Current position, reviewed 6 September 2026: The Registro de Productores de Productos (RPP), packaging section, is Spain’s national administrative register. Royal Decree 1055/2022 and the PPWR determine who registers, reports and joins an authorised producer-responsibility system.
Identify the producer after 12 August 2026
MITECO explains that the PPWR producer definition changes the role analysis for some businesses. For transport, service and primary-production packaging, the manufacturer, importer or distributor that first introduces it onto the Spanish market may be the producer. Own-brand commissioning and the microenterprise exception also require specific analysis.
RPP registration and annual reporting
Register the responsible entity in the packaging section of the RPP and maintain the packaging categories and producer-responsibility arrangements recorded there. Annual information covers packaging placed on the Spanish market; 2026 reporting requires attention to which entity held the producer role before and after the PPWR application date.
SRAP arrangements
Producers of household, commercial and industrial packaging must fulfil relevant obligations through an individual or collective extended-producer-responsibility system. MITECO states that certificates for contracted collective systems must be attached within the specified process and must cover the correct packaging category.
Foreign distance sellers
Businesses established outside Spain that first supply packaged products directly to final users in Spain must assess the requirement to appoint an authorised representative for EPR. The representative performs registration and reporting according to the Spanish framework.
Marketplace verification
Platforms enabling distance contracts must obtain registration information and producer self-certification concerning EPR compliance before allowing relevant producers to use the marketplace. Producers should therefore maintain a consistent record of their RPP identity, scheme status and representative.
Working file
- RPP registration and producer entity.
- Packaging category and market-route analysis.
- SRAP certificate or individual-system evidence.
- Authorised-representative documentation.
- Annual packaging quantities and reporting record.
- 2026 role-transition rationale where relevant.