By Razvan Toma · Founder · Last checked 4 October 2026 · Sources linked below
Etsy, Amazon.es and Zalando ask for your own ENV number, the registration number of the Spanish producer register (RPP). eBay is the exception: its help page gives international sellers a shared ENV number of its own to print on invoices. Since 12 August 2026, Article 45(4) PPWR requires online platforms to obtain your registration details and a self-certification that you take part in a SCRAP and, if you are not established in Spain, have appointed an authorised representative. MITECO's note of 13 August 2026 adds that platforms are not producers under the PPWR, so a marketplace is no longer the fallback that carries your obligations. Sources (6)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)Etsy HelpEtsy Help — Extended Producer Responsibility (EPR) in SpainAmazonAmazon — Extended Producer Responsibility compliance, EPR requirements: SpaineBayeBay — Extended Producer Responsibility selling in SpainZalando Partner UniversityZalando Partner University — EPR obligations in Spain (updated 8 July 2024)
Backed by data: Producer register size · Marketplace requirements dataset
What each marketplace asks for
From each platform's own page, read 4 October 2026.
| Marketplace | What it asks for | Where you enter it | Says you need a representative |
|---|---|---|---|
| Etsy | Your registration number for each category (packaging, electrical equipment, batteries) | Shop Manager › Finances › Legal and tax information › EPR registrations › Spain | Yes, for producers established outside Spain |
| Amazon.es | Your EPR registration number | The EPR Compliance Portal in Seller Central | Not mentioned |
| eBay | An RPP number on your invoices; eBay offers its own, ENV/2023/000034242 | On the invoice | Not mentioned |
| Zalando | Legal name and NIF as in the register, and your ENV number | Business Profile in zDirect | Yes, for partners not headquartered in Spain (page of 8 July 2024) |
| Your own shop (Shopify, WooCommerce) | Nothing: no platform checks you | — | The law applies exactly the same |
What changed on 12 August 2026
Under RD 1055/2022 as originally applied, a platform that let a foreign producer without a representative sell in Spain became that producer's substitute for financial and reporting duties. MITECO's interpretative note on the PPWR (version 2, 13 August 2026) reads the new rules differently: online marketplaces are not producers, but before letting you sell they must check your NIF, company name and registration number against the public RPP list and obtain your self-certification. MITECO is building a web service for those checks. The note is MITECO's reading, not binding law, but it is the authority's reading.
What the marketplace check does not cover
A registration number shows you are in the RPP. It does not file your annual RPP declaration, your SCRAP declaration or your fees. If your company is not established in Spain, the registration itself has to be made through an authorised representative with a Spanish NIF.
More on Marketplace sellers
- I sell on Etsy. Do I need EPR in Spain?
- I sell on Amazon.es. Do I need EPR in Spain?
- eBay gives me its own Spanish registration number. Is that enough?
- I sell on Zalando. What does it need from me for Spain?
- I sell from my own online shop (Shopify, WooCommerce). Do I need EPR in Spain?
- If I have no Spanish representative, does the marketplace become the producer for me?