Focus on… Spain

New EPR rules for domestic and commercial packaging from 2025

Royal Decree (1055/2022), which previously covered household packaging only, now unifies EPR rules for household, commercial and industrial packaging in Spain.

In so doing, it transposes EU Directive (2018/852) and aligns with the Spanish waste framework law (7/2022), while replacing Law (11/1997).

Obligated producers – packers, importers and online marketplaces of packaged products – must finance the collection and management of their packaging waste through individual or collective systems.

These producers had to indicate their compliance option before 31 December 2023 in the newly created packaging producer register and ensure the full implementation of their chosen system by 31 December 2024.

Producers already obligated under Law (11/1997) had to adapt their systems by 30 June 2024.

Overall recycling and separate collection targets are set for household and industrial/commercial packaging, effective in 2025 and 2027 respectively.

Material-specific recycling targets apply for all packaging while material-specific collection targets apply for household packaging made of plastic, wood, ferrous metals, aluminium, glass, beverage and food cartons, and paper and cardboard.

Non-statutory objectives for recyclability, re-use, recycled contents and waste prevention are also stipulated.

Notably, a deposit return scheme (DRS) is mandated for reusable containers; however, packaging must be declared as single-use until a producer responsibility organisation (PRO) establishes a DRS.

Additionally, a parallel DRS will become mandatory for plastic beverage containers of up to three litres within two years if the separate collection targets for single-use plastic bottles, as stipulated in Law (7/2022), are missed.

Lastly, from 2025, the following marking requirements become enforceable: household packaging must indicate the fraction/container for proper waste disposal and reusable containers must display the symbol of the DRS to which they belong.

Spain is one of the countries covered by Landbell Group’s regulatory information services. Find out more here.

For support with EPR in Spain, please contact ERP España.