+49 6196 5835357

info@ecopv-eu.com

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

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

Anyone selling packaged products in Spain has a legal obligation: Extended Producer Responsibility (EPR) makes companies jointly responsible for the end-of-life management of their packaging. The legal basis is Real Decreto 1055/2022, which for the first time also covers commercial and industrial packaging – not just household packaging. The system is administered by the Ministerio para la Transición Ecológica y el Reto Demográfico (MITERD).

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 Packaging in Spain |
Guide and Checklist 2026

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

Anyone selling packaged products in Spain has a legal obligation: Extended Producer Responsibility (EPR) makes companies jointly responsible for the end-of-life management of their packaging. The legal basis is Real Decreto 1055/2022, which for the first time also covers commercial and industrial packaging – not just household packaging. The system is administered by the Ministerio para la Transición Ecológica y el Reto Demográfico (MITERD).

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 “Productor de Producto”?

The status of “Productor de Producto” is tied to the initial commercial placing on the market of packaged goods in Spain – regardless of where the company is headquartered. Specifically, this applies to:

  • Fillers/packagers based in Spain – those who package products in Spain and distribute them under their own brand
  • Private-label owners – if a retailer commissions packaging under its own brand, the retailer is considered the manufacturer
  • Importers – those who import packaged products from abroad (EU/third countries) into Spain
  • Non-Spanish EU companies engaged in distance selling – any entity that delivers packaged goods directly to Spanish end customers via e-commerce (B2C or B2B) is considered a distributor for both the product packaging and the shipping packaging
  • Non-EU companies – in the case of direct B2C shipping, the foreign company is considered the manufacturer; in traditional B2B supply chains, the obligation passes to the Spanish importer
  • Marketplace operators – Online marketplaces have subsidiary liability. They must validate the packaging registration numbers of their third-party sellers.

Practical example: A German online store ships packaged cosmetic products directly to Spanish end customers → is considered a “Productor de Producto” → must designate a Spanish NIF and an authorized representative with a notarized power of attorney and apostille → enters into a SCRAP contract through the authorized representative → receives an ENV registration number on the MITERD portal

Types of Packaging Under Spanish Law:

TypeDescription
Household Packaging (Domésticos) Typically generated as waste in private households
Commercial Packaging (Comerciales) Retail and service sectors (e.g., offices, restaurants)
Industrial packaging (Industriales)Industrial production facilities or logistics centers
Transport packaging Pallets, crates, shrink wrap for securing cargo

The 7 Most Important Steps for EPR Compliance in Spain

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

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

The authorized representative assumes financial and administrative liability for compliance with EPR requirements towards MITERD and the take-back systems.

Requirements for the power of attorney documentation:

  • A notarized document with a Hague Apostille is required
  • In addition, a certified translation into Spanish is required
  • The authorized representative registers the foreign company in the central registry under its Spanish tax identification number for non-residents (NIF)

Step 2: Registration in the Product Producers Registry

Responsible authority: Ministry for Ecological Transition and the Demographic Challenge (MITERD)

Platform: MITERD’s electronic portal – Packaging section of the “Product Producers Registry” (RPP)

Procedure:

  1. Log in to the MITERD portal using a digital certificate
  2. Upon initial registration, proof of membership in an approved SCRAP must be provided
  3. Specify the packaging category: household, commercial, and/or industrial, as well as whether single-use, reusable, or both types of packaging are involved
  4. The system assigns a unique ENV registration number

Step 3: Membership in a SCRAP

Distributors must join a collective system – a Sistema Colectivo de Responsabilidad Ampliada del Productor (SCRAP) – for each packaging category they place on the market.

Process:

  1. Join the eco-organization
  2. Manual entry in the MITERD portal by your authorized representative (upload of the certificate)
  3. Direct generation of the ENV number in the MITERD portal

You must include this number on all invoices and commercial documents for your Spanish customers.

Step 4: Record packaging data and report annually

Reporting to MITERD (central registry):

  • By March 31 of the following year, distributors must declare the exact packaging quantities from the previous year
  • Breakdown by material, weight, intended use (household/commercial/industrial), and the SCRAP system used

Reporting to SCRAP: Depending on the size of the company, reports are submitted to the selected system monthly, quarterly, or annually (deadlines usually in January/February of the following year) for the financial settlement of fees.

Step 5: Calculate and Pay Fees

The eco-fee is calculated by multiplying the weight of the packaging components by the material-specific rate (euros per metric ton) of the respective SCRAP.

