By Razvan Toma · Founder · Last checked 4 October 2026 · Sources linked below
Yes. Nobody asks for your number, but the law is the same. Under Article 3(1)(15)(d) PPWR, a manufacturer, importer or distributor established outside Spain that makes packaged goods available for the first time directly to end users in Spain is the producer there. That includes distance sales from your own shop. MITECO's note of 13 August 2026 confirms that such a producer must appoint an authorised representative in Spain, who registers it in the RPP and reports. The shipping box counts too: see the shipping box answer. Sources (3)Regulation (EU) 2025/40 (PPWRegulation (EU) 2025/40 (PPWR), Article 45MITECOMITECO — Nota interpretativa sobre el productor conforme al Reglamento (UE) 2025/40, v2, 13 August 2026 (PDF)Real Decreto 1055/2022, envaReal Decreto 1055/2022, envases y residuos de envases
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