Packaging legislation in 2026: PPWR, Royal Decree 1055/2022, RPP and SCRAP

Two sets of rules that coexist

Packaging legislation in Spain now rests on two texts. Royal Decree 1055/2022 on packaging and packaging waste created the Producer of Product Register (RPP), extended producer responsibility (EPR, 'RAP' in Spanish) to commercial and industrial packaging, and laid down the annual reporting obligations.

Regulation (EU) 2025/40, known as the Packaging and Packaging Waste Regulation (PPWR), replaces the former packaging directive with a regulation that applies directly in every Member State. It entered into force in February 2025 and has applied in general terms since 12 August 2026, although many of its requirements have later deadlines: mandatory recyclability, minimum recycled content and reuse targets are phased in from 2030 onwards.

Where the two texts regulate the same matter in incompatible ways, the European regulation prevails. For everything else (RPP, declarations, SCRAP) the Royal Decree remains the practical reference.

Is your company a producer, a manufacturer or both?

The first question is not which packaging you use, but what role you play in the chain. The producer of product is whoever first places a packaged product on the Spanish market (manufacturer, packer, importer, own brand or distributor brand). The RPP, extended producer responsibility, membership of a SCRAP and the declarations all fall on them.

The packaging manufacturer is responsible for ensuring the packaging meets the PPWR requirements: composition, restricted substances, labelling, technical documentation and EU declaration of conformity. The same company may be both, or only one of them, and the outcome may vary by product or by market.

Obligations you should review now

• Registration in the RPP. The Producer of Product Register is run by the Spanish Ministry for the Ecological Transition (MITECO) through its online portal. Every obligated producer needs its registration number, which more and more customers and SCRAPs are asking for.
• Membership of a SCRAP (collective extended producer responsibility scheme) or an individual scheme, including for commercial and industrial packaging.
• Packaging declaration to the SCRAP, with packaging classified by material and type in the format required by each scheme.
• Annual packaging declaration to MITECO with the previous year's data, before 31 March. Producers placing less than 15 tonnes a year on the market may report in simplified form.
• Packaging requirements (PPWR): substance restrictions, such as PFAS in food-contact packaging, heavy metal limits, labelling and an EU declaration of conformity backed by technical documentation.

What about the old Catalan DAE?

The Annual Packaging Declaration (DAE) formerly submitted to the Waste Agency of Catalonia (Agència de Residus de Catalunya) has given way to the national reporting system under Royal Decree 1055/2022. Today the annual report is made through MITECO's procedures.

What to do if you do not know where to start

1. Map your commercial flow
   What you manufacture, import or sell, with which packaging (primary, secondary and transport) and who first places it on the market.
2. Determine the role per product
   Producer, manufacturer or both. This is where the specific obligations come from.
3. Regularise registration and membership
   RPP and SCRAP where they apply to you. Ask your suppliers for the information you need to classify the packaging.
4. Prepare the annual declaration
   With the year's data, before 31 March. Keep the supporting documentation.
5. Plan for the PPWR
   Note which requirements affect you in 2026 and which arrive in 2030 and beyond, so you are not redesigning packaging at the last minute.