If I have no Spanish representative, does the marketplace become the producer for me?

Not any more, according to MITECO. RD 1055/2022 (Article 2(t)) made an e-commerce platform the subsidiary producer, for financial and reporting duties, of packaged goods from outside Spain whose producer had no authorised representative. MITECO's FAQ described how platforms declared those goods. Since the PPWR applies (12 August 2026), MITECO's interpretative note of 13 August 2026 says online marketplaces are not producers. Under Article 45(4) PPWR they must instead obtain each producer's registration details and a self-certification, and assess whether they are complete and reliable, before letting the producer sell. A platform can still take on financial obligations under a written mandate from you, producer by producer. The note is MITECO's interpretation, not binding law. MMITECO+2