Spanish EPR for Packaging: Key issue updated to 2026

Royal Decree 1055/2022, of December 27, has significantly changed the landscape for Spanish EPR packaging compliance in Spain. It introduces a comprehensive framework that affects any company placing packaged goods on the Spanish market, with strict obligations, registration requirements and reporting deadlines.

In practice, this regulation impacts a wide range of businesses, particularly foreign companies selling into Spain through e-commerce or cross-border operations. From our experience advising more than 200 companies, we regularly see that many businesses are not fully aware of their obligations until they face a requirement or potential penalty.

If you sell packaged goods to customers in Spain—whether through your own website, marketplaces, or logistics platforms- this regulation likely applies to you. Understanding your obligations is essential not only to remain compliant, but also to avoid operational disruptions.

At VAT Green Tax, we support companies throughout the entire process on an end-to-end basis. This includes assessing whether the regulation applies to your business, handling the registration process, obtaining a Spanish tax identification number (NIF) where required, acting as your Authorized Representative (Spanish AR) and managing all interactions with Producer Responsibility Organizations (PROs).

Our approach is to simplify compliance, reduce internal workload and ensure that everything is handled correctly from the outset.

Below, we outline the key obligations and practical considerations based on our experience, so you can address them efficiently and avoid common issues.

Registration in the Product Producers Registry (Packaging Section). ENV number.

According to Article 15 of the Royal Decree, product producers or their authorized representatives must register in the packaging section of the Product Producers Registry. This registration must be completed within three months from the decree’s entry into force, meaning before March 29, 2023.

A product producer is understood as the entity that packages products marketed in Spain. It is important to clarify that, in some cases, even if a company only acts as a distributor or reseller, it may still be considered a product producer under this regulation.

The ENV number is the information that could be requested for certain clients or plataforms to sell goods in Spain,

For this reason, it is advisable to review the nature of business operations to determine the impact of this regulation. If you need guidance, feel free to reach out to us for further assistance.

Adherence to a Spanish Extended Producer Responsibility System (PRO)

After analyzing the company’s operations, adherence to an Extended Producer Responsibility System (PRO) is required. This ensures that the financing of the management of packaging placed on the market is handled through these systems.

Several SCRAPs are authorized by MITESCO. However, depending on the type of packaging introduced to the market (domestic, commercial, or industrial), companies must select the appropriate system.

Annual packaging declaration

Producers must submit annual reports on the packaging they place on the national market. For packaging introduced in 2025, the reporting deadline is from January 1 to March 31, 2026.

Additionally, during February, companies must submit a declaration to the chosen Extended Producer Responsibility system (PRO).

Other obligations under the packaging Royal Decree. Spanish EPR.

Beyond registration as a Product Producer, adherence to an Extended Producer Responsibility System, and submission of annual packaging declarations, companies must comply with the following obligations:

• Appointing a Spanish representantive (AR).
• Invoicing Requirements: The Product Producer registration number assigned by MITESCO (ENV number) must be included in all invoices, identifying the responsible entity for the packaging. Additionally, invoices must specify the contribution made to the SCRAP.
• Labeling Obligation: For certain types of packaging, it is mandatory to indicate, among other aspects, the appropriate disposal container.
• Implementation of Packaging Reduction Measures: If certain thresholds are exceeded, companies must implement strategies to reduce packaging waste.

Additional considerations

• Definition of Packaging: The Royal Decree defines “packaging” as any product made from any material used to contain, protect, handle, distribute, and present goods—from raw materials to finished products—at any stage of the manufacturing, distribution, and consumption chain. (Source: miteco.gob.es)
• Interpretative Note on the Definition of Product Producer: An interpretative note has been published to clarify certain aspects related to the definition of “Product Producer” under Article 2.t) of the Royal Decree. (Source: miteco.gob.es)
• Distinction Between the Packaging Royal Decree and the Non-Reusable Plastic Packaging Tax: It is essential not to confuse this regulation with the tax on non-reusable plastic packaging, as they have different compliance requirements.

