The authorized representative in Spain is responsible for fulfilling the Manufacturer’s obligations under the Spanish EPR legislation. If your company is not based in Spain, it can only comply with EPR obligations through an authorized representative.

According to Spanish EPR legislation, the term Manufacturer includes any operator who manufactures, sells, packages, imports, or makes intra-Community deliveries of packaged products, electrical and electronic equipment, or batteries and accumulators on the Spanish market.

This applies to both Spanish-based and foreign companies (established in the EU or outside the EU).

According to the Spanish EPR regulation, the following are also considered Packaging Producers:

• retailers, couriers and e-commerce operators who use packaging for shipping the products sold,
• companies not based in Spain that use packaging to market products in the country,
• e-commerce platforms that introduce packaged products from abroad to the Spanish market,
• companies that package products directly at the point of sale (e.g. take-away food),
• companies that package products destined for the Spanish market.

If you place packaged products, electrical and electronic equipment, or batteries and accumulators on the Spanish market and are not based in Spain, you are most likely required to appoint an authorized representative for your company.

To clarify your obligation, it is useful to refer to the definition of Producer.

Note: The Spanish EPR regulation does not provide for quantitative exemptions. EPR obligations therefore apply to all producers, regardless of the quantities of products or packaging placed on the market.

The obligation to appoint an authorized representative in Spain has been in force since January 1, 2023.
From this date, all foreign entrepreneurs placing packaged products, electrical and electronic equipment, or batteries and accumulators on the Spanish market must fulfill their obligations through an authorized representative.

Your company’s authorized representative in Spain can be a natural person, legal entity, or organization that meets all of the following conditions:

• have an address (registered office) in Spain,
• be a member of one of the extended producer responsibility schemes in Spain (SCRAP),
• be registered in the Registro de Productores de Producto (Register of Product Manufacturers).

Remember: your company’s authorized representative will fulfill your obligations and represent you before the Spanish authorities! Therefore, always choose experienced and reliable operators who can guarantee the highest quality service.

The appointment of an authorized representative must take place before the start of operations involving the placing on the Spanish market of packaged products, electrical equipment, or batteries and accumulators.
If you currently sell such products to customers in Spain and fall within the definition of a Manufacturer under the Spanish EPR regulation, you are required to appoint an Authorized Representative as soon as possible.

Your company’s authorized representative in Spain is responsible for fulfilling the obligations set forth in the Spanish Extended Producer Responsibility (EPR) legislation. Their duties include:

• registration of the company in the Producers Register,
• constant monitoring of the company’s compliance with the EPR regulation in Spain,
• submission of annual reports on the types and quantities of packaging, equipment and batteries placed on the Spanish market,
• organization and coordination of waste management activities resulting from introduced packaging, equipment and batteries (generally through membership in the Collective System of Extended Producer Responsibility – SCRAP),
• contacts with local authorities and offices,
• management of licenses for packaging and equipment placed on the market, including the payment of license fees to the competent authorities (when the established limits are exceeded).

Any company that fails to comply with the obligation to appoint an authorized representative in Spain may face:

• economic sanctions, the amount of which depends, among other things, on the quantities of packaging, equipment and batteries placed on the market,
• bans on the marketing of certain products on the Spanish market.

Yes. We currently provide authorized representation services in all 27 EU member states, as well as the United Kingdom, Norway, and Switzerland. We act on behalf of both EU and non-EU companies.

Thanks to our comprehensive EPR services, entrepreneurs placing packaging and products in multiple European markets can quickly, conveniently, and centrally appoint an Authorized Representative in different European countries.