Selling packaged products in Spain is no longer only a VAT, customs or logistics issue. Companies placing packaging or packaged products on the Spanish market must also review their obligations under Spanish EPR, or extended producer responsibility.
This is especially relevant for foreign companies selling into Spain through ecommerce, marketplaces, distributors or direct B2B channels.
Spain already has a specific legal framework for packaging and packaging waste: Royal Decree 1055/2022. However, the European Union has approved Regulation (EU) 2025/40 on packaging and packaging waste, also known as the PPWR.
This new Regulation will apply, as a general rule, from 12 August 2026. Until the new Spanish implementing rules are approved, companies need to understand which obligations remain in force, which ones may change, and what should be done now.
VAT & Green Tax helps companies comply with Spanish EPR obligations for packaging and acts as authorised representative in Spain when required.
Spanish EPR: the current packaging framework in Spain.
The current Spanish packaging regime is mainly regulated by Royal Decree 1055/2022 on packaging and packaging waste.
This regulation created the packaging section of the Spanish Product Producers Register and requires producers to register and report information on the packaging placed on the Spanish market.
In practice, companies may need to comply with several obligations:
- Obtaining a Spanish tax identification number.
- Register in the Product Producers Register, packaging section.
- Obtain a Spanish EPR registration number.
- Join or contract an individual or collective EPR system where applicable.
- Report packaging placed on the Spanish market.
- Keep supporting documentation on packaging materials, weights and categories.
Appoint an authorised representative in Spain when the producer is not established in Spain and sells packaged products into the Spanish market.
This is not only relevant for large groups. Many SMEs, ecommerce sellers and international companies are affected when they sell packaged products to customers in Spain.
Who must register for Spanish packaging EPR?
The obligation depends on the role of the company in the supply chain.
In general, the Spanish rules may affect packaging producers, importers, intra-EU acquirers, ecommerce sellers, marketplace operators and companies placing packaged products on the Spanish market.
A foreign company may be affected if it sells packaged products directly into Spain, even if it has no Spanish subsidiary.
This is one of the most common mistakes. Many companies assume that they are not subject to Spanish EPR because they are not physically established in Spain. That is not always correct.
The analysis must consider who places the packaged product on the Spanish market, who sells to the final customer, whether there is a Spanish distributor, and whether the transaction is made through a marketplace.
What does the Spanish Ministry say?
The Spanish Ministry for the Ecological Transition has published several documents and notes explaining the packaging register and the coexistence between Royal Decree 1055/2022 and Regulation (EU) 2025/40.
The Ministry has confirmed that the European Regulation will be fully applicable in Spain, as a general rule, from 12 August 2026.
It also explains that the Regulation will prevail over any incompatible national provision. This means that, if a provision of Royal Decree 1055/2022 conflicts with Regulation (EU) 2025/40, the EU rule will prevail.
However, this does not mean that the Spanish packaging EPR system disappears.
Until the new Spanish Royal Decree enters into force, the applicable framework will be based on Regulation (EU) 2025/40 and, for matters not regulated or not incompatible with it, Royal Decree 1055/2022.
This is a key point for companies. The current Spanish registration, reporting and EPR obligations should not be ignored simply because a new European Regulation has been approved.
What changes from August 2026?
From 12 August 2026, Regulation (EU) 2025/40 will become directly applicable in Spain, except for provisions with later application dates.
The Regulation introduces a more harmonised EU framework for packaging. Its objective is to reduce fragmentation between Member States and create clearer rules on packaging sustainability, labelling, recyclability, reuse and extended producer responsibility.
The main changes will affect areas such as:
- Packaging sustainability requirements.
- Recyclability and design for recycling.
- Reduction of excessive packaging.
- Harmonised labelling requirements.
- Reuse and refill obligations.
- Rules on producer registration and EPR.
- Deposit return schemes for certain packaging formats.
- Reporting and traceability obligations.
However, not all provisions apply on the same date. Some obligations will apply later, for example in 2028, 2029 or 2030, depending on the specific article and the implementing acts to be adopted by the European Commission.
Spain is preparing a new Royal Decree for Packaging.
Spain already has Royal Decree 1055/2022, but the Ministry has also started the process for a new Royal Decree on packaging and packaging waste.
The purpose of this future regulation is to adapt the Spanish framework to Regulation (EU) 2025/40 and to clarify those areas where the European Regulation allows or requires national implementation.
This future Spanish Royal Decree may address issues such as packaging labelling, compostability, restrictions on certain packaging formats, reuse targets, producer registration, EPR systems, deposit return schemes, reporting and recycling objectives.
Until that new Royal Decree is approved and enters into force, companies should continue managing their Spanish packaging EPR obligations under the current framework, while monitoring the changes introduced by the European Regulation.
Does the Spanish packaging registration remain in place?
Yes. The Spanish Product Producers Register remains relevant.
