Spain EPR

What is Spanish EPR for Packaging

Spain’s Extended Producer Responsibility (EPR) for packaging is regulated under:

• Law 7/2022 on Waste and Contaminated Soils
• Royal Decree 1055/2022 on Packaging and Packaging Waste

It requires companies that place packaged products on the Spanish market to finance and organize the collection, recycling, and treatment of packaging waste.

The law fully applies to household, commercial, and industrial packaging.

The objective is to:

• Increase recycling rates
• Promote eco-design
• Reduce packaging waste
• Support circular economy goals

Does This Apply to E-Commerce & Online Sales

Yes. Absolutely.

EPR applies to:

• Distance sellers shipping to Spain
• Non-Spanish companies selling via marketplaces
• Amazon, Shopify, eBay sellers
• Cross-border B2C sellers

If you ship packaged goods to customers in Spain — you are in scope.

Who is the Producer Under Spanish EPR

The “producer” is the entity that first places packaging on the Spanish market.

This includes:

• Spanish manufacturers
• Importers into Spain
• Distributors introducing packaged goods
• Online sellers selling cross-border into Spain
• Businesses using service packaging (bags, takeaway packaging, etc.)

For cross-border e-commerce, the foreign seller is considered the producer.

Who Must Register for Spanish Packaging EPR

All producers placing packaging on the Spanish market must:

1. Register with the Spanish Register of Product Producers (RPP) managed by the Ministry for Ecological Transition (MITECO)
2. Join an authorized Producer Responsibility Organization (PRO / SCRAP) OR establish an Individual Compliance System (SIRAP)

There is no minimum threshold exemption.

Even small sellers must register.

Spanish EPR Packaging Registration Threshold

There is no EPR Packaging thresholds in Europe de minimis.

If you place any amount of packaging on the Spanish market, registration is required.

EPR and PPWR for Spain

Companies selling packaged goods into Spain deal with two separate regulatory layers. First, there's SCRAP—Spain's collective system where you pay into a fund that finances waste collection and sorting. You register with the ministry, put down your annual volumes by material, and that satisfies Spain's domestic waste management rules. It's been working this way for years and isn't going anywhere. Register for PPWR and EPR in Spain with Lappa using our fee quote form or use EPR and PPWR compliance software from Lappa.

Then PPWR arrives in August 2026 and tackles something entirely different: what packaging actually looks like before it hits the shelf. The regulation cares about what materials are inside, how recyclable the design is, whether inks contain harmful chemicals, how much recycled plastic is baked in. None of that touches your SCRAP registration or fees. You're still paying into Spain's system; you've just got new rules about packaging engineering on top of it.

One thing that works in Spain's favour: unlike France, which has a national Triman logo requirement, Spain never mandated a single national labelling scheme. Spain asks for sorting symbols (the coloured bin icons), but there's no equivalent to France's legal battle over labelling. When PPWR's harmonised pictograms show up in 2028, there's less friction because Spain's existing system already sits lighter. That said, the transition still requires rethinking label designs and artwork placement.

PPWR Labels for Spain

PPWR labelling requirements for Packaging sold into Spain currently wears sorting symbols—four colour options telling consumers which bin it goes into. Yellow for plastic and metals. Blue for paper. Brown for compostables. Green for glass. These became mandatory on January 1, 2025, and there are no more extensions. If it's not physically printed on the package, you're not compliant with Spanish law. If you are interested in digital compliance labels from Lappa, we recommend to check our label manager.

PPWR flips that on its head starting 12 August 2028. Instead of "which bin," the new pictograms say "what is it" and "how recoverable." Material composition, recyclability grade, recycled-content percentage—all signalled through EU-wide standardised icons. It's solving a different problem than Spain's sorting system.

What happens in between 2028 and 2030? Probably both. Spanish retailers and online sellers will need to print sorting symbols (national law) and PPWR pictograms (EU law) on the same package. That's messier than ideal, but unavoidable. Eventually Spain may streamline or align the two, but for now, label real estate gets tighter and design costs climb.

PPWR Product Rules for Spain

Four separate rules land between now and 2030, each one a hard line, not a suggestion.

• Right now, August 2026: Certain chemicals used in inks, coatings, and barriers—specifically PFAS—are capped at 25 to 250 parts per billion. A food-contact surface with water-repellent coating that exceeds the limit? That shipment doesn't clear Spanish customs. No waivers for low volumes or phased timelines. It's immediate.
• January 2030: Every piece of packaging needs to be engineered so it actually recycles. That means the material choice, the glue holding labels on, the plastic closure snapped onto a glass jar—all of it gets tested or certified against PPWR criteria. Suppliers haven't widely done this work yet. Spanish companies should start now because the testing cycle takes months.
• January 2030: Recycled content hits hard minimums. Plastic packaging must be 30% recycled; cardboard 90%; glass 40%; aluminium 50%. It's not aspirational. Documentation proving where the recycled material originates is mandatory. Suppliers claiming recycled content without traceability get rejected.
• January 2030: Oversized or padded packaging draws scrutiny. The rule is simple: use what's necessary, nothing more. Air-filled boxes, excess cushioning, packaging that's bigger than the product inside—all of it faces enforcement action. The specific thresholds vary by product category and are still being defined, so early engagement with industry groups and SCRAP advisors makes sense.

