Spain EPR Guide | Lovat Compliance

Packaging

Extended Producer Responsibility (EPR) for packaging in Spain

Spanish Royal Decree 1055/2022 of 27 December on packaging and packaging waste establishes a number of obligations related to the obligations of product producers.

The requirements of the decree come into force on March 27, 2023.

Who is considered responsible?

Producers are considered responsible for packaging in Spain.

Producers of packaging mean buyers or economic agents engaged in importing or purchasing in other countries of the European Union, supplying packaging for sale on the Spanish market.

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What do you mean by packaging?

Any product made from materials of any nature and used for the storage, protection, processing, distribution and presentation of goods, from raw materials to finished products, at any stage of the chain of production, distribution and consumption; will be considered packaging. All disposable items used for the same purpose will also be considered packaging.

Thresholds

There are no thresholds.

Registration procedure

In order to register for an EPR number, producer should follow these steps:

Register for a Spanish NIF tax number if the company does not already have one.
Register with one of the approved Producer Responsibility Organization (PRO) and obtain a membership certificate.
The PRO chosen by the company will help with the registration of manufacturers with the Ministry of Environmental Transition and Demographic Challenges of Spain (MITECO), which subsequently issues the EPR number.
Pay periodic payments to the eco-operator according to its tariffs and waste volumes (license fee).
Submit reports on the amount of packaging placed on the market for each year of production.

Autorized representative

Foreign companies need authorized representatives to comply with extended producer responsibility requirements when supplying packaging to Spain.

Reporting Deadline

An annual report indicating the number of packaging sold in the Spanish market must be submitted to producer responsible organization by 28th of February.

Does obtaining an NIF number entail any obligations beyond the packaging system?

Obtaining an NIF number does not entail any obligations beyond the packaging system.

The NIF number is simply an identification number that is used by the Spanish government to track individuals and businesses. It is required for a variety of purposes, including paying taxes, opening a bank account, and purchasing property. However, it does not entail any additional obligations beyond those that are specifically associated with the packaging system.

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EEE

Extended producer responsibility for EEE in Spain

Following Spanish law and with Royal Decree 110/2015 of February 20 on Waste Electronic and Electrical Appliances and the introduction of new restrictions from January 2023, producers are responsible for managing electronic and electrical waste sold in Spain.

What the EEE includes

Heat exchange appliances
Monitors and screens having a surface larger than 100 cm2
Various types of lamps
Large electrical appliances
Small electrical appliances
Small telecommunication information and information devices
Large photovoltaic panels

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Who must register

Registration is a mandatory requirement for a wide range of entities present on the Spanish market, in particular:

Manufacturers
Suppliers
Retailers
Distributors

And any other persons who, in one way or another, sell electronic and electrical devices to end consumers in the country.

Threshold

There are no thresholds. When trading in electronic and electrical equipment in Spain, each producer is required to register for the EPR regulations.

Registration procedure

To obtain an EPR number, adhere to the following procedural steps must be followed.

Find a Producer Responsibility Organization (PRO) certified for the EEE category.
Register on the PRO website.
Fill out the membership form and sign a cooperation agreement.
The relevant organization will prepare an application for the company and submit it to the government agency Ministry of Environmental Transition and Demographic Challenges of Spain (MITECO), which issues the EPR number.
Submit declarations on the quantity of products sold.
Payment of quarterly environmental fees.

Authorized representative

All companies located outside of Spain that sell electronic and electrical devices in its territory and want to comply with the EPR rules must appoint an authorized representative who will be responsible for the company to the government.

Reporting Deadline

The 20th day of the next month following the reporting period is the deadline for filing declarations. Reports on the value of sales of electronic and electrical equipment in Spain must be submitted quarterly.

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Batteries

Extended producer responsibility for Batteries in Spain

In accordance with Spanish Royal Decree 993/2022, which was approved on November 29, 2022, and entered into force on January 16, 2023, Spain introduced new regulatory rules for the importation and sale of devices containing batteries in their composition.

What the Batteries include

Button batteries
Standard Batteries
Portable accumulators
Industrial and automotive batteries

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Who must register

Registration is required for manufacturers, sellers, importers, and distributors who place batteries or accumulators on the Spanish market for the first time, as well as batteries or accumulators built into devices or vehicles, within the scope of professional activities.

Threshold

No thresholds exist. Companies must register when selling goods with batteries or accumulators for the first time in the Spanish market.

Registration procedure

To acquire an EPR number, follow these steps:

Locate a certified Producer Responsibility Organization (PRO) for the Batteries category.
Register on the responsibility organization website and sign a contract.
The PRO will create and apply an application to the Spanish government agency, the Ministry of Environmental Transition and Demographic Challenges (MITECO), which issues the EPR number.
Submit declarations regarding the quantity of products sold.
Pay quarterly environmental fees.

Authorized representative

Companies situated outside Spain that sell batteries or accumulators within its jurisdiction and aim to adhere to EPR regulations must designate an authorized representative. This representative will assume responsibility for the company in dealings with the government.

Reporting Deadline

The 20th day of the month following the reporting period is the deadline for submitting the declaration. Quarterly reports on the sales value of batteries in Spain must be filed within this timeframe.

Have questions? Ask EPR team