Recycling packaging is, since January 1, 2025, the task of whoever produces it. This is dictated by the so-called extended producer responsibility (EPR), a rule that emanates from Royal Decree 1055/2022 and that obliges the companies that manufacture them to finance their management and account for their recovery. But joining does not mean ignoring the process.
He has stated that joining a SCRAP and paying the fee is not equivalent to complying with the law or the RAP. What direct surveillance actions should companies take to ensure that their packaging is collected and recycled operationally?
Membership is the first step, but responsibility really begins from there. I would recommend three very specific verifications to companies. First of all, let them check that they are declaring correctly: categories, materials, weights and channels. Without correct marketing data, compliance is weakened at the source. Next, ask for evidence, that is, auditable collection and recycling data, not just reports. Finally, they check the real capacity in the territory through agreements with administrations and operational operations. In short, they demand measurable results, not promises.
That said, we must keep in mind that regulations are complex, evolve and not all companies have the same resources, especially SMEs. Precisely for this reason, the SCRAP must help convert that complexity into practical and verifiable compliance.
Do you detect companies in the sector that assume the Green Point or the management fee as a simple “license to operate” without getting involved in the results?
What we detected, above all, is that many companies have a hard time landing the obligation: going from “I have to comply” to “what do I have to change in my packaging, in my data and in my processes.” That is where a SCRAP must provide clarity and ability to execute.
It is true that there is a risk that some will understand the contribution as a “license”. And RAP doesn’t work like that. The producer remains co-responsible and has to get involved: declare well, finance adequately, demand traceability and support the improvement of the system.
With the emergence of new systems, it is key that governance between producers and SCRAPs be consolidated. This translates into more shared criteria, more transparency and more clarity about what evidence needs to be provided and how.
The good news is that there is increasing awareness that circularity not only affects reputation, but is already a competitive factor, and that pushes companies to get more involved.
In 2025, Ecoembes allocates more than 800 million euros to finance the collection and recycling of 1.3 million tons of packaging in coordination with the public sector. How do you guarantee that this item accurately covers the costs that administrations determine by law?
The key is that RAP in packaging is articulated with agreements: there the operational needs, service standards and associated costs are defined. For the system to be solid, there must be methodology, traceability and verification.
At Ecoembes we work with administrations and operators so that financing is linked to the reality of the service: collection, transport, classification, treatment and control. And, in addition, we accompany it with verifiable data and public reports, because the credibility of the system depends on whether it can be explained and audited.
Currently, nine autonomous communities have agreements adapted to the new regulatory requirements. What is the planned schedule and what are the main obstacles to closing the agreements in the remaining communities?
We are moving forward progressively because adapting agreements is not just updating a text. It involves aligning responsibilities, operations, efficient costs, indicators, control and traceability with higher demands.
The main obstacle is usually precisely that: homogenizing criteria and closing a framework that is rigorous, but also applicable, because we are talking about services that are provided in very different territorial realities.
What role should Public Administrations play to supervise that each SCRAP provides the exact financing that corresponds to the producers it represents?
A fundamental role. The administration is the guarantor that the RAP fulfills its purpose: that the system works and that the costs are where they should be. In this sense, public supervision is key to ensuring three aspects. Firstly, each SCRAP provides the financing that corresponds to “its” producers; secondly, to require auditable data and comparable methodology and, finally, to avoid competition between systems at the cost of weakening compliance.
Royal Decree 1055/2022 contemplates ecomodulation criteria with bonuses for recyclable packaging and penalties for those that are less recyclable. To which R&D projects or specific studies is Ecoembes reincorporating the funds collected from these penalties?
Ecomodulation has a very practical objective: moving packaging design towards more circular solutions. For it to work, companies need technical criteria and tools that allow them to apply concrete improvements in the design.
At Ecoembes we ground it in tools and technical capabilities. For example, strengthening services such as CircularCheck, which helps assess recyclability and identify design improvements, and the work of TheCircularLab, where solutions, methodologies and pilots are tested to anticipate technical requirements and improve recovery and quality.
The focus is clear: that the penalty is not just a cost, but an incentive to reduce material, simplify, improve recyclability and increase the quality of the recovered material.
In light of the recent entry into force of Regulation (EU) 2025/40 (PPWR), what immediate operational changes will packagers, importers and e-commerce companies have to make to comply with the new definitions of manufacturer and producer?
From an operational point of view, it requires three issues to be sorted out. First, establish the roles and responsibilities of manufacturer, producer, importer and distributor. The main novelty is that whoever holds the brand assumes the technical conformity of the packaging, even if they do not physically manufacture it.
Second, the importance of data: more precision in marketing, materials, formats and traceability; Without that, compliance cannot be demonstrated.
And third, focus on design: changes will have to be prioritized to ensure real recyclability and meet deadlines. For e-commerce and distribution, it also involves reviewing packaging, oversizing and consistency of labeling and consumer information.