+49 6196 5835357

info@ecopv-eu.com

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

Extended Producer Responsibility (EPR) for Electrical and Electronic Equipment – 7 Steps to Compliance + Step-by-Step Checklist

Spain is one of the EPR markets in Europe that has seen the greatest increase in enforcement in recent years.

What makes Spain unique: the 17 Autonomous Communities (Comunidades Autónomas) as a parallel level of regulation, strict power-of-attorney requirements for foreign authorized representatives (notarization + Hague Apostille), and a marketplace liability regulation that, since 2023, has actively required platforms like Amazon to verify and enforce WEEE compliance among their third-party sellers.

What does this mean in practice?

Here are the 7 most important steps – including a practical checklist.

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

Extended Producer Responsibility (EPR) for Electrical and Electronic Equipment – 7 Steps to Compliance + Step-by-Step Checklist

Spain is one of the EPR markets in Europe that has seen the greatest increase in enforcement in recent years.

What makes Spain unique: the 17 Autonomous Communities (Comunidades Autónomas) as a parallel level of regulation, strict power-of-attorney requirements for foreign authorized representatives (notarization + Hague Apostille), and a marketplace liability regulation that, since 2023, has actively required platforms like Amazon to verify and enforce WEEE compliance among their third-party sellers.

What does this mean in practice?

Here are the 7 most important steps – including a practical checklist.

Who is considered a “producer” (Productor) under the Spanish WEEE regulations?

The definition is linked to the first placing on the market in Spain:

  • Companies based in Spain: Any entity that manufactures EEE in Spain and sells it under its own name or brand – or imports EEE into Spain from abroad.
  • Companies from other EU countries: Sell EEE via distance selling (e-commerce) directly to end consumers (B2C) or commercial end users (B2B) in Spain.
  • Companies outside the EU: Ship EEE directly to Spain – in traditional B2B supply chains, the role of producer is transferred to the first importer based in Spain.
  • Private-label / white-label providers: Have EEE manufactured by third parties but place it on the market in Spain under their own brand name.
  • Marketplace operators: Platforms such as Amazon.es are liable for all EPR obligations of their third-party sellers if they fail to ensure that these sellers have a valid REG-RAEE number. The marketplace is then legally treated as a manufacturer. Amazon.es, AliExpress, and other major platforms have been actively enforcing REG-RAEE checks since 2023.

Practical example: An Austrian company sells robotic vacuum cleaners directly to Spanish end customers through its online store → is considered a “Productor” → must appoint an authorized representative in Spain (notarized power of attorney with an apostille) → Apply for a NIF for non-residents → Sign up for SCRAP membership → Register with the RII-AEE → Include the REG-RAEE number on all invoices and in the Amazon.es seller account → Submit quarterly volume reports.

The 7 Most Important Steps for EPR Compliance in Spain

Step 1: Appoint an Authorized Representative (for foreign companies)

All foreign companies without a physical presence in Spain that ship to Spanish customers via e-commerce are required to appoint an authorized representative (Representante Autorizado) – this applies equally to both EU and non-EU companies.

Requirements for the authorized representative:

  • A natural or legal person domiciled in Spain (Spanish NIF required)
  • Assumption of full civil and administrative liability for all manufacturer obligations

Formal requirements for the power of attorney:

  • Notarization of the power of attorney
  • Hague Apostille (or equivalent legalization procedure for countries not party to the Apostille Convention)
  • Translation into Spanish (certified translation by a sworn translator)
  • A simple written agreement is not sufficient
  •  

NIF for non-residents: Before the authorized representative can complete registration in the RII-AEE, a Spanish NIF (Número de Identificación Fiscal) must be applied for on behalf of the foreign company – this is typically done by the authorized representative themselves.

