Spain EPR Obligations: Packaging, WEEE, Textiles and Batteries — SIG Registration and Eco-Fees

Spain currently has EPR obligations for these product categories: (1) packaging — managed by Ecoembes (for household packaging) and Ecovidrio (for glass); (2) WEEE — managed by ECOLEC, Tragamos or ERP España; (3) batteries and accumulators — managed by EColum or ERP España; (4) end-of-life vehicles and tires — managed by SIGAUS (oils) and SIGRAP (tires); (5) furniture — managed by SIG-Recoil; (6) textiles and footwear — new scheme under Ley 7/2022, operational from 2025, managed by a designated SCR. Each category has its own registration process, fee structure and reporting timeline. For cross-border sellers, packaging and WEEE are the most common obligations. If you sell electronics with batteries, you may need to register with both the WEEE and batteries SCRs.

Non-resident sellers must: (1) appoint an authorised representative established in Spain — this person acts as your legal contact for EPR compliance; (2) register in the Registro de Productores de Productos (Industrial Producers Registry) maintained by the Ministerio para la Transición Ecológica; (3) contract with the relevant SCR (collective system) for each product category — e.g., Ecoembes for packaging, ECOLEC for WEEE; (4) begin declaring your placed-on-market volumes and paying eco-contributions. Registration processing takes 2-6 weeks. The authorised representative must be a Spanish tax resident or a company with a Spanish address. Typical fees: representative €500-2,000 per year; SCR membership €100-500 per year plus per-unit eco-contributions.

Eco-contributions (eco-tasas) are calculated per unit or per kilogram of material placed on the Spanish market. Rates vary by category and material: packaging — €0.005-0.12 per unit depending on material type (paper €0.005-0.01, plastic €0.02-0.12, metal €0.005-0.01, glass €0.005-0.01); WEEE — €0.01-0.50 per unit depending on product weight and category. Eco-modulation means fees are adjusted based on environmental criteria: (1) recyclability — products using mono-materials score better; (2) reusability — refillable or durable designs get discounts; (3) hazardous substance content — products containing restricted substances pay more. Ecoembes publishes annual modulation tables. For 2025, the modulation can result in fee reductions of up to 20% for highly recyclable packaging, or increases of up to 50% for hard-to-recycle materials. Declare accurate material compositions to benefit from lower modulation rates.

Under Ley 7/2022, Spain is implementing a new EPR scheme for textiles, clothing and footwear, expected to become fully operational from 2025. This covers: clothing, household textiles (bed linen, towels), footwear, and textile accessories. Producers (including distance sellers importing these goods into Spain) must register with the designated SCR and pay eco-contributions based on the number of items placed on the market. The scheme aims to finance textile collection, sorting and recycling infrastructure. Estimated fees: €0.01-0.05 per garment depending on material composition. Natural fibres (cotton, wool) may have lower fees than synthetic fibres (polyester, nylon) due to recycling value. Cross-border sellers of clothing and textiles into Spain must comply — this applies regardless of whether you sell through a marketplace or your own DTC store.

Under Ley 7/2022, EPR non-compliance penalties are tiered: (1) minor infringements (e.g., late registration, incomplete declarations): fines of €1-10,000; (2) serious infringements (e.g., failure to register with an SCR, failure to pay eco-contributions): fines of €10,001-1,750,000; (3) very serious infringements (e.g., deliberate evasion, placing hazardous products on the market): fines of €1,750,001-3,500,000. Additional sanctions include: disqualification from placing products on the Spanish market for up to 2 years, and publication of the infringement (naming and shaming). For cross-border sellers, the most common risk is failing to register with the relevant SCR — this is classified as a serious infringement. Spanish authorities have been increasing enforcement against non-resident sellers, particularly for packaging and WEEE obligations.