Meet all your company’s packaging obligations: PPWR, RPP, EPR, reporting and new regulations
Packaging regulations have changed, and many companies are unsure which obligations apply, what they need to report and what documentation they need.
TMI Packaging is TMI Medioambiente’s ongoing advisory service for companies that manufacture, import, distribute or sell packaged products.
We analyse how your business operates, identify the requirements that apply and support you throughout the year to keep your packaging compliance under control.
What exactly does your company need to do?
Not every company has the same obligations.
They depend on what you manufacture, import or sell, the type of packaging you use, who first places it on the market and the role your company plays within the supply chain.
TMI Packaging can help if:
- You are unsure how the new European PPWR affects your business.
- You have been asked for your Spanish RPP registration number.
- You have been told that you need to join a collective EPR scheme (SCRAP).
- You need to prepare your annual packaging report.
- You need to report your packaging to your SCRAP.
- You previously submitted the DAE in Catalonia and are unsure how the system works now.
- You have been asked for packaging compliance documentation or a Declaration of Conformity.
- You have changed packaging, suppliers, products or markets and want to know whether your obligations have changed.
- You simply want to make sure your company is complying correctly in Spain.
TMI Packaging: year-round packaging compliance support
Packaging compliance is not a one-off administrative task.
Products change. Materials change. Suppliers and markets change. And legal obligations change too.
That is why TMI Packaging is an ongoing advisory service: you have access to a technical team that understands your business and can answer your packaging compliance questions throughout the year.
In addition to ongoing advice, we prepare the periodic packaging reports included in the service.
What does TMI Packaging include?
Advice on the European PPWR
Regulation (EU) 2025/40 on packaging and packaging waste, commonly known as the PPWR, has generally applied since 12 August 2026.
It introduces and updates requirements relating to packaging design, composition, recyclability, reuse, labelling, documentation and the responsibilities of different economic operators.
We assess how the PPWR affects your company, the role you play in the supply chain and the requirements you need to consider now and over the coming years.
Advice on Spanish Royal Decree 1055/2022
We review which obligations under Spanish Royal Decree 1055/2022 on packaging and packaging waste apply to your business.
Among other areas, we assess:
- Whether your company is considered a producer.
- Registration in the Spanish Register of Product Producers (RPP).
- Extended Producer Responsibility (EPR).
- Packaging classification.
- Reporting and information obligations.
Packaging reporting to your SCRAP
If your company is a member of a Spanish collective Extended Producer Responsibility scheme, we prepare the packaging declaration for your SCRAP using the information provided by your company.
We help structure the data and correctly classify your packaging to reduce errors in the declaration.
Annual packaging reporting to MITECO
Producers subject to the obligation must report annually to the Spanish Ministry for the Ecological Transition and the Demographic Challenge on the packaging they have placed on the market.
TMI prepares the annual packaging report to MITECO using the information provided by your company, helping you meet this obligation within the required deadline.
Advice throughout the year
Changing supplier? Introducing a new material? Starting to sell in another market? Adding a new type of packaging?
You can ask us how that change affects your obligations.
The aim is to avoid having to reinterpret the regulations from scratch every time something changes in your business.
PPWR: what is changing for packaging compliance?
The PPWR regulates packaging from its design and manufacture through to its management once it becomes waste.
Among other areas, it introduces requirements relating to:
- Packaging recyclability and minimisation.
- Recycled content.
- Substances contained in packaging materials.
- Packaging labelling.
- Reuse.
- Technical documentation.
- EU Declaration of Conformity.
- Responsibilities of manufacturers, importers, distributors and producers.
Many of these obligations are introduced progressively. It is therefore important not only to comply with what is required today, but also to understand what changes your company will need to prepare for in the coming years.
Producer and manufacturer are not always the same thing
One of the most common questions under the new rules is determining the role of each company.
Being a producer is mainly associated with Extended Producer Responsibility, RPP registration, EPR schemes and packaging reporting.
Being a manufacturer is associated with compliance requirements for the packaging itself, its technical documentation and conformity.
The same company may have both roles, or only one of them.
This is where we start at TMI: we analyse the commercial flow and determine your company’s role in each situation.
Who is TMI Packaging for?
Particularly for companies that need to comply with packaging regulations in Spain but do not have an internal team dedicated exclusively to monitoring them.
- Manufacturers and packers.
