By Razvan Toma · Founder · Last checked 4 October 2026 · Sources linked below
Yes. There is no minimum below which registration stops applying. MITECO's FAQ says even a business using packaging in small quantities must register; the only consequence of a small volume is that under 15 tonnes a year you file the declaración simplificada instead of the standard annual declaration. The PPWR foresees a lighter declaration below 10 tonnes, but MITECO says the 15-tonne simplified route of RD 1055/2022 stays in place until the Commission's implementing act is adopted. Sources (2)MITECOMITECO — Documento técnico (FAQ) sección envases del RPP, 3 December 2025 (PDF)Real Decreto 1055/2022, envaReal Decreto 1055/2022, envases y residuos de envases
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