In Spain, a SCRAP (Sistema Colectivo de Responsabilidad Ampliada del Productor) is a collective Extended Producer Responsibility scheme that takes over the legal and financial obligations for packaging waste on behalf of member companies. If you place packaged products on the Spanish market, you are a productor de producto under Royal Decree 1055/2022 and must either join a SCRAP or run an individual system (SIRAP), register with MITECO, and declare your packaging volumes every year.
This guide focuses only on what SCRAP means for packaging in Spain: who must comply, how registration works, what you declare, and how to avoid the data gaps that trigger fines or incorrect fee calculations.
What SCRAP means for packaging in Spain
SCRAP is the collective route to comply with RAP (Responsabilidad Ampliada del Productor) for packaging. Instead of organising collection and recycling yourself, you pay a collective scheme to fulfil your legal obligations: financing separate collection, sorting, recycling, and reporting to authorities.
The alternative is a SIRAP (individual system), where the producer sets up its own compliance structure. For most companies, especially those with mixed packaging formats across multiple sites, SCRAP membership is the practical default.
The legal framework is Royal Decree 1055/2022 on packaging and packaging waste, under Law 7/2022 on waste and contaminated land. MITECO manages the Registro de Productores de Producto (RPP) packaging section through its electronic office.
SCRAP is national. If you sell in France, Germany, or Portugal, you need equivalent EPR registration in each market. Spain does not accept a foreign scheme in place of local RAP.
Who must register and join a SCRAP
You are a packaging producer in Spain if you first place packaged goods on the Spanish market, including as:
- A company that fills packaging with its product (envasador)
- An importer of packaged products from outside the EU
- An intra-EU acquirer when no producer is established in Spain
- In some cases, e-commerce platforms under Article 2(t) of RD 1055/2022
The obligation applies to domestic, commercial, and industrial packaging categories. Until recently, collective SCRAP membership was most familiar for household (doméstico) packaging. From 1 January 2025, commercial and industrial packaging also requires an SRAP (SCRAP or SIRAP), which expanded the producer base significantly.
Tip: "Producer" under packaging law is not the packaging manufacturer alone. If your brand puts product in packaging on the Spanish market, you are likely the registered producer even when a supplier prints the box or bottle.
Domestic, commercial, and industrial packaging: why it matters
MITECO requires you to declare packaging by category because each follows different RAP rules and may use different authorised schemes.
Domestic packaging (envases domésticos): reaches households after purchase. Bottles, trays, bags, cartons for retail consumers. Long-standing SCRAP obligation; most food, beverage, and FMCG companies know this category.
Commercial packaging (envases comerciales): used in B2B distribution but not typically taken home by consumers. Secondary packaging in wholesale channels.
Industrial packaging (envases industriales): pallets, drums, IBCs, stretch film, one-way industrial formats that become waste at the final holder. Often overlooked until the 2025 extension.
You must indicate, for each category, whether packaging is single-use or reusable, which SRAP/SCRAP covers it, and attach the membership certificate (not the contract) when registering or updating your RPP profile.
How MITECO registration works step by step
Registration happens in the MITECO RPP packaging section. The typical flow:
- Identify packaging categories you place on the market (domestic, commercial, industrial) and material types.
- Choose SCRAP or SIRAP for each category. MITECO publishes the list of authorised collective and individual systems granted by regional authorities.
- Sign with your chosen SCRAP and obtain the one-page certificate of membership (max 10 MB PDF).
- Complete RPP registration with company certificate, packaging categories, SRAP/SCRAP selected, and certificate attached.
- Receive your producer number and display it on invoices and commercial documents for packaged products, together with the economic contribution linked to RAP compliance where required.
Ordinary updates to categories or SCRAP membership can be filed in the last quarter of each year. You can also attach new certificates during the year via MITECO personal area without resubmitting the full initial registration.
Main collective schemes and how to choose
Spain has several authorised collective SCRAP operators. The right choice depends on packaging category, material mix, and sector. Two widely used collective schemes illustrate the landscape:
Ecoembes has historically been the reference for domestic packaging across materials (plastic, metal, paper/cardboard, glass, wood, other composites). Most FMCG producers placing household packaging on the market are familiar with its fee structure and annual declaration process.
Procircular operates as a collective SCRAP covering domestic, commercial, and industrial packaging nationally. It is relevant for companies that want one collective membership across categories or that need commercial/industrial coverage alongside domestic formats.
MITECO’s official list is the only authoritative source for authorised systems. Do not rely on marketing pages alone: verify that your SCRAP holds definitive or provisional authorisation for the categories you declare.
Tip: If you use different SCRAPs for domestic and industrial packaging, your RPP profile must reflect each scheme separately with its certificate. A single domestic SCRAP membership does not cover industrial pallets or commercial secondary packaging unless that scheme is authorised for those categories.
