With changing consumption patterns and a growing population, waste management has become a global concern.
In order to make the transition from a linear to a circular economy and to prevent the generation of waste, many EU countries have adopted Extended Producer Responsibility (EPR) programs.
Among them are French EPR, German EPR, British EPR, Italian EPR and Spanish EPR, which aim to reduce waste, conserve resources, increase recycling rates and promote the use of eco-products by design.
EPR is the abbreviation of an EU policy called Extended Producer's Responsibility (EPR).
Producers are required to ensure their responsibility and accountability for the management of waste generated at the end of the useful life of their products through the payment of an "eco-contribution" fee.
Simply put, it is a post-consumer environmental policy approach that extends the producer's responsibility for the product to the product's life cycle.
As a result of the EU Packaging Waste Directive, each member state enforces its own national laws, and the Spanish packaging law is no exception.
Today, Green Circle shares with sellers the Spanish EPR packaging law and Spanish WEEE matters needing attention.
I. Spanish EPR (WEEE)
With the update of 2002/96/EC to 2012/19/EU, Spain issued Royal Decree 110/2015 (Royal Decree on Waste Electrical and Electronic Equipment, known as RD RAEE).
The products covered by the RD RAEE are the same as those covered by the WEEE Directive, and fall into the following seven categories:
1. Temperature switching equipment.
2. Monitors and displays.
3. Lights.
4. Large appliances (external dimensions > 50 cm).
5. Small electrical appliances (external dimensions 50 cm).
Similar to the German ElektroG, Spain has established an electronic platform, the National Registry of Industry, known as RII-AEE.
Manufacturers should register with RII-AEE and report the recycling of WEEE equipment. Manufacturers who complete the registration process will receive a WEEE registration number.
For the recycling of each type of waste product (packaging, batteries, tires, WEEE, etc.), Spain has established a different recycling system - the Integrated Management System, or SIG.
Producers can set up their own compliant recycling system or join a specialized recycling system.
Each recycling system covers different types of recycling and producers should pay special attention when selecting a recycling system.
Producers who do not register with the RII-AEE, known as free-riders in the RD RAEE, will be targeted with severe penalties of up to €1.75 million by the regulatory authorities.
II. Spanish EPR (Packaging Act)
The famous Green Dot logo was once mandatory on sales packaging in most European countries, and Spain is still the only country in the European Union, with the exception of Cyprus, where it is still mandatory to use the Green Dot logo on packaging.
It is for this reason that Green Dot's monopoly in Spain has had more serious consequences.
In terms of recycling costs, the minimum recycling cost is around €600/year, regardless of whether 1kg or 1t of packaging waste is generated each year.
Compared to other EU countries, Spain's packaging recycling costs are very high, which is a significant burden for cross-border sellers at Spanish sites.
Another notable feature is a separate recycling program for glass.
Sellers of glass bottles with carton packaging through cross-border e-commerce platforms are required to join a separate recycling program in order to comply with the Spanish Packaging Law. (Sellers of wine, beverages and cosmetics will be affected).
With this in mind, if Spain is a core site for the seller and the seller is also registered with the Spanish VAT, the recommendation is to complete the Spanish EPR compliance program as soon as possible.
In this way, it will be faster to get highly recognized by Spanish consumers, and the cost of packaging compliance will be more meaningful.
In addition, according to Spanish media reports, a decree being drafted by Spain's Ministry of Ecological Transformation includes a measure: "From 2023, supermarkets and grocery stores in Spain will ban the sale of fruits and vegetables packaged in plastic and encourage the sale of fresh produce without packaging."
In the face of the implementation of regulations and policies, sellers entering the European market access rules are getting higher and higher, for the EU EPR compliance, it is necessary to combine with their own situation, as soon as possible to complete the registration of packaging law, battery law, WEEE and other related categories.
For EPR compliance registration in Europe, look no further than Green Circle!
For European VAT self-declaration, look for Green Circle!
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