If I appoint a Spanish representative, who is ultimately responsible?

Q: If I appoint a Spanish representative, who is ultimately responsible?

You are. MITECO's FAQ says that when a producer appoints an attorney, the one ultimately responsible is always the grantor of the power, the producer. The representative registers and reports for you; the accuracy of what is reported, and the fees, remain yours.

You are. MITECO's FAQ says the final responsibility stays with the producer who granted the power.

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

Quick answer

You are. MITECO's FAQ answers this directly: whatever the power of attorney, the one ultimately responsible is the grantor (poderdante), meaning the producer. The representative registers you in the RPP and files the annual information on your behalf, and RD 1055/2022 requires representatives to keep the documents proving the appointment. The quantities you report, and the fees owed to your SCRAP, remain your responsibility.

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Selling into Spain without a Spanish company?

Since 12 August 2026, PPWR Article 45(3) requires an authorised representative established in Spain. We are that representative, for €199 a year.

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