EPR · Spain
EPR in Spain: the Ecoembes, MITECO, and plastic tax guide for sellers
If you sell packaged goods to customers in Spain, you have to register in the packaging section of MITECO's producer register, join an approved collective scheme such as Ecoembes, and declare the packaging you place on the market every year. There is no small-seller exemption, and if you have no legal presence in Spain you must act through an authorised representative established there. On top of EPR, Spain also charges a separate tax on non-reusable plastic packaging.
Assuro connects to Shopify. The guidance below applies whatever platform you sell on.
- 1
Register
in the national registry
- 2
License
your volumes and pay fees
- 3
Report
those volumes each year
Spain EPR at a glance
Five moving parts, and they are not all the same kind of thing. Here is what to do, where, and by when, before the detail below.
| What you do | Where or who | When | Cost basis |
|---|---|---|---|
| Register as a producer | The RPP producer register, run by MITECO | Before your first sale to Spain | Registration itself is free |
| Join a compliance scheme | Ecoembes for household packaging, Ecovidrio for glass | Before your first sale | Eco-contribution per kg by material, around €0.52/kg for PET |
| Appoint a representative | An authorised representative established in Spain, if you have no Spanish entity | Before you can register | A service fee, priced per country |
| Declare last year's volumes | To your scheme, then the RPP report | Scheme data by 28 February; RPP report by 31 March (confirm the exact window each year) | Drives your scheme fee |
| Pay the plastic packaging tax | AEAT, the tax agency, if it applies to your import structure | Ongoing, separate from EPR | €0.45/kg of non-recycled plastic in non-reusable packaging |
EPR and the plastic tax are two separate tracks
Everything in the first four rows is packaging EPR, run through MITECO and your scheme. The last row is a tax, run through the tax agency, and whether you pay it directly depends on who is the importer of record for your goods. Paying one does nothing for the other.
Who has to register
Anyone who first places packaged products on the Spanish market, including non-Spanish and non-EU sellers shipping direct to consumers by distance selling. The framework is Royal Decree 1055/2022 on packaging and packaging waste, built on Spain's 2022 waste law. Like France, Spain sets no volume threshold: your first parcel to a Spanish customer puts you in scope.
The pieces you have to put in place
For packaging, the obligations are:
- Register in the Registro de Productores de Producto (RPP), the producer register run by MITECO, Spain's ministry for the ecological transition. You get a producer registration number that marketplaces and authorities can check.
- Join an approved collective scheme (SCRAP). For household packaging the main one is Ecoembes (Ecovidrio handles glass); commercial and industrial packaging has its own schemes, such as Envalora. You pay an eco-contribution based on the weight and material of what you place on the market.
- Declare your volumes every year. Your scheme collects the previous year's packaging data early in the year, with 28 February the usual cut-off, and the register's annual declaration follows in the first quarter.
- Label household packaging for sorting. Since 1 January 2025, household packaging placed on the Spanish market must indicate the bin or fraction it belongs in.
If you have no Spanish entity: the authorised representative
A producer without a legal presence in Spain cannot register in the RPP directly. You have to appoint an authorised representative (representante autorizado) established in Spain, who registers you, files your declarations, and answers to the authorities on your behalf. This is national law and applies now, not a future deadline. From 12 August 2026 the EU Packaging Regulation (PPWR) extends the same pattern across the EU, one representative per member state, so the Spanish appointment is the first of several rather than a one-off.
The plastic packaging tax is separate from EPR
Spain is one of the few EU countries with a plastic packaging tax on top of EPR. Since 1 January 2023, non-reusable plastic packaging is taxed at €0.45 per kilogram of non-recycled plastic it contains. It is an excise collected by the Spanish tax agency, entirely separate from your Ecoembes eco-contribution, and it catches importers and intra-EU acquirers of packaged goods, not just Spanish manufacturers. If your mailers, void fill, or product packaging contain virgin plastic, budget for both charges.
Two systems, two bills
The eco-contribution to your collective scheme and the plastic tax to the tax agency are independent obligations with independent paperwork. Paying one does not cover the other, and recycled-content claims for the tax need documentation, typically a certificate.
What non-compliance costs
Breaches of the packaging rules are sanctioned under Spain's waste law, where fines run from about €2,000 for minor infringements through €100,000 for serious ones, and up to €3.5 million for the most serious cases. Those figures are the statutory range, not what a small distance seller should expect first. In practice the earlier disruption is commercial: a marketplace asking for a producer registration number you do not have, or a listing blocked until you appoint a representative and register.
How Spain differs from Germany and France
If you have already worked through Germany's LUCID register or France's Citeo and Triman rules, Spain will feel familiar in shape: register, join a scheme, declare, label. The differences are the plastic tax, which neither Germany nor France charges as a separate per-kilogram excise, the split of schemes by packaging type rather than one household system, and a sorting-label rule that is newer and less prescriptive than France's Triman and Info-Tri. Like France, and unlike the Netherlands with its 50,000 kg fee threshold, Spain expects registration from the first sale.
How Assuro helps
The volumes you declare should come from your actual catalogue, not a guess. Assuro totals packaging by material across your Shopify products, flags Spain as a likely obligation when you ship there without a registration on record, and tracks the annual declaration window. It organizes and flags. It does not register you with MITECO, join Ecoembes for you, file the plastic tax, or certify anything.
- Appoint a Spanish authorised representative if you have no entity in Spain
- Register in MITECO's producer register (RPP) and keep your number where marketplaces can see it
- Join the right collective scheme for your packaging, Ecoembes for household
- Declare the previous year's volumes: scheme data by 28 February, RPP report by 31 March, confirming both windows for the year in question
- Check whether the €0.45/kg plastic packaging tax applies to your packaging
- Add the household sorting indication required since 1 January 2025
Frequently asked questions
I only ship a few orders to Spain. Do I still need to register?
Yes. Royal Decree 1055/2022 sets no small-seller threshold for packaging, so the obligations apply from your first sale to a Spanish customer. What scales with your size is the cost, since eco-contributions are weight-based, not the duty to register.
Do I need an authorised representative in Spain?
If you have no legal establishment in Spain, yes. Foreign sellers register in the producer register and deal with their collective scheme through an authorised representative established in Spain. This applies now under Spanish law.
What is the difference between the EPR eco-contribution and the plastic tax?
The eco-contribution is what you pay a collective scheme like Ecoembes to fund the collection and recycling of your packaging. The plastic tax is a separate excise of €0.45 per kilogram of non-recycled plastic in non-reusable packaging, collected by the tax agency since January 2023. Many sellers owe both.
What is the RPP number?
It is the registration number issued by MITECO's Registro de Productores de Producto. It is proof that you are registered as a producer, and marketplaces increasingly ask for it before letting you sell into Spain.
Does Assuro register me with MITECO or Ecoembes?
No. Assuro organizes and flags. It shows when you sell into Spain without a registration on record and tracks the declaration deadlines, but it does not register you, file declarations, or handle the plastic tax.
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