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13. April 2023

Extended Producer Responsibility (EPR) with Envalora in Spain - Registration Obligation

Extended Producer Responsibility

Within the scope of a consulting project, RIGK is active in implementing a take-back system for industrial and commercial packaging in Spain. With the new legislation, the Spanish government implements the obligation for extended producer responsibility (EPR) for industrial and commercial packaging for the first time. It specifies on the responsibility for the organization and financing of the recycling or removal of one-way and returnable packaging.  

This extended producer responsibility was part of a corresponding decree (1055/2022), passed in December 2022 and affected all companies that place packaged products on the Spanish market. The regulation also affects foreign companies that sell products to Spain and do not have a branch and tax number (CIF) in Spain.  

Even before December 2022, the Cicloplast  Association presented the Envalora take-back system.

Envalora is the Spanish take-back system (Sistema Colectivo de Responsabilidad Ampliada del Productor (SCRAP)) for industrial and commercial packaging from the chemical, plastics, rubber and construction sectors.

The system will be officially established and up and running before December 30, 2024; however, there are already about 450 companies participating in Envalora.

To comply with the EPR, companies must register in a national product manufacturer registry in the packaging section (RPP). Initially, the deadline for registration was the end of March 2023. Before this date, the responsible Ministry of Environmental Change and Demographic Challenges indicated that the deadlines would be extended and registration would be possible even after March 29 in 2023, to make registration possible for all manufacturers.  

Along with this, the notification of packaging quantities for 2021 and 2022 was also included the notification process.   

The following periods for notification have been set as follows:  

  • From 01.05.2023 to 31.07.2023. - Data collection period for the reporting year 2021.  

  • From 01.08.2023 to 31.10.2023. - Data collection period for the reporting year 2022.  

ENVALORA will assist those companies that have joined ENVALORA in the registration in the register of product manufacturers and the notification of quantity with a guide.    

If you have any further questions, please do not hesitate to contact us.  


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