RD 1055/2022: key points of EPR for commercial and industrial packaging

Royal Decree 1055/2022 on packaging and packaging waste (published in Spain's Official State Gazette on 28 December 2022) reshaped the environmental responsibility framework for packaging in Spain. Its most significant novelty is that, for the first time, it extends Extended Producer Responsibility (EPR) to commercial and industrial packaging, which until then fell outside the regulatory focus.

This requires manufacturers, importers and distributors to take on the management of the packaging they place on the market, not just household packaging. Far from being a mere administrative burden, the EPR model is an opportunity to improve material traceability, gain efficiency in the supply chain and strengthen environmental reputation.

This article covers the key points of RD 1055/2022, who is covered, which deadlines apply and how it fits with the new European packaging regulation.

What is Extended Producer Responsibility (EPR)?

Extended Producer Responsibility (EPR) is a European principle that transfers to the producer who places a product on the market the responsibility for managing the waste it generates. In the case of packaging, companies must finance, organise and ensure its collection, treatment and recycling, as well as report data on its composition and destination.

Until 2022, this obligation focused on household packaging, managed through systems such as Ecoembes. RD 1055/2022 broadens the scope and also brings in commercial and industrial packaging, with a direct impact on sectors such as logistics, food, retail and manufacturing.

What are the objectives of RD 1055/2022?

The Royal Decree is aligned with the European Green Deal and the circular economy, and pursues several objectives:

1. Reduce the use of virgin materials and promote reuse

It drives the transition towards reusable packaging with recycled content, with concrete reduction targets. This means rethinking designs, prioritising secondary materials and finding logistics alternatives that extend the packaging's useful life, with less dependency on new raw materials and a lower carbon footprint.

2. Increase recycling and recovery of industrial packaging

RD 1055/2022 corrects the historical lack of control over commercial and industrial packaging, bringing it into the EPR system and setting up collection and traceability mechanisms so that recovered materials return to the production cycle.

3. Prevent waste generation through ecodesign

The decree places packaging ecodesign at the centre: the best waste is the one that is never generated. It encourages optimising formats, reducing weight, using mono-material packaging and removing non-recyclable elements. You can read more in our article on the Environmental Product Declaration (EPD).

4. Ensure traceability and transparency across the value chain

RD 1055/2022 sets registration, reporting and verification obligations that make it possible to know the destination of every package placed on the market, which improves environmental oversight and gives companies useful information for their internal management.

Who must comply with EPR and what is its scope?

RD 1055/2022 affects all companies that manufacture, import, pack or market products in packaging, whether plastic, metal, cardboard or glass, both those placing the product on the national market and those operating from other EU countries with Spain as their destination.

Commercial and industrial packaging (drums, pallets, transport crates, shrink film, etc.) is expressly included. In general, any company that places packaging on the Spanish market must register as a producer, meet its information obligations and join an EPR system, individual or collective.

Key deadlines of RD 1055/2022

Two dates are worth keeping in mind:

• The EPR obligations for commercial and industrial packaging had to be in place before 31 December 2024.
• The annual declaration of packaging placed on the market is submitted each year, as a general rule, before 31 March.

How to comply with EPR: individual and collective systems

The Royal Decree allows two routes:

1. Individual EPR system

The producer takes on the organisation and financing of the collection and treatment of its packaging on its own, demonstrating full traceability of the flows and submitting periodic reports to the competent authority. It is usually the option for large manufacturers with full control of their reverse logistics.

2. Collective EPR system (SCRAP)

Companies can join collective extended producer responsibility systems (SCRAPs), which group several producers and manage packaging jointly. Depending on the type of packaging, SCRAPs such as Envalora (commercial and industrial packaging) or Ecoembes (household packaging) handle collection, recycling and legal compliance. In all cases, each company must register in the Product Producer Register (RPP) and declare the quantity and type of packaging placed on the market.

New obligations for commercial and industrial packaging

Non-household packaging (cardboard boxes, reusable pallets, metal drums, plastic film and other logistics packaging) is now regulated under the EPR principle. The main obligations include:

• Registration in the RPP before marketing products in Spain.
• Financing the treatment and recycling of the packaging placed on the market.
• Annual declaration with data on weight, material, recyclability and end-of-life destination.
• Incorporation of recycled materials into new packaging, in line with EU targets.
• Design for reuse and recyclability, following ecodesign principles.

