Ley 7/2022 de Residuos
Spain EPR — Ley 7/2022 de Residuos. The regulatory authority is Ministry of Ecological Transition, operating through the Ecoembes system.
All producers, importers, online sellers, and fulfillment service providers placing packaged goods on the Spain market must register with a PRO and fulfill EPR obligations. Non-Spain sellers must appoint an Authorized Representative.
Spain operates a material-based compliance system. Two approved collective schemes (SCRAP) cover all packaging types. Each is the sole approved scheme for its material categories:
Registration: Registro de Productores de Productos — Ministerio para la Transición Ecológica
Reporting & Deadlines: Annual by March 31. Packaging data must be reported by material type and weight. Reports are submitted through Registro de Productores (REP).
Maximum Fine: €2,000,000. Non-compliance with Spain EPR regulations can result in fines, marketplace listing deactivation, and legal consequences. Amazon and other marketplaces may independently verify compliance and suspend non-compliant sellers.
REP registration number required for marketplace compliance
If you sell on Amazon, eBay, or other marketplaces and ship products to Spain, you are responsible for EPR compliance in this market. The "pay on behalf" model is ending — marketplaces will no longer handle this for you. Register now to avoid listing deactivation.
Follow these steps to register for EPR packaging compliance in Spain. Note that Spain requires both a national producer registry entry and a PRO contract — a dual obligation many sellers miss.
Register at MITERD producer registry
Register your company in the Registro de Productores de Productos (Section of Packaging) at the Ministry for Ecological Transition and the Demographic Challenge (MITERD). This is the mandatory national producer registry. You will receive a REP registration number.
Contract with Ecoembes (and Ecovidrio if glass)
Sign a contract with Ecoembes for lightweight packaging (plastic, metal, carton) and paper/cardboard compliance. If you use glass packaging, you must also contract separately with Ecovidrio. Each is the sole approved collective scheme (SCRAP) for its material categories.
Report packaging volumes
Report your packaging volumes to Ecoembes (and Ecovidrio if applicable) by material type and weight. Annual declarations must be filed through the Registro de Productores (REP) by March 31 each year.
Upload registration to Amazon
Upload your REP registration number and Ecoembes confirmation to your Amazon Seller Central account. Navigate to Settings → Account Info → EPR Compliance to enter your Spain packaging registration details.
File annual declaration by March 31
File your annual packaging declaration by March 31 each year, reporting all packaging placed on the Spanish market during the previous calendar year. This declaration goes through the Registro de Productores and to your contracted PRO(s).
The EU Packaging and Packaging Waste Regulation (PPWR) will introduce harmonized rules across all EU member states, including Spain. Spain already has relatively strict packaging rules under Ley 7/2022, but PPWR will add further requirements.
Spanish sellers should prepare for both continued national obligations and the new EU-wide requirements. ekoniq monitors these developments and will guide you through both layers of compliance.
If your company manufactures products outside the EU and exports them to the European market, PPWR requires you to prove that your packaging meets EU sustainability standards — before your goods cross the border. ekoniq prepares the complete PPWR compliance package so you can export with confidence.
What we deliver (15–18 documents):
✓ Full Technical Documentation (Annex VII, Module A)
✓ EU Declaration of Conformity (Annex VIII)
✓ Recyclability assessment of all packaging
✓ Substance restriction verification (PFAS, heavy metals)
✓ Recycled content declaration
✓ Packaging minimisation statement
✓ Labeling guidance (material codes, sorting pictograms, QR)
✓ Accredited lab testing coordination (SGS, Intertek, Bureau Veritas)
✓ EPR registration in target EU countries
✓ Authorised Representative appointment (Article 45)
These are the most frequent compliance mistakes we see sellers make in the Spanish market.
Only registering with Ecoembes without national registry
Spain requires dual registration: you must register both in the national Registro de Productores de Productos at MITERD and contract with a collective scheme (Ecoembes/Ecovidrio). Many sellers only do one or the other. Both are mandatory under Ley 7/2022.
Forgetting glass requires Ecovidrio separately
If your products use glass packaging, Ecoembes does not cover you for glass. You must separately contract with Ecovidrio, which is the sole approved collective scheme for glass packaging in Spain. This is an obligation specific to the Spanish market.
Not knowing Spain requires packaging labeling
Under Ley 7/2022, Spain requires packaging to carry specific labeling indicating material composition and the appropriate waste collection stream. Many sellers are unaware of this obligation and risk non-compliance. This is separate from the Ecoembes/Ecovidrio registration.
Ignoring Autonomous Community (regional) requirements
Spain's Autonomous Communities may have additional packaging and waste requirements beyond the national framework. Depending on where your products are stored and distributed, regional regulations may apply. This is a unique feature of the Spanish regulatory landscape that sellers from other EU countries often overlook.
Not appointing an Authorized Representative
Non-Spanish sellers who place packaged goods on the Spanish market must appoint an Authorized Representative established in Spain. Without an AR, you cannot register in the national producer registry or contract with Ecoembes. ekoniq can serve as your AR for the Spanish market.
It depends on your packaging materials. Ecoembes covers lightweight packaging (plastic, metal, carton) and paper/cardboard. Ecovidrio covers glass packaging exclusively. If you sell products in glass bottles or jars, you need both. Most e-commerce sellers who use only cardboard and plastic packaging only need Ecoembes.
EPR compliance costs in Spain depend on your packaging volumes, material types, and whether you need an Authorized Representative. Ecoembes and Ecovidrio fees are calculated based on the weight and type of packaging materials you place on the market. Contact ekoniq for a personalized quote based on your specific situation.
The Registro de Productores de Productos is the national producer registry maintained by MITERD (Ministry for Ecological Transition). It is a government-run registry where all packaging producers must register. This is separate from your Ecoembes contract — you need both. The registry assigns your official REP number, which Amazon and other marketplaces require.
Yes. If you use Amazon FBA and your products are stored in or shipped to Spain, you must register in the Registro de Productores and contract with Ecoembes (and Ecovidrio for glass). Amazon requires your REP registration number as proof of compliance and may deactivate your listings without it.
Under Ley 7/2022, packaging in Spain must carry labeling indicating the material composition and the appropriate waste collection stream (e.g., yellow bin for lightweight packaging, blue bin for paper/cardboard, green bin for glass). The labeling must help consumers sort waste correctly. PPWR may further harmonize these requirements across the EU.
The dual registration process in Spain can take longer than in single-system countries. The national Registro de Productores may take several weeks to process, and the Ecoembes contract is a separate process. When ekoniq handles your registration, we manage both processes in parallel to minimize the timeline. Contact us for current processing estimates.
Yes. Spain's 17 Autonomous Communities have the authority to set additional packaging and waste regulations beyond the national framework. While the national Ley 7/2022 and Ecoembes/Ecovidrio registration cover your primary obligations, some regions may impose extra reporting or environmental requirements. ekoniq can advise you on any regional requirements that apply to your distribution footprint in Spain.
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ekoniq handles your complete EPR registration and compliance. We take care of registration, reporting, and ongoing obligations so you can focus on selling.
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