How to comply with the Spanish Royal Decree on SCRAP

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What is SCRAP and why is it mandatory?

Royal Decree 1055/2022 on packaging and packaging waste regulates extended producer responsibility in Spain. In this context, SCRAP (the Collective Extended Producer Responsibility Scheme) enables manufacturers, importers and distributors to meet their obligations. However, failure to adapt entails financial penalties, potential trade barriers and the loss of customers who are increasingly demanding in terms of sustainability and regulatory compliance.

SCRAP’s obligations:

Royal Decree 1055/2022 establishes the following obligations for companies:

  • Registration as a product producer with the relevant authority.
  • Submission of the annual packaging declaration.
  • Financing of waste management through a PRO system.
  • Compliance with packaging labelling and marking requirements.
  • Ensuring proper consumer information.

These obligations are essential to ensure regulatory compliance and avoid penalties.

Steps to comply with the Royal Decree

We’ll walk you through the process in a clear and practical way so that you can identify your obligations, avoid mistakes and ensure your packaging is managed correctly:

Find out if you are a producer

Carefully analyse your business activities to determine whether you place packaging on the domestic market, either directly or indirectly. It is also essential to correctly identify the type of packaging you handle: household, commercial or industrial, as each category is subject to specific obligations under the Royal Decree.

You must register with the Product Producers’ Register, which is managed by the relevant ministry. To do so, you will need to compile and submit key information about your company, its activities, the products it sells and the types of packaging used in the market.

You must accurately calculate the quantities of packaging you place on the market, broken down by material (plastic, cardboard, glass, etc.), total weight and type. This step is critical, as it determines your financial obligations and your compliance with the SCRAP scheme.

Select the most suitable SCRAP scheme based on your business activity and the type of packaging (e.g. Ecoembes or other authorised schemes). You will then need to formalise your membership by signing a contract, which will enable you to outsource waste management and comply with current regulations.

Finally, you must submit the annual packaging declaration, reporting the quantities placed on the market. It is also advisable to monitor the data regularly to ensure consistency, avoid errors and guarantee ongoing compliance with legal obligations.

Why choose EmasConsultors?

At Emas Consultors, we support you from start to finish to comply with PRO system requirements in an agile, rigorous and error-free way:

  • Initial diagnosis: We analyse your activity to confirm whether you are considered a producer and which obligations apply to you under Royal Decree 1055/2022.
  • Packaging calculation: We correctly quantify packaging by material, weight and type, ensuring data consistency and traceability.
  • Registration management: We handle registration in the Product Producer Register and prepare all the necessary documentation.
  • Relationship with the PRO system: We advise you on selecting the appropriate system, such as Ecoembes or others, and manage the membership process and contract.
  • Ongoing support: We prepare the annual declaration, carry out periodic reviews and keep you updated on regulatory changes.

We help you comply with all the requirements of the Royal Decree. Contact us to establish a budget tailored to your needs.

FAQs SCRAP

Is there a standard, such as ISO 14001, that requires the use of SCRAP?

Not directly. ISO 14001 does not require compliance with SCRAP, but it does require compliance with applicable environmental legislation. Therefore, if your business falls within the scope of Royal Decree 1055/2022, then ISO 14001 indirectly requires you to comply with SCRAP. If it does not apply to you legally, the standard does not require it.

Failure to comply may result in significant financial penalties, problems with customers or distributors, and even the inability to sell products on the market.

Royal Decree 1055/2022 is now in force, although some requirements are being phased in gradually. It is important to check the specific deadlines depending on the type of packaging and activity.