Do I owe EPR fees Spain

Check your own case

Choose your role, add your revenue and the packaging you supply, and the checker applies the rules this page describes to your figures. It runs in your browser and stores nothing.

The Instica free plan covers the threshold check, exemption tracking, the deadline calendar, packaging templates and fee sources, so you can start without paying. See what the free plan includes

How the checker reaches a result

The checker asks the same questions in the same order for every place, and it stops with a result as soon as a question settles the matter. It never fills a missing answer in for you.

1. Whose brand is on the packaging? If it is another company's brand, you are not the producer for those goods under the roles recorded for Spain. If you have not said, the checker asks first.
2. Do you sell into Spain? A place where you report no sales returns not obligated.
3. Does a size limit apply? The checker compares your revenue or packaging weight with each limit on record and, where a limit is not met, returns below threshold.
4. Is an exemption on record for your case? An exemption that is not yet verified is never assumed, and the checker asks for more data instead.
5. Are related companies counted together? Where the rules add up affiliated companies, their figures are combined before the limits are compared.

Who is the producer in Spain?

The first question is whose duty it is. Spain assigns the duty by packaging level, and the table shows which roles count as the producer at each level.

• Spain: for primary (sales) packaging the producer is the manufacturer or brand owner, importer, or first distributor.
• Spain: for secondary packaging the producer is the manufacturer or brand owner, importer, or first distributor.
• Spain: for service packaging the producer is the manufacturer or brand owner, importer, or first distributor.
• Spain: for shipping packaging the producer is the online marketplace seller or manufacturer or brand owner.
• Spain: for tertiary (transport) packaging the producer is the manufacturer or brand owner, importer, or first distributor.

Find the row that describes you. Where more than one role appears in a row, the checker asks whose brand is on the product before it gives a result.

Does revenue matter in Spain?

Size limits in Spain

Some rules switch the duty on or off by size. These are the limits on record for Spain, each with what happens when you meet it.

The packaging weight limit: 10 tonnes per calendar year

Spain: the packaging weight limit is 10 tonnes per calendar year. Spain: at the packaging weight limit of 10 tonnes per calendar year, a reduced duty applies. Spain: the packaging weight rule reads, in plain words: Below 10 t a producer submits the reduced Annex IX Part B point 2 information; a Member State may set a lower ceiling for a specific year. Spain: the packaging weight limit is counted as follows: packaging made available for the first time in the Member State.

The packaging weight limit: 15 tonnes per year

Spain: the packaging weight limit is 15 tonnes per year. Spain: at the packaging weight limit of 15 tonnes per year, a reduced duty applies. Spain: the packaging weight rule reads, in plain words: Producers below 15 tonnes per year submit simplified annual information. Spain: the packaging weight limit is counted as follows: packaging placed on the market.

Exemptions in Spain

An exemption removes the duty for a producer that meets its conditions. Some must be applied for; others apply on their own.

What the rules cover in Spain

A duty applies only to the packaging and the sales channels that the rules cover. This is what is on record for Spain.

Spain: a producer may pass the duty to another party under the rules.

Every case, worked through

Below, the same engine that powers the checker is run on a set of standard cases for Spain. Each case states the input, the result and the next step. The figures are test inputs set at half, equal to and twice each recorded limit, read as of September 29, 2026; they are not rules.

Packaging of 20 tonnes per calendar year: above the limit

Your own brand is on the goods and you supply 20 tonnes per calendar year of packaging, twice the limit of 10 tonnes per calendar year. The rules we hold set no size limit that applies here, so your own brand on packaged goods is enough and the engine returns obligated. Result: obligated. Next: register, report and pay as the sections below describe, and prepare your figures in a workspace.

Packaging of 30 tonnes per year: above the limit

Your own brand is on the goods and you supply 30 tonnes per year of packaging, twice the limit of 15 tonnes per year. The rules we hold set no size limit that applies here, so your own brand on packaged goods is enough and the engine returns obligated. Result: obligated. Next: register, report and pay as the sections below describe, and prepare your figures in a workspace.

Above every limit

Your own brand is on the goods and every figure is above every limit on record. The rules we hold set no size limit that applies here, so your own brand on packaged goods is enough and the engine returns obligated. Result: obligated. Next: register, report and pay as the sections below describe, and prepare your figures in a workspace.

If you owe: what happens next

If the result is obligated, these are the steps on record for Spain. You register, report and pay yourself; Instica prepares the figures and the files.

Spain: registration is made with Packaging section of the Register of Product Producers (Registro de Productores de Productos). Spain: registration is made by this party: Product producers, or authorised representatives under Art. 17(2). Spain: the registration identifier is called: registration number (to appear on invoices).

Spain: producers meet the duty through more than one producer responsibility organisation. Spain: the organisations on record are Ecoembes and Ecovidrio. Spain: membership of an organisation is required. Spain: an authorised representative is required.

Deadlines on record

• Spain: the other deadline is August 12, 2026.