Companies placing packaging or packaged products on the Spanish market should continue to review whether they must register in the packaging section of the Product Producers Register.
The registration number remains important for compliance, invoicing, clients, marketplaces, and distributors.
In practice, many operators are already requesting evidence of Spanish EPR registration before allowing products to be sold or distributed in Spain.
This is particularly common in ecommerce, marketplace and retail environments.
What information is reported under Spanish packaging EPR?
The annual reporting obligation generally refers to the packaging placed on the Spanish market during the relevant year.
Companies must usually collect and classify information such as:
- Packaging material.
- Packaging weight.
- Domestic, commercial or industrial packaging.
- Reusable or single-use packaging.
- Packaging units or quantities.
- Products placed on the Spanish market.
- The exact reporting requirements depend on the company’s activity, packaging volumes and position in the supply chain.
Companies placing less than certain thresholds of packaging on the market may be able to use simplified reporting, but this must be reviewed carefully.
Authorised representative for Spanish EPR
Foreign producers selling packaged products in Spain may need to appoint an authorised representative in Spain.
The authorised representative acts in Spain for EPR purposes and helps ensure that the producer complies with its obligations under the Spanish packaging regime.
This is especially important for companies established in another EU Member State or in a third country that commercialise packaged products in Spain.
If no authorised representative is appointed when required, other operators in the Spanish supply chain may become exposed to subsidiary responsibilities.
VAT & Green Tax acts as authorised representative for packaging EPR in Spain and supports foreign companies with registration, reporting and ongoing compliance.
How long does Spanish EPR registration take?
VAT & Green Tax can usually register a company in the Spanish packaging register within 2 to 3 working days when the company already has a Spanish NIF and the necessary documentation is available.
If the company does not yet have a Spanish NIF, the process usually takes longer. In these cases, registration may take approximately 3 to 4 weeks, depending on the documentation, powers of attorney and administrative processing times.
This is why companies should not wait until a marketplace, client or distributor blocks their sales.
Spanish EPR registration should be handled before the commercial issue appears.
Why companies should act now
The approval of Regulation (EU) 2025/40 does not eliminate current Spanish EPR obligations.
On the contrary, the trend is towards more control, more traceability and more harmonised compliance across the European Union.
Companies selling packaged products in Spain should review:
- Whether they are considered producers for Spanish EPR purposes.
- Whether they need to register in the packaging section of the Product Producers Register.
- Whether they need an authorised representative in Spain.
- Whether their packaging data is correctly classified.
- Whether they must join an EPR system.
- Whether their invoices, marketplace information and internal records are aligned.
- Whether upcoming PPWR changes could affect labelling, packaging design or reporting.
A preventive review is usually easier and cheaper than correcting an EPR issue after a client, marketplace or authority has detected it.
VAT Green Tax: Spanish EPR support for foreign companies
VAT & Green Tax helps foreign companies comply with Spanish EPR obligations for packaging.
We assist with the analysis of the obligation, registration in the Spanish Product Producers Register, appointment as authorised representative, coordination with EPR systems and preparation of annual packaging declarations.
We also support companies selling in several European countries by coordinating EPR compliance from a single point of contact.
This allows companies to avoid fragmented advice, duplicated work and inconsistent positions across different EU markets.
If your company sells packaged products in Spain, now is the right time to review your Spanish EPR position.
Contact VAT Green Tax and we will assess whether your company must register, appoint an authorised representative or report packaging placed on the Spanish market. Contact with us if you requiere any clarification. Our email is hola@vatgreentax.com
FAQS
Is Spanish EPR registration still required after the new EU Packaging Regulation?
Yes. The new EU Packaging Regulation will apply from 12 August 2026, but the Spanish register remains relevant. Until the new Spanish Royal Decree is approved, companies must apply Regulation (EU) 2025/40 and Royal Decree 1055/2022 where it remains applicable and compatible.
Does Spain already have packaging EPR rules?
Yes. Spain already has Royal Decree 1055/2022, which regulates packaging and packaging waste and created the packaging section of the Product Producers Register.
Is there a new Spanish Royal Decree in process?
Yes. The Spanish Ministry has started the process for a new Royal Decree to adapt the national framework to Regulation (EU) 2025/40 and clarify the provisions requiring national implementation.
Can VAT & Green Tax register my company for Spanish packaging EPR?
Yes. VAT & Green Tax can manage the Spanish packaging EPR registration process. If the company already has a Spanish NIF, the registration can usually be completed in 2 to 3 working days, provided the documentation is available.
What happens if my company does not have a Spanish NIF?
If the company does not have a Spanish NIF, the process usually takes longer. In practice, it may take around 3 to 4 weeks, depending on the documentation and administrative processing.
Can VAT & Green Tax act as authorised representative in Spain?
Yes. VAT & Green Tax can act as authorised representative for Spanish packaging EPR and support foreign companies with registration, reporting and ongoing compliance.
