Spain's packaging rules are set by Royal Decree 1055/2022 on packaging and packaging waste, which broadened EPR beyond household packaging to include commercial and industrial packaging.
What producers must do
Enrol in the producer register (Registro de Productores de Producto, RAP) section for packaging, obtaining a registration number.
Join a collective scheme — for household packaging this is commonly Ecoembes (and Ecovidrio for glass) — or, where allowed, operate an individual system.
Declare and pay based on the packaging placed on the market, with fees modulated by recyclability.
Points to watch
Because the decree extended obligations to commercial and industrial packaging, businesses that previously assumed they were out of scope (for example B2B suppliers) may now be caught. A non-Spanish seller placing packaging on the Spanish market is treated as the producer and must appoint a representative where required.
Verify current scope, thresholds and scheme obligations against the official RD 1055/2022 guidance and the RAP register.
