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Packaging EPR in Spain

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Checked 2026-09-14 · 3 sources · 1 open question

Register
Registro de Productores de Producto (RPP), sección envases — code ENV/YEAR/counter
Authority
MITECO — Subdirección General de Residuos
Law
Real Decreto 1055/2022, art. 15 y 17.2; register created by RD 293/2018registration in the RPP is the FIRST step and is separate from joining a SCRAP — the register is the administrative duty, the SCRAP does the collection and recycling. Both are needed. A producer may empower another entity to do the registration and the annual report on its behalf. Sede electrónica procedure codes: 1523222 registration, 2945277 annual declaration. The register issues a number that 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. A second and separate obligation sits beside EPR: the impuesto especial sobre los envases de plástico no reutilizables (Ley 7/2022), collected by the tax authority and not by a scheme, at 0.45 € per kilogram of non-recycled plastic, declared on modelo 592 and with its own registration. It is owed by manufacturers in Spain, importers from outside the EU and intra-EU acquirers, with a threshold of 5 kg of non-recycled plastic a month. Recycled content is exempt only where an ENAC-accredited body has certified it under UNE-EN 15343:2008; a self-declaration is not accepted.
Who registers
Whoever first places packaging on that market, foreign sellers included
Threshold
15 t a yearNOT an exemption — it is the line for the simplified annual declaration (Declaración Simplificada) instead of the general one. Registration is required regardless.
Authorised representative
Only for distance selling to consumersrepresentante autorizado in Spain — MITECO limits this to first placing direct to end users. Sell to a Spanish importer, intra-EU acquirer or distributor and that Spanish party is the producer instead. Not needed if the producer already has a Spanish subsidiary. Sources disagree here: the broad reading, that any foreign seller needs a representative, comes mainly from firms that sell the service.
Reporting
Annual declarationtwo procedures: Declaración General, or Declaración Simplificada for three cases — under 15 t a year, e-commerce platforms placing foreign packaged goods where the producer named no representative, and the first distributor. The window for 2026 data is 2 January to 31 March 2027 inclusive, and missing it is an administrative infraction under article 108 of Ley 7/2022. MITECO says the 2026 report carries particularities because Regulation (EU) 2025/40 applies from 12 August 2026.
Also required
Membership of a SCRAP
Household packaging schemes
Ecoembes (handles most household and commercial packaging waste, except glass packaging), Procircular (handles household, commercial and industrial packaging), and Ecovidrio (handles glass packaging only).
Industrial packaging schemes
A producer responsibility system, individual or collective, has been required for commercial and industrial packaging since 31 December 2024 (RD 1055/2022, transitional provision three). MITECO publishes which schemes are authorised for each packaging category. The membership certificate must be filed in the register within one month of signing, and the scheme must be authorised for that category; an adhesion made indirectly through a one-stop-shop service counts the same.

What is not settled

The same in every EU country

Sources

Countries with the same answer

We do not register you, we are not your authorised representative, and we do not pay a scheme. This is public information gathered in one place and checked on the date shown. Confirm with the national authority before acting.

Tarafex

The number these registers ask for is kilograms by material for one year of deliveries. If your shipments are recorded as they go out, that number already exists.

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