EPR guide for Spain

Learn how Spain’s new EPR regulations for packaging impact e-commerce. Stay compliant with reporting deadlines and understand your producer obligations.

Extended Producer Responsibility (EPR) Compliance Guide for E-commerce in Spain

 

In the framework of Spain’s EPR regulations, producers are held accountable for the environmental impacts of their products, from production to post-consumer waste. This comprehensive guide aims to support e-commerce sellers within the European marketplace regarding their EPR compliance in Spain.

Key Actors and Definitions

 

Who is a Producer?

In the Spanish EPR context, a producer includes any entity that manufactures, imports, or sells products under its own brand in Spain. This also extends to those importing products into Spain from outside the European Union.

Producer Responsibility Organizations (PROs)

Spain has designated PROs as the organizations responsible for managing waste collection and treatment in line with EPR obligations. They are nonprofit entities authorized by regional and national authorities. They are legally obliged to report the recycling numbers to the Spanish government.

Authorized Representative for Compliance

For companies based outside of Spain that engage in the sale of batteries or accumulators within Spanish territory, adherence to EPR regulations necessitates the appointment of an authorized representative. This individual or entity is tasked with managing the company’s obligations and interactions with governmental authorities regarding EPR compliance.

Steps for EPR Compliance in Spain

To comply with the Spanish EPR regulations, producers should initially identify which product categories are applicable to the items they sell. Following this, the next step is to register with the relevant PRO for each category. After registration, producers must report the quantities of products placed on the market and pay fees as determined by the PRO.

Key Steps for EPR Compliance

  1. Register with a Producer Responsibility Organization (PRO) for each relevant product category, EPR registration is required. You’ll need a unique registration number for each category, and thus register with the relevant, multiple individual systems.
  2. Fulfill annual reporting requirements and pay necessary fees to maintain the validity of the UIN.

Registration and Declaration Process

Who Needs to Register for EPR in Spain?

An EPR registration number in Spain is required for companies that manufacture, import, or sell under their brand within the country, including foreign companies and those importing from outside the EU.

What is the Threshold for EPR Registration?

There is no threshold for EPR registration in Spain, meaning that every producer in Spain must register (for the right categories). This means that in any case, you need a packaging registration.

Where to Register?

EPR registration takes place through local authorities to acquire a producer number and joining relevant PROs for each product category.



EPR Product Categories and Relevant PROs

Here’s an overview of Spain’s EPR categories and their relevant PROs.

Overview of Spain’s EPR Categories & PRO’s

Product CategoryPRO(s)
PackagingEcoembes (household and commercial), Ecovidrio (glass)
Electrical and Electronic Equipment (EEE)Recyclia (Ecoasimelec, Ecofimática, Tragamóvil), Ecotic
Batteries and AccumulatorsEcopilas, Ecolec
Commercial Paper and CardboardAspapel
Chemicals and PesticidesSpecific PROs or recycling systems
Furniture and TextilesUpcoming regulations may specify PROs

 



The Registration Process

The registration process involves identifying applicable categories, gathering necessary documentation, submitting registrations with regional waste authorities and chosen PROs, and obtaining a producer number.

The Declaration Process

Producers must declare annually the quantities of their products on the market and the waste management measures they have taken. This process is completed with financial obligations of paying fees based on reported quantities and set rates by PROs.

How to Maintain Compliant with the EPR Rules?

Compliance is maintained through accurate record-keeping of sales and waste management, regular updates to declarations due to product or volume changes, and staying informed on legislative updates.

Labeling Requirements

Products and packaging must reflect labeling that indicates their recyclability or provides disposal instructions, complying with consumer information obligations under EPR. For products sold in Spain, this means that a Green Dot on all packaging is required.

 

What If You Don’t Comply With the EPR Regulations?

Registration and declaration are mandatory legal requirements that reflect the producer’s contribution to environmental sustainability.

Failure to comply with EPR regulations can incur a range of penalties. Below you find an overview of the penalties for non-compliance to EPR regulations in Spain. It’s important to mention that there is no maximum amount for fines: so make sure you’re always compliant to avoid unpleasant surprises. Not sure if you’re 100% compliant? Give us a call.

Overview of Potential Penalties

Non-compliance AspectPotential Penalties
Failure to Register with Relevant PROFines and sanctions
Inaccurate or Late ReportingFinancial penalties
Non-payment of FeesLegal actions and fines
Improper LabelingFines and corrective actions
Lack of Waste Management PlanSevere financial penalties and prosecution

 

Compliance made easy

Talk to us today to arrange it.

Any questions?

Do you have inventory stored abroad because you sell through Amazon FBA, for example, or use a European fulfillment center? Then you need an European VAT registration in that country! Save yourself the paperwork and let us apply for your VAT registration.

Where can I use the VAT registration?

You can use the VAT number for any business purpose. For example, when selling through Amazon, Bol.com, Shopify or another platform. The number is also valid if you are going to do business locally that requires a European VAT number.

If you have a VAT registration abroad, you will also have to file VAT returns there. How often and when to do so, depends on the country. It can be monthly, or quarterly.

We understand that you don’t feel like doing all the VAT administration. So leave it to us: link your sales accounts to Staxxer, so we can always accurately file your European VAT return. Then you won’t spend any more time on VAT returns.

July 1, 2021, the One Stop Shop went into effect, also known as the One-Stop Shop system. Do you sell more than €10,000.- across borders every year? Through this new regulation, you declare your VAT of all the countries in which you do business at once. If you have all your stock in your country of residence, you no longer need a VAT number in those other countries. In the One Stop Shop declaration, you declare every cross-border sale within the EU.

That involves quite a bit of math. Especially if you sell through multiple platforms! We’ve come up with something on that: you can link all your sales channels (Amazon, Bol.com, Shopify and more) to Staxxer. This way you always have all your VAT data at hand, and within 5 minutes you have your One Stop Shop declaration arranged. Staxxer does the calculations, and our Staxxers handle the declaration further. Handy right?

A tariff is a tax on imported goods, and the tariff number, also called a tariff code or HS code, gives customs officials more information about what kind of item is being imported. The standard code is a six-digit number, but some countries have codes of 8 or 10 digits.

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Vat consult for e-commerce

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