+49 6196 5835357

info@ecopv-eu.com

🇪🇸 EPR Compliance for Batteries in Spain |
Guide and Checklist 2026

Extended Producer Responsibility (EPR) for Batteries and Rechargeable Batteries – 7 Steps to Compliance + Step-by-Step Checklist

Anyone who sells batteries or battery-powered devices in Spain has a legal obligation: Extended Producer Responsibility (EPR) makes companies jointly responsible for the end-of-life management of their batteries. Spain maintains a centralized national registry with particularly strict requirements for foreign authorized representatives.

What does this mean specifically for your company? Here are the 7 most important steps – including a checklist to get you started.

🇪🇸 EPR Compliance for Batteries in Spain |
Guide and Checklist 2026

Extended Producer Responsibility (EPR) for Batteries and Rechargeable Batteries – 7 Steps to Compliance + Step-by-Step Checklist

Anyone who sells batteries or battery-powered devices in Spain has a legal obligation: Extended Producer Responsibility (EPR) makes companies jointly responsible for the end-of-life management of their batteries. Spain maintains a centralized national registry with particularly strict requirements for foreign authorized representatives.

What does this mean specifically for your company? Here are the 7 most important steps – including a checklist to get you started.

Who is considered a “producer” under Spain’s battery EPR?

The definition of a “producer” is based on the initial placing on the Spanish market – regardless of the company’s registered office. Specifically, this applies to:

  • Companies based in Spain – any entity that manufactures batteries or battery-powered equipment (AEE) in Spain, markets them under its own name, or imports them from third countries or other EU member states
  • Non-Spanish EU companies engaged in distance selling – any entity that delivers batteries or battery-powered devices directly to Spanish end customers via distance selling (online store, marketplace) (B2C/B2B)
  • Non-EU companies – any entity that delivers directly to Spanish customers; stricter customs controls apply here
  • White-label / private labels – any company that markets devices with built-in or included batteries under its own brand in Spain is legally considered a battery manufacturer
  • Marketplace operators – similar to WEEE regulations, platforms bear subsidiary liability; they must validate the registration numbers of third-party sellers. If these are missing, the marketplace bears direct financial and administrative liability

Practical example: A German company operates an online store and delivers electrical appliances with built-in rechargeable batteries directly to Spanish end customers → is considered a “Productor” under the Battery EPR → must appoint an authorized representative based in Spain with a notarized power of attorney and an apostille → requires RII-PYA registration as well as SCRAP membership → must report quantities on a quarterly basis

Overview of Battery Categories

CategoryDescription
Portable BatteriesSealed, under 5 kg, excluding industrial or vehicle batteries
LMT Batteries Light vehicles such as e-bikes and e-scooters
Starter BatteriesFor motor vehicles
Industrial BatteriesIndustrial use or over 5 kg, unless classified as EV or LMT
Traction Batteries (EV) For electric vehicles

The 7 Most Important Steps for EPR Compliance in Spain

Step 1: Appoint an Authorized Representative (for Foreign Companies)

Foreign manufacturers without a Spanish branch that sell directly to Spanish end customers must appoint an authorized representative based in Spain.

The authorized representative acts fully on behalf of the manufacturer in dealings with the authorities and is liable for all financial (contribution payments) and administrative obligations.

Requirements for the power of attorney documentation – stricter than in Belgium or Italy:

  • Requires a notarized document with a Hague Apostille (not required for purely electronic registration via a Spanish digital certificate)
  • A simple, informal power of attorney will be rejected by the Spanish registry
  • The authorized representative must first apply for a Spanish tax identification number for non-residents (NIF IVA) on behalf of the foreign company
  • Since the EU Battery Regulation came into effect, the authorized representative must also demonstrate to the state registry that they have the operational and legal resources to report accurately

Step 2: Mandatory registration in the national registry (RII-PYA)

Competent authority: Ministry of Industry and Tourism (Ministerio de Industria y Turismo)

Platform: RII-PYA – Integrated Industrial Registry of Batteries and Accumulators

Procedure:

  1. Online application via the RII-PYA portal
  2. Validation of data by the Subdirectorate General for Industrial Quality and Safety
  3. Assignment of a unique REG-PYA identification number

Step 3: Membership in a SCRAP

Physical and financial take-back is handled through collective systems – Sistemas Colectivos de Responsabilidad Ampliada del Productor (SCRAP).

