Spain's packaging EPR rules, explained

Packaging is the EPR stream that catches almost everyone, because almost everything ships in a box. Spain overhauled its packaging rules with Royal Decree 1055/2022, and added a separate tax on non-reusable plastic. Together they reshaped what a foreign seller has to do before goods can move into the Spanish market.

What changed with Royal Decree 1055/2022

The decree on packaging and packaging waste transposed the EU's updated rules and went further in one important way: it extended producer responsibility beyond household packaging to commercial and industrial packaging too. Previously, much of the obligation focused on consumer packaging; now the transport boxes, pallets wrap and bulk packaging that businesses use are squarely in scope. It also tightened registration, labelling and reporting duties.

Who is a packaging producer

If you put packaged goods on the Spanish market (including the secondary and transport packaging around them), you are a packaging producer. That holds whether you are a manufacturer, an importer, or a distance seller shipping to Spanish customers from abroad. The packaging you are responsible for is the packaging that ends up in Spain with your product.

Joining a SCRAP

Most producers meet their obligation by joining a collective scheme, a SCRAP (Sistema Colectivo de Responsabilidad Ampliada del Productor). The scheme organises collection and recycling on your behalf, and you pay an eco-contribution based on the weight and type of material you place on the market. Different schemes cover different materials and channels, so the right one depends on what your packaging is made of and whether it is household, commercial or industrial.

The plastic packaging tax

Separate from the EPR eco-contribution, Spain levies a special tax on non-reusable plastic packaging. It is charged per kilogram of non-recycled plastic (€0.45/kg at the time of writing), and it applies to the manufacture, import and intra-EU acquisition of that packaging. Non-resident companies that are liable generally need to appoint a representative in Spain and, of course, hold a Spanish NIF to register for the tax.

Labelling and reporting

• Packaging increasingly has to carry standardised information about how it should be sorted and disposed of.
• Producers report the quantities and materials placed on the market, on a recurring basis.
• Records need to be kept so that volumes can be substantiated if the authorities ask.

First steps for a foreign seller

• Get a Spanish NIF (the N98 type for non-resident companies).
• Register in the producer registry for packaging.
• Join the SCRAP that matches your materials and sales channel.
• Register for the plastic packaging tax if you place non-reusable plastic on the market.
• Set up recurring reporting of your volumes.

The order matters: none of the registrations are possible without the NIF, so that is where a packaging compliance project starts. For the wider set of streams beyond packaging, see our guide to the EPR requirements in Spain.