The Ministry for the Ecological Transition and the Demographic Challenge (MITECO) has published a new interpretative note to clarify the definition of packaging producer and the obligations associated with registration in the Register of Product Producers (RPP), in the context of the application of Regulation (EU) 2025/40 on packaging and packaging waste (PPWR).

With the application of the PPWR from August 12, 2026, the new definition of producer introduces changes that may affect the responsibility of the different agents in the packaging value chain.

What are some of the main changes? Among the clarifications published by MITECO are:

• Transport, service and primary production packaging: manufacturers, importers or distributors who introduce them for the first time into the Spanish market will be considered producers.

• White labels or distribution labels: in general, the producer will be the company that commissions the design or manufacture of the packaging or packaged product under its own brand. The regulations provide for a specific exception in the case of micro-enterprises, provided that the entity that manufactures the packaging or packaged product is located in Spain.

• Operators established outside Spain: in certain cases of direct sales to end users in Spain, they must appoint an authorised representative for the purposes of extended producer responsibility.

• E-commerce platforms: they no longer have the subsidiary consideration of the producer provided for so far in certain cases, although the PPWR attributes other obligations to them.

• Declaration of packaging marketed during 2026: MITECO specifies how the information should be reported depending on whether the operator maintains, loses or acquires producer status as a result of the application of PPWR.

These changes make it advisable for companies to review the role they play in the marketing chain of their packaging and packaged products, as well as the possible implications for registration in RPP and declaration obligations.

See the interpretative note of 13/08 and the  updated information from MITECO in the Register of Product Producers.

From the Packaging Cluster we continue to monitor the news derived from the application of the PPWR to facilitate its understanding and adaptation by companies in the sector.

This October we are organizing the training "Adapting to the new packaging legislation: PPWR requirements and ecodesign strategies", in which we will address the new requirements of PPWR and RD 1055 and the tools to transfer them to the ecodesign and circularity strategy of packaging.

More information and registration here.