Businesses introducing packaged products, electrical equipment and batteries to the Spanish market must comply with many obligations imposed by the regulations on extended producer responsibility (EPR). This also applies to foreign companies, which the legislator has additionally obliged to establish an authorized representative in Spain. How to comply with the new EPR regulations in Spain?

The regulations on Extended Producer Responsibility (EPR) in Spain were introduced by several legal acts: Law 7/2022 of 8 April 2022 and Royal Decrees 106/2008, 110/2015 and 1055/2022. According to these regulations , all traders who sell packaged products, electrical and electronic equipment and batteries and accumulators to Spain must comply with a number of legal obligations .

The most important responsibilities of the EPR in Spain include:

• obtaining a tax identification number (NIF),
• registration in the Producer Register – Registro de Productores de Producto (Spanish equivalent of BDO) and obtaining an individual EPR number,
• ensuring the management of waste generated from packaging, equipment (WEEE) and batteries introduced to the Spanish market,
• submitting annual reports on the types and quantities of products covered by the EPR that the entrepreneur has introduced to the Spanish market,
• licensing of introduced packaging and equipment

Foreign entrepreneurs cannot perform any of these tasks on their own – EPR regulations oblige them to appoint an authorised company representative in Spain who will take over all the obligations related to extended producer responsibility.

The obligation to appoint an authorised EPR representative applies to companies not established in Spain that introduce to the Spanish market:

• electrical and electronic equipment (e.g. household appliances, consumer electronics, electronic toys),
• batteries and accumulators (as well as devices containing batteries or accumulators),
• products in packages :
• domestic ( individual in which the product is delivered to consumers),
• commercial (used for storage and packaging in retail and service outlets),
• industrial (collective) .

EPR regulations apply not only to entrepreneurs selling the above-mentioned products through traditional distribution channels (stationary shops, wholesalers). They also cover companies that offer their products through own online stores or sales platforms, e.g. Amazon, Zalando or eBay.

Importantly, Spanish EPR regulations do not provide for quantitative exemptions, which means that even companies that sell just a few such packages or products to Spain must appoint an authorized representative. Signing an agreement with an entity that will take over EPR obligations in Spain is therefore a necessary condition that all entrepreneurs introducing any packaged products, batteries and accumulators, and electrical and electronic equipment to the Spanish market must meet.

At Interzero, we provide comprehensive support to entrepreneurs in fulfilling their obligations under Extended Producer Responsibility (EPR). We offer an authorized representative service in Spain to all companies that introduce packaged products, electrical and electronic equipment, and batteries to the Spanish market.

As an authorized representative of your company in Spain , we will take care of:

• registration of your company in the Spanish Register of Producers,
• recycling and management of waste from packaging, equipment and batteries that you introduce to the Spanish market,
• joining the extended producer responsibility system (EPRS, SCRAP),
• reporting on packaging, equipment and batteries introduced in each calendar year,
• licensing of packaging and equipment and payment of licensing fees on behalf of your company (if necessary),
• representing your company in the scope of EPR obligations before Spanish authorities and offices.

Discover the range of our services and choose Interzero as your authorized representative in Spain!

By choosing Interzero services, you will complete all formalities quickly, conveniently and 100% online .

1. Create a free account for your company on Interzero España (it only takes 1 minute!).
2. Complete the information on the quantity and types of packaging being introduced and calculate the cost of the service.
3. Confirm your details and proceed to finalize your order.
4. Follow the further instructions that we will send you electronically.

Once the formalities are completed, we will take care of registering your company and fulfilling the remaining obligations arising from the EPR in Spain.

Find answers to the most frequently asked questions about the Authorized Representative and EPR regulations in Spain.

For more information click here: EPR Obligations – Interzero Authorized representative in Spain

The Authorized Representative in Spain is the company’s representative who takes responsibility for fulfilling the Producer’s obligations under the Spanish EPR regulations. If your company is not based in Spain, you can only fulfill your obligations under the EPR through an Authorized Representative!

According to the Spanish EPR regulations, the term Producer should be understood as meaning any entrepreneur who manufactures, sells, packages, imports or carries out intra-Community supply of packaged products, electrical and electronic equipment or batteries and accumulators on the Spanish market.

This applies to both entrepreneurs based in Spain and foreign companies (based in the EU or outside the EU).

Under Spanish regulations on extended producer responsibility, packaging producers are also:

• sellers, courier companies and online sellers who use shipping packaging to deliver the products they sell,
• companies not based in Spain that use packaging to introduce products to the Spanish market,
• e-commerce platforms that introduce products packaged outside Spain to the Spanish market,
• companies that package products directly at the point of sale (e.g. takeaway food),
• entities involved in packaging products intended for introduction to the Spanish market.

If you are introducing packaged products, electrical and electronic equipment or batteries and accumulators to the Spanish market and you are not based in Spain, you probably need to appoint an authorized representative of your company in Spain. The definition of Producer provided above may be helpful in identifying your obligation.

NOTE: Spanish EPR regulations do not provide for quantitative exemptions. EPR obligations must therefore be fulfilled by all Producers, regardless of the quantity of packaged products, equipment and batteries placed on the market.

Need more information about EPR obligations in Spain and other European countries?Create a free account at Licenzero and learn about your company’s obligations!

The obligation to appoint an authorised representative in Spain came into force on 1 January 2023. From now on, all foreign entrepreneurs who introduce packaged products, electrical and electronic equipment or batteries and accumulators to the Spanish market must fulfil their obligations as an introducer through an authorised representative.

The authorized representative of your company in Spain can be a natural person, a legal person or an organization that meets all of the following conditions :

• has an address (registered office) in Spain,
• is a member of one of the extended producer responsibility systems in Spain (SCRAP),
• is registered in the Spanish Register of Producers ( Registro de Productores de Producto ).

Remember that your company’s authorized representative will perform your duties and represent you before Spanish authorities and offices! For this reason , choose only experienced, proven entities as your authorized representative, who can guarantee the highest quality of services provided!

You should appoint an authorised representative for your company before you start your business of introducing packaged products, electrical equipment or batteries and accumulators to the Spanish market. If you currently sell such products to customers in Spain and you are a manufacturer within the meaning of the Spanish EPR regulations, you must appoint an authorised representative as soon as possible

Your company’s authorized representative in Spain takes responsibility for fulfilling the obligations arising from the Spanish regulations on extended producer responsibility. Their duties therefore include, among others:

• registration of the company in the Register of Producers,
• ongoing monitoring of the company’s compliance with EPR regulations in Spain,
• annual reporting of the types and quantities of packaging, equipment and batteries introduced to the Spanish market,
• organization and coordination of activities related to the management of waste from introduced packaging, equipment and batteries (usually comes down to joining the collective extended producer responsibility system – SCRAP),
• contact with local authorities and offices,
• licensing of introduced packaging and equipment , including payment of a license fee to the relevant authorities (charged after exceeding the limits).

Any company that fails to meet its obligation to appoint an authorised representative in Spain may be subject to:

• financial penalties , the amount of which depends on, among other things, the amount of packaging, equipment and batteries introduced,
• bans on introducing specific products onto the Spanish market.

Yes . We currently provide authorised representative services in all 27 EU member states, as well as in the UK, Norway and Switzerland . This allows businesses introducing packaging and products covered by EPR regulations to many countries to quickly, conveniently and comprehensively establish an authorised representative in various European markets.

Discover our authorization offer for small and large companies !