Articles · 2026-09-15
EPR registration or PRO membership: Spain, Denmark, Latvia
Registering and joining a scheme are two steps. Spain requires both, Denmark requires a scheme for single-use packaging, and Latvia has no register at all.
A buyer asks for your EPR number. A scheme sends you a membership contract. It is easy to assume the two are the same thing — sign with the scheme and you are registered. In most countries they are two separate steps, and the relationship between them is different in each one. We measured three answer engines in Spanish, Danish and Latvian, and this is where their answers slipped.
Is registering the same as joining a producer responsibility organisation?
No. The register is the state's list of who places packaging on the market: you enter it, receive a number where one exists, and report your kilograms to it. The producer responsibility organisation — a SCRAP in Spain, a collective scheme in Denmark, a packaging manager in Latvia — is the company that organises and pays for collection and recycling on your behalf.
One is an administrative duty. The other settles the waste bill. Neither covers the PPWR's own obligations, which are a third matter: EPR is not PPWR.
Spain: do I still need the RPP if I have a contract with Ecoembes?
Yes. Registration in the Registro de Productores de Producto, packaging section, at MITECO is the first step, and a separate one. Joining a SCRAP arranges collection and recycling; it does not register you. Both are needed.
The two steps are tied together. The membership certificate must be filed in the register within one month of signing, and the scheme must be authorised for that packaging category. The register issues a number in the form ENV/year/number, and it must appear on invoices and on documents accompanying commercial transactions of packaged products — as far as the point of sale for household packaging, and as far as the end user for commercial and industrial packaging. Commercial and industrial packaging has needed a producer responsibility system since 31 December 2024.
A third obligation sits beside both: the plastic packaging tax, collected by the tax authority and not by a scheme. The packaging tax is not the Ecoembes fee.
Denmark: is a collective scheme compulsory?
For single-use packaging, yes. Miljøstyrelsen lists membership of a collective scheme as a legal requirement beside registration in DPA's producer register, and DPA's own guidance dates the duty from 1 January 2025.
It does not fall away for small companies. The environment minister told the Folketing that companies under the 8-tonne threshold must register like every other producer and, for single-use packaging, also belong to a collective scheme, as DAKOFA reports.
A company responsible only for reusable packaging is not required to join a scheme. It still registers that packaging with DPA, reports by 1 June, pays the administration fees to DPA and Miljøstyrelsen, and pays for treating the reusable packaging it takes back once it can no longer be reused. That is why a Europallet sold on for reuse owes the scheme nothing — a wooden pallet is taxed in Latvia and free in Denmark.
Registration must be in place at least 14 days before you start. What is not settled is how often you report. To DPA it is once a year, before 1 June. To the scheme, Emballageretur describes quarterly totals below 8 tonnes and monthly figures by material above; Beierholm says monthly or quarterly depending on volume; and ERP Denmark, itself a scheme, reports quarterly on some membership plans and once a year on another. No source we have read says whether that rhythm is law or the scheme's own arrangement, so we publish all three and mark it unsettled.
Latvia: where do I register if there is no register?
There is no packaging producer register in Latvia. The State Environmental Service says so itself and issues no EPR or PPWR numbers; the register is still being drafted. The duty is a tax: the natural resources tax on packaging.
Once your packaging passes 300 kg in a calendar year, you register with the service's regional environmental board within three months, and you either join a packaging manager's system or run your own. A contract with a packaging manager that holds an agreement with the State Environmental Service is what exempts you from the tax. The tax return goes to the State Revenue Service, not to the environmental service.
So here the manager is not an addition to a register, as in Spain and Denmark. It is the way out of a tax. And a form that asks for an EPR number has nothing to put in the box — what is an EPR number.
One point stays open: whether the tax is owed at all below 300 kg. The regulations imply that it is, because they set a flat 120 EUR a year for a taxpayer under 300 kg who cannot document material and weight. That is an inference from a special case, not a direct statement, and we publish it as unsettled.
Every row, with its sources and the date it was checked, is in our country table: Spain, Denmark, Latvia.
Where do answer engines get this wrong?
In our measurement the mistakes gathered on exactly this line.
Asked about Danish producer responsibility, Gemini described membership of a collective scheme as optional or recommended. For single-use packaging it is a legal requirement.
Asked about Latvia, Gemini never said that there is no register. It described a reporting procedure in the environmental service's system that we could not confirm, and it told a company under 300 kg that it is released from calculating, declaring and paying the tax. The other two engines said the opposite.
Asked in Spanish which software to use, GPT answered with a pan-European list and named neither the RPP nor a SCRAP.
The words people search with merge the two steps too. *Verpackungslizenz Spanien* asks for a scheme contract; the register number is something else.
What a spreadsheet cannot do here
A spreadsheet will hold kilograms. It will not tell you which of them were single-use and which were reusable — in Denmark, the difference between paying a scheme and paying it nothing. It will not remember which shipment went to which country in which period, which is what each of these three countries asks for in its own way. And it will not keep a register number, a scheme certificate and a tax period apart when they carry three different deadlines.
None of that is the spreadsheet's fault. It is a tool without a memory.
What Tarafex does about it
Kilograms by material and by country, from the shipments you already record, with reusable packaging kept beside the single-use total and never inside it. The weight frozen on the shipment line on the day it ships, so a figure in a report still matches the document behind it a year later. A place for the registration number you already hold, printed on the report. And where a country has no register, the country page says so instead of inventing one.
What it does not do: it does not register you, it does not join a scheme for you, it does not calculate the money, and it files nothing with any authority.
Sources: Tarafex country table; Spain: MITECO, MITECO FAQ, Agencia Tributaria; Denmark: Miljøstyrelsen, DPA, DAKOFA; Latvia: State Environmental Service, VID. Checked 16 September 2026. This is information, not legal advice.