Amber Global Finance-EPR Regulations in Spain (Deep interpretation)

Amazon officially implemented the Spanish EPR regulations on October 16th and notified sellers who have not uploaded their packaging law registration numbers to force withholding and payment before December 31, 2023. This news has caused quite a stir, and for sellers without tax numbers, it is even more difficult to register under the packaging law! On the other hand, the Spanish royal decree has issued a no packaging law, and sellers will be fined up to 600000 euros. How to complete EPR compliance?

Catalogue

1.Amazon Spain EPR regulations come into effect
2.For sellers without an EPR registration number, the platform will fully withhold and pay
3.Who and which products are required to register for Spanish EPR?
4.Can I apply for Spanish EPR without a tax number?
5.The relationship between Hague certification and Spanish EPR?
6.Is the Spanish EPR registration service chosen for 2023 or 2024?
7.Complete compliance process for Spanish EPR

 

1、 Amazon Spain EPR regulations come into effect

Starting from October 16, 2023, Amazon officially implemented the Spanish EPR (Extended Producer Responsibility) regulations, including the Spanish Packaging Law, Spanish Battery Law, and Spanish WEEE. At the same time, mandatory sellers that comply with regulations must:

Submit a valid Spanish EPR packaging law registration number on the Amazon platform before December 31, 2023.

In the Spanish EPR, sellers need to focus on the Spanish packaging law because the product coverage is wide, and the seller's coverage is wide, involving all packaged products sold to Amazon's Spanish site. PS: On January 1, 2023, AliExpress officially implemented the Spanish packaging law.

EPR in Spain 2023

 

2、 For sellers without an EPR registration number, the platform will fully hold and pay

Sellers who have not registered or uploaded their Spanish EPR registration number will be forced to withhold and pay by Amazon.

Among them, Amazon officially announced the "payment on behalf" measures under the Spanish packaging law:

If a valid packaging law registration number is not submitted to the platform before December 31, 2023, Amazon will fully withhold and pay all product categories under this compliance, that is, for the year 2023 and beyond, Amazon will collect declaration and pay environmental protection fees on behalf of the platform, and will also charge an additional service fee.

Amazon withholding and payment will not assume the obligation of the extended producer responsibility organization, nor is it your authorized representative!

Withholding and remitting means that you will not be able to independently declare and do not want to be withheld in two ways:

  1. Immediately register for the Spanish packaging law and upload the unique identification code of the packaging law to the platform before December 31st;

It may take 5 working days for Amazon to verify the packaging laws registration number. It is recommended that sellers submit the registration number as soon as possible.

  1. Stop selling all products that comply with packaging laws on Amazon's Spanish site. (This is impossible)

What if I want to exit the "payment agency" service after being withheld and remitted? According to Amazon's official notification, sellers must submit a valid packaging registration number on the platform's compliance portal before December 31st.

 

3、 Who and which products are required to register for Spanish EPR?

◉ packaging laws for Spanish EPR

  1. Who wants to register for Spanish packaging laws?

All sellers selling products to end consumers in Spain.

      2.Which products need to register under Spanish packaging laws?

All packaged products must be registered and reported for payment on time, regardless of product composition. Note: All products sold within Spain and supplied to consumers along with packaging bags, packaging materials, pallets, etc. must be registered.

◉ Battery Method for Spanish EPR

  1. Who wants to register for the Spanish Battery Laws?

All sellers importing batteries and battery products from third countries to Spain.

      2.Which products need to be registered under the Spanish Battery Laws?

Button batteries (alkaline button batteries, lithium button batteries)

Ordinary batteries (alkaline, alkaline, lithium)

Digital lithium-ion batteries (mobile phone lithium-ion batteries, laptop lithium-ion batteries, tablet lithium-ion batteries)

Industrial batteries

◉ WEEE of Spanish EPR

  1. Who wants to register for WEEE in Spain?

All sellers importing electrical and electronic equipment products from third countries to Spain.

      2.Which products need to be registered with WEEE in Spain?

Temperature exchange equipment, display screen equipment, lighting equipment, large equipment, small equipment, small IT and communication equipment, large photovoltaic panels.

 

4、 Can I apply for Spanish EPR without a tax number?

From a compliance perspective, before registering under Spanish packaging laws, it is necessary to have a Spanish VAT number.

According to the Spanish Royal Decree, packaging law registration must be officially registered with the Ministry of Ecology, and sellers need to provide their Spanish VAT number to apply.

The standard format for Amazon's Spanish Packaging Law registration number is "ENV/YEAR OF REGISTration/XXXXXXXX"

Amazon is registered with the Ministry of Industry, which means that sellers need to have a Spanish tax number to apply. The packaging law registration number applied for by other institutions on the market is a string of numbers, which is not in compliance with the registration number format and does not support binding to all OMPs after the number is issued. OMP usually directly connects to the local environmental protection bureau database, and other platforms predict that no tax registration will be supported in the future. So:

For sellers without a VAT number, it is recommended to register one first.

Sellers with a VAT number can provide the tax number and we can proceed immediately.

 

5、 The relationship between Hague certification and Spanish EPR?

Only with a Spanish VAT number can one comply with Spanish packaging laws. As the end of December approaches, how can I quickly obtain and apply for Spanish packaging laws without a tax ID?

There are two ways to register a Spanish VAT number: Hague certification and official translation

There are also two registration methods for Spanish packaging laws: Hague certification or digital certificate

Note: The Hague certification of the two is a different concept, and the Hague certification obtained by registering a tax number cannot be used for the Hague certification of packaging law.

 

6、 Is the Spanish EPR registration service chosen for 2023 or 2024?

Whether it is 2023 or 2024, Amber can handle EPR business in Spain.

Sellers with tax ID: To avoid Amazon's withholding and payment of Spanish packaging laws after December 31st, they can choose to apply for the 2023 Spanish EPR service (please refer to the official progress for specific numbers, and there is no guarantee that they can be issued before the end of this year);

Sellers without tax ID: It is recommended to register a Spanish tax ID first, and you can choose to apply for the 2024 Spanish EPR service.

EPR is a natural year renewal, early registration and early compliance.

 

 7.Spanish EPR Compliance Guidelines

Sellers with tax ID: Compliant with Spanish Packaging Law Registration → Upload registration number to Amazon platform before December 31st → Apply and pay recycling fees on time → Print recycling labels

Sellers without tax ID: Register a Spanish tax ID → Compliant with Spanish Packaging Law → Upload the registration number to Amazon platform before December 31st → Apply for and pay recycling fees on time → Print recycling labels

 

*Sign up and consult us to register Spanish VAT number or EPR ASAP .

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