EPR obligations for packaging
Whether you are a manufacturer, importer, or distributor of products, have an online store, or sell through third-party retailers, you are required to comply with Extended Producer Responsibility (EPR) in Spain.
This means that you are required to register your company in the Product Manufacturers Register and, in a PRO, as well as to declare all packaging and packaged products that you market in Spain.
The main objective of this regulation is that:
- The financial responsibility for the management of waste from packaged products marketed is transferred to producers and from them to end consumers.
- A circular economy is promoted to encourage more sustainable products and packaging, minimizing the total amount of packaging and improving its materials.
- The costs of waste treatment are covered, directly or indirectly, by the producer and passed on to the end consumer.
- The costs of waste treatment are covered, directly or indirectly, by the producer and passed on to the end consumer.
Obligations of packaged products producers
In accordance with Royal Decree 1055/2022 on packaging and packaging waste, manufacturers of packaged products or companies that market packaging or packaged products in Spain must comply with the legal and environmental obligations arising from Extended Producer Responsibility.
These obligations include, among others:
- Registration of companies in:
- Product Producer Register, or RPP – packaging section
- Registration of companies in a PRO,
- Completion of annual declarations of packaging and materials.
- Payment of the costs arising from the treatment and recycling of these materials
With our Authorized Representation services, INTERZERO takes care of these procedures and fulfills your obligations so that you can focus on what matters most: your business.
What annual declarations am I required to make?
The provisional packaging declaration (or DEA) must be submitted each year at the beginning of the fiscal year and include a realistic estimate of all packaging that will be marketed during the fiscal year, also specifying the materials of which it is composed.
The deadline for submitting this declaration is March 31 March of each financial year, except for companies that register after this date, for which the deadline is December 31 of each financial year.
Once the financial year has ended, the final declaration must be made. This is an adjustment to the provisional declaration, reflecting the actual quantities of packaging and materials placed on the market in the previous financial year. The deadline for submitting this declaration is February 28 of each financial year.
How do you fulfil your obligation?
Any company that markets packaged or packaged products and packaging must comply with its obligations. Companies that pack or package products must comply with their obligations, but how?
1. Make all relevant registrations
In order to comply with current legislation, it must be registered in the following registers:
- register of product manufacturers,
- packaging register,
- SCRAP packaging register.
Ask us how we can make this process easy for you.
2. Application of the Declaration of Estimated Annual Amounts
The annual packaging declaration (AAD) must be submitted each year at the beginning of the financial year and include a realistic estimate of all packaging to be placed on the market in the financial year. Ask us how we can simplify this procedure and help you make the necessary calculations. On the basis of these estimates, the annual fee to be paid to SCRAP for the management of packaging waste will be calculated.
3. Use an annual packaging declaration
After the end of the financial year, it must make an adjustment to the DEA to reflect the actual quantities of packaging and materials placed on the market in the previous year. You will also need to submit a realistic estimate for the following year and pay a fee. To avoid confusion, please contact us so that we can help you with these two procedures and simplify your obligations. A fixed amount, low and incomparably lower than the price of the product.
We look forward to hearing from you. Please do not hesitate to contact us.
