Green Circle Talks Cross-border] - Spanish Extended Producer Responsibility (EPR) Explained

If you sell or package certain categories of products in the Spanish market, including batteries, electrical and electronic equipment (EEE) (hereinafter referred to as the "EPR Categories"), you are subject to the Extended Producer Responsibility ("EPR") compliance obligations under Spanish law. Extended Producer Responsibility ("EPR") requires that the manufacturer, importer, or person introducing the product into the Spanish market be responsible for the management of the end-of-life recycling of the particular type of product or related material that it produces or sells.

EPR obligations include: (1) registering with a Producer Responsibility Organization (PRO) for the EPR category(ies) of the product(s) you sell and obtaining your valid registration number. Please note that if you sell products in more than one EPR category, you will need to register for each EPR category; (2) periodic reporting and payment to the PRO based on the EPR categories of the products you sell; and (3) other possible recall obligations.

You are free to choose any PRO for registration. If you complete the EPR registration for the corresponding category, you should immediately provide the Platform with the registration number and other relevant proof of these EPR product categories by submitting the following: Account Management - Entity Management - Entity Details - Extended Producer Responsibility (EPR) Qualification. In addition, in accordance with Spanish law, the Platform is obliged to confirm that all packaged products sold through its platform comply with the relevant EPR requirements.

The table below lists the types of extended producer responsibility (EPR) you may currently be subject to. Please check if it applies and, if so, fulfill your EPR obligations in accordance with the relevant laws and regulations.

• Electrical and Electronic Equipment (EEE): Household goods, lamps, fire extinguishers, light bulbs, solar panels and professional electronic products
• Batteries: Portable, automotive and industrial batteries
• Packaging: product boxes and packaging (e.g. boxes with toys), shipping boxes, shipping labels, tapes, etc.
• Tires: car tires, agricultural tires and heavy construction machinery tires, etc., excluding bicycle tires.
• Industrial oils: lubricants based on mineral oils, synthetic oils or similar animal oils, especially for burners, transmission systems, lubricants, turbines and hydraulic systems
• Disposable plastics: plastic bottles used to hold drinks or plastic utensils for food, as well as packaging and wrapping paper made from flexible materials, including PET plastic bottles, plastic boxes, plastic wrapping paper, etc.