Rechtsstand: 30 September 2026 — the date every statement on this page was checked against the sources below.
If you ship packaged goods from your own site to customers in Spain, you are the producer in Spain and need a representative, a registration and a scheme contract — the same as an Amazon seller. The difference is that no platform will stop you trading until you have it, so the obligation goes unnoticed until an authority or a scheme asks. Sources (4)Real Decreto 1055/2022, envaReal Decreto 1055/2022, envases y residuos de envasesEcoembesEcoembes — precios Punto VerdeMITECOMITECO — Registro de Productores de Producto, sección envasesRegulation (EU) 2025/40 (PPWRegulation (EU) 2025/40 (PPWR), Article 45
Nobody is checking, and that is the problem
A marketplace seller finds out about Spanish EPR when a listing is suspended. A Shopify or DTC brand finds out much later, because there is no gatekeeper in the way. The obligation is identical; only the enforcement moment differs.
That asymmetry matters commercially. A direct seller who has been shipping to Spain for three years does not have three years of grace — they have three years of unreported packaging that has to be quantified when they do register.
The duty is the same
RD 1055/2022 attaches the producer obligations to whoever first places the packaged product on the Spanish market, regardless of channel. Your own shop is a channel like any other. There is no turnover threshold, no volume threshold, and no exemption for small brands.
What direct sellers usually get wrong
- Thinking VAT covers it. OSS and IVA are tax registrations. They have no relationship to packaging EPR and do not satisfy it.
- Thinking the carrier or 3PL handles it. They do not. The obligation attaches to the seller, not the logistics provider.
- Declaring only the product packaging. The shipping box, void fill, tape and labels are all packaging you place on the market.
- Ignoring the film. Poly mailers are charged by Ecoembes at €1.269/kg, nearly eleven times cardboard. For a DTC brand this is usually the largest single line in the scheme bill.
What to do
Appoint a representative, register in the RPP, obtain the ENV number, join the right scheme, and declare. If you have been shipping to Spain for a while, say so at the start — back-years are much cheaper handled deliberately than discovered by a scheme audit.
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
- Ecoembes — precios Punto Verde — read 2026-09-30
- MITECO — Registro de Productores de Producto, sección envases — read 2026-09-30
- Regulation (EU) 2025/40 (PPWR), Article 45 — read 2026-09-30
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 ↗