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The new obligation of an authorized representative for packaging in Spain
A change in environmental legislation 

(Effective since January 1st, 2023, updated on December 4th, 2023)

Authorized representative for packaging in Spain

Service for our customers

At My Compliance, we also address the current changes regarding the application for the NIF "N" number. Through our international partner network, we are well-prepared for changes in the authorization process of the authorized representative by the environmental authority in Spain.

 

We fully register your company with the International EPR Full-Service, entrusting your extended producer responsibilities into the right hands.

or give us a call: +49 2443 994912-0

Introduction

The Spanish government has introduced an important change in environmental legislation: the obligation to appoint an authorized representative for packaging, which has been in effect since January 1st, 2023. In this blog post, we will examine this new requirement in more detail and explain its implications for companies.

Background of the new obligation

As part of the international effort to reduce environmental pollution and waste, the Spanish government has decided to increase the responsibility of foreign manufacturers for the disposal of packaging. To achieve this, the obligation of an authorized representative for packaging has been introduced. This decision is based on the concept of Extended Producer Responsibility (EPR), which aims to reduce the environmental impact of products and packaging throughout their entire lifecycle.

Role of the authorized representative

The authorized representative is responsible for ensuring that manufacturers fulfill their obligations regarding the collection, treatment, and recovery of packaging. The main tasks of the representative include:

  • Registering the company with the relevant authority
  • Monitoring compliance with laws and regulations
  • Reporting results to the authorities

Organizing and coordinating recycling and disposal measures.

Implications for companies

The introduction of an authorized representative for packaging has significant implications for foreign companies operating in Spain or importing products to Spain. They are now required to appoint a representative who ensures compliance with environmental laws and regulations. This incurs additional costs and administrative burden, especially for smaller companies who may not have the resources to meet these new requirements.Before appointing the authorized representative, a NIF "N" number (a Spanish VAT ID) must be applied for, companies that already have a NIF number starting with "A" or "B" are exempt from this requirement.

 

With the latest change in requirements by the environmental authority, the NIF "N" can only be applied for by a natural person with a NIE number. The NIE number is only issued to foreign individuals who have a residence in Spain.

 

At My Compliance, we are always looking for new solutions to ensure the appointment of the authorized representative in Spain.

Collaboration with the authorized representative

To make the transition to the new regulations smooth, companies should collaborate closely with their authorized representative. The representative can help to understand the requirements of Spanish environmental legislation and ensure that all necessary measures are taken to ensure compliance with the laws. This may involve developing strategies for the collection and treatment of packaging as well as implementing efficient recycling and disposal processes.

Future developments and challenges

There are still many challenges that companies and authorities in Spain, as well as worldwide, must face. These include the continuous improvement of recycling and waste management systems, adapting to changing environmental regulations, and implementing new technologies to reduce waste. Companies should use this obligation as an opportunity to improve their sustainability practices and rethink their packaging. This can contribute to protecting the environment in the long term, improve the company's image, and ultimately promote its economic success through cost savings.

or give us a call: +49 2443 994912-0

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