Non-compliance can lead to penalties; but, beyond the risk, the companies that adapt early gain in image and operational efficiency.

From RD 1055/2022 to the European packaging regulation (PPWR)

The framework does not stop at the Royal Decree. Regulation (EU) 2025/40 on packaging and packaging waste (PPWR) sets a more ambitious common European framework and, being a regulation, is directly applicable in all member states. This means the Spanish legislation, including RD 1055/2022, will have to be adapted to ensure consistency with it. Getting ahead of these European requirements is the best way to avoid surprises.

Ecodesign: the core of competitiveness under EPR

Complying with EPR is not only about managing waste, but about rethinking packaging from its design. Ecodesign cuts costs and emissions, extends the useful life of materials and improves circularity. An effective strategy integrates:

• Reducing the weight and volume of packaging.
• Using recycled or recyclable materials.
• Return and reuse systems in the logistics chain.
• Optimising transport and storage to reduce the carbon footprint.

How to prepare your company to comply with RD 1055/2022

Adapting to EPR requires a cross-cutting view that combines environmental management, logistics, ecodesign and regulatory compliance. These are the essential steps:

1. Inventory all packaging across the product life cycle

Carry out a complete inventory of the packaging in the value chain: from primary to secondary and industrial transport and storage packaging. This is how you detect the critical points of waste generation.

2. Analyse the material flow and calculate the quantities placed on the market

Quantify volume, weight and composition by material. This analysis is the basis of the annual packaging report and makes it possible to set circularity and material-footprint indicators.

3. Register the company in the RPP and choose the EPR system

The Product Producer Register (RPP) is the gateway to compliance. Once registered, decide whether you will manage EPR individually or collectively (by joining a SCRAP), depending on your packaging volume and logistics capacity.

4. Coordinate internally

Complying with EPR means coordinating procurement, production, quality, sustainability and logistics. An internal communication plan makes it easier to collect data and embed environmental criteria into decisions.

5. Integrate packaging data into ESG reporting

Data on packaging, materials and waste should be incorporated into ESG (environmental, social and governance) reporting. This reinforces consistency between legal compliance and communication, and can feed frameworks such as GRI or the CSRD.

Strategic benefits of EPR for companies

Complying with RD 1055/2022 is not only a response to a legal requirement: it opens the door to improvements in competitiveness, efficiency and reputation.

• Cost optimisation for materials, transport and storage thanks to ecodesign and reuse.
• Greater traceability in the supply chain, which improves supplier control and risk management.
• Access to tenders and projects with sustainability criteria, where environmental compliance adds to the score.
• Better positioning with investors and large B2B customers, in line with the EU green taxonomy.
• Reinforced reputation as a responsible and circular company.

RD 1055/2022: comply, transform and lead

RD 1055/2022 marks a turning point in packaging management in Spain. Companies that act proactively, adapting their logistics, redesigning their packaging and communicating transparently, do not just comply with the law: they build a sustainable competitive advantage aligned with the economy of the future.

If you want to centralise packaging and waste data and simplify your annual declaration, find out how Manglai helps with waste management.

Frequently asked questions about RD 1055/2022 and EPR

Since when is compliance with RD 1055/2022 mandatory?

The Royal Decree has been in force since the end of 2022, with gradual application. The EPR obligations for commercial and industrial packaging had to be in place before 31 December 2024, and the annual declaration is submitted each year before 31 March.

Does it affect all companies equally?

Yes, although the obligations vary depending on the type of packaging and the volume. SMEs can join collective systems (SCRAPs) that simplify compliance.

What happens if EPR is not complied with?

Companies that do not register or do not submit the required information can face administrative penalties and lose access to public tenders.

How is EPR related to the circular economy?

EPR is the mechanism that makes the circular economy effective in the packaging sector, promoting ecodesign, reuse and recycling.

How does RD 1055/2022 relate to the European packaging regulation?

Regulation (EU) 2025/40 (PPWR) sets a common, directly applicable European framework; the Spanish legislation, including RD 1055/2022, will be progressively adapted to keep consistency with it.