New packaging regulation Royal Decree 1055/2022 on Packaging and packaging waste in Spain

New AR requirements for foreign companies in Spain

In our last Spain update from March 2023 we informed you about the new liabilities concerning the Spanish packaging registry in connection with the new packaging law.

But now the Spanish Ministry of Environment (MITECO) requests that all foreign companies that want to be registered have to apply for (and obtain) a Spanish tax number for non-established entities – a so-called NIF. According to MITECO this is “because the electronic offices of the Ministries and other public administrations only allow electronic certificates supplied by trusted providers in Spain. So it is necessary for foreign companies to previously have a NIF of entities not established in Spain in order to obtain such certificate.”

That means foreign companies without a Spanish NIF can not register in the new packaging registry for packaging as foreign VAT numbers are not accepted by the authorities.

There are two “solutions” for the current status:

  • Companies that sell/deliver their products to a Spanish intermediary (distributor/dealer) should ensure that their clients are registered and report their packaging
  • Companies that sell directly to end users in Spain currently have no other option than to apply for a NIF at the Spanish embassy in their country or in Spain directly

A lot of Spanish market actors (such as AR providers, consultants etc.) have filed several complaints about this complicated procedure to the Spanish government and even to the EU (as it is a comparable market entry barrier like the Triman issue in France).


As soon as we get any new information on the AR situation for packaging in Spain we will share them with you. In the meantime feel free to contact us if you got further questions