Packaging disposal fees on invoices in Spain – impractical and poorly timed?

helmut.minor • 14. Dezember 2024

envenance on compliance.

Background
Starting January 1, 2025, Spain will enforce new transparency rules under Real Decreto 1055/2022, Article 23, Paragraph 5. Producers must clearly list contributions to Extended Producer Responsibility (EPR) systems for packaging waste on invoices. These fees must be itemized separately from product prices, aiming to inform consumers about actual disposal costs and the manufacturers' environmental efforts.

Spain as a Pioneer
Spain’s approach involves:

explicit EPR fee disclosure: fees must be listed separately from product prices.
enhanced transparency: consumers and authorities gain clearer insight into waste management costs.
compliance monitoring: easier oversight of producers' financial obligations.

Challenges for EU-wide Implementation and PPWR
The upcoming EU Packaging and Packaging Waste Regulation (PPWR) lacks such invoicing transparency requirements. No other EU country currently mandates separate EPR fee listings on invoices, causing potential inconsistencies within the internal market.

Logistical Challenges for Businesses
The Spanish rule creates complex data and accounting requirements:

data collection and reporting: Companies must track packaging waste contributions by product.
invoice adjustments: Fees must be listed without VAT, posing technical issues for enterprise resource planning (ERP) systems.
undefined scope: It's unclear whether all packaging types are affected or just primary and secondary packaging.

Future Outlook and PPWR Requirements
While PPWR emphasizes recycling and circular economy goals, it does not mandate visible disposal fees. This raises the question of whether Spain’s unilateral approach will remain after PPWR’s implementation.

Additional Obligations
From 1st January 2025, registration under Real Decreto 1055/2022 and participation in a collection system will be mandatory for all packaging producers. Non-Spanish producers must appoint a local representative.

Need Assistance?
For help with compliance, registration, or packaging fee disclosure in Spain, contact us. We’re here to support your business!

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