Spain's Royal Decree 993/2022 of November 29, 2022, requires the indication of an industrial registration number in the product documentation of electrical and electronic equipment (EEE) and batteries and accumulators imported into Spain from third countries.
This Royal Decree will take effect on January 16, 2023.
The implementation of this policy will be the responsibility of SOIVRE (Spanish Import and Export Inspection and Quarantine Agency), which has created the DOCUCICE database.
If the importer or cross-border e-commerce company's products have been registered with RII-AEE or RII-PYA and the relevant documents have been uploaded through the DOCUCICE database in advance, SOIVRE will grant the importer or cross-border e-commerce company a green channel after checking the correctness of the documents, and the shipment will generally be released automatically.
The new Customs declaration document has been specifically marked out for the Ministry of Industry registration code, without the Spanish EPR registration code will not be able to clear customs.
On December 23rd, Sizzler platform has released "Announcement about the new Spanish EPR compliance qualification".
Next, the Spanish Customs authorities and other e-commerce platforms will gradually require cross-border e-commerce sellers to complete the Spanish EPR compliance.
1
Basic Terminology
1. The Royal Decree on the Abandonment of Electrical and Electronic Equipment, referred to as RD RAEE;
2. Similar to the German ElektroG, Spain has established an electronic platform, the National Industrial Registry, known as RII-AEE;
The Registro Industrial de España (RII-AEE) is responsible for the registration and administration of manufacturers of electronic products:
3, for each type of waste products (including packaging, batteries, tires, WEEE, etc.) recycling, Spain has established a different recycling system - integrated management system (Sistemas Integrados de Gestión, referred to as SIG.).
Each recycling system covers different types of recycling and producers should pay special attention when selecting a recycling system.
4. Regarding waste and contaminated soil, the "extended responsibility of the producer of the product" is explicitly listed.
Sistema Colectivo de Responsabilidad Ampliada del Productor, known as SCRAP.
2
What are the categories and products included in the Spanish EPR?
1、Spanish packing method
Similar to Germany and France, any product entering Spain needs to be registered under the Spanish Packaging Law, as almost all products are packaged. For example (including but not limited to):
2. Spain WEEE
Like the German weeee classification, the Spanish WEEE classification consists of seven categories:
Category 1: Temperature exchange equipment
Category 2: Displays, screens (greater than 100 cm2)
Category 3: Lamps (any one dimension greater than 50 cm)
Category 4: Large Appliances
Category 5: Small electrical appliances (without any one side exceeding 50 cm in size)
Category 6: Small telecommunication equipment (without any one side exceeding 50 cm in dimension)
Category 7: Large Photovoltaic Panels
3. Spanish Battery Law
Batteries and accumulators are devices that allow electrical energy to be obtained by converting chemical energy. They are used for a wide range of applications, from storing energy from stationary energy sources in electrical and electronic equipment (computers, cell phones, tools, medical equipment, toys, etc.), to traction in internal combustion engine vehicles and electric vehicles in the automotive industry, to lightweight electric vehicles, and many other applications in industrial use.
The Spanish Battery Law product range is divided into 4 main categories:
1）New Button Batteries: Alkaline New Button Batteries, Lithium New Button Batteries
(2) General batteries: alkaline batteries, carbon batteries, lithium batteries
3) Digital lithium-ion battery: mobile phone lithium-ion battery, notebook ion battery, tablet lithium-ion battery
4) Industrial Battery
4
Specificity of the Spanish Packaging Law
Similar to Germany or France, when selling (packaging) products to buyers in Spain, the seller is obliged to register for the Spanish packaging law and the packaging recall obligation takes effect from the seller's first product sold in Spain. The Spanish Packaging Law has a number of features that differ from those of Germany and France:
1, the basic cost of the Spanish packaging method is very high
Recycling costs in Spain are high because the Spanish packaging law is based on a minimum of 1 ton. Therefore, regardless of whether the seller has 1 kilogram or 1 ton of packaging waste per year, the current minimum recycling fee is €600 per year.
2. Glass packaging has a special recycling obligation.
The sale of products in glass bottles (packaged in cardboard boxes) through the e-commerce channel requires the inclusion of a separate recycling program to comply with the Spanish Packaging Law.
Sellers of cosmetics, alcohol and beverages need to pay special attention.
Producers in Royal Decree 993/2022
Specifically what?
Manufacturers, distributors, importers, exporters, cross-border e-commerce (remote sellers)
According to the Spanish Royal Decree 110/2015 on Waste Electrical and Electronic Equipment (WEEE), the following producers shall be subject to ECOTASA.
Established in Spain and manufactures AEE (electronic products) under its own brand name;
Established in Spain and marketed under its own brand of AEE manufactured by third parties;
Established in Spain, importing AEE from other countries to Spain;
Established in Spain to export AEE to other countries;
5. Sell AEE to Spanish users through the web platform.
Therefore, whenever AEE products (electrical and electronic equipment, batteries and accumulators) are sold to Spain, the manufacturer should register and declare them with the RII-AEE.
6
Consequences of not registering with the Spanish EPR
(1) The Customs and Excise Department (C&ED) prohibits the entry of non-compliant electrical appliances, batteries and accumulators into the market;
2) Customs clearance is not possible and the platform may not be able to sell;
(3) Non-declared manufacturers will be sanctioned and fined by the government and the EPA, and in serious cases, their business licenses may be revoked for 10 years or permanently banned from operating;
4) A fine of up to €1.75 million imposed by the regulatory authorities.
7
Logo Requirements
1、Spanish Packaging Law Labeling
The GreenDot logo used to be mandatory on most packaging sold in Europe. As recycling programs were opened up to other competitors, the obligation to print GreenDot on packaging disappeared. However, in Spain, with the exception of Cyprus, the Green Label is still used in Spain.
Green Dot Logo
Green Dot Logo
2、Spain WEEE Labeling
Labeling of electronic products: The RD RAEE follows the WEEE Directive's labeling requirements, which require the marking of a forked wheeled garbage can and a thick black line below it.
3、Spanish Battery Law Labeling
The marking of the Spanish battery law is the same as the marking of the German battery law for trash cans without underlining and marking with a cross.
Sellers into the European market access rules are getting higher and higher, the EU product compliance is getting more and more stringent, sellers friends not only have to keep an eye on the store operation, but also to respond to the platform to update the policy, in order to make timely countermeasures plan.
For the EU EPR compliance, sellers and friends must take into account their own situation and complete the registration of packaging law, battery law, WEEE and other related categories as soon as possible. If you are not sure whether you want to register for the Spanish EPR, please contact Ms. Green Circle to help you decide.
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