Procedure: Online contract conclusion with the SCRAP (providing the NIF); the registration number (RII-PYA) is submitted at a later stage. The SCRAP reports the active status directly to the Ministry of Industry.

Step 4: Financial Contributions and Warranty Obligations

Calculation of the Eco-Fee:

  • Calculated per kilogram of battery mass, differentiated by chemical composition
  • Lithium-based systems are subject to significantly higher rates than lead-acid or alkaline batteries (higher recycling costs, higher safety risks)

Eco-Modulation (since 2025/2026): Spanish SCRAPs are increasingly incorporating criteria from the EU Battery Regulation:

  • Bonus: Batteries with a verifiably high recycling rate receive fee discounts
  • Penalty: Non-replaceable battery solutions in devices are subject to penalty surcharges

Guarantee Obligations:

  • To cover disposal costs, the government generally requires financial guarantees
  • Exemption through SCRAP membership: Those who join an approved collective system are exempt from the individual bank guarantee requirement

Step 5: Quarterly Volume Reporting

Reporting to the RII-PYA:

  • Manufacturers (or their authorized representatives) must report the exact weights and quantities of all batteries placed on the market in Spain on a quarterly basis.
  • Deadlines: April, July, October, and January for the preceding quarter, respectively.
  • Submission must be made digitally via the RII-PYA portal.

Reporting to the SCRAP:

  • At the same time, the selected take-back system requires reports for billing purposes. Most Spanish SCRAPs require quarterly reports as standard. Very large distributors may be contractually obligated to submit monthly reports.

Expanded reporting requirements under the EU Battery Regulation:

  • Carbon footprint: Manufacturers of EV batteries (and, in the future, certain industrial batteries) must submit a verified carbon footprint declaration digitally. This requirement will be phased in gradually but will become mandatory as part of the Digital Battery Passport starting in February 2027.
  • Due diligence: Larger battery manufacturers must document and record their due diligence obligations regarding the sourcing of raw materials (cobalt, lithium, nickel, natural graphite) in the system.

Step 6: Labeling Requirements

  1. Crossed-out trash can: Required on every battery or its packaging
  2. Chemical symbols: Lead and cadmium thresholds require labeling below the trash can symbol.
  3. Capacity information: For all portable batteries and vehicle batteries, the capacity (in mAh, Ah, or Wh) must be clearly legible

Step 7: Ensuring Marketplace Compliance

Online marketplaces enforce EPR compliance through technical measures. Amazon Spain and similar platforms require valid REG-PYA certification before sales of batteries or battery-powered products are permitted.

Recommended Action:

  • Proactively enter the REG-PYA number in the seller’s backend – before making your first sale
  • For imports from third countries: Provide the REG-PYA number to the logistics service provider before shipment so that Spanish customs can verify the number during import inspection

Who is considered a “producer” under Spain’s battery EPR?

The definition of a “producer” is based on the initial placing on the Spanish market – regardless of the company’s registered office. Specifically, this applies to:

  • Companies based in Spain – any entity that manufactures batteries or battery-powered equipment (AEE) in Spain, markets them under its own name, or imports them from third countries or other EU member states
  • Non-Spanish EU companies engaged in distance selling – any entity that delivers batteries or battery-powered devices directly to Spanish end customers via distance selling (online store, marketplace) (B2C/B2B)
  • Non-EU companies – any entity that delivers directly to Spanish customers; stricter customs controls apply here
  • White-label / private labels – any company that markets devices with built-in or included batteries under its own brand in Spain is legally considered a battery manufacturer
  • Marketplace operators – similar to WEEE regulations, platforms bear subsidiary liability; they must validate the registration numbers of third-party sellers. If these are missing, the marketplace bears direct financial and administrative liability

