The regulations on Extended Producer Responsibility (EPR) are in effect in many European countries. In a small series, we aim to address the legal provisions and their implementation outside of Germany. To start, we take a closer look at Spain.

In Spain, the „Ley 7/2022 Impuesto especial sobre los envases de plástico no reutilizables“ introduced a plastic tax starting in 2023. We previously reported on this in our news section.

The „Royal decreto sobre envases y embalajes“ (Royal Decree on Packaging) complements the law and also incorporates Extended Producer Responsibility (EPR). It includes precise definitions for the implementation of the law, as well as objectives for the prevention, reuse, and recycling of packaging. With the decree's announcement, the exact start date for packaging return systems was set for December 2024. As part of the Extended Producer Responsibility outlined in the accompanying Royal Decree, manufacturers are responsible for financing and organizing the waste management of their commercial and industrial packaging. This obligation can be fulfilled by the manufacturer individually or through participation in a collective collection system. This function is, for example, carried out by ENVALORA

In the course of a consulting project, RIGK is actively involved in implementing this take-back system for industrial and commercial packaging in Spain called ENVALORA to comply with EPR. ENVALORA is the Spanish take-back system (Sistema Colectivo de Responsabilidad Ampliada del Productor - SCRAP) for industrial and commercial packaging in the chemical, plastic, rubber, and construction sectors, with more than 890 companies already participating. The system will be operational at the beginning of 2025.

Who needs to report what, where?

Manufacturers and distributors of products and their packaging in Spain, as well as organizations selling products in Spain, must report their packaging quantities and types in a central register. Unlike the previous packaging law, in Spain since 2023, not only household packaging but also commercial, trade, and industrial packaging must be registered.

Registration is done through the Manufacturer Register („Registro de productores de Producto“) at the Spanish Ministry for the Ecological Transition and the Demographic Challenge (Ministerio para la Transición Ecológica y el Reto Demográfico, MITECO) electronically and must provide information annually on the packaging put into circulation.

However, reporting is only possible if a company has a Spanish tax number, thus maintaining a presence in Spain or appointing a Spanish representative. Otherwise, the Spanish importer is responsible for registering the imported packaging. After registration in the Registro, the company receives an RPP (Registro de Productor de Producto) number. This number must be included on invoices.

Deadlines:

Manufacturers and distributors of packaging in the Spanish market must adhere to deadlines regulating the reporting of their packaging data through the packaging register.

Current deadlines:

Reporting deadline for the reporting year 2024: End of March 2025

Here we provide a comprehensive overview of all current deadlines and obligations in Spain.

For further information:
Claudia Hoese
Customer Relationship Manager, RIGK GmbH
Phone: +49 611 308600-12
hoese(at)rigk.de