Since the enactment of Real Decreto 1055/2022, Spain has had a comprehensive EPR system with three main obligations:

• RII-AEE – Registry of Electrical Appliances at MITECO (Ministry for Ecological Transition)
• Batteries and Accumulators – Battery Register
• Packaging – Connection to an SCRAP system (Sistema Colectivo de Responsabilidad Ampliada del Productor), e.g., Ecoembes for paper, cardboard, and lightweight packaging, or Ecovidrio for glass

In addition, the Spanish plastic tax (Impuesto especial sobre los envases de plástico no reutilizables) has been in effect since January 1, 2023: €0.45 per kg of non-recycled plastic packaging material. This tax must be paid separately from the EPR license and is often overlooked.

• NIF (Número de Identificación Fiscal) – Spanish tax identification number; foreign companies must apply for an NIE/NIF-E
• Notarized power of attorney with an apostille for the Spanish representative
• Detailed data on materials and quantities for the previous year’s packaging (to 4 decimal places per material category)
• Registration with at least one SCRAP system—Ecoembes is the industry standard; competitors such as Envalora and EcoEnvases have been approved since 2024

€0.45 per kilogram of non-recycled virgin plastic in single-use packaging. Example: Anyone who imports 10 metric tons of PET bottles made from virgin material pays €4,500 in taxes per year—in addition to the Ecoembes license fee.

Manufacturers in Spain, intra-Community purchasers, and importers are subject to the tax. Those who use recycled material may deduct the proportion of recycled material from the tax base—but the proportion of recycled material must be verified by EuCertPlast or an equivalent certification.

Registration with the Spanish tax authority (AEAT); monthly or quarterly filings, depending on volume.

• RII-AEE: Low government fee; take-back system contribution based on volume
• Authorized Representative (Representante Autorizado): 1,200–3,000 € per year
• Ecoembes licensing fee (Punto Verde): typically €200–1,500 per year for small to medium quantities
• One-time notary and apostille fees: €300–600
• Plastic tax (separate, if applicable): €0.45 per kg

Total for the first year without a plastic tax: €3,500–7,000.

6–10 weeks with a complete set of documents. The bottlenecks, in this order, are: NIE application (4–6 weeks, if not already available), notary appointment and apostille (2–3 weeks), and processing by MITECO or Ecoembes (2–4 weeks).

Anyone starting without an NIE should expect the process to take a total of 10–14 weeks.

• The plastic tax is often confused with the Ecoembes license—both must be paid separately
• Several competing SCRAP systems have been approved since 2024—the choice affects rates
• Requirement to Label Reusable vs. Single-Use Packaging (Law 7/2022)
• Catalonia, the Balearic Islands, and other autonomous regions have imposed additional regional taxes on single-use plastics

Inventory already in storage in Germany is considered not yet placed on the market as long as it has not been sold. Once registration is complete, it can be shipped as usual. In the case of retroactive registration, quantities that have already been sold must be reported retroactively—CERTIFY will assess whether voluntary retroactive reporting is advisable to avoid fines.

Standard four-step process:

• Initial Consultation (free of charge): Review of current registrations, product portfolio, and markets
• Compliance Check: Written list of obligations and gaps, including a risk assessment
• Powers of Attorney and Onboarding: Appointment as an Authorized Representative, Transfer of Existing Registrations, or New Registration
• Ongoing Operations: Quantity Reports, Warranty Renewals, Communication with Government Agencies, Annual Reporting

Contracts can generally be terminated on an annual basis.