Practical example: A German company operates an online store and delivers electrical appliances with built-in rechargeable batteries directly to Spanish end customers → is considered a “Productor” under the Battery EPR → must appoint an authorized representative based in Spain with a notarized power of attorney and an apostille → requires RII-PYA registration as well as SCRAP membership → must report quantities on a quarterly basis

Overview of Battery Categories

  1. Portable Batteries: Sealed, under 5 kg, excluding industrial or vehicle batteries
  2. LMT Batteries: Light vehicles such as e-bikes and e-scooters
  3. Starter Batteries: For motor vehicles
  4. Industrial Batteries: Industrial use or over 5 kg, unless classified as EV or LMT
  5. Traction Batteries (EV): For electric vehicles

The 7 Most Important Steps for EPR Compliance in Spain

Step 1: Appoint an Authorized Representative (for Foreign Companies)

Foreign manufacturers without a Spanish branch that sell directly to Spanish end customers must appoint an authorized representative based in Spain.

The authorized representative acts fully on behalf of the manufacturer in dealings with the authorities and is liable for all financial (contribution payments) and administrative obligations.

Requirements for the power of attorney documentation – stricter than in Belgium or Italy:

  • Requires a notarized document with a Hague Apostille (not required for purely electronic registration via a Spanish digital certificate)
  • A simple, informal power of attorney will be rejected by the Spanish registry
  • The authorized representative must first apply for a Spanish tax identification number for non-residents (NIF IVA) on behalf of the foreign company
  • Since the EU Battery Regulation came into effect, the authorized representative must also demonstrate to the state registry that they have the operational and legal resources to report accurately

Step 2: Mandatory registration in the national registry (RII-PYA)

Competent authority: Ministry of Industry and Tourism (Ministerio de Industria y Turismo)

Platform: RII-PYA – Integrated Industrial Registry of Batteries and Accumulators

Procedure:

  1. Online application via the RII-PYA portal
  2. Validation of data by the Subdirectorate General for Industrial Quality and Safety
  3. Assignment of a unique REG-PYA identification number

Step 3: Membership in a SCRAP

Physical and financial take-back is handled through collective systems – Sistemas Colectivos de Responsabilidad Ampliada del Productor (SCRAP).

Procedure: Online contract conclusion with the SCRAP (providing the NIF); the registration number (RII-PYA) is submitted at a later stage. The SCRAP reports the active status directly to the Ministry of Industry.

Step 4: Financial Contributions and Warranty Obligations

Calculation of the Eco-Fee:

  • Calculated per kilogram of battery mass, differentiated by chemical composition
  • Lithium-based systems are subject to significantly higher rates than lead-acid or alkaline batteries (higher recycling costs, higher safety risks)

Eco-Modulation (since 2025/2026): Spanish SCRAPs are increasingly incorporating criteria from the EU Battery Regulation:

  • Bonus: Batteries with a verifiably high recycling rate receive fee discounts
  • Penalty: Non-replaceable battery solutions in devices are subject to penalty surcharges

Guarantee Obligations:

  • To cover disposal costs, the government generally requires financial guarantees
  • Exemption through SCRAP membership: Those who join an approved collective system are exempt from the individual bank guarantee requirement

Step 5: Quarterly Volume Reporting

Reporting to the RII-PYA:

  • Manufacturers (or their authorized representatives) must report the exact weights and quantities of all batteries placed on the market in Spain on a quarterly basis.
  • Deadlines: April, July, October, and January for the preceding quarter, respectively.
  • Submission must be made digitally via the RII-PYA portal.

Reporting to the SCRAP:

  • At the same time, the selected take-back system requires reports for billing purposes. Most Spanish SCRAPs require quarterly reports as standard. Very large distributors may be contractually obligated to submit monthly reports.

Expanded reporting requirements under the EU Battery Regulation:

  • Carbon footprint: Manufacturers of EV batteries (and, in the future, certain industrial batteries) must submit a verified carbon footprint declaration digitally. This requirement will be phased in gradually but will become mandatory as part of the Digital Battery Passport starting in February 2027.
  • Due diligence: Larger battery manufacturers must document and record their due diligence obligations regarding the sourcing of raw materials (cobalt, lithium, nickel, natural graphite) in the system.