Eco-modulation (Ecomodulación):

Bonuses:

  • Packaging with certified recyclability
  • Single-material products
  • Verified recycling content

Penalty surcharges (up to a 100% surcharge):

  • Contaminants such as carbon black pigments
  • Insoluble adhesives
  • Multilayer plastics without a realistic recycling pathway

Step 6: Labeling and Ecodesign Requirements

Material Labeling:

  • Requirement to label products with Europe-wide harmonized identification codes for sorting facilities and consumers

Sorting Instructions:

  • Vague environmental claims such as “sustainable” or “environmentally friendly” are prohibited
  • Instead, clear sorting instructions are required that direct users to the correct container

Ecodesign requirements:

  • Strict guidelines for minimizing the weight and volume of packaging
  • Reusable quotas: Mandatory, increasing quotas for marketing via reusable systems apply in particular to the beverage industry in the HoReCa sector

Step 7: Financial Guarantees and Marketplace Compliance

Guarantee Requirement: Spain requires proof that the disposal costs for the quantities of packaging placed on the market are covered even in the event of the manufacturer’s insolvency.

  • Exemption through SCRAP membership: Anyone who duly joins an approved SCRAP is exempt from the individual guarantee requirement – the SCRAP provides MITERD with a collective, government-approved guarantee for the entire system

Who is considered a “Productor de Producto”?

The status of “Productor de Producto” is tied to the initial commercial placing on the market of packaged goods in Spain – regardless of where the company is headquartered. Specifically, this applies to:

  • Fillers/packagers based in Spain – those who package products in Spain and distribute them under their own brand
  • Private-label owners – if a retailer commissions packaging under its own brand, the retailer is considered the manufacturer
  • Importers – those who import packaged products from abroad (EU/third countries) into Spain
  • Non-Spanish EU companies engaged in distance selling – any entity that delivers packaged goods directly to Spanish end customers via e-commerce (B2C or B2B) is considered a distributor for both the product packaging and the shipping packaging
  • Non-EU companies – in the case of direct B2C shipping, the foreign company is considered the manufacturer; in traditional B2B supply chains, the obligation passes to the Spanish importer
  • Marketplace operators – Online marketplaces have subsidiary liability. They must validate the packaging registration numbers of their third-party sellers.

Practical example: A German online store ships packaged cosmetic products directly to Spanish end customers → is considered a “Productor de Producto” → must designate a Spanish NIF and an authorized representative with a notarized power of attorney and apostille → enters into a SCRAP contract through the authorized representative → receives an ENV registration number on the MITERD portal

Types of Packaging Under Spanish Law:

  1. Household Packaging (Domésticos): Typically generated as waste in private households
  2. Commercial Packaging (Comerciales): Retail and service sectors (e.g., offices, restaurants)
  3. Industrial packaging (Industriales): Industrial production facilities or logistics centers
  4. Transport packaging: Pallets, crates, shrink wrap for securing cargo

The 7 Most Important Steps for EPR Compliance in Spain

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

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

The authorized representative assumes financial and administrative liability for compliance with EPR requirements towards MITERD and the take-back systems.

Requirements for the power of attorney documentation:

  • A notarized document with a Hague Apostille is required
  • In addition, a certified translation into Spanish is required
  • The authorized representative registers the foreign company in the central registry under its Spanish tax identification number for non-residents (NIF)

Step 2: Registration in the Product Producers Registry

Responsible authority: Ministry for Ecological Transition and the Demographic Challenge (MITERD)

Platform: MITERD’s electronic portal – Packaging section of the “Product Producers Registry” (RPP)

Procedure:

  1. Log in to the MITERD portal using a digital certificate
  2. Upon initial registration, proof of membership in an approved SCRAP must be provided
  3. Specify the packaging category: household, commercial, and/or industrial, as well as whether single-use, reusable, or both types of packaging are involved
  4. The system assigns a unique ENV registration number

Step 3: Membership in a SCRAP

Distributors must join a collective system – a Sistema Colectivo de Responsabilidad Ampliada del Productor (SCRAP) – for each packaging category they place on the market.

Process:

  1. Join the eco-organization
  2. Manual entry in the MITERD portal by your authorized representative (upload of the certificate)
  3. Direct generation of the ENV number in the MITERD portal

You must include this number on all invoices and commercial documents for your Spanish customers.

Step 4: Record packaging data and report annually

Reporting to MITERD (central registry):

  • By March 31 of the following year, distributors must declare the exact packaging quantities from the previous year
  • Breakdown by material, weight, intended use (household/commercial/industrial), and the SCRAP system used

Reporting to SCRAP: Depending on the size of the company, reports are submitted to the selected system monthly, quarterly, or annually (deadlines usually in January/February of the following year) for the financial settlement of fees.

