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.
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.
There are no thresholds.
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.
Foreign companies need authorized representatives to comply with extended producer responsibility requirements when supplying packaging to Spain.
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.