Amazon announced on October 16th the official implementation of the Spanish EPR regulations for sellers who have not uploaded their packaging law registration number by December 31st, 2023, mandatory withholding and payment, and additional service fees. 👉 Important notice, not uploaded Spanish EPR will face withholding!
What should we do if we do not want to be subject to withholding?
I. Certificate of Spanish Packaging Law
The Spanish EPR includes the Packaging Act, WEEE, Batteries Act, Lubricants and Industrial Oils Act, and Tires Act.
Among them, sellers need to pay attention to the Spanish packaging law, because any packaging products into Spain, need to register the Spanish packaging law, to the Spanish buyers of products containing packaging sellers have the obligation to register the packaging law.
There are two types of registration under the Packaging Act, namely, Ministry of Industry Registration and Organization Registration.
Ministry of Industry Registration Method (ENV)
Registration requires sellers to have all the basic materials, the time taken to issue the certificate is slightly longer than the ordinary registration method, and the registration number can be applied to all cross-border e-commerce platforms.
Certificate issued by the Ministry of Industry
Organization Registration
The information required for registration is simple, the time efficiency of the certificate is fast, it is applicable to some platforms except Amazon, and it is not guaranteed that the later platforms will require to make up for the certificate of the packaging method starting with ENV.
Certificates issued by accredited organizations
Difference between Ministry of Industry Registration and Organization Registration
Registered with the Ministry of Industry
Registration time: 8-12 weeks
Special features of registration: obtain ENV certificate for the beginning of the packaging law tax code, do the Hague application for an electronic signature, the certificate is used on all platforms.
Registration Information: Hague Document, Spanish Local Tax ID Certificate, Packaging Law Data Collection Form
VS
Organization Registration
Registration time: 3-4 weeks
Registration features: cheap price, simple registration information, but only some platforms recognize their certificates.
Registration Information: Authorized Representative Contract, Merchant Information, Packaging Law Data Collection Forms
Second, Amazon recognizes certificates registered by the Ministry of Industry.
Both certificates registered by the Ministry of Industry and certificates registered by organizations are certificates of compliance with the Spanish Packaging Law.
The biggest difference between the two is whether or not you need a Hague and Spanish mainland tax code. The number is different for different certificates. The registration number of the Ministry of Industry starts with ENV. The registration number of the Ministry of Industry starts with ENV, while the Amazon backend recognizes the number of the Ministry of Industry.
From the "What is the format of the package registration number?" provided by Amazon, we can understand that it requires the format of the registration number as "ENV/YEAR OF REGISTRATION/XXXXXXXXX". You can see that it requires the registration number to be in the format "ENV/YEAR OF REGISTRATION/XXXXXXXXX", where ENV is the fixed text that appears in all the numbers, YEAR OF REGISTRATION is the year you are registered in the Producer's Register, and XXXXXXXXXX is a nine-digit number. XXXXXXXXXXX is a nine-digit number."
The certificate issued by the organization, it only has 6 numbers, no fixed text, under the number will not be able to bind all the OMP. at present, does not comply with the Amazon standard.
*OMP usually connects directly to local EPA databases, while other platforms are not expected to support no-tax-number registration in the future.
According to the green circle to understand, at present, there are some service providers in the market to do not need VAT tax number, do not need to pass the Hague certification, and even lower prices to attract sellers to register the Spanish EPR, but it is worth noting that they use the way the organization is registered, only to provide institutional certificates. Therefore, sellers need to be careful when choosing a service provider and pay attention to screening whether the certificate is a certificate of registration of the Ministry of Industry.
Is the Spanish EPR also renewed on a natural year basis?
Yes. 2023 is coming to an end and many sellers are weighing whether they should register their Spanish EPR in 2023 or 2024.
The Green Circle recommends that sellers prioritize 2024 registrations because the EPR is based on a natural year, which means that if a seller registers in 2023, they will have to pay for two years of service.
In addition, if the seller's store has special operational needs and does not want to be withheld and paid by Amazon, they can choose to subscribe to the Spanish EPR service for 2023 + 2024.
In order to ensure that sellers can operate legally and in compliance with platform regulations, Green Circle Technology provides EPR registration services in Spain, with relatively stable processing time and support for all platform bindings, sellers who need to contact Green Circle for consultation.
Can I apply for Spanish EPR without a tax ID number?
According to the Spanish Royal Decree, sellers need to provide Spanish VAT number in order to apply for packaging law registration. There are two ways to apply for a Spanish VAT number: Hague certification and official translation.
It should be noted that the Hague certification here refers to the Hague certification of the Spanish VAT number, which is different from the Hague certification of the packaging law. The time and price required to apply for Hague certification is different between the two, it is recommended to understand in advance.
After Germany and France, Spain's EPR compliance policy has also been mandated, and EPR compliance has become a general trend. Little K suggests all European sellers to lay out their business early and complete the compliance operation.
Green Circle Technology focuses on providing one-stop services for cross-border enterprises, professional accountants and lawyers team, specializing in providing sellers with global VAT & EPR, global trademarks, and overseas business registration and reporting cross-border compliance one-stop services for every seller to go to sea escort. If you have any questions about EPR registration in Spain, please feel free to contact us.
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