Annual packaging declaration in the RPP: a practical guide

The annual packaging declaration in the Product Producers Register (RPP) is the obligation under which companies placing packaging on the Spanish market must report to MITECO, every year and before 31 March, the packaging they put on the market the previous year. It stems from the Law 7/2022 and Royal Decree 1055/2022, and filing it correctly avoids penalties and administrative blocks.

If your company places packaging on the market, this procedure tends to raise questions. In this guide we explain what to declare, who is obliged, how to do it step by step and how to connect it with your sustainability reporting.

What is the Product Producers Register (RPP) and why does it affect you?

The Product Producers Register (RPP), in its packaging section, is the administrative instrument in which producers must register and annually declare information on the packaging they place on the market. Its purpose is to ensure traceability, give effect to extended producer responsibility (EPR) and verify compliance with waste and circular economy rules.

The RPP is not optional: all companies considered product producers are required to register and submit the annual packaging declaration. Non-compliance may lead to financial penalties, administrative blocks and reputational risks.

Which companies must declare packaging in the RPP?

Any company that:

• Places packaging on the Spanish market for the first time.
• Manufactures, imports or acquires packaged products from other EU Member States.
• Sells packaged products under its own brand.

This includes manufacturers, distributors, e-commerce businesses, importers and private-label brands. Company size does not matter: the criterion is placing packaging on the market. RD 1055/2022 provides a simplified declaration for producers that place less than 15 tonnes of packaging on the market per year and for other specified cases.

Which regulations govern the annual packaging declaration?

The obligation to declare derives mainly from:

• Law 7/2022 on waste and contaminated soils for a circular economy.
• Royal Decree 1055/2022 on packaging and packaging waste, whose Article 16 sets the declaration deadline of 31 March.

On top of this national framework comes Regulation (EU) 2025/40 on packaging and packaging waste (PPWR), applicable from 12 August 2026, which strengthens requirements on recyclability, recycled content and traceability. The structural change is clear: the producer assumes both the financial and organisational responsibility for managing the waste generated by its packaging.

What information must the annual packaging declaration include?

The declaration requires a high, verifiable level of detail. This is the minimum information:

Packaging types

• Primary, secondary and tertiary packaging.
• Household, commercial and industrial packaging.

Materials

• Plastic.
• Paper and cardboard.
• Glass.
• Metal.
• Wood.
• Composite materials.

Quantities

Quantities must be declared in kilograms by material type and packaging category.

Extended producer responsibility system

The company must indicate how it meets EPR:

• Collective system (SCRAP).
• Individual system.

The declared data must be consistent with the information reported to the extended producer responsibility systems.

When and how is the annual declaration submitted?

Deadlines

The annual packaging declaration must be submitted before 31 March each year, with data from the previous financial year.

Submission channel

It is done electronically through the electronic office of the Ministry for the Ecological Transition (MITECO). Failure to submit on time is treated as an administrative infringement.

How to prepare the declaration correctly, step by step

1. Identify the packaging scope

The first common mistake is underestimating the scope. It is essential to identify all packaging placed on the market, including promotional packaging, samples and transport packaging.

2. Collect reliable primary data

Data must come from product technical specifications, packaging suppliers and ERP and logistics systems. Estimates without traceability increase the risk of penalties.

3. Classify materials and categories correctly

Incorrect classification distorts the declaration and can create inconsistencies with the SCRAPs.

4. Validate consistency with other reporting

Packaging data must be consistent with ESG reporting, carbon footprint declarations and CSRD disclosures. This is where digitalisation provides the greatest value.

What is the relationship between RPP, circular economy and CSRD?

The annual packaging declaration is not an isolated procedure: it feeds key indicators on the circular economy, efficient use of materials and waste generation. Those data are required by the ESRS standards under the CSRD, specifically the ESRS E5 standard on resource use and circular economy. Companies that integrate the RPP into their ESG system reduce duplication and improve reporting quality.

Penalties for non-compliance with the RPP

Non-compliance with RPP obligations is governed by the penalty regime of Law 7/2022 and may lead to:

• Financial fines proportionate to the seriousness of the breach.
• Correction requirements.
• Risk of exclusion from public tenders.

Preventive compliance is always less costly than corrective action.

The RPP declaration as a lever for compliance and sustainability

The annual packaging declaration has become a key element of regulatory compliance and sustainability strategy. Managing it rigorously avoids penalties, improves the quality of ESG reporting and advances towards real circular economy models. In an increasingly demanding regulatory context, professionalising this process delivers efficiency, traceability and preparedness for future obligations.

Frequently asked questions about the annual packaging declaration in the RPP

Do I need to declare packaging if I sell online?

Yes. The sales channel does not exempt you from the obligation when the company places packaging on the Spanish market.

Can I delegate the declaration to a SCRAP?

The SCRAP manages part of the EPR obligations, but the producer remains responsible for the accuracy of the declared data.

What happens if I detect an error after submitting the declaration?

You must submit a supplementary declaration as soon as possible to correct it and reduce the risk of penalties.

How can I reduce the annual effort of the declaration?

With digital systems that automate the collection and validation of packaging, waste and materials data.

To centralise your packaging data and connect it with your regulatory reporting, you can rely on a waste management tool.