The direct answer
Registration, scheme participation and volume reporting are separate tasks. PPWR has changed the producer role.
What to check
RPP and SRAP
MITECO describes registration and individual or collective SRAP for household, commercial and industrial packaging. The scheme must cover the relevant category. MITECO · Registro de Productores, envases
Foreign direct sellers
Foreign producers first supplying directly to end users in Spain must appoint an EPR authorised representative in Spain. MITECO · Registro de Productores, envases
Reporting 2026 volumes
MITECO specifies 2 January–31 March 2027 as the reporting window. Allocate volumes using the producer role applicable when sold. MITECO · Registro de Productores, envases
Your action plan
The following steps are our suggested way to organise your project.
- Document customer, supply route and packaging category for each sales model.
- Separate transactions before and after the PPWR transition in your records.
- Reconcile RPP records, scheme evidence and authorisations.
- Plan a data close before the official reporting window.
Prepare your records
Tax identifier, dated sales records, weights by material, RPP evidence and any authorisations.
Frequently asked questions
Does a scheme invoice prove registration?
Treat the scheme contract and registry entry as separate evidence and check both.
Does this guide cover WEEE?
No. It covers packaging; electrical equipment and batteries require separate checks.
Sources and scope
This guide covers the product stream described. Check other EPR streams separately; your supply chain and sales model determine the specific obligations.