Selling in Spain: the EPR requirements, stream by stream

If you ship physical products into Spain, whether through your own online shop, a marketplace like Amazon or eBay, or wholesale, there is a good chance you fall under Spain's Extended Producer Responsibility (EPR) rules. EPR is a European framework, written into Spanish law, that makes the company placing a product on the market pay for the collection, sorting and recycling of the waste that product eventually becomes. Packaging, electronics, batteries, textiles, tyres and more are all in scope, and the list keeps growing. The penalties for ignoring it are serious: fines for the worst cases reach 3.5 million euros.

This guide walks through what EPR actually asks of you as a foreign seller: who is covered, the main waste streams and their eco-organisations, how registration and reporting work, what it costs in a typical year, and the mistakes that turn a manageable obligation into a fine. It also explains where a Spanish NIF fits in, because for a company based outside Spain the tax number is the first practical step before any of this is possible.

What EPR is, and why it applies to you

EPR rests on a simple idea, often called polluter pays: the business that first puts a product on the market is responsible for its whole life cycle, including what happens once the customer is finished with it. In practice that means funding the systems that collect and recycle the resulting waste, rather than leaving that bill to local councils and taxpayers.

Spain has turned the European directives into national law through several texts. The general framework is Ley 7/2022 on waste and contaminated soils. On top of it sit stream-specific decrees: Real Decreto 1055/2022 for packaging, Real Decreto 110/2015 for electrical and electronic equipment, Real Decreto 106/2008 for batteries, and separate rules for textiles, oils, tyres and medicines.

The reason this matters so much now is cross-border e-commerce. A large number of foreign sellers ship into Spain without ever registering. Since 2023 the Spanish authorities have tightened enforcement and started sharing data with customs and with the marketplaces themselves, which makes non-compliant sellers far easier to identify than they used to be.

Who has to comply

EPR covers almost everyone who places a product on the Spanish market, not just manufacturers. You are in scope if you are:

• A Spanish manufacturer, or an importer buying abroad to sell in Spain.
• A foreign online seller shipping to Spanish customers, including through Amazon FBA, eBay or similar platforms.
• A distributor or wholesaler.
• A marketplace, which can carry shared responsibility depending on how the sale is structured.

There is generally no minimum volume that lets you off. Even a small shop selling a few hundred items a year is covered, although a handful of streams set specific thresholds for very small businesses.

If you sell into Spain from another country and have no permanent establishment there, you must appoint an authorised representative who registers and reports on your behalf. That representative, and the reporting itself, run through the Spanish tax system, which is why a Spanish NIF is the starting point for a foreign company. Our guide on getting a Spanish NIF for a foreign company covers that first step.

The waste streams you might fall under

For most sellers the relevant streams are packaging, electronics and batteries, with textiles now joining the list. Each stream has its own register and its own eco-organisations, known in Spain as SCRAPs (colectivos de responsabilidad ampliada del productor).

Packaging is the broadest and catches almost everyone. Under Real Decreto 1055/2022, the box, filler, tape and labels around anything you ship all count, whether the packaging is household, commercial or industrial. You register in the Registro de Productores de Producto and join a scheme such as Ecoembes for household packaging or Ecovidrio for glass. Contributions typically run from around 50 to 200 euros per tonne depending on the material.

Electrical and electronic equipment (WEEE) is covered by Real Decreto 110/2015: anything with a plug, battery or cable, from appliances to LED bulbs. You register in the RII-AEE and join a scheme like Ecolec, Ecotic or Ambilamp, with fees that range from a cent to a few euros per item by category.

Batteries and accumulators fall under Real Decreto 106/2008, whether sold on their own or built into a product. Registration is in the REIPA, with schemes such as Ecopilas or ERP, and contributions of roughly one cent to fifty cents per battery.

Textiles became an EPR stream in 2025, so every clothing and textile seller is now in scope. The register and the textile schemes are still being set up, and new operators are appearing.

