Can I file the simplified declaration? Is the threshold 15 or 10 tonnes?

Q: Can I file the simplified declaration? Is the threshold 15 or 10 tonnes?

15 tonnes for now. RD 1055/2022 lets producers placing under 15 tonnes of packaging a year in Spain file a simplified RPP declaration. The PPWR allows a lighter declaration under 10 tonnes, but MITECO says the 15-tonne route stays until the Commission's implementing act is adopted. Count all categories and all packaging, not just primary packaging.

15 tonnes for now. The PPWR's 10-tonne threshold applies only once the Commission's implementing act is adopted, MITECO says.

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

Quick answer

15 tonnes, for now. Article 16(1) RD 1055/2022 lets producers placing under 15 tonnes of packaging a year on the Spanish market file the RPP information in simplified form. Article 44(8) PPWR foresees a simpler declaration below 10 tonnes, but MITECO's note of 13 August 2026 says that until the Commission adopts the implementing act under Article 44(14) and the new data structure is in place, the 15-tonne simplified option continues. MITECO's FAQ adds that the threshold counts all packaging, every category and type, not only primary packaging, and only what is placed on the Spanish market.

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