Step 6: Labeling Requirements

  1. Crossed-out trash can: Required on every battery or its packaging
  2. Chemical symbols: Lead and cadmium thresholds require labeling below the trash can symbol.
  3. Capacity information: For all portable batteries and vehicle batteries, the capacity (in mAh, Ah, or Wh) must be clearly legible

Step 7: Ensuring Marketplace Compliance

Online marketplaces enforce EPR compliance through technical measures. Amazon Spain and similar platforms require valid REG-PYA certification before sales of batteries or battery-powered products are permitted.

Recommended Action:

  • Proactively enter the REG-PYA number in the seller’s backend – before making your first sale
  • For imports from third countries: Provide the REG-PYA number to the logistics service provider before shipment so that Spanish customs can verify the number during import inspection

Step-by-Step Checklist

(a) Companies based in Spain

1. Classify batteries into the 5 current categories

2. Enter into a SCRAP contract

3. Complete RII-PYA registration via the Ministry’s portal and obtain a REG-PYA number

4. Verify technical compliance: CO₂ footprint data for industrial and EV batteries

5. Submit quarterly sales data reports

6. Display the REG-PYA number on all invoices and on the website

7. Verify labeling: trash can symbol, Cd/Pb warnings, capacity information

(b) Companies from other EU countries

1. Apply for a Spanish NIF (tax identification number) for foreign companies

2. Issue a power of attorney for the authorized representative in Spain (notarized + apostille or digital).

3. The authorized representative enters into a SCRAP agreement on behalf of the EU manufacturer

4. The authorized representative activates the registration on the RII-PYA portal

5. Enter the REG-PYA number in the backend of Amazon Spain / marketplaces

6. Ensure quarterly volume reporting is submitted via the authorized representative

(c) Companies from third countries (outside the EU)

1. Check the distribution channel: Is a Spanish importer acting as the “Productor”? For direct sales to end customers via e-commerce → Follow the steps listed under (b)

2. Before physical shipment: Provide the REG-PYA number to the logistics service provider

3. Ensure that the Spanish customs database can verify the number during the import process

Step-by-Step Checklist

(a) Companies based in Spain

1. Classify batteries into the 5 current categories

2. Enter into a SCRAP contract

3. Complete RII-PYA registration via the Ministry’s portal and obtain a REG-PYA number

4. Verify technical compliance: CO₂ footprint data for industrial and EV batteries

5. Submit quarterly sales data reports

6. Display the REG-PYA number on all invoices and on the website

7. Verify labeling: trash can symbol, Cd/Pb warnings, capacity information

(b) Companies from other EU countries

1. Apply for a Spanish NIF (tax identification number) for foreign companies

2. Issue a power of attorney for the authorized representative in Spain (notarized + apostille or digital).

3. The authorized representative enters into a SCRAP agreement on behalf of the EU manufacturer

4. The authorized representative activates the registration on the RII-PYA portal

5. Enter the REG-PYA number in the backend of Amazon Spain / marketplaces

6. Ensure quarterly volume reporting is submitted via the authorized representative

(c) Companies from third countries (outside the EU)

1. Check the distribution channel: Is a Spanish importer acting as the “Productor”? For direct sales to end customers via e-commerce → Follow the steps listed under (b)

2. Before physical shipment: Provide the REG-PYA number to the logistics service provider

3. Ensure that the Spanish customs database can verify the number during the import process

Are you planning to sell your products in Spain?

We’ll help you ensure compliance with Spain’s EPR regulations for batteries so you can get started with legal certainty.

Are you planning to sell your products in Spain?

We’ll help you ensure compliance with Spain’s EPR regulations for batteries so you can get started with legal certainty.

Contact

We look forward to your message!

info@ecopv-eu.com

+49 6196 5835357

Frankfurter Str. 70-72
65760 Eschborn

Contact

We look forward to your message!

info@ecopv-eu.com

+49 6196 5835357

Frankfurter Str. 70-72
65760 Eschborn