Amazon and Spanish packaging EPR

Rechtsstand: 30 September 2026 — the date every statement on this page was checked against the sources below.

Why Amazon asks at all

Not out of diligence. Under RD 1055/2022, if packaged goods from outside Spain reach the Spanish market through a platform and the producer has appointed no authorised representative, the platform becomes the producer for those goods and inherits the organisational, financial and reporting obligations. Amazon therefore has a direct financial incentive to verify every seller, and to suspend listings where the number is missing.

The number it wants is the ENV number

Registration in the packaging section of the Registro de Productores de Producto produces an identifier in the form ENV/year/nine digits. It identifies your company, not your representative, and it has to appear on invoices and commercial documentation accompanying packaged products. It is the number to paste into Seller Central.

It is not the same thing as a SCRAP membership number, a Spanish NIF or a VAT number, and those are frequently confused for one another — we untangle all four in a separate guide.

Pay on Behalf is not registration

Amazon offers a Pay on Behalf service in Spain, charging a fee plus a percentage of the eco-contribution, under which it pays the scheme charges for eligible units sold through Amazon. It is a payment convenience, and it is useful. But it does not register you, it does not produce an ENV number, and it does not cover anything you sell outside Amazon.

So a seller who relies on Pay on Behalf alone typically has: the eco-contribution paid on Amazon units, no producer registration, no ENV number, and nothing at all covering their own shop or other marketplaces. That is not compliance, and the missing registration is exactly what gets the listing suspended.

FBA stock does not make you established

Holding inventory in a Spanish fulfilment centre is not an establishment. You remain a foreign producer and you still need a representative. The corollary is worth knowing too: under FBA, Amazon licenses its own outbound shipping boxes, so what you declare is your own product and sales packaging, not Amazon's cartons.

What to do, in order

1. Appoint an authorised representative established in Spain.
2. Register in the RPP and obtain the ENV number.
3. Join a SCRAP — Ecoembes for household packaging, or Envalora and the others where your packaging reaches businesses.
4. Enter the ENV number in Seller Central.
5. Declare your volumes to the scheme and file the annual declaration at MITECO.

We do all of that for €199 a year, with the scheme's charges passed through at cost.

Sources

Every claim above comes from one of these. Primary law and the competent authority first; no provider marketing pages.

• Real Decreto 1055/2022, envases y residuos de envases — read 2026-09-30
• MITECO — Registro de Productores de Producto, sección envases — read 2026-09-30
• MITECO — FAQ sección envases (PDF) — read 2026-09-30
• Regulation (EU) 2025/40 (PPWR), Article 45 — read 2026-09-30

Who wrote thisRazvan Toma

Razvan Toma is the founder of EPR Spain Rep, the authorised representative for packaging in Spain, and of EPR France Rep and EPR Germany Rep. Every page here is written from the BOE, MITECO or the scheme's own published schedule, never from another provider's marketing.

Razvan on LinkedIn ↗