By Operator One Editorial — 16 December 2025
Spain's packaging Extended Producer Responsibility regime — Real Decreto 1055/2022, de 27 de diciembre, de envases y residuos de envases — came into force on 1 January 2025, ending Spain's status as one of the last large EU markets without modern packaging EPR enforcement on marketplaces. Twelve months in, this is what 2025 actually looked like for brands selling on Spanish marketplaces.
What the Royal Decree changed
Royal Decree 1055/2022 implements the EU Single-Use Plastics Directive (Directive (EU) 2019/904) and the Waste Framework Directive's EPR requirements (Article 8a) for the packaging stream specifically. Its key consequences for cross-border sellers:
- Mandatory producer registration through a recognised producer responsibility organisation — primarily Ecoembes (ecoembes.com) for household packaging and Ecovidrio for glass — or via a collective scheme
- Submission of an annual packaging declaration with quantities and material types
- Application of an eco-modulated fee per packaging type and recyclability
- Explicit liability of marketplaces for non-EU sellers without an authorised representative in Spain (Article 26 of the Royal Decree)
How marketplace enforcement rolled out during 2025
Enforcement did not switch on uniformly on 1 January. The pattern over 2025 was:
- Q1 2025 — Major marketplaces (Amazon ES, eBay, Cdiscount, ManoMano, MediaMarkt) added the Ecoembes / Ecovidrio / collective-scheme registration field to seller accounts as optional
- Q2 2025 — Field became required for new sellers; existing sellers received notices to complete the registration during the quarter
- Q3 2025 — Marketplaces began withholding listings from non-registered accounts; suspensions started in earnest
- Q4 2025 — Enforcement universal; verification is now systematic at upload across all the major Spanish marketplaces
What brands need on file
For a brand selling on Spanish marketplaces in late 2025:
- An NIMA (Número de Identificación Medioambiental) — the environmental identification number issued by the regional autonomous community (or by the Ministry MITECO for cross-region operators)
- A producer registration with Ecoembes (or an alternative authorised scheme), with packaging quantities declared
- The Ecoembes producer code surfaced to the marketplace's compliance dashboard
- For non-EU brands without Spanish establishment: an authorised representative in Spain, or operation through a marketplace or Merchant of Record taking the producer role
What did not happen
One source of confusion through 2025 was the assumption that Royal Decree 1055/2022 would also enforce textile, WEEE, or battery EPR through marketplaces at the same time. It does not — the Royal Decree is packaging-specific. Spain's textile EPR is being implemented through a separate Royal Decree expected during 2026, the WEEE regime under Royal Decree 110/2015 continues with its own enforcement track, and battery EPR is following the Battery Regulation (EU) 2023/1542 transposition timetable.
Operational implications for 2026
Three things to expect in 2026:
- Eco-fee modulation will start to bite — Ecoembes is increasing fees for non-recyclable and mixed-material packaging during 2026
- The Spanish textile EPR Royal Decree is expected to be published in H1 2026, with marketplaces likely starting verification in Q3 or Q4
- Audit and back-data requests from Spain to declared packaging volumes are increasing, matched against DAC7 data reported by the marketplaces themselves
The Operator One position
For brands where O1 is Merchant of Record on Spanish marketplaces, our Ecoembes registration and NIMA cover the brand's catalogue, the eco-modulated contributions are paid out of O1's compliance budget and reflected in the monthly settlement, and the marketplace verification passes on our identifiers. The brand does not need an authorised representative in Spain.
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