Packaging Covered (and Excluded)

Covered Packaging

Spain applies EPR to:

• Primary packaging (product packaging)
• Secondary packaging (grouped packaging)
• Tertiary packaging (transport packaging)
• Household packaging
• Commercial packaging
• Industrial packaging

Materials Covered

• Plastic
• Paper & cardboard
• Glass
• Metals (steel, aluminum)
• Wood
• Composite materials

Not Covered Under This Scheme

• Batteries (separate EPR)
• WEEE (electronics)
• Tyres
• Other regulated waste streams

Producer Responsibility Organization (PRO / SCRAP)

Producers must join an authorized SCRAP (Sistema Colectivo de Responsabilidad Ampliada del Productor).

Major examples include:

• Ecoembes – household packaging (plastic, metal, paper)
• Ecovidrio – glass packaging
• Procircular – multi-material packaging

Each PRO sets its own fee structure.

Alternatively, companies may establish an Individual System (SIRAP), though this is rare and complex.

EPR Registration in Spain – Step-by-Step

1. Obtain a Spanish tax ID (NIF)
2. Appoint an Authorized Representative (if non-resident)
3. Join a PRO (SCRAP)
4. Register in the official RPP register
5. Obtain your Producer Registration Number
6. Start reporting packaging volumes
7. Pay eco-fees

Authorized Representative

If your company is not established in Spain, you must appoint a Spanish Authorized Representative.

The representative:

• Registers you in the RPP
• Handles communication with authorities
• Ensures reporting compliance
• Assumes legal responsibility

This is mandatory for foreign distance sellers.

What Data Must Be Reported?

Producers must report annually:

• Total weight of packaging placed on the Spanish market
• Breakdown by material (plastic, paper, glass, etc.)
• Type of packaging (household, commercial, industrial)
• Recycled content (if applicable)
• Reusable packaging (if applicable)

Reports are submitted to:

• The PRO (for fee calculation)
• The Spanish authorities (via RPP)

First Reporting Period

The packaging regulation became fully operational from:

1 January 2025
(Extension to commercial and industrial packaging included.)

Registration obligations started earlier (2023–2024).

EPR Reporting Deadlines

Deadlines vary depending on the PRO, but generally:

• Annual reporting for previous year volumes
• Reporting typically due in Q1 or Q2
• Eco-fees payable annually (sometimes quarterly advances)

Always confirm with your specific PRO.

Labels & Marketing Claims

Spain does not have a single mandatory recycling logo for all packaging. However, the "Recicla" label — managed by Ecoembes, Spain's packaging PRO — is widely used and strongly recommended for producers placing packaging on the Spanish market.

An example of what a label looks like on packaging for Spain

This packaging shows the blue "Recicla" label used for paper and cardboard packaging. The blue colour indicates that the packaging should be placed in the blue recycling bin (contenedor azul), which collects paper and cardboard across Spain. The label appears on boxes, bags, and cartons.

📎 Download the Recicla label for paper/cardboard:

•  PNG – best for digital use.
•  SVG  - ideal for printing and scaling.

Recicla label — yellow bin (plastic, cans, cartons)

This packaging shows the yellow "Recicla" label used for plastic bottles, metal cans, and drink cartons. The yellow colour indicates that the packaging should be placed in the yellow recycling bin (contenedor amarillo). The label is applied per packaging component and helps consumers identify the correct collection stream.

📎 Download the Recicla label for plastic/metal:

•  PNG – best for digital use.

EPR Eco-Fees & Eco-Modulation

Eco-fees depend on:

• Material type
• Weight
• Recyclability
• Recycled content
• Design sustainability

Eco-modulation means:

• Better recyclable packaging = lower fees
• Non-recyclable packaging = higher fees

Each PRO defines its own tariff tables.

Want to estimate your potential costs before registration? Use the EPR fee calculator to get an indicative estimate based on country, material type and packaging volume. For a broader overview of service costs, registration fees and ongoing compliance expenses, see our EPR pricing page.

Risks, Penalties & Common Mistakes

Risks & Penalties

Non-compliance may result in:

• Significant administrative fines
• Sales bans
• Marketplace delisting
• Legal enforcement actions

Fines can reach tens or hundreds of thousands of euros depending on severity.

Common Mistakes

• Assuming e-commerce is exempt
• Not registering industrial packaging
• Not appointing an Authorized Representative
• Underreporting packaging weights
• Using incorrect material classifications

What E-Commerce Sellers Should Do Now

1. Audit your packaging materials
2. Calculate annual packaging volumes
3. Determine if you qualify as a producer
4. Appoint an Authorized Representative (if needed)
5. Join a Spanish PRO
6. Register in the RPP
7. Implement packaging data tracking systems
8. Review eco-design opportunities to reduce fees

FAQ

• Do I need Spanish VAT registration to register for EPR?

Not necessarily — but you need a Spanish NIF and possibly an Authorized Representative.

• Does this apply to Amazon FBA sellers?

Yes, if you sell to Spanish customers.

• What happens if I don’t comply?

You risk fines, blocked sales, and marketplace enforcement.

• Is Amazon responsible for my packaging EPR?

No. The seller remains responsible unless the platform assumes producer status under specific circumstances.

• Is there a reporting threshold?

No. Any quantity triggers obligation.