EPR in Spain: packaging and RAEE rules for Amazon sellers

Until August 2026 most sellers held two packaging registrations, Germany and France, because those were the two Amazon actively verified. The rest of the EU sat in a grey zone nobody enforced.

Since 12 August 2026, under the PPWR (Regulation (EU) 2025/40), online marketplaces must verify seller EPR registration, and Amazon now checks a packaging registration in every EU country where you sell or hold stock. It was a hard date, not a phased rollout.

There is no single EU-wide registration. Each country issues its own number, and a missing one means the listing is deactivated in that country, or you are enrolled into Amazon Pay on Behalf and charged for it. Pan-EU sellers are caught most often, because stock is placed in countries they never chose to sell in: check your inventory placement, not your marketplace list.

Registration lead times are long and vary widely by country, and in several cases they exceed the deadline that has already passed. If you are late, register anyway and keep the dated proof that you started: an unfinished registration you can evidence is a very different conversation with an authority than no registration at all.

Royal Decree 1055/2022 extended producer responsibility to all packaging, including commercial and industrial packaging, not just household.

You must register in the producer register and join a collective scheme (SCRAP, such as Ecoembes) to cover your packaging volumes placed on the Spanish market.

For electrical and electronic equipment, Royal Decree 110/2015 (RAEE) requires registration in the integrated industrial register before you place products on the Spanish market.

Spain’s waste law, Law 7/2022 on waste and contaminated soils, classifies infringements as minor, serious and very serious.

Very serious infringements can be fined up to €1.75M, with even higher bands for the gravest cases, on top of suspended Amazon.es listings. This is why Spain is the highest-fine EU market.