I sell to a Spanish retailer or distributor that resells my goods. Am I the producer?

Generally not, under the PPWR. MITECO's note of 13 August 2026 applies Article 3(1)(15) PPWR: a manufacturer established outside Spain is the producer only for packaged goods it makes available directly to end users in Spain. For everything else, the producer is the importer, intra-EU acquirer or distributor that first makes the goods available in Spain. Your Spanish customer then registers and reports for those goods. Any sales you make directly to Spanish end users, through your shop or a marketplace, are still yours. MITECO's older FAQ, written under RD 1055/2022 alone, treated the foreign packer as producer even when selling through a Spanish intermediary; the PPWR note is the later reading. MMITECO+1