From October 2025, sellers are required to submit their Spanish Extended Producer Responsibility registration numbers (ERN) via the Seller Performance Dashboard. All ERNs must be submitted by December 31, 2025 to avoid automatic enrollment in the “Payment on your behalf” service. The “Seller Performance” page will become the central hub for EPR compliance in Spain.
What do sellers need to be aware of?
Secure early registration: From October 2025, ERN submission will be mandatory. Brands should register with a Producer Responsibility Organization in good time to submit their numbers by December 2025 and avoid penalties or automatic EPR fees.
Include tobacco and battery categories: The obligation for SUP tobacco and batteries is new. Companies must ensure that these categories are also correctly reported to guarantee full compliance and smooth listing of their products in Spain.
Hold suppliers accountable: If you are not a manufacturer, you must request the ERN from your upstream supplier and document its submission. This helps sellers avoid liability risks and ensures EPR guidelines are met along the entire supply chain.
