Who must register for packaging EPR in Spain, and how

Checked against RD 1055/2022 and Law 7/2022 on 29 September 2026. This is general information about Regulation (EU) 2025/40 and Spain's national EPR scheme, not legal advice. Thresholds, fees, penalty amounts and go-live dates come from national law and PRO schedules that change: treat every figure as needing a fresh check, and confirm anything you act on with the national authority or qualified counsel.

The register and what it involves

Producers register in the Register of Producers of Products (Registro de Productores de Productos, RPP), packaging section, operated by MITECO under Royal Decree 1055/2022 (Art. 15). Registration yields a registration number that must appear on invoices and on the other documents that travel with the goods down the supply chain.

You must also join a collective SCRAP (or run an individual system), split by packaging type: household packaging → Ecoembes (and Ecovidrio for glass); commercial and industrial packaging → Envalora and others. Commercial and industrial packaging has had to be covered by an EPR system since 31 December 2024.

The Authorised Representative rule

Article 17.2 of RD 1055/2022 requires producers established in another EU member state or in a third country that market products in Spain to designate a person or company in Spain as their authorised representative for the producer obligations, holding documents that prove the appointment. It applies whether or not you sell direct to end users, so it goes further than Article 45(3) PPWR. The representative can register you in the RPP and file your annual declaration (Arts. 15.1 and 16.1).

If you do not appoint one, the first distributor or trader based in Spain becomes responsible for your producer obligations (Art. 17.2). Where your goods reach Spain through an e-commerce platform, the platform acts as producer for the financial and reporting duties instead (Art. 2(t)).

De-minimis and reporting

There is no general registration or reporting exemption: all producers must register and declare. Producers placing under 15 tonnes of packaging a year may report in simplified form (Art. 16.1), which eases the reporting but exempts no one. Reporting is an annual declaration of the quantity and type of packaging placed on the market, sent to MITECO before 31 March of the following year (Art. 16.2 and Annex IV). If you belong to a collective SCRAP, it needs your data before 28 February (Art. 17.1(j)).

Penalties and the plastic tax

Sanctions come from Law 7/2022 (Art. 109): fines of up to €2,000 for minor breaches, €2,001 to €100,000 for serious ones and €100,001 to €3,500,000 for very serious ones, with higher bands for hazardous waste, plus possible disqualification from the activity and, for some breaches, confiscation of goods. Which band applies depends on how Art. 108 classifies the breach. Separately, a plastic-packaging tax (Impuesto Especial sobre Envases de Plástico No Reutilizables, also in Law 7/2022) has applied since 1 January 2023 at €0.45 per kg of non-recycled plastic. It runs alongside EPR and is not discharged by it.

How onerous is it?

Moderate to high. A dual step (RPP registration plus a SCRAP contract, split household vs commercial/industrial), a Spanish authorised representative for every producer established outside Spain, an annual declaration by 31 March, and a separate plastic-packaging tax running alongside EPR.

Frequently asked questions