Other streams exist for more specific products, each with its own scheme:

• Industrial and lubricating oils: SIGAUS.
• Tyres: Signus and TNU.
• Medicines: SIGRE.
• End-of-life vehicles: SIGRAUTO.
• Agricultural plastics: SIGFITO.

How to get compliant, step by step

The path is much the same across streams, even if the details differ:

• Identify your streams. Map every product to the streams it triggers. A single laptop can be WEEE (the device), packaging (its box) and a battery (the internal cell) all at once, which means three memberships.
• Register in the national register. That is the Registro de Productores de Producto for most products, or a stream register such as the RII-AEE for electronics or the REIPA for batteries.
• Join a SCRAP for each stream. You sign a membership contract with a scheme per stream, usually an entry fee of 100 to 500 euros plus an annual contribution based on your volumes.
• Report your volumes. Depending on the scheme you declare quarterly or yearly how much you placed on the market, by units and by weight, and the scheme calculates your contribution.
• Mark and inform. Some products need a specific label (a recycling mark, the crossed-out bin symbol for WEEE), and you have to tell customers how to sort and recycle the item at the end of its life.

What it costs

Costs scale with your volumes and the number of streams. Getting started usually means registration fees of 50 to 200 euros, SCRAP entry fees of 100 to 500 euros per stream, and, if you use a specialist for the first setup, advisory fees of 500 to 2,000 euros.

The recurring annual cost for a typical online seller looks roughly like this:

• Small volume, under 10 tonnes a year: 500 to 2,000 euros.
• Medium volume, 50 to 200 tonnes: 5,000 to 20,000 euros.
• Large volume, over 500 tonnes: 50,000 euros and up.

If you sell through a marketplace, check what it handles for you. Since 2023 some platforms, Amazon in particular, cover part of the compliance for certain streams (often the shipping packaging), but the responsibility for the products themselves stays with you.

The penalties for getting it wrong

Ley 7/2022 grades the fines by seriousness:

• Minor breaches, such as late declarations or occasional oversights: 900 to 9,000 euros.
• Serious breaches, such as never declaring or never joining a scheme: 9,001 to 1,200,000 euros, depending on the volumes involved.
• Very serious breaches, such as repeated offences or hiding large volumes: up to 3,500,000 euros.

The fines are only part of the risk. Non-compliant sellers also face having their listings suspended on platforms that now cooperate with the authorities, shipments held at customs where EPR declarations are checked, and a wider tax review by the Agencia Tributaria. For an online business, losing a sales channel overnight can hurt more than the fine itself, as our breakdown of what happens if you ignore EPR spells out.

The mistakes that catch foreign sellers out

• Assuming the marketplace handles everything. Platforms cover a limited slice, often just their own shipping packaging. You stay responsible for the products themselves.
• Underestimating how many streams apply. One phone in a box with a charger and a battery is three streams at once, and three schemes to join.
• Missing the new textile rules. Many clothing sellers have not yet registered for the 2025 textile obligation and are quietly falling behind.
• Selling from abroad with no authorised representative. Without one you are non-compliant by default, even if you pay the contributions.
• Confusing EPR with tax. Holding a Spanish NIF does not cover your EPR duties, and being EPR-registered does not settle your VAT or income tax. They are separate obligations.
• Under-reporting your volumes. Schemes cross-check their figures against customs and marketplace data, and an audit can reach back several years with penalties on top.

Where to start

EPR in Spain is now unavoidable for anyone selling physical goods there, but it is a finite, known process. Identify the streams your products trigger, register in the right national registers, join the matching schemes, and keep your volume declarations up to date, ideally with a partner who automates the reporting so nothing slips.

For a company based outside Spain, none of it can begin without a Spanish tax number. The NIF is what lets you register as a producer, appoint an authorised representative and interact with the authorities at all. It is the first practical move, and it takes minutes to start and usually 12 to 24 hours to land. That is exactly what EPRNIF does: we get foreign companies their Spanish NIF quickly, so the rest of your EPR compliance has somewhere to stand.