Grouped by subject. Every answer states the rule, the source and the date it was last checked. The whole library as one file: answers.md · answers.json
Marketplace sellers 7
I sell on a marketplace. What does Spain require for my packaging?
Etsy, Amazon.es and Zalando ask for your own ENV number from the Spanish producer register (RPP). eBay publishes a shared number of its own for international sellers. Since 12 August 2026 the PPWR requires every platform to check your registration and a self-certification, and MITECO says platforms are no longer producers in your place.
I sell on Etsy. Do I need EPR in Spain?
Yes, if you ship packaged goods to buyers in Spain. Etsy asks producers for their Spanish registration number in Shop Manager › Finances › Legal and tax information, under EPR registrations › Spain, and its help page says producers established outside Spain need an authorised representative in Spain.
I sell on Amazon.es. Do I need EPR in Spain?
Yes. Amazon says producers selling packaged goods on Amazon.es must obtain a Spanish EPR registration number and submit it in the EPR Compliance Portal in Seller Central. Without a valid number Amazon can enrol you in its EPR payment service, declare your sales to a SCRAP and deduct the fees plus a management fee. That service is not your registration.
eBay gives me its own Spanish registration number. Is that enough?
eBay's help page tells international business sellers to print eBay's own registration number, ENV/2023/000034242, on invoices for goods shipped to Spain, and says eBay declares those goods through Ecoembes. It covers eBay sales only. MITECO's August 2026 note says platforms are not producers under the PPWR and must check each seller's own registration, so check eBay's page before relying on it.
I sell on Zalando. What does it need from me for Spain?
Zalando asks partners not headquartered in Spain for the legal name and NIF used in the Spanish register and their ENV number, entered in the Business Profile in zDirect. Its page says such partners need a Spanish authorised representative and that failing to provide the number could suspend selling in Spain. If you use Zalando Fulfilment Solutions, Zalando is the producer of the shipping packaging.
I sell from my own online shop (Shopify, WooCommerce). Do I need EPR in Spain?
Yes. No platform checks you, but the obligation is identical. A seller established outside Spain who sells packaged goods directly to end users in Spain is the producer under Article 3(1)(15)(d) PPWR, for the product packaging and for the shipping packaging, and needs a Spanish authorised representative.
If I have no Spanish representative, does the marketplace become the producer for me?
Not any more, according to MITECO. RD 1055/2022 made an e-commerce platform the fallback producer for goods from foreign producers without a representative. MITECO's note on the PPWR (13 August 2026) says online marketplaces are not producers; instead they must check each seller's registration and self-certification before letting them sell.
Who needs a representative 5
I only send a few parcels a year to Spain. Does the packaging law still apply?
Yes. Spain has no de minimis for registration: the obligation follows from making packaged goods available to end users, not from a volume. Small quantities only change the paperwork: producers placing under 15 tonnes of packaging a year file the simplified annual declaration.
Does a Spanish VAT number, stock in a Spanish warehouse or a branch make me established in Spain?
No. MITECO's August 2026 note, following the Commission's PPWR guidance, says “established” means a legal person constituted in the Member State, not a branch. A non-EU or non-Spanish company with only a branch must form a subsidiary or appoint an authorised representative. A VAT number or stock in a warehouse is not a legal entity at all.
We have a Spanish subsidiary. Do we still need an authorised representative?
MITECO says no: a manufacturer that already has a subsidiary in Spain does not need to designate an authorised representative, because the person named in the subsidiary's representative certificate or REA power already holds that role. A branch is different: it is not a separate legal person and does not count.
Does a Spanish authorised representative also cover my sales to other EU countries?
No. Under Article 3(1)(19) PPWR, the authorised representative for EPR is a person established in the Member State where you make the packaging available, appointed for that country's obligations. Selling to consumers in Germany or France needs a representative there too.
I have stopped selling to Spain. How do I leave the RPP?
File a deregistration (baja) in MITECO's electronic office, procedure code 1523221. If you register again later you get a new ENV number and the old one becomes obsolete. If you are only switching SCRAP, RD 1055/2022 requires you to tell both schemes and the register before the last quarter of the year.
NIF, RPP and the ENV number 6
Why do I need a Spanish NIF to register for packaging EPR?
Because the RPP and the power-of-attorney register (REA) both identify companies by Spanish NIF. A foreign legal person gets an NIF starting with N from the tax agency (AEAT), requested through a representative who holds a Spanish NIF or NIE. MITECO calls this step indispensable in every case.
How is a Spanish authorised representative actually appointed?
Two routes, per MITECO: a digital representative certificate for your company's Spanish NIF naming the representative, or a power of attorney in the Registro Electrónico de Apoderamientos (REA), type C, for the RPP procedures 1523222, 1523221, 2962548 and 2945277. Whoever is named becomes the authorised representative for the packaging rules.
If I appoint a Spanish representative, who is ultimately responsible?
You are. MITECO's FAQ says that when a producer appoints an attorney, the one ultimately responsible is always the grantor of the power, the producer. The representative registers and reports for you; the accuracy of what is reported, and the fees, remain yours.
