Guide to the Annual Packaging Declaration in the Product Producers Register (RPP)

The annual packaging declaration in the Product Producers Register (RPP) is a key obligation for companies that place packaging on the Spanish market.

Submitting it correctly not only ensures regulatory compliance, but also enables more efficient management of responsibilities associated with packaging and its waste.

If your company places packaging on the Spanish market, the annual declaration in the Product Producers Register (RPP) is a procedure that can generate doubts and errors.

In this article, we explain what you must declare, how to do it correctly, and which aspects you should consider in order to comply without complications or risk of penalties.

‍

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

The Product Producers Register (RPP) is the administrative instrument through which companies that place packaging on the Spanish market must annually declare information regarding the packaging they introduce.

Its purpose is to ensure traceability, extended producer responsibility (EPR), and compliance with waste and circular economy regulations.

The RPP is not optional. All companies considered product producers are required to register and submit an annual packaging declaration. Non-compliance may result in financial penalties, administrative restrictions, and reputational risks.

‍

Which companies are required to 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 determining factor is placing packaging on the market.

‍

Which regulations govern the annual packaging declaration?

The obligation to declare packaging primarily derives from:

• Law 7/2022 on Waste and Contaminated Soils for a Circular Economy
• Royal Decree 1055/2022 on Packaging and Packaging Waste

This legislation introduces a structural change: the producer assumes both the financial and organizational responsibility for managing the waste generated by their packaging.

‍

What information must be included in the annual packaging declaration?

The annual declaration requires a high level of detail and verifiable data.

At a minimum, the declaration must include:

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 whether it complies with EPR through:

• A collective system (SCRAP)
• An 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?

Understanding deadlines and submission procedures is key to avoiding errors and penalties.

Here we explain when the declaration must be submitted and how to complete the process step by step through the Product Producers Register.

Deadlines

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

Submission channel

Submission is carried out electronically through the platform enabled by the Ministry for the Ecological Transition.

Failure to submit within the deadline constitutes an administrative infringement.

‍

How to properly prepare the annual declaration step by step

Preparing the annual declaration correctly requires collecting accurate data and following a structured process.

Here we guide you step by step to organize the information, avoid common errors, and submit the declaration correctly and efficiently.

1. Identify the packaging scope

A common mistake is underestimating the scope. It is essential to identify all packaging placed on the market, including:

• Promotional packaging
• Samples
• Transport packaging

2. Collect reliable primary data

Data must come from:

• Product technical specifications
• Packaging suppliers
• ERP and logistics systems

Estimates without traceability increase the risk of penalties.

3. Correctly classify materials and categories

Incorrect classification distorts the declaration and may create inconsistencies with SCRAP systems.

4. Validate consistency with other reporting

Packaging data must align with:

• ESG reporting
• Carbon footprint declarations
• CSRD disclosures

This is where digitalization 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 related to:

• Circular economy
• Efficient use of materials
• Waste generation

These data are required under ESRS standards within the CSRD framework. Companies that integrate RPP into their ESG systems reduce duplication and improve reporting quality.

Platforms like Manglai allow companies to centralize packaging, waste, and materials data, connecting them directly with regulatory reporting.

‍

Penalties for non-compliance with the RPP

Failure to comply with the obligations of the Product Producers Register (RPP) may lead to financial penalties and administrative consequences.

The penalty regime includes:

• Financial fines proportional to the volume of packaging
• Correction requirements
• Risk of exclusion from public procurement processes

Preventive compliance is always less costly than corrective action.

‍

The RPP declaration as a lever for compliance and sustainability

The annual packaging declaration in the Product Producers Register (RPP) has become a key element of regulatory compliance and corporate sustainability strategy.

Managing it rigorously not only helps avoid penalties and reduce legal risks, but also improves ESG reporting quality and advances real circular economy models.

In an increasingly demanding regulatory context, professionalizing this process is a strategic decision that enhances efficiency, traceability, and preparedness for future obligations.

‍

Frequently Asked Questions about the Annual Packaging Declaration in the Product Producers Register (RPP)

Is it necessary to declare packaging if I sell online?

Yes. The sales channel does not exempt you from the obligation.

Can I delegate the declaration to a SCRAP?

No. The producer remains responsible for the accuracy of the data.

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

You must submit a corrective declaration as soon as possible to avoid potential penalties.

How can I reduce the annual workload of the declaration?

By implementing digital systems that automate data collection and validation.