I am a seller from outside the EU (UK, US, Switzerland, China…). Do I need a Spanish EPR representative?

Yes, if you sell packaged goods directly to end users in Spain. A company established outside the EU that makes packaged goods available directly to Spanish end users, through a marketplace or its own shop, is the producer under Article 3(1)(15)(d) PPWR, and Article 45(3) PPWR and Article 17(2) RD 1055/2022 require it to appoint an authorised representative in Spain. The practical sequence MITECO gives: a Spanish NIF starting with N from the AEAT, then a representative certificate or an REA power naming the representative, then registration in the RPP with a SCRAP certificate. If instead a Spanish importer buys from you and resells, MITECO treats the importer as the producer for those goods. RRegulation (EU) 2025/40 (PPW+3