Step 2: Classify the EEE category according to the Spanish system

Spain uses its own 7-category system for WEEE, which differs from the 6 EU categories in the WEEE Directive:

Spanish CategoryDescriptionExamples
Cat. 1Large household appliancesWashing machines, refrigerators, stoves
Cat. 2Small household appliancesToasters, coffee makers, vacuum cleaners
Cat. 3IT and telecommunications equipmentPCs, laptops, smartphones, routers
Cat. 4Consumer electronics and photovoltaicsTelevisions, monitors, PV modules
Cat. 5Lighting equipmentLEDs, fluorescent tubes, compact lamps
Cat. 6Electric and electronic toolsDrills, saws, sewing machines
Cat. 7Toys, leisure, and sports equipmentElectronic toys, game consoles

Separate reporting for household and commercial use: Within each category, a distinction must be made between B2C (household) devices and B2B (professional) devices – both are reported separately and priced differently.

Step 3: Membership in an Authorized SCRAP

In Spain, the physical handling of the collection, transport, and recycling of waste equipment is carried out almost exclusively by state-authorized SCRAPs (Sistema Colectivo de Responsabilidad Ampliada del Productor). Membership in a SCRAP simultaneously exempts the manufacturer from the obligation to provide an individual financial guarantee – the SCRAP provides the collective guarantee for all members.

Costs: A one-time admission fee, typically €100–500, plus annual dues proportional to the quantities placed on the market.

Step 4: Mandatory Registration with the RII-AEE

Registration with the RII-AEE must take place before EEE is first placed on the market in Spain.

Portal: industria.gob.es (WEEE / RII-AEE section)

Procedure:

  1. Complete membership in a SCRAP (Step 3)
  2. Submit an online application on the RII-AEE portal, providing the Spanish NIF
  3. Specify the EEE categories, brands, distribution channels, and provide proof of SCRAP membership
  4. Pay the registration fee
  5. Receive the REG-RAEE number

Step 5: Financial Obligations & Fee Structure

Eco-fees are calculated based on the number of units, weight, and EEE category.

Fee Range (Royal Decree 110/2015):

€0.01 to €5.00 per device, depending on category and weight

 

Differentiation Between B2C and B2B:

  • B2C: Fixed rates set by SCRAP
  • B2B: Customized contracts with SCRAP are often possible; In some cases, costs are incurred only upon the actual return of the end-of-life device

Financial guarantee exemption through SCRAP membership:

A major advantage of SCRAP membership: Manufacturers are not required to provide their own collateral (such as bank guarantees or insurance) to cover future disposal costs. SCRAP collectively assumes this guarantee towards MITECO.

Step 6: Reporting Requirements: Quarterly + Annual Consolidation

Quarterly Reports (Primary Requirement)

  • Content: Exact quantities (units + kilograms) of EEE placed on the market in Spain, broken down by Spanish categories and B2C/B2B
  • Frequency: Quarterly, in the month following the end of each quarter:
    • Q1 (Jan–Mar) → Report due by the end of April
    • Q2 (Apr–Jun) → Report due by the end of July
    • Q3 (Jul–Sep) → Report due by the end of October
    • Q4 (Oct–Dec) → Report due by the end of January

Consolidated Annual Report

  • Submission due by January 31 of the following year
  • Includes all four quarterly reports as well as an overview of collection rate compliance

Step 7: Labeling Requirements

1. Crossed-out trash can symbol: Must be permanently affixed to the device or – if the device is too small – to the packaging

2. Manufacturer information on the product: The manufacturer’s name or registered trademark must be clearly visible on the device (traceability).

Who is considered a “producer” (Productor) under the Spanish WEEE regulations?

The definition is linked to the first placing on the market in Spain:

  • Companies based in Spain: Any entity that manufactures EEE in Spain and sells it under its own name or brand – or imports EEE into Spain from abroad.
  • Companies from other EU countries: Sell EEE via distance selling (e-commerce) directly to end consumers (B2C) or commercial end users (B2B) in Spain.
  • Companies outside the EU: Ship EEE directly to Spain – in traditional B2B supply chains, the role of producer is transferred to the first importer based in Spain.
  • Private-label / white-label providers: Have EEE manufactured by third parties but place it on the market in Spain under their own brand name.
  • Marketplace operators: Platforms such as Amazon.es are liable for all EPR obligations of their third-party sellers if they fail to ensure that these sellers have a valid REG-RAEE number. The marketplace is then legally treated as a manufacturer. Amazon.es, AliExpress, and other major platforms have been actively enforcing REG-RAEE checks since 2023.

