Rechtsstand: 30 September 2026 — the date every statement on this page was checked against the sources below.
All three now require an authorised representative under PPWR Article 45(3), but each has its own register, its own schemes and its own declarations, and representation is appointed per member state. Spain and Germany are structurally similar — one register plus one scheme contract. France is far broader, with nineteen separate streams. Spain has no textile EPR; France has had one since 2007. Sources (4)Regulation (EU) 2025/40 (PPWRegulation (EU) 2025/40 (PPWR), Article 45Real Decreto 1055/2022, envaReal Decreto 1055/2022, envases y residuos de envasesLey 7/2022, de residuos y suLey 7/2022, de residuos y suelos contaminados para una economía circularMITECOMITECO — Registro de Productores de Producto, sección envases
What is the same
Since 12 August 2026, Article 45(3) of the PPWR requires a producer selling into a member state where it is not established to appoint an authorised representative there. That is now true in all three countries, and in the other twenty-four.
In each, the structure is a public register plus a private scheme: you register with the state, and you contract with an organisation that actually collects and recycles.
What is different
| Spain | Germany | France | |
|---|---|---|---|
| Register | RPP (MITECO) | LUCID (ZSVR) | SYDEREP / eco-organisme |
| Your number | ENV/year/9 digits | LUCID number | IDU |
| Scheme | SCRAP — Ecoembes, Ecovidrio, Envalora | Duales System — ten operators | Éco-organisme — Citeo, Léko… |
| Packaging streams | One, split household / commercial | One, split household / § 39 B2B | Household and professional, separately |
| Other EPR streams | Tyres, bags, tobacco; WEEE and batteries elsewhere | WEEE, batteries | Nineteen streams |
| Textiles | None yet | None | Yes, since 2007 |
| Annual declaration | 31 March | Varies by scheme | Varies by stream |
The textile trap
Companies that already declare textiles in France routinely assume Spain works the same way. It does not. Ley 7/2022 foresees producer responsibility for textiles and footwear, but the implementing regulation has not been approved, so there is no register section to join and nothing to declare. A provider offering to register your textiles in Spain today is selling you something that does not exist.
The same applies to furniture, industrial oils, wet wipes and balloons: foreseen, not yet in force.
One representative cannot cover three countries
Representation is appointed per member state, and the representative must be established in that state. A company selling into Spain, Germany and France needs three appointments, three registrations and three sets of declarations. There is no single EU representative for EPR, whatever a provider's marketing implies.
We run the Spanish side. For the other two, EPR Germany Rep and EPR France Rep are ours as well, which at least makes the paperwork consistent.
Sources
Every claim above comes from one of these. Primary law and the competent authority first; no provider marketing pages.
- Regulation (EU) 2025/40 (PPWR), Article 45 — read 2026-09-30
- Real Decreto 1055/2022, envases y residuos de envases — read 2026-09-30
- Ley 7/2022, de residuos y suelos contaminados para una economía circular — read 2026-09-30
- MITECO — Registro de Productores de Producto, sección envases — 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 ↗