- Companies selling products under their own brand.
- Companies selling private-label products.
- Importers.
- Companies making intra-EU acquisitions.
- Distributors.
- Food and agricultural businesses.
- Industrial companies.
- Companies using pallets, boxes, film, strapping, drums, IBCs or other transport packaging.
How do we work?
1. We understand how your business operates
We review the products you manufacture, import or sell, the types of packaging you use and how they reach the market.
2. We identify your obligations
We determine your company’s role and assess the PPWR, RPP, EPR, SCRAP and reporting obligations that apply.
3. We organise your packaging information
We help you identify and classify the information required to comply correctly with your obligations.
4. We prepare your packaging reports
Using the information you provide, we prepare the packaging declarations to your SCRAP and to MITECO that are included in the service.
Your company reviews and validates the information before submission.
5. We support you throughout the year
We answer your questions and help you interpret regulatory changes that may affect your business.
What do you gain with TMI Packaging?
- Know which obligations apply to your company and which do not.
- Correctly identify who is responsible for each type of packaging.
- Submit packaging reports using the correct classifications.
- Reduce errors and compliance risks caused by incorrect interpretation.
- Prepare in advance for future PPWR requirements.
- Have access to a technical team whenever something changes.
- Avoid burdening your internal team with constantly monitoring complex packaging regulations.
Frequently asked questions about PPWR, RPP, EPR and packaging regulations in Spain
What is the PPWR?
The PPWR is Regulation (EU) 2025/40 on packaging and packaging waste. It establishes a common framework across the European Union and regulates areas such as prevention, recyclability, reuse, composition, labelling, documentation and the responsibilities of economic operators.
When does the PPWR apply?
Regulation (EU) 2025/40 has generally applied since 12 August 2026, although some obligations have later application dates or transitional periods.
Does Spanish Royal Decree 1055/2022 still apply?
Yes. The European Regulation is directly applicable and takes precedence where the two rules regulate the same issue incompatibly, while Royal Decree 1055/2022 remains relevant for numerous obligations and procedures in Spain.
Who needs to register in the Spanish Register of Product Producers (RPP)?
Companies that meet the definition of producer under the applicable packaging rules need to assess this obligation.
Determining this requires analysing who manufactures, imports or first places certain packaged products on the market and how those products are sold.
What is a SCRAP?
A SCRAP is a Spanish collective Extended Producer Responsibility scheme.
It allows multiple producers to collectively fulfil certain obligations relating to the management and financing of packaging waste arising from the packaging they place on the market.
What happened to the former DAE in Catalonia?
The former Annual Packaging Declaration submitted to the Catalan Waste Agency was replaced by the national reporting system established following Spanish Royal Decree 1055/2022.
Producers subject to the obligation now report annual packaging information through the procedures established by MITECO.
When must annual packaging information be reported?
As a general rule, information on packaging placed on the market during a given year must be reported before 31 March of the following year.
Can pallets, film, boxes or strapping be considered packaging?
Yes. Certain items used to contain, protect, handle or transport products may be considered packaging and may create obligations for the company placing them on the market.
What is an EU Declaration of Conformity for packaging?
It is the document through which the manufacturer declares that compliance with the applicable packaging requirements has been demonstrated.
It must be supported by the relevant technical documentation.
Does TMI prepare the EU Declaration of Conformity?
Under TMI Packaging, we advise on conformity requirements and the documentation your company may need.
Where additional specific work is required, this is assessed separately depending on the scope.
Can TMI handle RPP registration or joining a SCRAP?
As part of the service, we assess your company’s situation and advise on the obligations relating to the RPP and collective EPR schemes.
If additional administrative work outside the standard service is required, it can be quoted separately.
Why use an ongoing service if packaging reporting is annual?
Because packaging obligations do not only arise when the annual reporting deadline arrives.
Suppliers, materials, products, markets, references and legal requirements can all change during the year.
TMI Packaging allows you to address those changes as they happen and reach the annual reporting deadline with your information already organised.
TMI Packaging: a specialised packaging compliance team at your disposal
You do not need to turn someone on your internal team into an expert in PPWR, RPP, EPR and Spanish packaging regulations.
Tell us what your company manufactures, imports or sells, what types of packaging you use and what questions you currently have.
We will analyse your situation, explain which obligations apply and show you how we can support your business throughout the year.