Spain: Extended Producer Responsibility (EPR)

On March 31, 2022, the Spanish Parliament subsequently approved the new waste law which explains how producers ought to take financial and/or financial and organizational responsibility for their waste.

In Spain, a legislative concept known as extended producer responsibility (EPR) strives to lay on producers’ control for managing post-consumer products in lieu of consumers and communities.

The legal framework for EPR is established under Law 22/2011, of July 28, as well as the Royal Decree 110/2015, of February 20.

Who is considered responsible?

• Producer of the product.
• If the product is not produced in Spain, the organization that sells the product for the first time in Spain.
• The same as above is true for a product that is imported as an e-commerce service into the country.

What products are involved?

• EPR obligations include products under the following.
• Light packaging and paper cardboard.
• Glass containers.
• Packaging of agricultural products.
• Packaging of phytosanitary products and fertilizers.
• Packaging of medicines and expired medicines.
• Batteries and accumulators.
• Out-of-use tires.
• Used industrial oils.
• Waste electrical and electronic equipment.

Thresholds

There are no thresholds.

Producers’ obligations for EPR

1. Register on the public product producer register in the Spanish Ministry of Ecological Transition and Demographic Challenge (MITECO) to get EPR number.
2. Enter into an agreement with one of the approved Producer Responsibility Organizations (eco-operators).
3. Pay periodic fees to the eco-operator according to their tariffs and waste volume (license fee).
4. Submit reports on amount of packaging placed on the market for each production year.

Authorized representative

Foreign companies need authorized representatives to register for EPR registration on some categories, for example, for EEE.

Reporting Deadline

• Until 31.07.2023 – for the reporting year 2021.
• Until 31.10.2023 – for the reporting year 2022.

Read more about the EPR in Spain here.