Step 5: Calculate and Pay Fees

The eco-fee is calculated by multiplying the weight of the packaging components by the material-specific rate (euros per metric ton) of the respective SCRAP.

Eco-modulation (Ecomodulación):

Bonuses:

  • Packaging with certified recyclability
  • Single-material products
  • Verified recycling content

Penalty surcharges (up to a 100% surcharge):

  • Contaminants such as carbon black pigments
  • Insoluble adhesives
  • Multilayer plastics without a realistic recycling pathway

Step 6: Labeling and Ecodesign Requirements

Material Labeling:

  • Requirement to label products with Europe-wide harmonized identification codes for sorting facilities and consumers

Sorting Instructions:

  • Vague environmental claims such as “sustainable” or “environmentally friendly” are prohibited
  • Instead, clear sorting instructions are required that direct users to the correct container

Ecodesign requirements:

  • Strict guidelines for minimizing the weight and volume of packaging
  • Reusable quotas: Mandatory, increasing quotas for marketing via reusable systems apply in particular to the beverage industry in the HoReCa sector

Step 7: Financial Guarantees and Marketplace Compliance

Guarantee Requirement: Spain requires proof that the disposal costs for the quantities of packaging placed on the market are covered even in the event of the manufacturer’s insolvency.

  • Exemption through SCRAP membership: Anyone who duly joins an approved SCRAP is exempt from the individual guarantee requirement – the SCRAP provides MITERD with a collective, government-approved guarantee for the entire system

Step-by-Step Checklist

(a) Companies based in Spain

1. Packaging audit: Record primary, secondary, and tertiary packaging by material type and weight

2. SCRAP selection: Sign a contract

3. MITERD registration: Register in the national registry, specifying SCRAP affiliation; obtain an ENV number

4. Include the ENV number on all B2B invoices and commercial documents

5. Submit the annual report via the MITERD portal by March 31

6. Submit periodic reports to SCRAP according to the agreed-upon schedule

7. Review labeling and ecodesign requirements (sorting instructions, weight minimization)

(b) Companies from other EU countries

1. Apply for a Spanish NIF with the Spanish tax authority

2. Appoint an authorized representative: notarized power of attorney with an apostille and a certified Spanish translation

3. The authorized representative enters into a SCRAP agreement (including a declaration of the shipping cartons used)

4. The authorized representative must activate the registration on the MITERD portal to generate the ENV number

5. Enter the ENV number in the seller’s account

6. Ensure that the annual volume report is submitted via the authorized representative

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

1. Distribution channel analysis: Is the shipment being made to a Spanish importer? If yes → the manufacturer’s obligations are contractually transferred to the importer; product data must be provided as specified in the contract

2. Direct sales (B2C): For direct shipments via e-commerce to Spanish end customers → all steps listed in (b) must be handled through a Spanish authorized representative

Step-by-Step Checklist

(a) Companies based in Spain

1. Packaging audit: Record primary, secondary, and tertiary packaging by material type and weight

2. SCRAP selection: Sign a contract

3. MITERD registration: Register in the national registry, specifying SCRAP affiliation; obtain an ENV number

4. Include the ENV number on all B2B invoices and commercial documents

5. Submit the annual report via the MITERD portal by March 31

6. Submit periodic reports to SCRAP according to the agreed-upon schedule

7. Review labeling and ecodesign requirements (sorting instructions, weight minimization)

(b) Companies from other EU countries

1. Apply for a Spanish NIF with the Spanish tax authority

2. Appoint an authorized representative: notarized power of attorney with an apostille and a certified Spanish translation

3. The authorized representative enters into a SCRAP agreement (including a declaration of the shipping cartons used)

4. The authorized representative must activate the registration on the MITERD portal to generate the ENV number

5. Enter the ENV number in the seller’s account

6. Ensure that the annual volume report is submitted via the authorized representative

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

1. Distribution channel analysis: Is the shipment being made to a Spanish importer? If yes → the manufacturer’s obligations are contractually transferred to the importer; product data must be provided as specified in the contract

2. Direct sales (B2C): For direct shipments via e-commerce to Spanish end customers → all steps listed in (b) must be handled through a Spanish authorized representative

Are you planning to sell your products in Spain?

We’ll help you ensure compliance with Spain’s EPR regulations for packaging 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 packaging 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