I am now also going to supply to Spain what do I need to arrange now

Supplying to Spain makes you a manufacturer there

From now on, if you supply to customers in Spain, you will in most cases be considered the manufacturer of the packaging there, and this entails a registration obligation in the Spanish register. This is separate from what is already arranged in the Netherlands: the Dutch threshold of 50,000 kg plays no role in Spain, and according to current expectations, that threshold will be discontinued anyway from August 2027 onwards. Spain has its own system, with its own registration point and its own reporting rules, separate from the Dutch Verpact.

For distance sales — that is, directly to Spanish consumers, for example via a webshop — there is a point to note: in such situations, the obligation often rests with the seller itself, even without an establishment in Spain, and it may be necessary to appoint an authorised representative there. How exactly this works out varies depending on the form of supply (direct to consumers or via a local party), and that is precisely the type of question where the role finder on epria.eu indicates per country and per packaging type which role applies and which register, which costs and which deadlines are involved. More about when that representative is needed can be found at when do I need an authorised representative in another EU country, and an overview of the registration obligation in Spain and other countries can be found at in which EU countries must I register my packaging.

The basis in the regulation

This obligation follows from Article 44 of Regulation (EU) 2025/40, which regulates the registration obligation per Member State, and from Article 45, which specifically addresses distance sales and the role of the authorised representative in this regard. Because it is a regulation, these rules apply in Spain on the same legal basis as in the Netherlands; the difference lies in the national implementation — the register, the notification procedure and the administrative details are set per country, and Spain has its own interpretation of this.