Companies that place packaging on the Spanish market are approaching a key compliance deadline under Spain’s updated packaging and packaging waste regime.
Producers must submit annual packaging declarations for packaging placed on the market in 2025 within the reporting window from 1 January to 2 April 2026, in line with Extended Producer Responsibility (EPR) requirements introduced under Royal Decree 1055/2022.
The obligation forms part of Spain’s implementation of European waste legislation and aims to improve reporting transparency and support national recycling and circular economy targets.
Updated extended producer responsibility requirements in Spain
Royal Decree 1055/2022, adopted in December 2022, establishes a comprehensive regulatory framework for packaging and packaging waste in Spain, setting out obligations for producers of household, commercial and industrial packaging.
The decree expands the scope of EPR, making producers — including importers and companies selling through e-commerce — responsible for financing and organising the treatment of packaging waste they place on the market.
Under this regime, companies that place packaged products in Spain must register with the national Product Producers Registry and arrange membership with a Producer Responsibility Organisation (PRO).
Registered producers are then required to file an annual packaging declaration each year, reporting quantities of packaging placed on the market and details of materials and uses.
Authorities have confirmed that the reporting window for 2025 packaging data runs from 1 January to 2 April 2026, with potential extensions or adjustments applied at the national or regional level.
What the annual packaging declaration must include
The annual packaging declaration requires companies to report specific information on the packaging they have placed on the Spanish market.
Key data typically includes total weights in tonnes, material composition (such as plastics, paper, glass, metals and multi-materials) and whether packaging is intended for domestic, commercial or industrial use.
The declaration may also require details on recycled content and whether the packaging is reusable or single-use.
These reporting obligations apply to all producers, including those based outside Spain but selling into the Spanish market through cross-border sales or online marketplaces.
To comply, foreign companies often need to appoint a Spanish authorised representative, register in the Product Producers Registry and ensure timely submission of their packaging data before the 2 April 2026 deadline.
Non-compliance with reporting requirements can result in sanctions under Spanish waste and product regulations.
Implications for international producers and supply chains
For international businesses operating in or targeting the Spanish market, the early 2026 packaging reporting deadline represents a major compliance milestone within broader packaging regulation and EPR reporting obligations.
The regime aims to provide greater transparency in packaging waste management and to align Spain with EU objectives for recycling and the circular economy.
Producers must integrate reporting processes into their environmental compliance strategies to meet the January-April 2026 submission period for packaging placed on the market in 2025.
As regulatory frameworks continue to evolve — including forthcoming labelling requirements and EU-level packaging rules — companies selling into Spain will need robust data systems and compliance oversight to avoid penalties and maintain market access.
