I dropship to customers in Spain. Who is the producer?

Q: 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.

Usually you, as the seller who makes the goods available to the Spanish end user at a distance, even if a supplier abroad ships them.

By Razvan Toma · Founder · Last checked 4 October 2026 · Sources linked below

Quick answer

Usually you. Article 3(1)(15)(d) PPWR makes the producer any manufacturer, importer or distributor that makes packaged goods available for the first time directly to end users in another Member State, whatever the selling technique, distance contracts included. In dropshipping you sell to the Spanish customer, so you are that distributor even though your supplier packs and ships. If you are not established in Spain, you need a Spanish authorised representative. Agree in writing with your supplier what packaging it uses, because you have to declare its weight.

More on Who is the producer

All answers →

Selling into Spain without a Spanish company?

Since 12 August 2026, PPWR Article 45(3) requires an authorised representative established in Spain. We are that representative, for €199 a year.

Free 2-minute check Get started