need posed by these regulations, at SUN REPACK we collaborate with technological centers and institutes specialized in packaging to provide a solution to companies in terms of the design of their products. All this, starting from the base model in which the aspects to improve are previously analyzed and measures are proposed to redesign the product so that it is more sustainable.

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