How do you register for EPR in Spain in 2026?

By the end of this guide your company will hold every registration Spain requires under extended producer responsibility (EPR) for packaging, electronics and batteries, with the right party filing each one, whether you are established in Spain or sell into it from abroad.

How do I register for EPR in Spain?

Spain has three separate EPR registrations, one each for packaging, electronics and batteries, and they sit with two different ministries.

• Packaging is registered in the RPP, the producer register run by the environment ministry MITECO. A company abroad only files it when it sells directly to end users in Spain, and then through a Spanish authorised representative.
• Electronics and batteries are two separate registrations with the Ministry of Industry and Tourism, the RII-AEE and the RII-PyA. A company with no Spanish establishment files both through a Spanish authorised representative.

Every registration must exist before the first product is made available in Spain, and each one ends in a number that goes on your invoices. The six steps below take the three registrations in the order Spain's rules set.

What to gather first

Before you open any of the registers, gather these five company details and documents.

1. A Spanish tax number (NIF)

   MITECO's portal identifies every company by one, and a company abroad applies to the Spanish tax agency for a NIF starting with N.

2. A way to sign in to the Spanish portals

   That is a digital certificate or a Cl@ve login, or a power of attorney in the REA, Spain's online register of powers, for whoever files for you.

3. Your brand names

   Every brand name you place electronics and batteries under in Spain.

4. A product list sorted by stream

   Count the batteries built into your devices as batteries, and sort your packaging into household, commercial and industrial.

5. A mandate for a Spanish representative

   A written mandate for a Spanish authorised representative, if you have no establishment in Spain.

The one question that decides your whole route

For packaging, it also matters who buys from you:

• A Spanish business. That business is the producer and registers in the RPP.
• End users directly. You are the producer, and your Spanish representative registers you.

Two ministries and three answers to who files

EPR registration is national everywhere in the EU, and how to register for EPR in Europe sets out that frame. Spain then splits it between two ministries.

Across EPR in Spain the duties most producers trigger sit in three registrations, and a webshop selling a packaged device with a battery inside touches all three. What catches producers is that each one answers the question of who files differently.

Below are Spain's three registrations side by side, with fees as published in September 2026.

The packaging rule is the newest. Since 12 August 2026 the EU packaging regulation (PPWR) decides who the packaging producer is, and MITECO applies its definition in place of the old Spanish one.

A company abroad that sells to Spanish businesses stopped being the producer, and marketplaces stopped standing in for sellers without a representative. They now have to check each seller's RPP number instead.

Batteries changed a year earlier. Since 18 August 2025 the EU Battery Regulation's register rules apply, and a seller abroad that ships batteries straight to Spanish users must appoint a representative in Spain.

A draft royal decree that closed consultation on 3 September 2026 would move battery registration to MITECO from 2028, and it is not law yet.

A 6-step guide to EPR registration in Spain

This guide takes you from the first check, whether Spain counts you as the producer, to holding every registration number you need. The steps run in the order Spain's rules set, and each one ends with what you should have in hand before you move on.

Step 1. Confirm Spain counts you as the producer

All three Spanish rules point at whoever first makes a product available in Spain, per stream.

For packaging that is the PPWR definition. You are the producer if you are established in Spain and first make packaged products available here, or established anywhere else and sell them directly to end users in Spain.

A company abroad that sells to a Spanish importer is not the producer, because the importer is.

For electronics it is the manufacturer, the own-brand seller, the importer and the seller abroad that ships equipment to Spanish users (Real Decreto 110/2015). For batteries it is the first time a battery is placed in Spain, the one inside your device included.

You are done when every product line has a yes or no against each stream. A packaged cordless drill sold direct to Spanish customers is three yeses.

Step 2. Work out which registers you owe

Each yes maps to one registration. Packaging goes to the RPP at MITECO, in its packaging section, before the first packaged product is made available.

Electronics go to the RII-AEE at the Ministry of Industry and Tourism. Batteries go to the RII-PyA, a separate section of the same industrial register, and one registration does not cover the other.

You are done with the list of registrations you owe. The drill owes three, under two ministries. Any other stream you sell into is in the table further down this page.

Step 3. Decide who files each one

Established in Spain. You register all three in your own name. You may also let someone file for you: for the RPP only under a power in the REA, and for the two industry registers your scheme can file as a service.

Selling from abroad. Your Spanish authorised representative files the RII-AEE and the RII-PyA. For packaging you need one only when you sell directly to end users, and a Spanish subsidiary takes that role while a branch does not.

You are done when each registration has a name against it. If you are still choosing a representative, how to appoint an EPR authorised representative walks the appointment.

Step 4. Gather what each register asks for

Each portal checks the data before it issues a number, so collect it register by register.

1. The RPP asks for your NIF and activity code, your packaging categories and whether each is single-use or reusable, and at least one scheme per category with a one-page membership certificate.
2. The RII-AEE asks for a Cl@ve login, your and your representative's details, the scheme contract, the type of financial guarantee, how you sell, each product's category and brand, and a first-year estimate in units and kilos.
3. The RII-PyA asks for your brands, the battery classes you place, how you meet your obligations and your tax number.