Practical example: An Austrian company sells robotic vacuum cleaners directly to Spanish end customers through its online store → is considered a “Productor” → must appoint an authorized representative in Spain (notarized power of attorney with an apostille) → Apply for a NIF for non-residents → Sign up for SCRAP membership → Register with the RII-AEE → Include the REG-RAEE number on all invoices and in the Amazon.es seller account → Submit quarterly volume reports.

The 7 Most Important Steps for EPR Compliance in Spain

Step 1: Appoint an Authorized Representative (for foreign companies)

All foreign companies without a physical presence in Spain that ship to Spanish customers via e-commerce are required to appoint an authorized representative (Representante Autorizado) – this applies equally to both EU and non-EU companies.

Requirements for the authorized representative:

  • A natural or legal person domiciled in Spain (Spanish NIF required)
  • Assumption of full civil and administrative liability for all manufacturer obligations

Formal requirements for the power of attorney:

  • Notarization of the power of attorney
  • Hague Apostille (or equivalent legalization procedure for countries not party to the Apostille Convention)
  • Translation into Spanish (certified translation by a sworn translator)
  • A simple written agreement is not sufficient
  •  

NIF for non-residents: Before the authorized representative can complete registration in the RII-AEE, a Spanish NIF (Número de Identificación Fiscal) must be applied for on behalf of the foreign company – this is typically done by the authorized representative themselves.

Step 2: Classify the EEE category according to the Spanish system

Spain uses its own 7-category system for WEEE, which differs from the 6 EU categories in the WEEE Directive:

Cat. 1 – Large household appliances: Washing machines, refrigerators, stoves
Cat. 2 – Small household appliances: Toasters, coffee makers, vacuum cleaners
Cat. 3 – IT and telecommunications equipment: PCs, laptops, smartphones, routers
Cat. 4 – Consumer electronics and photovoltaics: Televisions, monitors, PV modules
Cat. 5 – Lighting equipment: LEDs, fluorescent tubes, compact lamps
Cat. 6 – Electric and electronic tools: Drills, saws, sewing machines
Cat. 7 – Toys, leisure, and sports equipment: Electronic toys, game consoles

Separate reporting for household and commercial use: Within each category, a distinction must be made between B2C (household) devices and B2B (professional) devices – both are reported separately and priced differently.

Step 3: Membership in an Authorized SCRAP

In Spain, the physical handling of the collection, transport, and recycling of waste equipment is carried out almost exclusively by state-authorized SCRAPs (Sistema Colectivo de Responsabilidad Ampliada del Productor). Membership in a SCRAP simultaneously exempts the manufacturer from the obligation to provide an individual financial guarantee – the SCRAP provides the collective guarantee for all members.

Costs: A one-time admission fee, typically €100–500, plus annual dues proportional to the quantities placed on the market.

Step 4: Mandatory Registration with the RII-AEE

Registration with the RII-AEE must take place before EEE is first placed on the market in Spain.

Portal: industria.gob.es (WEEE / RII-AEE section)

Procedure:

  1. Complete membership in a SCRAP (Step 3)
  2. Submit an online application on the RII-AEE portal, providing the Spanish NIF
  3. Specify the EEE categories, brands, distribution channels, and provide proof of SCRAP membership
  4. Pay the registration fee
  5. Receive the REG-RAEE number

Step 5: Financial Obligations & Fee Structure

Eco-fees are calculated based on the number of units, weight, and EEE category.

Fee Range (Royal Decree 110/2015):

€0.01 to €5.00 per device, depending on category and weight

 

Differentiation Between B2C and B2B:

  • B2C: Fixed rates set by SCRAP
  • B2B: Customized contracts with SCRAP are often possible; In some cases, costs are incurred only upon the actual return of the end-of-life device

Financial guarantee exemption through SCRAP membership:

A major advantage of SCRAP membership: Manufacturers are not required to provide their own collateral (such as bank guarantees or insurance) to cover future disposal costs. SCRAP collectively assumes this guarantee towards MITECO.

