Spain introduces new environmental signage requirements for packaging

Every EU state is now one by one establishing its own regulations that govern packaging waste management, answering the EU European Green Deal and in compliance with the EU Packaging Waste Directive. Spain updates its requirements, including packaging labeling, in its new decree, Real Decreto 1055/2022 for packaging and packaging waste. As a brand within apparel, footwear, or home textiles, are you aware of what you must comply with?

Spanish Royal Decree was published on December 27th, 2022, and is related to product packaging and waste management. It aims to achieve complete recyclability or reusability of packaging by 2030, thus contributing to environmental protection and ensuring sustainable development by reducing packaging waste generated in Spain. It also introduces measures to increase transparency and producer accountability concerning product marketing and waste management.

New EPR scheme and highlights

The Spanish decree includes a set of targets to prevent, reuse and recycle packaging and an updated Extended Producer Responsibility (EPR) scheme, aligning with the European Directives. Spain’s objective is to reach 100% of recyclable or reusable packaging by 2030.

Here’s what you need to know:

• B2B and B2C packaging are concerned.
• Producers are required to set up an individual or collective EPR scheme and necessary financial guarantee (by June 30^th, 2023).
• Producers should 1. submit annual waste volume declaration and 2. make a financial contribution for the collection and treatment of packaging waste.
• The packaging must not exceed 100 ppm regarding the total amount of lead, cadmium, mercury, and hexavalent chromium.
• The packaging must bear visible labeling, physically printed on the packaging item for waste sorting. Making this available only digitally is not mentioned as an option.
• An additional tax applies for single-use plastic made packaging.

Spanish Decree Environmental labeling requirements

• For B2C packaging, the waste collection bin must be shown for each component of the packaging that can be separated by hand. If not separable, it should indicate the bin of the main material by weight.
• Reusable packaging should indicate the reusability conditions, including the sorting instructions.
• The terms “Environmentally friendly” or similar are forbidden.
• Material composition is optional.
• Recyclable packaging should mention the percentage of recyclability based on documented proof.
• Compostable packaging can be claimed if certified EN 13432:2001 and should bear the mention “do not throw away in nature” (“no abandonar en el entorno”).
• The percentage of recycled content can be claimed under the condition that it is certified.

Timeline

The provisions of the Royal Decree 1055/2022 were published in the Official State Gazette on December 28^th, 2022. However, the labeling requirements outlined in the decree will come into effect from January 1, 2025.

Trimco solutions to comply with the new Spanish Real Decree

The packaging team at Trimco Group can assist your brand in revising the packaging design to reflect the updated signage requirements.

• The ProductDNA® Certificate Manager allows you to collect all certifications and documented proofs required by the Spanish authorities to support your claims:
• Percentage of recycled material
• Compostable products
• Recyclability level

ProductDNA® Packaging Manager prepares the yearly report on packaging consumption for you, including all criteria required by the Spanish EPR scheme organization based on validated data. You only have to upload the information to the Spanish EPR scheme organization platform.

What about the Green Dot in Spain?

The green dot used to be mandatory from the previous regulation, Packaging law 1997.
The new regulation published last December 2022, replaces it, and therefore the Green Dot is no longer mandatory in Spain.

The Green Dot becomes a licensed symbol, which can be applied if you purchase a license to use it.

Get in touch with our team, and let’s talk about your packaging compliance in Spain.

Sources:

• BOE-A-2022-22690 Real Decreto 1055/2022, de 27 de diciembre, de envases y residuos de envases.

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