Extended producer responsibility (EPR) is a legal obligation that requires producers to finance and manage the waste generated by the products they place on the market.
In Spain, amongst other products, this applies to batteries and accumulators, as well as to electrical and electronic equipment (WEEE). The main legal framework is established in Royal Decree 110/2015 of 20 February on waste electrical and electronic equipment (WEEE, known in Spain as RAEE) and Royal Decree 106/2008 of 1 February on batteries and accumulators and the environmental management of their waste.
Who must register
In Spain, registration is required for:
- Manufacturers placing electrical or electronic equipment or batteries on the Spanish market under their own brand.
- Importers of these products for sale in Spain. Actually, if you are not registred, you will not be able to import the goods.
- Distance sellers established outside Spain who sell to Spanish consumers.
- Repackagers or rebranders placing on the market products made by third parties under their own brand.
Note: platforms such as Amazon or eBay require a valid producer registration number before allowing the sale of batteries or electronic devices.
Batteries & Electronics (EPR) registration in Spain
Registration is carried out separately depending on the type of product, but in both cases it is managed through a SCRAP (collective extended producer responsibility system), which then communicates the registration to the competent authority.
At VAT & GREEN TAX we coordinate all the paperwork and we carry out the registration process on your behalf.
Registration of EEE producers (RAEE)
Regulated by Royal Decree 110/2015, producers must join an authorised SCRAP for electrical and electronic equipment. The SCRAP will:
- Collect the company’s details and tax identification number.
- Identify the EEE categories to be marketed according to Annex III of Royal Decree 110/2015.
- Submit quarterly returns before the SCRAP
- Submit the registration to the Integrated Industrial Register (RII) on behalf of the producer.
- Provide the official registration number.
- Appoint a Spanish entity to act as the representantive.
Registration of battery and accumulator producers
Regulated by Royal Decree 106/2008, producers must join an authorised SCRAP for batteries and accumulators. The SCRAP will:
- Identify the type of batteries or accumulators placed on the market (portable, automotive, or industrial).
- Record the company’s details, tax identification number, categories, and estimated quantities.
- Submit the registration to the Register of Battery and Accumulator Producers on behalf of the producer.
- Provide the official registration number to be used on all invoices and product documentation.
Recommendations and professional services
The EPR process in Spain involves multiple legal obligations beyond simply obtaining a registration number. Producers must also meet periodic reporting requirements, maintain documentation for inspections, and ensure that their SCRAP fees are calculated correctly based on the quantities placed on the market.Likewise, they have to appoint a Spanish entity to carry out all this tasks.
As a tax and compliance adviser specialised in EPR, batteries, and RAEE in Spain, we offer for more than 250 clients:
- Obtainment of a Spanish NIF if necessary.
- Complete EPR registration management through authorised SCRAPs. We offer also for Packaging (if necessary).
- Ongoing compliance with reporting deadlines and data validation.
- Acting as representantive in Spain.
- Integration with other environmental obligations, such as packaging EPR, for a coordinated approach. Only one contact point.
Recommendation:
Start the registration process before placing products on the Spanish market. This avoids blocked sales on platforms, administrative penalties, and reputational risks. Work with an adviser who understands both the legal and operational aspects of EPR to ensure that compliance is handled efficiently and without unnecessary costs.
If you need more clarification, call us 0034 673045233 or send an e-mail hola@vatgreentax.com
