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Are you a Producer?

Are you a Producer?

Electronic recycling cycle

Are you a Producer?

Article 2 of RD 1055/2022, of December 27, on packaging and packaging waste. Section t) establishes the condition of PRODUCER of packaging and packaging waste for packers or economic agents dedicated to the importation or acquisition in other Member States of the European Union of packaged products for placing on the market, including electronic commerce platforms.

Who is a Battery Producer?

Article 2 of RD 1055, of December 27, on packaging and packaging waste. Section t) establishes the condition of PRODUCER of packaging and packaging waste for packers or economic agents dedicated to importing or acquiring them in other States. members of the European Union of packaged products to be placed on the market, including electronic commerce platforms.

Quarterly Communications

The companies that produce packaging and packaging waste, once they have obtained the producer number from the Ministry of Ecological Transition and Demographic Challenge, must send the pertinent communications (units and Kilos) to SUN RE - PACK.

The data of said COMMUNICATION will be reported to SUN RE - PACK in the model provided by the association that will be easy to use and personalized for each Producer.

Once the communication has been made, our Association will ensure that this information is sent to the Ministry, as established by the Regulations.

At the end of the process, the Producer company will receive an invoice according to the amount of containers placed on the market and the rates (Recycling Rate) established between the SUN RE-PACK Association and the company.

In this way, and according to the reporting period of the communications, the company must pay the amount of the invoice, which will be obtained by multiplying the Recycling Fee by the number of Kilos or units placed on the market by the company.

Other obligations

1 - Registration in the packaging section of the Register of Product Producers in accordance with Royal Decree 1055/2022, of December 27, on packaging and packaging waste.

2 - Manufacturers and importers or intra-community purchasers of empty containers or, where appropriate, importers or intra-community purchasers of packaged products, must have the documents and information that allow them to certify or demonstrate the conformity that the containers marketed or that are intended to be commercialize meet the basic requirements on the manufacture and composition of packaging and on the nature of reusable and recoverable packaging, including recyclables.

3 - The containers must be designed in such a way that throughout their entire life cycle their environmental impact and the generation of waste are reduced, both in their manufacture and in their subsequent use, and in a way that ensures that the recovery and elimination of the containers.

4 - Apply a five-year prevention and ecodesign business plan.

5 – Indicate the number of the container producer on the issued invoices.

6 - The company will indicate on the containers the accrediting recycling symbol provided by the SCRAP, warning in this way that it is registered in the Register of Producers.

How to Comply?: Adhesion Procedure

To adhere to the Collective System of Extended Producer Responsibility (SCRAP) SUN RE - BATTERY, the following procedure must be followed:
  1. ADHESION FORM     The company must complete the "Adhesion Form" that you will find on the web sunrebattery.eu. Once completed, SUN RE - BATTERY will check that the data is correct.
  2. CONTRACT     With the details of the Adhesion Form, SUNREUSE ASSOCIATION will prepare and send the Contract that must be signed by both parties.
  3. FORMALIZATION OF REGISTRATION     The SUN RE - BATTERY association will be in charge of registering The Integrated Industrial Registry of Battery and Accumulator Producers (RII-PYA) of the Ministry of Industry, Commerce and Tourism (MINCOTUR) ↓
Obtaining by assignment of the Ministry of the number RII-PYA


In the event that the company was already registered in another SCRAP and proceeds to join the SUN RE - BATTERY association, the PREVIOUS steps to follow would be the following:

The SUN RE - BATTERY association will be in charge of preparing the Deregistration Request in the old SCRAP.
  1. Registration in the SCRAP SUN RE - BATTERY with the aforementioned procedure.
  2. Communication to the Ministry of the change in SCRAP (during the last quarter of the year).

What we offer

Services that we provide



SUN RE - PACK provides consultancy regarding packaging regulations. 1. TAX on NON-REUSABLE PLASTIC PACKAGING The Tax on Non-reusable Plastic Containers is an indirect tax that falls on the use in Spanish territory of non-reusable containers that contain plastic, whether they are empty or containing, protecting, handling, distributing and presenting merchandise. 2. PACKAGING AND PACKAGING WASTE RD 1055/2022, of December 27 Purpose: to establish the legal regime applicable to packaging and packaging waste with the aim of preventing and reducing its impact on the environment throughout its entire life cycle. WHO IS A PACKAGING PRODUCER? • Packers or economic agents dedicated to the importation or acquisition in other Member States of the European Union of packaged products for their placing on the market. • When, in the packaged products placed on the market through distribution brands, the producer of the product is not identified, the owner of the distribution brand based in Spain under which the product is marketed will act as such. • In the same way, in the case of those products packaged at the request of a third party that acts as the person in charge of placing them on the market, the latter will act as a producer of the product. • When packaged products from outside Spain are placed on the market through electronic commerce platforms and the producer has not designated an authorized representative in accordance with the provisions of article 17.2, said platform will act, secondarily, as a producer of the product. for the purposes of financial and information obligations, as well as organizational when appropriate, regulated in this royal decree, with respect to those containers.