Spain Packaging Plastic Tax (PPT): PPT Registration and Data Reporting
Quick answer: Spain’s PPT applies to the manufacture, import, and intra-EU acquisition of non-reusable plastic packaging (incl. semi-finished items and closures). The taxable base is the kilograms of non-recycled plastic in scope, taxed at €0.45/kg; manufacturers keep electronic accounting, intra-EU acquirers keep a stock register, and returns are filed via Model 592 (refunds via Model A22), typically by the 20th of the following month (1–15 if direct debit).
Workflow: Determine scope → certify recycled content → register/obtain CIP → file Model 592 / keep records → (if applicable) claim refunds with A22.
Spain Packaging Plastic Tax (PPT): PPT Registration and Data Reporting
Law 7/2022, in force since 1 January 2023, introduced the Special Tax on Non-Reusable Plastic Packaging (PPT) as part of Spain’s circular economy strategy. It applies to the manufacture, import, or intra-Community acquisition of non-reusable plastic packaging, semi-finished products (such as preforms and thermoplastic films), and products containing plastic intended to enable the closure, marketing, or presentation of packaging. Businesses must register with the Spanish Tax Agency, maintain proper records, and submit tax returns electronically using Form 592 (self-assessment) and Form A22 (refund request).
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Spain EPR PPT Requirements Manufacturers, Importers and Ecommerce
Under the PPT, the following obligations apply to different actors:
- Manufacturers: Must register in the territorial registry, obtain a plastic identification code (CIP), keep electronic accounting of products and raw materials, and file Form 592.
- Importers: Pay the tax at customs and declare the amount of non-recycled plastic in kilograms. They are exempt from maintaining accounting or stock records.
- Intra-Community acquirers: Must register in the tax registry, keep a stock register, and submit Form 592 unless acquisitions are below 5 kg/month of non-recycled plastic packaging (in which case they are exempt).
- E-commerce sellers not established in Spain: Must appoint a representative established in Spain who is responsible for compliance and registration.
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Covered and Exempted Packaging under Spain PPT
The PPT covers:
- Non-reusable plastic packaging placed on the Spanish market
- Semi-finished plastic products used to produce non-reusable packaging (e.g., preforms, thermoplastic films)
- Plastic products for closure, marketing, or presentation of non-reusable packaging
Exemptions include:
- Small operators: intra-Community acquisitions under 5 kg of non-recycled plastic per month
- Packaging for medicines, medical devices, special medical foods, infant formula for hospital use, or hazardous medical waste
- Semi-finished products for producing such exempted packaging
- Plastic rolls used in silage for agriculture or livestock
- Exported products or those sent outside Spain before the tax is due
- Products destroyed or rendered unusable before the tax is due, with proof provided to the Tax Agency
- Semi-finished plastics not intended for packaging within the scope
- Plastic components not intended for closure, marketing, or presentation of non-reusable packaging
- Paints, inks, lacquers, and adhesives incorporated into packaging products
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Who Must Register under Spain PPT
- Manufacturers of non-reusable plastic packaging and semi-finished plastic products (must register with the territorial registry before starting activity).
- Intra-Community acquirers of non-reusable plastic packaging (mandatory registration if exceeding 5 kg of non-recycled plastic per month).
- Non-resident taxpayers must appoint and register a tax representative in Spain before carrying out taxable operations.
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Spain PPT Data Reporting
Obligated parties must provide detailed data for compliance, including:
- Quantity of non-recycled plastic in kilograms for each product
- Certification of recycled plastic content by an accredited body (UNE-EN 15343:2008 or successor standard). For chemically recycled plastic, certification by an accredited or authorized entity is required
- Invoices and delivery notes must indicate the tax amount due, the weight of non-recycled plastic, and reference to applicable exemptions
- Certificates or invoices (other than the first sale) must include the tax paid or exemption reference and the weight of non-recycled plastic
- Imports: Customs declarations must state the amount of non-recycled plastic in kilograms and any applicable exemptions
- Stock records: Intra-Community acquirers must maintain a stock register via the electronic Tax Agency system
- Accounting records: Manufacturers must record both products and raw materials in an electronic accounting system through the Tax Agency
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Spain PPT Schedule and Deadlines
- Form 592 (self-assessment): Due by the 20th day of the month following the end of each filing period (quarterly by default; monthly if subject to monthly VAT).
