Spain EPR# Spain Packaging Method# Europe EPR Compliance
1.
Which sellers need to register with EPR Spain?
If you sell products to consumers in Spain (including manufacturers, distributors, importers, exporters, cross-border e-commerce), you are obliged to register for the Spanish Packaging Act.
Simply put, cross-border sellers need to register as long as their products fall under the Spanish EPR compliance category and they are selling to the Spanish market.
2.
Do I need a Spanish Tax ID to register for the Spanish Packaging Act?
If a seller wants to apply for the Spanish Packaging Act, it is necessary to obtain your Spanish Taxpayer Identification Number (NIF), i.e. the Spanish local tax code, which is a prerequisite for registration.
3.
What is the format of the Spanish Packaging Register?
The format of the package registration number is "ENV/YEAR OF REGISTRATION/XXXXXXXXXXX", where ENV is the fixed text that appears in all the numbers, YEAR OF REGISTRATION is the year in which you are registered in the Producer's Register, and XXXXXXXXXX is a nine-digit number. XXXXXXXXXXX is a nine-digit number.
4.
How do I upload my Packaging Act registration number?
Go to the "Spain" section of the Amazon Compliance Portal, enter a valid package registration number in the corresponding box, and click "Submit".
5.
How do I verify that my Packaging Act registration number is valid?
First of all, you can check that your package registration number is displayed in the register by clicking on the link at the end of the "Información pública" section on this Miteco page.
If the number is correct, Amazon will mark it as [VALID] on the compliant door within five business days of your submission.
6.
What is Amazon EPR Payment Services?
The Amazon EPR Payment Service helps Amazon sellers comply with Extended Producer Responsibility (EPR) requirements in France and Spain. The service requires Amazon to make EPR payments on behalf of sellers for sales on the Amazon.fr and Amazon.es malls, and then collects these amounts from the seller's account.
If you are not a producer with a business in Spain and do not submit a valid package registration number by December 31, 2023, Amazon will automatically register you for the Payment on Behalf service.
Payment-in-lieu services do not include recycling or other organizational obligations, such as prevention and eco-design business programs designed to reduce the use of non-renewable resources, increase the use of recycled materials, and improve the recyclability of goods.
7.
How does Amazon's Spanish packaging method pay for the calculation of environmental payments?
If you sell merchandise in an Extended Producer Responsibility (EPR) category without submitting a valid registration number to Amazon, Amazon will automatically register you for Payment on Behalf of the Producer.
Amazon calculates environmental payments as follows.
The Packaging Act applies to two types of packaging: primary packaging and transportation (secondary) packaging.
Primary packaging is the packaging (e.g., boxes, bottles) in which the merchandise is stored directly;
Transportation (secondary) packaging is additional packaging (e.g., overwrapped boxes, blister packs) used for transportation.
Amazon uses a calculation based on the weight of the item to calculate the eco-friendly amount of the package. This applies whether you use FBA or not.
🔹 For Level 1 packaging, Amazon will make environmental payments to Producer Responsibility Organizations (PROs) on your behalf and will deduct these amounts from your seller account.
🔹 For secondary packaging, Amazon will only pay the organization on your behalf if you are an Amazon Logistics seller. However, Amazon will not charge your account for these amounts.
There are two components to the environmental program.
🔹 The first part is based on sales volume and is calculated by multiplying the Total_Units_Sold by the Eco Money Fee_Per_Unit, which is set by the Producer Responsibility Organization (PRO).
🔹 The second part is based on the weight of the packaging materials used. Amazon uses standard material weight ratios defined by an external consultant to determine the weight of the packaging materials. The weights of packaging materials such as paper, glass, and plastic (Paper_KG, Glass_KG, and Plastic_KG) are multiplied by their respective material weight charges (Paper_Charge, Glass_Charge, and Plastic_Charge).
The sum of the above 2 components is the amount payable for environmental protection per item.
This can be found in the "ECO_CONTRIBUTION" field.
8.
How do I opt out of Amazon's "pay-as-you-go" service?
For sales transactions in 2023 and beyond, if you have auto-enrolled in Payment on Behalf and wish to discontinue use of the service, you must submit a valid Packaging Act registration number and complete verification on the Compliance Portal by the last day of the year (i.e., December 31st).
Green Circle provides EPR compliance services in Spain to help you meet the extended producer responsibility requirements more easily and to ensure that you comply with all regulations. Feel free to contact Green Circle for a consultation!