RPP, ENV, SCRAP and NIF explained

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

RPP — the register

The Registro de Productores de Producto is run by MITECO, the Spanish environment ministry. It is a public register, not a scheme and not a service: registering there is a legal obligation under RD 1055/2022 for anyone placing packaged products on the Spanish market. It has separate sections for different product flows; packaging is one of them.

Registration costs nothing in itself. What it produces is your ENV number.

ENV — the number

The packaging section issues an identifier in the form ENV / year of registration / nine digits. The prefix identifies the section: ENV for packaging, with other prefixes for tyres, plastic bags and tobacco.

Two things matter about it. It identifies your company, not your representative, so it stays yours. And it must appear on invoices and on the commercial documentation accompanying packaged products — through to the point of sale for household packaging, and to the end user for commercial and industrial packaging.

SCRAP — the scheme

A Sistema Colectivo de Responsabilidad Ampliada del Productor is a private collective scheme that organises and finances the collection and recycling of packaging. Ecoembes covers household light packaging, Ecovidrio household glass, and Envalora and others commercial and industrial packaging.

Joining one is a different act from registering in the RPP, and this is the single most common confusion in Spanish packaging compliance. The register is public and free; the scheme is private and charges per kilo. You need both. A company whose packaging reaches both consumers and businesses needs two schemes.

The alternative is a SIRAP — running your own individual system. It is legally available and almost nobody does it.

NIF — the tax number, and you do need one

A Número de Identificación Fiscal is a Spanish tax identification number. It is not an EPR concept, but you cannot complete the EPR registration without one, and it is worth understanding why.

MITECO registers producers in the RPP by NIF. You identify yourself to the electronic office with a digital certificate, and that certificate is issued against a Spanish NIF. So the sequence is fixed:

1. A foreign legal entity obtains a Spanish NIF beginning with the letter N from the Agencia Estatal de Administración Tributaria.
2. That application must be made through a representative who already holds a Spanish NIF or NIE — which is what your authorised representative is for.
3. The N-number then allows a certificado digital de representante to be issued for the company.
4. Only then can the RPP registration be filed, and the ENV number issued.

MITECO's own guidance calls the NIF step imprescindible — indispensable. Any provider implying you can skip it is wrong, and any provider that does not mention it at all has left a required step out of their quote.

Separately, the representative's own NIF or NIE is mandatory on the application form. That is ours, not yours.

And the one that is not a number at all

The plastic tax is not a registration, a scheme or a contribution. It is an excise tax of €0.45 per kilo on the non-recycled fraction of non-reusable plastic packaging, administered by the Agencia Tributaria under Ley 7/2022. It is separate from, and additional to, whatever your SCRAP charges. We give it its own guide because conflating the two is how companies end up with a number that is wrong by a factor of three.

Which one is the marketplace asking for?

The ENV number. Every time.

Sources

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

• MITECO — Registro de Productores de Producto, sección envases — read 2026-09-30
• MITECO — FAQ sección envases (PDF) — read 2026-09-30
• Real Decreto 1055/2022, envases y residuos de envases — read 2026-09-30
• Agencia Tributaria — impuesto sobre envases de plástico no reutilizables — read 2026-09-30
• Ley 7/2022, de residuos y suelos contaminados para una economía circular — 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 ↗