As a Member State of the European Union, Spain has implemented numerous Extended Producer Responsibility (EPR) requirements.  These are regulations designed to ensure that producers take responsibility for the environmental impact of their products.

Online marketplaces such as Amazon are required, by law, to ensure that their sellers are fully compliant and up to date with new regulations.  

What does this mean for you?

Producers under the EPR regulations 

Under the EU EPR framework, a ‘producer’ is categorised as any of the following: 

• Retailers (including distance sales)
• Importers 
• Manufacturers 
• Resellers (including distance sales)

The broad definition of producer means that many businesses, especially ecommerce sellers and retailers, will be considered as producers and therefore required to comply with EPR regulations.  

What are the EPR categories in Spain? 

In Spain, the following categories have been implemented or proposed:

• Batteries
• Packaging
• Waste Electrical and Electronic Equipment (WEEE) 
• Single-Use Plastics (tobacco only) 
• Textiles (under consultation, planned implementation in 2026)
• Tyres

Products belonging to any of the above categories will therefore require an EPR registration number. 

Once registered, producers selling products belonging to any of the affected categories are required to:

1. Submit declarations detailing their sales
2. Pay a proportional contribution fee 

The contribution fee is used by local authorities to offset the environmental impact and costs of product end-of-life management and disposal. 

How does this affect my sales on Amazon?

Amazon is taking an active role in ensuring EPR compliance across its European marketplaces, and is strengthening its enforcement measures in Spain.  

As part of this role, Amazon is legally obliged to ensure that only compliant products are sold on its platform, helping to support Spain’s sustainability efforts whilst protecting the platform from regulatory breaches.  As part of its measures to ensure greater compliance, an updated deadline has been provided for compliance.   

As part of its enforcement efforts, Amazon sellers who offer products to Spanish consumers will therefore be required to provide valid EPR registration numbers for Packaging, Single-Use Plastics (Tobacco) and Tyres by 31 December 2025.  

Amazon sellers should take the following steps:

• Identify affected product listings – Amazon will also flag any relevant EPR categories 
• Register with an authorised Producer Responsibility Organisation in Spain to obtain the relevant EPR registration number(s) for each affected category 
• Submit the relevant EPR number(s) to Amazon Seller Central for verification 

Registration and ongoing compliance   

Businesses must: 

• Ensure that they are registered for VAT

Under Spanish EPR regulations, businesses seeking to register for any of the EPR categories must also register for VAT as a prerequisite, even if they do not plan to store inventory in Spain. 

• Appoint a local Authorised Representative to facilitate the registration process 

Non-resident (i.e. non-Spanish) businesses must appoint a local Authorised Representative based in Spain to facilitate the registration process, and comply with any ongoing obligations such as reporting requirements.   

• Register with the appropriate Producer Responsibility Organisation (PRO) for each relevant category

Each EPR category has been assigned different Producer Responsibility Organisations responsible for arranging the registration and reporting process.  

• Prove EPR compliance

Upload your EPR registration number(s) to any relevant sales platforms such as Amazon.  If you are selling on your own platform or website, you are responsible for ensuring that transaction data is recorded accurately and that you have obtained the necessary EPR registration(s) before selling.  

• Comply with ongoing reporting requirements 

As part of your responsibility as a registered producer, you are required to report your sales for each registered category, and pay a proportional contribution fee.  Different EPR categories will have different reporting rules and contribution fee rates.  

Act now to ensure compliance 

Many of the EPR categories are in effect and enforcement has already begun.  Online marketplaces such as Amazon have issued updated deadlines for when they will take action against any sellers that remain non-compliant.  

Amazon sellers that fail to prove that they are compliant will risk having their listings suspended or removed, or automatically enrolled onto Pay on Behalf (if eligible).  

The registration process involves multiple steps and can be a lengthy process.  To avoid any disruption to your business operations, it is vital for your business to take measures towards compliance as soon as possible.