Step 6: Reporting Requirements: Quarterly + Annual Consolidation

Quarterly Reports (Primary Requirement)

  • Content: Exact quantities (units + kilograms) of EEE placed on the market in Spain, broken down by Spanish categories and B2C/B2B
  • Frequency: Quarterly, in the month following the end of each quarter:
    • Q1 (Jan–Mar) → Report due by the end of April
    • Q2 (Apr–Jun) → Report due by the end of July
    • Q3 (Jul–Sep) → Report due by the end of October
    • Q4 (Oct–Dec) → Report due by the end of January

Consolidated Annual Report

  • Submission due by January 31 of the following year
  • Includes all four quarterly reports as well as an overview of collection rate compliance

Step 7: Labeling Requirements

1. Crossed-out trash can symbol: Must be permanently affixed to the device or – if the device is too small – to the packaging

2. Manufacturer information on the product: The manufacturer’s name or registered trademark must be clearly visible on the device (traceability).

Step-by-Step Checklist

(a) Companies based in Spain

1. Classify EEE into the 7 Spanish WEEE categories; clarify the B2C/B2B breakdown

2. Select SCRAP and complete the membership process

3. Register on the RII-AEE portal; obtain a REG-RAEE number

4. Include the REG-RAEE number on all invoices, the website, and in marketplace profiles

5. Affix the crossed-out trash can symbol and manufacturer information to devices and packaging

6. Submit quarterly volume reports via the RII-AEE portal

7. Submit the annual consolidated report by January 31

(b) Companies from other EU countries

1. Appoint an authorized representative in Spain

2. Apply for a Spanish NIF (Número de Identificación Fiscal) for non-residents through the authorized representative

3. The authorized representative must sign up for SCRAP membership on behalf of the foreign manufacturer

4. The authorized representative must complete registration with the RII-AEE and obtain a REG-RAEE number

5. Provide the REG-RAEE number to Amazon.es and other marketplaces to avoid account suspensions

6. Ensure structured data: quantity + weight by category + B2C/B2B for quarterly reports

7. Check labeling: waste bin symbol + manufacturer information on devices/packaging for the Spanish market

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

1. Verify whether a Spanish importer acts as the legal manufacturer (B2B supply chain) – if so, provide the partner with supply chain data (weight, category) in a timely manner

2. For direct B2C shipments: Appoint an authorized representative in Spain

3. Complete all steps in checklist (b) through the authorized representative

4. Customs compliance: Enter the REG-RAEE number correctly in customs declarations to avoid import restrictions

Step-by-Step Checklist

(a) Companies based in Spain

1. Classify EEE into the 7 Spanish WEEE categories; clarify the B2C/B2B breakdown

2. Select SCRAP and complete the membership process

3. Register on the RII-AEE portal; obtain a REG-RAEE number

4. Include the REG-RAEE number on all invoices, the website, and in marketplace profiles

5. Affix the crossed-out trash can symbol and manufacturer information to devices and packaging

6. Submit quarterly volume reports via the RII-AEE portal

7. Submit the annual consolidated report by January 31

(b) Companies from other EU countries

1. Appoint an authorized representative in Spain

2. Apply for a Spanish NIF (Número de Identificación Fiscal) for non-residents through the authorized representative

3. The authorized representative must sign up for SCRAP membership on behalf of the foreign manufacturer

4. The authorized representative must complete registration with the RII-AEE and obtain a REG-RAEE number

5. Provide the REG-RAEE number to Amazon.es and other marketplaces to avoid account suspensions

6. Ensure structured data: quantity + weight by category + B2C/B2B for quarterly reports

7. Check labeling: waste bin symbol + manufacturer information on devices/packaging for the Spanish market

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

1. Verify whether a Spanish importer acts as the legal manufacturer (B2B supply chain) – if so, provide the partner with supply chain data (weight, category) in a timely manner

2. For direct B2C shipments: Appoint an authorized representative in Spain

3. Complete all steps in checklist (b) through the authorized representative

4. Customs compliance: Enter the REG-RAEE number correctly in customs declarations to avoid import restrictions

Are you planning to sell your products in Spain?

Are you planning to sell your products in Spain? We’ll help you ensure compliance with Spain’s EPR regulations for WEEE so you can get started with legal certainty.

Are you planning to sell your products in Spain?

Are you planning to sell your products in Spain? We’ll help you ensure compliance with Spain’s EPR regulations for WEEE 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