What is the ENV number, and where do I have to show it?
It is your registration number in the packaging section of the RPP, in the form ENV/year/nine digits. It must appear on invoices and other documents accompanying packaged goods in Spain, from first placing on the market to the point of sale, and every business that invoices the goods onward repeats the producer's number. It is only needed on documents within Spain.
Does my ENV number change if I update my registration?
No. MITECO's FAQ says the ENV number stays the same when you update your registration data. It changes only if you deregister and register again; the new number is then the one to use on invoices. A change of company NIF needs a new registration and deregistration of the old one.
How can I check whether a company is registered in the Spanish RPP?
MITECO publishes the public list of registered producers on the packaging section page of the RPP (“Información pública”). Its August 2026 note tells marketplaces to check that the NIF, company name and registration number a seller gives match that list. Missing ENV numbers on a supplier's invoices are MITECO's own warning sign.
SCRAPs and reporting 5
Do I have to join a SCRAP before I can register in the RPP?
In practice, yes. MITECO's note says the RPP registration must include a certificate from the SCRAP proving you take part, for each packaging category, and the SCRAP must be authorised for that category. Membership through a one-stop shop or an agreement between SCRAPs counts too.
Which SCRAP do I need: household, commercial or industrial?
It depends on the packaging category. MITECO's test: if the general public can buy the packaged product, the packaging is household (doméstico). Otherwise it is commercial (services and trade, NACE sections G to U) or industrial. Each category needs a SCRAP authorised for it; MITECO publishes the list.
When do I have to report my packaging in Spain?
Twice, for the previous calendar year: to your SCRAP, which sets its own declaration date (Zalando's page gives 28 February), and to the RPP between 1 January and 31 March. Each year can only be filed in its own window. Producers under 15 tonnes a year file the RPP's simplified declaration.
Can I file the simplified declaration? Is the threshold 15 or 10 tonnes?
15 tonnes for now. RD 1055/2022 lets producers placing under 15 tonnes of packaging a year in Spain file a simplified RPP declaration. The PPWR allows a lighter declaration under 10 tonnes, but MITECO says the 15-tonne route stays until the Commission's implementing act is adopted. Count all categories and all packaging, not just primary packaging.
Do I have to declare the shipping box and filling too?
Yes. Under Article 3(1)(15)(c) PPWR, a seller established outside Spain that sends transport packaging directly to end users in Spain is its producer. MITECO's own example of a Portuguese online seller makes it the producer in Spain of both its sales packaging and its shipping packaging.
Who is the producer 3
I sell to a Spanish retailer or distributor that resells my goods. Am I the producer?
Generally not, since 12 August 2026. MITECO's PPWR note says that when a foreign manufacturer does not sell directly to end users in Spain, the producer is the importer, intra-EU acquirer or distributor that first makes the packaged goods available in Spain. Direct sales to Spanish end users remain yours.
I dropship to customers in Spain. Who is the producer?
Usually you. The PPWR's producer definition covers a manufacturer, importer or distributor that makes packaged goods available for the first time directly to end users in Spain, whatever the selling technique, including distance contracts. As the seller of record, you are that distributor, even if your supplier packs and ships.
I import goods from China and sell them in Spain. Who is the producer?
It depends on where you are established and to whom you sell. A Spanish company that imports and resells in Spain is the producer itself. A seller abroad that sells directly to Spanish end users is the producer and needs a Spanish representative. The Chinese factory is the producer only if it sells directly to end users in Spain.
Other obligations 2
Is the Spanish plastic packaging tax the same as packaging EPR?
No. The impuesto especial sobre los envases de plástico no reutilizables is an excise tax administered by the AEAT under Ley 7/2022, charged at €0.45 per kilo of non-recycled plastic. EPR is a separate regime: registration in MITECO's RPP and fees to a SCRAP. Paying one does not discharge the other.
I also sell electronics or batteries in Spain. Is that the same registration?
No. Packaging is registered in MITECO's Registro de Productores de Producto (packaging section) and gives an ENV number. Electrical and electronic equipment goes in the RII-AEE, and batteries in the RII-PYA, each with its own registration number that marketplaces such as Etsy ask for separately. The packaging around your electronics still counts as packaging.
Sellers by country 2
I am a seller from outside the EU (UK, US, Switzerland, China…). Do I need a Spanish EPR representative?
Yes, if you sell packaged goods directly to end users in Spain, from a marketplace or your own shop. You are the producer under Article 3(1)(15)(d) PPWR and must appoint a Spanish authorised representative. Your company also needs a Spanish NIF starting with N before it can be registered. If a Spanish importer buys from you and resells, it is the producer instead.
I am a seller from another EU country (Portugal, France, Germany, Italy, Netherlands…). Do I need a Spanish EPR representative?
Yes, if you sell packaged goods directly to end users in Spain. Your registration at home covers your home market only; in Spain you are a producer under Article 3(1)(15)(d) PPWR and need a Spanish authorised representative. OSS VAT registration does not establish you in Spain, and you still need a Spanish NIF starting with N.