All three want your scheme before they want you. A SCRAP is Spain's name for a producer responsibility scheme, and joining one comes first.

Step 5. Register in the order the schemes set

All three registrations wait on your schemes, so line those up first.

1. Appoint the representative if you need one. Both Ministry of Industry registrations wait on it.
2. Join a SCRAP for each stream and each packaging category. How to choose a producer responsibility organisation covers the choice.
3. Register in the RPP through MITECO's packaging register page. The number, ENV plus the year and nine digits, comes the moment you sign.
4. Apply for the RII-AEE and the RII-PyA on the Ministry of Industry's electronic office. Each number follows once your data is validated.
5. Put each number on your invoices, and as a seller abroad show the industry numbers on your website too.

You are done with three registration numbers, each held by the party the rules name.

Step 6. Do what each registration makes due next

Each number starts its own reporting clock.

1. Packaging. Give your SCRAP its data by 28 February and file the annual declaration of packaging placed on the market with MITECO by 31 March, in a simplified form below 15 tonnes. Changes of scheme or category run from 1 October to 31 December.
2. Electronics. Declare the equipment you placed on the market to the RII-AEE every quarter, zero quarters included, and update your entry within a month of any change.
3. Batteries. Declare the batteries you placed on the market to the RII-PyA, and make sure your SCRAP files the annual activity report with each region before 1 April.

The reports themselves are their own guide. How to do EPR reporting walks the cycle.

The other streams Spain regulates

Beyond packaging, electronics and batteries, Spain runs producer duties for four more streams, while its textile decree is still a draft.

Below is the register each one runs through, so you can rule them in or out in one pass.

One product record behind three registrations

There are two ways through the work above, and both rest on the same product data.

Run the filings yourself

Every step above is data work before it is filing work. The packaging split by category and material, the equipment by category, brand and weight, the batteries by class, and then the same figures again in the shape each register and scheme wants them.

Repax Core holds one structured record per product, broken down to its materials and components, takes your sales data in through integrations or order imports, and builds the per-register cut from it.

The quarterly RII-AEE declaration, the battery figures and the yearly packaging declaration for MITECO come out of the same record.

Or hand the filings over

If you would rather not run them yourself, Repax Comply is the managed route, linked at the top of this guide. Producers register and report through Repax market by market, with an authorised representative appointed where the country requires one.

The Spanish detail to know is how that handover works. MITECO lets someone else file the RPP entry only under a power you grant in the REA, so the registration stays in your name whoever files it.

For the tools that hold Spanish register data side by side today, the best Spanish EPR software in 2026 ranks them.

6 common mistakes when registering for EPR in Spain

Below are the six mistakes producers make most often when they register in Spain.

1. Registering packaging you do not owe

   A company abroad that sells only to Spanish businesses registering in the RPP. Since 12 August 2026 its Spanish importer or distributor is the packaging producer and registers instead.

2. Opening a portal before the scheme

   Applying before joining a SCRAP. The RPP asks for a membership certificate per packaging category, and the RII-AEE is not validated without the scheme contract.

3. Taking everything to one ministry

   Expecting MITECO to hold every registration. Electronics and batteries sit with the Ministry of Industry and Tourism, in two separate sections.

4. Counting a device as one registration

   Treating a device with a built-in battery as one filing. It is an RII-AEE registration for the equipment and an RII-PyA registration for the battery, plus the packaging in the RPP.

5. Reporting electronics once a year

   Carrying the packaging rhythm over to electronics. The RII-AEE wants a declaration every quarter, while packaging is declared to MITECO once a year by 31 March.

6. Leaving the number off your invoices

   Treating the registration as the end of it. Each number has to appear on the invoices for the products it covers, and marketplaces check the RPP number before they let you sell packaged goods.

Frequently asked questions about registering for EPR in Spain

Below are the five questions producers ask most often about registering for EPR in Spain.

How long does this take?

The RPP assigns your number when you sign the application. The Ministry of Industry publishes no processing time for the RII-AEE or the RII-PyA and issues each number after validating your data. Joining the schemes first is what usually takes longest.

Do I need a company or an address in Spain?

No. Without an establishment you need a Spanish authorised representative for electronics and batteries, and for packaging when you sell directly to end users. A Spanish subsidiary counts as established, a branch does not.

Do I have to register in Spain if I only sell online from another country?

Yes, when you ship straight to Spanish customers. You are then the producer for packaging, electronics and batteries, and you register through a Spanish representative. Selling only to Spanish businesses moves the packaging registration to your buyer.

Can Repax register for me?

Yes. Repax Comply runs the filings through a Spanish authorised representative where one is required. For the RPP, MITECO only accepts a filer you have authorised in the REA, so the entry stays in your name.

What happens if I sell in Spain without registering?

Distributors may only sell electronics from registered producers, and marketplaces must check your RPP number. Failing to register packaging is a serious offence under Spain's waste law, with a fine of up to 100,000 euros.