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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. 

Extended producer responsibility (EPR) 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.

Extended producer responsibility (EPR) 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.

Who must register for packaging EPR in Spain

According to EPR registration Spain requirements, the following parties are obligated:
  • Companies that manufacture, import, or distribute packaged goods in Spain
  • Online sellers and distance sellers delivering packaged products to end users in Spain
  • Foreign companies that do not have a Spanish legal presence
Ready to make extended producer responsibility effortless for Spain? Request a personalized EPR fee quote now and start turning regulatory obligations into sustainable value for your brand for cross-border sales!

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.

What the package includes

EPR packaging Spain covers all types of packaging, including:
  • Household packaging: Food containers, bottles, cartons, etc
  • Commercial packaging: Boxes, film, crates used in retail
  • Industrial packaging: Pallets, drums, and heavy-duty containers used in logistics
This applies to all packaging materials: paper, plastic, glass, metal, wood, and composites.

Thresholds

There are no thresholds.

EPR registration procedure in Spain

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.

Packaging and labeling compliance

Packaging and labeling are critical components of Spain's EPR requirements. Companies must ensure that all packaging complies with environmental regulations, including proper labeling to facilitate recycling and waste management. For a detailed overview of packaging and labeling standards in Spain, visit our dedicated blog post.

Who assumes responsibility?

Responsibility lies with:
  • Domestic producers and importers placing packaged products on the Spanish market.
  • Foreign distance sellers, via a local authorized representative.
  • Marketplace operators (e.g., Amazon) if they facilitate third-party sales.
EPR obligations apply from the moment packaging enters the Spanish market, regardless of where it was manufactured.

Duties of each group

  • Producers: Register with MITECO, report volumes, finance collection and recycling via eco-fees, and ensure packaging meets recyclability criteria.
  • Authorized Representatives: Ensure full EPR packaging Spain compliance for foreign entities.
  • Compliance Schemes (e.g. Ecoembes): Organize sorting, collection, treatment, and public awareness campaigns.
  • Marketplace Operators: In some cases, must ensure third-party sellers are registered.
Stay ahead of global EPR requirements with our all-in-one compliance platform. Book a free demo today to see how easily you can register and report,whether it’s packaging, electronics, batteries, textiles, or any other regulated stream, anywhere in the world.

Who must register for EPR in Spain

According to EPR registration Spain rules, these entities are obligated:
  • Manufacturers of EEE in Spain
  • Importers and distributors placing EEE on the Spanish market
  • Online sellers offering EEE to Spanish consumers
  • Foreign companies without legal establishment in Spain (must appoint a representative)
Ready to make extended producer responsibility effortless for Spain? Request a personalized EPR fee quote now and start turning regulatory obligations into sustainable value for your brand for cross-border sales!

What the package includes

EPR Spain for EEE applies to all equipment that depends on electric currents or electromagnetic fields to operate. This includes:
  • Large and small household appliances
  • IT and telecommunications equipment
  • Consumer electronics
  • Lighting equipment
  • Electrical tools
  • Toys and sports devices
  • Medical and monitoring instruments
  • Automatic dispensers
Covered devices must be intended for use at 50–1000 volts AC or 75–1500 volts DC.

Threshold

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

EPR registration procedure in Spain

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.

Who assumes responsibility?

Under Spanish law, responsibility falls on:
  • Producers placing EEE on the Spanish market
  • Authorized representatives, for foreign sellers
  • Online marketplaces, in certain cases, if facilitating non-compliant third-party sellers
All obligated parties must comply with registration, reporting, labeling, and financial responsibilities.

Duties of each group

  • Producers: Register with RII-AEE, finance collection/treatment, label products, join a SCRAP, and submit reports
  • Authorized Representatives: Act on behalf of foreign brands and ensure full compliance
  • SCRAPs (e.g., Recyclia, Ecotic, Ecolec): Coordinate logistics, data aggregation, recycling targets, and communication with authorities
Stay ahead of global EPR requirements with our all-in-one compliance platform. Book a free demo today to see how easily you can register and report,whether it’s packaging, electronics, batteries, textiles, or any other regulated stream, anywhere in the world.

Who must register for batteries EPR in Spain

Under EPR registration Spain, the following producers are obligated:
  • Manufacturers and importers of portable, industrial, or automotive batteries
  • Companies placing batteries on the Spanish market as stand-alone products or integrated into devices
  • E-commerce and distance sellers shipping batteries directly to Spanish consumers
  • Foreign entities without legal presence in Spain (must appoint an authorized representative)
Ready to make extended producer responsibility effortless for Spain? Request a personalized EPR fee quote now and start turning regulatory obligations into sustainable value for your brand for cross-border sales!

What the package includes

EPR Spain for batteries includes:
  • Portable batteries: AA, AAA, coin cells, and those in small electronic devices
  • Industrial batteries: Used in solar panels, backup power, forklifts, etc
  • Automotive batteries: Lead-acid batteries used in cars and other vehicles
All battery chemistries are included: lithium-ion, nickel-metal hydride, lead-acid, alkaline, etc.

Threshold

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

EPR registration procedure in Spain

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.

Who assumes responsibility?

Responsibility for EPR batteries Spain lies with:
  • Spanish producers and importers
  • Online and distance sellers
  • Foreign producers, via their appointed authorized representative
  • Distributors, in some cases where they serve as importers
Responsibility begins the moment batteries or battery-powered products are placed on the market.

Duties of each group

  • Producers: Register, report volumes, pay eco-fees, and ensure correct labeling
  • Authorized Representatives: Handle full compliance for non-Spanish entities
  • SCRAPs (e.g., Ecopilas): Organize national battery collection and recycling logistics
  • Retailers and Distributors: Obligated to accept used batteries from consumers and promote collection awareness
Stay ahead of global EPR requirements with our all-in-one compliance platform. Book a free demo today to see how easily you can register and report,whether it’s packaging, electronics, batteries, textiles, or any other regulated stream, anywhere in the world.
January 10, 2025 2885
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