Royal Decree 1055/2022 establishes extended producer responsibility (EPR) for all packaging placed on the Spanish market (household, commercial, and industrial). Producers must register with MITERD’s Product Producers Registry, participate in an EPR system (individual or collective like Ecoembes), report packaging data annually, and finance collection and treatment of packaging waste. Key time markers: the decree entered into force on 29 December 2022; financial responsibilities apply from 1 January 2024; and new marking rules (Art. 13) apply from 1 January 2025.

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Spain EPR Regulations for Manufacturers, Importers and Ecommerce

Under Spain’s EPR regime, a “producer” includes packers and those who import or acquire intra-EU packaged products for the Spanish market, as well as businesses that supply service packaging (e.g., bags, wrappers) at point of sale and certain online sellers/marketplaces (subsidiary liability can apply). Participation can be through a collective system (e.g., Ecoembes for household packaging) or an individual system meeting all legal requirements.

• Household packaging: typically covered via Ecoembes (yellow/blue bins stream).
• Commercial & industrial packaging: EPR obligations also apply; producers may use individual or collective systems that meet targets.
• Reuse & recycled content objectives and design/label standards apply across materials.

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Covered and Exempted Packaging under Spain EPR

Covered: all packaging placed on the market in Spain across industries and settings (industry, commerce, services, offices, and households). Illustrative items considered packaging include glass bottles for injectables, paper/plastic bags, and foil. Not considered packaging examples include printer cartridges, disposable plates/cups, toolboxes, coffee capsules/pods, and certain sterile barrier systems, among others. Exported packaging is generally exempt.

• Coverage is material-agnostic (glass, metal, paper/cardboard, plastic, wood, composites).
• Deposit/return rules apply to reusable packaging; deposit may be retained if item loses functionality due to user reasons.

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Who Must Register under Spain EPR

Any entity that first places packaging on the Spanish market must register in the Product Producers Registry (MITERD). Foreign producers selling into Spain must appoint an Authorized Representative in Spain. Upon registration, producers receive an ENV number (format ENV/Year/XXXXXXXXX) to be used on invoices and documentation along the supply chain.

• Small-quantity scenarios may allow simplified reporting (e.g., <15 t placed on market, certain e-commerce cases).
• Service packaging below certain thresholds may allow joint registration by the relevant economic operators.

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Spain EPR Data Reporting

Producers report both to MITERD (registry declarations) and to their EPR system (e.g., Ecoembes). Core datasets typically include:

• By type/material (single-use vs. reusable), units, weight (t or g), and % recycled content.
• Household vs. commercial vs. industrial packaging breakdown; beverage/non-beverage flag where applicable.
• For reusable packaging: service life/rotations.
• Ecoembes declaration fields: sector, type, material, weight (g), units, colour (for plastic/glass), % recycled material.

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Spain EPR Schedule and Deadlines

• Entry into force: 29 Dec 2022; registration obligation arose shortly after (BOE notes a three-month window for initial inscription).
• Financial responsibilities: from 1 Jan 2024.
• Marking obligations (Art. 13): from 1 Jan 2025.
• Ecoembes annual declaration: due by 28 Feb (for the previous calendar year).
• MITERD annual reporting (producers): typically by 31 Mar (to the Directorate-General).
• Data to Local Entities: by 31 Mar (as per agreements).
• EPR systems’ annual report to regions & the Waste Coordination Commission: by 31 May.
• Prevention & Eco-design Plan reporting to Ecoembes: provide measures by 10 Mar each year.
• Transitional set-up of systems: adapt/constitute systems by 30 Jun 2024 (others) or 31 Dec 2024 (if previously outside SIG), per BOE.

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Spain EPR Fees and Penalties

Fees are calculated mainly on weight, material, and design (eco-modulation) factors. For Ecoembes, rates reflect the actual recycling system costs and can be adjusted based on recyclability and recycled content; no public agency sets the rates. Non-compliance can trigger administrative controls and sanctions under the decree and broader waste law.

• Ecoembes invoices quarterly (with specific invoicing timelines and exceptions for <€400 yearly amounts).
• Producers must budget for fees covering collection, selection, treatment, and awareness costs.

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Common EPR Compliance Challenges In Spain

• Scoping correctly: distinguishing household vs. commercial vs. industrial packaging.
• Data quality: aligning units, weight, materials, recycled content, and reuse rotations with schema.
• Authorized Representative requirements for non-Spanish entities.
• Multiple systems rules and limits (cannot split same product/material across systems in certain cases).
• Eco-modulation readiness (design for recycling, recycled content requirements).
• Meeting deadlines (28 Feb Ecoembes; 31 Mar MITERD; 31 May EPR systems).

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Why choose RegSurance as your Spain EPR Compliance Partner

RegSurance is a trusted EPR compliance service provider for international businesses needing to comply with Spain packaging EPR rules. We support manufacturers, importers, and e-commerce sellers with complete EPR solutions — including EPR registration, packaging compliance assessments, ongoing regulatory updates, and accurate EPR data reporting for Spain. With our in-depth knowledge of Spain EPR requirements, we ensure your business stays fully compliant and up to date with changing legislation.

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Get expert help with EPR registration for Spain with compliance assessment and data reporting

• Get a free EPR compliance Assessment
• Receive a personalized registration roadmap
• Book a 1:1 consultation with our experts
• Register or Sign-in for our comprehensive EPR Compliance Guide

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Spain EPR — Frequently Asked Questions

• Who is considered a “producer” under Spain’s Packaging EPR?
  Packers, importers/intra-EU acquirers placing packaged products on the Spanish market, businesses supplying service packaging at POS, and certain online sellers/marketplaces (subsidiary liability) are in scope.
• Do foreign sellers need an Authorized Representative?
  Yes. Producers established outside Spain must appoint a natural/legal person in Spain to fulfil EPR obligations.
• What packaging is covered or excluded?
  All materials across household, commercial, and industrial settings are covered. Examples of non-packaging include printer cartridges, disposable plates/cups, coffee capsules/pods, certain sterile barrier systems, etc.
• When did the law take effect and when do specific duties start?
  Decree effective 29 Dec 2022; financial responsibilities apply from 1 Jan 2024; marking (Art. 13) from 1 Jan 2025.
• What is the Product Producers Registry and what number do I get?
  MITERD’s registry assigns an ENV registration number (format ENV/AÑO/XXXXXXXXX) which must appear on invoices and documentation.
• What data do I report each year?
  Type/material (single-use vs. reusable), units, weight, % recycled content; for reusable, service life/rotations. Ecoembes also requires sector, type, material, weight (g), units, colour (plastic/glass), % recycled.
• When are the main deadlines?
  Ecoembes declaration by 28 Feb; MITERD annual reporting by 31 Mar; EPR systems’ annual report by 31 May; data to local entities by 31 Mar.
• Do I have to join Ecoembes?
  Ecoembes is the collective system for household packaging; producers may alternatively run an individual system if it meets all organizational, financial, and performance obligations.
• How are fees calculated?
  By material and weight, with eco-modulation (recyclability/recycled content); fees are set by the system (e.g., Ecoembes) and not by a public agency.
• Are there recycled-content or collection targets I should know?
  Yes. Example: plastic PET bottles ≥25% recycled content in 2025; systems must meet escalating collection/recycling targets by material/year.