Do I need a Spanish EPR representative?

Spain does not ask where you are incorporated and stop there. It asks whether you are established in Spain, and who receives your goods. Four questions, and the answer is sometimes no — a check that always says yes is a sales form, not a check.

This follows the test RD 1055/2022 sets for distinguishing a manufacturer from a producer, and the domestic-precedence rule that decides who is the producer in Spain.

Questions people actually ask

Is there a minimum volume below which I can ignore this?

No. Spain sets no turnover or volume threshold for the representative obligation. A single parcel to a Spanish consumer puts you in scope.

What if I only sell through Amazon?

You still need your own registration. Amazon's Pay on Behalf service covers the eco-contribution for eligible units; it does not create your producer registration and does not make you compliant on its own.

My Spanish customer resells the goods. Am I still the producer?

Generally not for those goods: the business that first places them on the Spanish market carries the obligations. Get it confirmed in writing, and remember any direct sales remain yours.

Can you tell me I do not need you?

Yes, and we do. The check returns “no representative needed” where that is the right answer, and we will read an unclear arrangement for you without charging.

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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Do I need a Spanish EPR representative?

Does your company have an establishment in Spain?

Who receives your goods in Spain?

What kind of packaging is involved?

Roughly how much packaging do you place on the Spanish market per year?

Where should we send your result?

Questions people actually ask

Selling into Spain without a Spanish company?