It is also important to note that EPR obligations in Spain go beyond packaging. If your business involves electronic equipment or batteries, additional compliance requirements may apply. You can explore this in our WEEE and batteries EPR guide for Spain.

Ensure compliance and avoid penalties due to Spanish EPR.

Businesses and producers subject to this regulation must clearly understand their obligations and deadlines to ensure compliance. In practice, non-compliance can lead to significant consequences, including penalties exceeding €100,000, the seizure of products and, in some cases, the inability to sell through certain platforms or work with key clients.

For more details and expert advice on the Packaging Royal Decree and the Non-Reusable Plastic Packaging Tax,

We can quickly assess whether your business is affected and handle the entire process on your behalf.

Feel free to contact us. We can quickly assess whether your business is affected and handle the entire process on your behalf or through our e-mail hola@vatgreentax.com. We can get everything done in less than 7-10 working days.

Frequently Asked Questions (FAQ)

Who is considered a product producer under Spanish EPR rules?

A product producer is not only a manufacturer. In practice, many companies acting as distributors, resellers or e-commerce sellers may also be considered producers if they place packaged goods on the Spanish market. This is one of the most common points of confusion we see with our clients.

Do foreign companies need to comply with Spanish EPR obligations?

Yes. Non-Spanish companies selling packaged goods into Spain are also subject to these rules. In most cases, they are required to appoint a Spanish Authorized Representative (AR) to act on their behalf.

What is the ENV number and why is it important?

The ENV number is the registration number obtained after registering in the Product Producers Registry. It is often requested by marketplaces, clients and logistics providers as proof of compliance. Without it, companies may face restrictions when selling in Spain.

How long does the EPR registration process take?

At VAT & GREEN TAX we know that time is important for our client. Our approach ensures that the standard EPR registration process is completed within 4 to 6 weeks. For time-sensitive situations, we offer an accelerated service, completing the process within 7 to 10 working days, including the obtainment of a Spanish NIF.

Is the process complex for foreign companies with VAT & GREEN TAX?

The process is more straightforward than it may seem. The entire notarisation and documentation process can be handled online, making it simple, fast and cost-efficient. We manage this process on behalf of our clients to ensure everything is completed correctly from the outset.

Is it mandatory to join a PRO (SCRAP) in Spain?

Yes. Companies placing packaging on the Spanish market must adhere to an authorized Producer Responsibility Organization (PRO). The correct system depends on the type of packaging (household, commercial or industrial).

What happens if a company does not comply with Spanish EPR obligations?

Non-compliance can have serious consequences. Penalties can exceed €100,000, products may be seized and companies may face restrictions when selling through marketplaces or working with certain clients.

Do I need a Spanish NIF for EPR compliance?

Yes. Especially for foreign companies, obtaining a Spanish Tax Identification Number (NIF) is a necessary step to complete the registration and operate correctly.

What are the main ongoing obligations after registration?

Once registered, companies must submit annual packaging declarations, report to the selected PRO, include the ENV number in invoices and comply with labeling and packaging reduction requirements.

When do I need to submit the annual packaging declaration?

For packaging placed on the market in 2025, the declaration must be submitted between January 1 and March 31, 2026. For 2026, the deadline will be in 2027.

Additionally, reporting to the PRO is usually required in February.

Can I manage EPR compliance internally?

It is possible, but in practice we see that it requires ongoing monitoring, regulatory understanding and coordination with multiple stakeholders. Many companies prefer to externalize the process to ensure compliance and avoid risks. Specially, when it is not a Spanish company which would requiere a Spanish Representantive.

How does VAT & Green Tax support companies with EPR compliance?

We manage the entire process end-to-end. This includes assessing whether the regulation applies, handling registration, obtaining a Spanish NIF, acting as Authorized Representative and managing all interactions with PROs. Our goal is to ensure full compliance while reducing the internal workload for our clients.