I import goods from China and sell them in Spain. Who is the producer?

Q: 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.

If you are established in Spain and import for sale there, you are. If you are abroad and sell directly to Spanish end users, you are too, through a representative.

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

Quick answer

It depends on where you are and who buys. MITECO's note applies the PPWR as follows. If your company is established in Spain and imports packaged goods to sell there, you are the producer and register yourself; MITECO's FAQ adds that goods re-exported in full outside the EU or sold to other Member States need no registration. If your company is outside Spain and sells directly to Spanish end users, you are the producer and need a Spanish authorised representative. The Chinese manufacturer is the producer only for goods it sells directly to end users in Spain.

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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.

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