Annual declarations and critical deadlines
Beyond registration, producers must declare packaging placed on the market each year through the RPP. Volumes are reported by material, category, and format according to MITECO and SCRAP templates.
Key dates to track in your compliance calendar:
- 28 February: deadline commonly cited for the definitive annual packaging declaration for the previous calendar year.
- Last quarter of the year: ordinary window to update RPP categories and SCRAP membership for the following period.
- Ongoing: any change of SCRAP or packaging scope should trigger an RPP update with a new membership certificate.
Under-declaring volumes, using the wrong material classification, or failing to match RPP data with SCRAP fee declarations creates audit risk under Law 7/2022, which sets administrative penalties for waste law breaches.
SCRAP fees: what drives your contribution
SCRAP fees are not a flat tax. They depend on:
- Material type (plastic, cardboard, glass, metal, wood, others)
- Packaging category (domestic, commercial, industrial)
- Weight or units placed on market in the declaration period
- Ecodesign factors where schemes apply bonuses or penalties for recyclability, recycled content, or format design
Incorrect master data in purchasing or product specifications flows directly into wrong declarations. Companies that manage packaging weights in spreadsheets disconnected from ERP and product master data often discover discrepancies only when the SCRAP invoice arrives or MITECO requests documentation.
How SCRAP connects to PPWR and the plastic tax
SCRAP compliance in Spain sits alongside EU PPWR obligations from August 2026 and Spain’s special tax on non-reusable plastic packaging (Model 592). They are different legal instruments but share the same underlying data:
- Packaging inventory by material and weight
- Recycled content percentages and certificates
- Format classification (single-use vs reusable)
- Volumes placed on market by period
Data collected for SCRAP declarations should feed PPWR compliance and plastic packaging tax reporting without re-keying. Treating each obligation as a separate Excel project is how companies pay twice: once in SCRAP fees from bad data, again in tax or PPWR rework.
Dcycle centralises packaging volumes, material classification, and SCRAP-ready outputs in one governed platform. The same data supports MITECO declarations, PPWR recyclability scoring, and plastic tax calculations.
Request a demoHow Dcycle helps with SCRAP packaging compliance
Dcycle is not a SCRAP operator and does not replace Ecoembes, Procircular, or any authorised scheme. It manages the data layer that makes SCRAP and RPP compliance repeatable:
Packaging inventory by SKU and material. Register primary, secondary, and tertiary formats with weights, materials, and category flags (domestic, commercial, industrial). Updates flow from ERP, product specs, or supplier data instead of annual reconstruction.
Volume aggregation for RPP and SCRAP declarations. Aggregate placed-on-market volumes by material and category for the reporting period, aligned with the structure MITECO and your SCRAP require.
Certificate and evidence traceability. Link SCRAP membership certificates, supplier packaging specs, and declaration files to each reporting cycle for internal audit and MITECO requests.
PPWR and plastic tax integration. The same packaging registry generates recyclability grades, recycled content tracking, and Model 592 inputs, plus ESRS E5 circular economy disclosures where applicable.
Multi-site consolidation. Groups with several production or distribution entities in Spain consolidate packaging data before splitting declarations by legal producer or SCRAP membership.
Request a demo to see how Dcycle connects SCRAP packaging data with PPWR, plastic tax, and CSRD reporting from one platform.
Frequently asked questions
Is SCRAP the same as MITECO registration?
No. MITECO RPP registration is the public producer registry managed by the ministry. SCRAP membership is how you fulfil your financial and operational RAP obligations for packaging waste. You need both: register in RPP and prove membership in an authorised SCRAP (or an approved SIRAP) with the membership certificate.
Can I use Ecoembes for all my packaging?
Only if Ecoembes is authorised for every category you declare (domestic, commercial, industrial) and you hold valid membership for each. Many companies use one SCRAP for domestic packaging and a different authorised scheme for commercial or industrial formats. Your RPP profile must match reality.
What happens if I declare less packaging than I actually placed on the market?
Under-declaration is a compliance breach under Spanish waste law. Authorities and SCRAP operators cross-check declarations against market data, audits, and sector benchmarks. Penalties under Law 7/2022 can include fines and orders to regularise volumes retroactively, with back fees to the SCRAP.
Do importers have the same SCRAP obligations as Spanish manufacturers?
Yes, if they first place packaged product on the Spanish market and no other producer is registered in Spain for that packaging. Importers must register in RPP, join a SCRAP or run a SIRAP, declare volumes, and show the producer number on commercial documents.
How does SCRAP relate to PPWR?
SCRAP is Spain’s national EPR mechanism for packaging waste. PPWR is the EU regulation harmonising packaging requirements across member states from 2026, including recyclability, recycled content, and producer registration. You will need consistent packaging data for both. Platforms like Dcycle manage that data once and map it to SCRAP declarations, PPWR reports, and other outputs.