In accordance with Royal Decree 1055/2022, dated December 27, on packaging and packaging waste, we inform our customers and collaborators that, starting January 1, 2025, all companies producing packaging subject to Extended Producer Responsibility (EPR) must itemize the contribution to the Collective System of Extended Producer Responsibility (SCRAP) on their invoices.
As stipulated in Article 23, Section 5 of Royal Decree 1055/2022, the amount corresponding to the financing of the SCRAP for the management of packaging waste must appear separately and be clearly identified on invoices issued to distributors, commercial establishments, and other recipients of the products. This measure aims to promote financial transparency in waste management, providing customers and consumers with greater awareness of the environmental cost of packaging.
The inclusion of this information on invoices aligns waste management with the principles of the circular economy and environmental sustainability in Spain. Through SCRAP, producers fund the management of the packaging waste they place on the market, thereby contributing to recycling and reducing environmental impact. This measure will make visible to all actors in the supply chain the costs associated with waste management.
Below are some technical aspects impacted by this new regulation that need to be reviewed by companies affected by these requirements:
- Data: Companies must register new data to define packaging types, the materials they are made of, and assign a cost to each material based on the information provided by the SCRAP system the company works with. These data will be included in new maintenance records, and templates can be used to facilitate this process.
- Invoice templates: Customized invoice templates must be updated to include new fields for printing waste management costs (SCRAP).
- Invoice accounting processes: Accounting templates and SPLs (if customized) must be updated to incorporate new types of accounting lines (pc_enlace_fin) that reflect waste management costs in invoices.
- Process customization (optional): Packaging materials used for delivering goods are recorded through item lines on sales delivery notes. In some cases, it may be necessary to implement customizations that simplify the entry of these lines at the time of shipment.
If your company operates in one of the affected sectors, it must itemize the economic contribution to SCRAP on its invoices starting from the indicated date.
Distributors of pre-packaged products who repackage them in any way must register with the RPP (Packaging Producer Registry). This is because when products are packaged for transport (in boxes, pallets, film, etc.), they are considered packagers and therefore producers. This involves meeting information and recycling obligations for the packaging materials used.
