Proposed changes to the waste and EPR framework

On 30 June, the Ministry for the Ecological Transition and the Demographic Challenge (MITECO) launched a public consultation (which closed on 3 September 2026), on potential amendments to the Law on Waste and Contaminated Soils for a Circular Economy (7/2022) seeking views on broad changes to Spain’s waste and EPR framework.
Key areas under consideration included:
- Introducing a registration fee for producers and determining how such a fee should operate
- Limiting individual EPR systems to industrial/professional streams
- Allowing municipalities to require PROs/individual systems to organise collection directly, rather than only financing municipal collection
- Strengthening measures to address free-riding (an ongoing issue across several Spanish EPR streams) and improving the regulation of competing PROs
- Revising key waste law concepts, including the definitions of ‘by-product’ and ‘end-of-waste’
- Amending the tax on non-reusable plastic packaging to facilitate its implementation and enforcement
