Articles · 2026-09-15
Spain: the packaging tax is not the Ecoembes fee
Spain has two packaging obligations: the RPP register with a scheme, and a plastic tax at 0.45 €/kg collected by the tax authority. They are not the same.
A questionnaire arrives from a Spanish customer and asks for your EPR number. You register, you join a scheme, you send the number back. Then someone mentions a tax, and it is not the scheme fee.
Spain runs two separate packaging obligations, with two authorities, two registrations and two returns. Almost every summary describes one of them and calls it compliance.
Do I have to register in Spain if I sell to a Spanish distributor?
Often not. MITECO limits the foreign producer duty, and the authorised representative that goes with it, to first placing direct to end users. If you sell to a Spanish importer, an intra-EU acquirer or a distributor, that Spanish party is the producer and registers.
This is worth checking rather than assuming, because the broad reading — that any foreign seller needs a representative in Spain — is repeated widely, and mostly by firms that sell exactly that service. Our Spain country page records both readings and names the source of each.
What is the RPP, and what number does it give me?
The Registro de Productores de Producto, sección envases, at MITECO. Registration comes first and is separate from joining a scheme. You receive a number in the form ENV/YEAR/number, and it must appear on invoices and on any document 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.
Is the plastic tax the same as the Ecoembes fee?
No. The impuesto especial sobre los envases de plástico no reutilizables comes from Ley 7/2022 and is collected by the tax authority, not by a scheme. The rate is 0.45 € per kilogram of non-recycled plastic, the return is modelo 592, and it has its own registration. An answer in which Ecoembes is the whole story has lost one of the two obligations.
Who actually pays it?
Manufacturers in Spain, importers from outside the EU, and intra-EU acquirers. There is a threshold: acquisitions and imports under 5 kg of non-recycled plastic in a month are outside it.
Note who that usually is. A producer established elsewhere in the EU is frequently not the taxpayer — the Spanish buyer is the intra-EU acquirer — while the packaging obligations follow a different line entirely. Two obligations, two answers, and they do not have to land on the same company.
How do I prove recycled content for the tax?
With a certificate, not a sentence. The recycled share is exempt only where a body accredited by ENAC has certified it under UNE-EN 15343:2008. A self-declaration is not accepted. A supplier writing "recycled cardboard" in an email is not evidence, and neither is a claim with no certificate number behind it.
When do I declare, and to whom?
To MITECO, for the previous calendar year. The window for 2026 data runs from 2 January to 31 March 2027, inclusive, and missing it is an administrative infraction under article 108 of Ley 7/2022. The scheme declaration is separate and has its own deadline. Your scheme membership certificate has to be filed in the register within one month of signing, and the scheme must be authorised for that packaging category.
Does this cover commercial and industrial packaging?
Yes, and it has since 31 December 2024 — transitional provision three of RD 1055/2022. Pallets, crates and stretch wrap are not outside the system because nobody takes them home.
What a spreadsheet cannot do here
A spreadsheet will hold the kilograms. It will not tell you that the weight in row 12 was measured and the weight in row 13 was estimated. It will not keep the certificate number that made a recycled percentage true, or notice that the certificate expired. It will not remember which supplier answered, when, and in which words. And when the tax return and the scheme declaration disagree, it cannot show you why, because it never kept the reason.
None of that is the spreadsheet's fault. It is a tool without a memory, and Spain asks two authorities the same question in two different shapes.
What Tarafex does about it
One row per component, with the weight frozen on the line the day you ship it, so a figure on a return still matches the document behind it a year later. The recycled share on a weight basis, with the component that nobody answered named rather than counted as zero. The supplier answers through a link with no account and no password, and the answer is kept with a name and a date on it. Kilograms per country, from the shipments you already recorded.
What it does not do: it does not register you, it does not calculate the money, and it will not tick a box you have not answered. Where we do not know, the page says so.
Spain, Denmark and Latvia are the next three country pages under review.
Sources: Tarafex country table; Spain: MITECO, MITECO FAQ, Agencia Tributaria, Ley 7/2022, RD 1055/2022. Checked 15 September 2026. This is information, not legal advice.