Frequently asked questions
FAQ Spain – Everything you need to know about EPR regulations in Europe.
Spain
Companies are obligated to be EPR compliant by law. Failure to fulfil the legal requirements can result in severe sanctions or sales bans.
The legal framework for EPR in Spain is established under Law 22/2011, of July 28, as well as the Royal Decree 110/2015, of February 20.
All companies subject to EPR on the Spanish market must register with a spanish Producer Responsibility Organization (PRO). The operating PROs in Spain are currently Procircular and Ecoembes. On top of regestering with a spanish PRO, they also have to request a Spanish VAT number in digital form by registering for a Digital NIF. Companies, who are selling products on the spanish market but do not have a registered office in Spain, need to appoint an authorized representative to fulfil their EPR duties in Spain. Provider for this service are a. o. AuthoriseMe or Arca Consortium. Last but not least, companies need to be registered in the public manufacturer register “Registro de productores de producto” (Register of product producers), and need to report the amount of packaging they put on the market to the register. After registration, each company is assigned a corresponding EPR number.
Companies that sell products on the Spanish market but do not have a registered office in Spain must appoint an authorized representative to fulfil their EPR obligations in Spain. Providers for this service include AuthoriseMe or Arca Consortium.
The Spanish NIE number is a foreign identification number (Número de Identificación de Extranjero) issued by the Spanish National Police and can be applied for either online or at Spanish authorities. It is a unique tax identification number that foreigners need for legal or tax-related activities in Spain. It begins with either the letter “X”, “Y” or “Z” and then consists of 7 digits and another letter. The NIE number is required in order to be able to apply for a tax identification number (NIF number) for the foreign company in Spain in the next step.
The Spanish NIF number is a tax identification number (Número de Identificación Fiscal). Every company that does business in Spain must have a NIF number. As there is no other tax number in Spain, it is also mandatory on all invoices. However, an NIF number can only be requested for a foreign company if the foreign person requesting it (i.e. the proprietor/owner of the company) already has an NIE number. The NIF consists of nine characters: a letter, followed by seven numbers, and one character, which can be either a letter or a number. The first letter indicates the type of company or institution (e.g. limited liability company, public limited company, association, etc.).