- Direct debit payments: Must be made between the 1st and 15th of the following month.
- Form A22 (refund request): Must be submitted within the first 20 calendar days following the end of the quarter when refund conditions arise.
- Accounting & stock records: To be submitted electronically within the month following the settlement period (with August considered a non-working month).
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Spain PPT non compliance Penalties; H3: Common PPT Compliance Challenges In Spain.
- Failure to register with the territorial registry: fixed fine of €1,000
- False or incorrect certification of recycled plastic content: fine of 50–75% of unpaid PPT, minimum €1,000
- Undue application of exemptions: fine of 150% of the undue tax benefit, minimum €1,000
- General penalties also apply for late payment or late filing
- Correctly classifying which packaging falls under the tax’s scope
- Tracking and certifying the exact weight of non-recycled plastic
- Ensuring invoices include mandatory details on tax amounts and exemptions
- Maintaining accurate electronic stock records and accounting records
- Meeting strict filing and payment deadlines
- Managing representative requirements for non-resident companies
- Understanding and applying exemptions correctly
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Why choose RegSurance as your Spain PPT Compliance Partner
RegSurance is a trusted PPT compliance service provider for international businesses needing to comply with Spain packaging PPT rules. We support manufacturers, importers, and e-commerce sellers with complete PPT solutions — includingPPT registration, packaging compliance assessments, ongoing regulatory updates, and accurate PPT data reporting for Spain. With our in-depth knowledge of Spain PPT requirements, we ensure your business stays fully compliant and up to date with changing legislation.
Get expert help with PPT requirements for Spain with compliance assessment and data reporting
- Get a free PPT compliance Assessment
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- Book a 1:1 consultation with our experts
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Frequently Asked Questions — Spain PPT
1) What is Spain’s Plastic Packaging Tax (PPT)? Who pays it?
It’s a special tax on non-reusable plastic packaging used in Spain. It applies to manufacturers, importers (via customs), and intra-Community acquirers. Filing uses Model 592; refunds use Model A22.
2) What’s the tax rate and tax base?
The tax is €0.45 per kg and is calculated on the kilograms of non-recycled plastic contained in the products in scope.
3) Which products are covered vs. out of scope?
Covered: non-reusable plastic packaging, semi-finished products (preforms, films), and plastic items for closure/marketing/presentation of such packaging. Not subject/exempt examples include paints, inks, lacquers, adhesives incorporated into packaging, and certain items not designed to be delivered with goods.
4) Is there a de-minimis threshold?
Yes. Intra-EU acquirers are excepted from registration if their non-recycled plastic acquired does not exceed 5 kg per month.
5) Who must register and what is the CIP?
Manufacturers and qualifying intra-EU acquirers must register with the territorial registry (before starting activity). Upon approval, you receive a CIP (plastic identification code) used in filings; non-established taxpayers must appoint a Spanish representative.
6) What must appear on invoices?
Invoices for in-scope products must show: tax amount due, kg of non-recycled plastic, and any exemption reference. For later sales, a certificate/invoice must also state tax paid or exemption article and the kg of non-recycled plastic.
7) What are the deadlines for Model 592 and A22?
Model 592: 1–20 of the month after the period; 1–15 if you direct-debit. Model A22: generally the first 20 days after the quarter in which refund conditions occur.
8) What records do I need to keep?
Manufacturers: electronic accounting of products and raw materials via AEAT systems. Intra-EU acquirers: electronic stock register. Submissions are typically due the month after the settlement period, with August treated as non-working for these filings.
9) What exemptions are common?
Among others: specific medical/medicinal packaging; silage rolls; exports (products sent outside Spain before tax is due); products destroyed/unusable before tax is due; semi-finished plastics not used for packaging in scope; plastic parts not intended for closure/marketing/presentation of packaging.
10) What penalties apply for non-compliance?
Examples include: €1,000 fixed fine for failure to register; 50–75% of PPT (min. €1,000) for false recycled-content certificates; and 150% of the undue tax benefit for incorrect exemption use. General late filing/payment penalties also apply.