Packaging law obligations for anyone who palletises
The obligations of the packaging law now reach the film that wraps the pallets. Since 1 January 2025, Royal Decree 1055/2022 extends extended producer responsibility to commercial and industrial packaging, transport packaging included.
Aerix Packaging · Technical team
In practice, companies that pack or import products for the Spanish market must register in the Register of Product Producers, include their registration number on invoices and join a collective scheme (SCRAP) or set up an individual one (SIRAP). They also have two fixed dates each year.
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5 obligations of the product producer
- Register in the Register of Product Producers.
- State the registration number and the SCRAP contribution on invoices.
- Join a SCRAP or set up an individual scheme (SIRAP).
- Report to the SCRAP the packaging placed on the market before 28 February.
- File the annual packaging declaration before 31 March.
Since 12 August 2026 the European Packaging Regulation (PPWR) also applies. According to a clarification note from the Spanish Ministry for Ecological Transition (MITECO) in May 2026, RD 1055/2022 remains in force in everything not incompatible with the regulation, which prevails in case of conflict, and the ministry is preparing a new royal decree to adapt. The two rules add up; they do not replace each other.
For anyone who palletises, every kilo of stretch film counts in the declarations. Optimising consumption per pallet reduces the kilos declared and simplifies compliance. It is worth checking with your environmental adviser what role the company plays in the chain, because its obligations depend on it.
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