Spain · Packaging EPR · Launching

Spain EPR for sellers placing packaged goods on the market

Spain operates a packaging producer register and extended producer responsibility duties under Royal Decree 1055/2022, now read together with Regulation (EU) 2025/40. Distance sellers without a Spanish establishment are a common case.

This page is for orientation. It is not a determination of your legal status and not legal advice.

Who this can affect

Royal Decree 1055/2022 sets information and EPR duties on producers of packaged products placed on the Spanish market, covering household, commercial and industrial packaging. Online shops can be affected even if the company sits outside Spain, including sellers in Germany, the UK, the US or Latin America who ship directly to Spanish end users.

Article 17.2 of the decree requires producers established in another Member State or in a third country who market products in Spain to appoint a natural or legal person in Spain as authorised representative. If no representative is appointed, the first distributor or trader established in Spain is subsidiarily responsible.

Foreign distance sellers

MITECO’s current register guidance focuses the authorised-representative duty on operators established abroad who place packaged products on the Spanish market for the first time directly to end users. If the manufacturer already has a Spanish subsidiary, MITECO says a separate authorised representative is not needed in the same way, because the subsidiary’s electronic representative already appears in the procedure.

Online platforms that enable distance contracts with such producers have their own checks under Regulation (EU) 2025/40, including producer registration information and, where relevant, confirmation that an authorised representative has been appointed.

Producer registration

Producers or authorised representatives (in the Article 17.2 case) register in the packaging section of the Registro de Productores de Producto (RPP), operated by MITECO. The application identifies packaging categories and the EPR system the producer belongs to. Collective systems require a membership certificate. After signature, the procedure assigns a register number in the form ENV/YEAR/XXXXXXXXX, which must appear on invoices and related commercial documents.

SCRAP / EPR system membership and annual reporting

Producers fulfil certain duties through individual or collective producer responsibility systems (SRAP / SCRAP). MITECO publishes authorised collective systems by packaging category. Registration in the RPP and participation in a producer responsibility system are related but distinct. EPRGo does not treat SCRAP fees, eco-contributions or similar scheme charges as part of the EPRGo country service price. Article 16 of Royal Decree 1055/2022 requires the previous year’s packaging data to be sent to the ministry before 31 March of the following year. A simplified route exists for producers placing less than 15 tonnes of packaging on the market in a year. Because Regulation (EU) 2025/40 applies from 12 August 2026, MITECO has published specific 2026 reporting splits; merchants should follow the ministry’s current note rather than a generic calendar assumption.

Role of the local partner

The Spanish partner is the in-country operator for authorised representation where required, RPP filings, SCRAP membership mechanics and annual reporting. MITECO also notes that, in Spain, collective systems are not expected to perform those register acts without a prior power of attorney from the producer.

Role of EPRGo

EPRGo supplies the shop connection, destination-country workflow and a single merchant view across Spain, Germany and later markets. It coordinates; it does not replace Spanish authorities or invent a one-click legal status.

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