FAQ

Frequently Asked Questions

Invoice contribution envelope

On the obligation for invoices issued by product producers for commercial transactions of packaged products placed on the market to identify the amount of the financial contribution paid by the producer to the ECOTIC ENVASES SCRAP .

What is the financial contribution paid by the producer to SCRAP?

The economic amount that the product producer pays to ECOTIC ENVASES SCRAP for the costs that it is obliged to assume according to its share of responsibility (the packaged products that the producer places on the domestic market – not including those exported outside Spanish territory).

Who are the parties obliged to comply with the obligation to indicate the amount of the financial contribution paid by the producer to SCRAP in the invoices issued for commercial transactions of packaged products?

Only the product producer has the legal obligation to indicate in the invoices issued for the commercial transactions of its packaged products, the amount of the contribution paid to the SCRAP of ECOTIC ENVASES.

The following operators in the distribution chain of the packaged product do not have this obligation (it is voluntary).

Does the obligation to indicate the amount of the financial contribution paid by the producer to SCRAP on invoices issued for commercial transactions of packaged products apply to all packaging?

Yes, it applies to all packaging regardless of its category (domestic, commercial or industrial).

Should the producer's contribution to SCRAP be passed on throughout the distribution chain of the packaged product?

Only to packaging of products subject to the Food Chain Law (agricultural or food products, for which the contribution paid to SCRAP should be passed on to the consumer). to throughout the distribution chain of the product, from its placing on the market to its sale to the consumer or end user, as it constitutes an effective cost of production. effective cost of production.

Although there are two plausible interpretations of Article 23.5 of Royal Decree 1055/2022 of 27 December on packaging and packaging waste:

It applies to all packaged products, since it is understood that the reference to the Chain Law is for the sole purpose of applying the concept of effective production cost to any distribution chain.
It only applies to packaging of products subject to the Food Chain Law (agricultural or food products), because the reference to the Law must be understood in the strict sense of applying to this chain. This is the most literal interpretation of the regulation and therefore, the legally safest.

In what documentation should the SCRAP contribution be included?

Only on product invoices (not on other commercial documentation).

It is only mandatory for invoices with domestic destination.

Should the contribution paid to SCRAP be shown separately and independently from the other items on the invoice?

Yes, it must be stated separately and independently from the rest of the invoice items. It must not be included in the unit price.

Example:

CORRECT

Article	Quantity	Unit Price
Product A	2	200 €
Contribution SCRAP ECOTIC ENVASES		50 €

INCORRECT

Article	Quantity	Unit Price
Product A	2	250 €

Where on the invoice should the contribution paid to SCRAP be stated?

Together with the rest of the invoice items, on a separate line.

Example:

Article	Quantity	Unit Price	VAT	TOTAL
Product A	1	200 €	21%	242
Product B	1	300 €	21%	363
Contribution SCRAP ECOTIC ENVASES		100 €	21%	121
TOTAL				726

CORRECT

Article	Quantity	Unit Price	VAT	TOTAL
Product A	1	200 €	21%	242
Product B	1	300 €	21%	363
TOTAL				605

Contribution SCRAP ECOTIC ENVASES: 121 €.

INCORRECT

Should the amount to be indicated on the invoice correspond to the contribution paid by the producer to SCRAP for the specific packaged products that are the subject of the commercial transaction?

Yes, it is mandatory to indicate on the invoice the contribution paid to SCRAP for the specific packaged products that are the object of the commercial transaction in question.

IS NOT CORRECT:

Indicate an amount that does not refer to the packaged products that are the subject of the invoices;
Indicate only the total annual contribution paid to SCRAP;
Only indicate on the invoices the rate approved by SCRAP (€/weight), without detailing the specific amount of the financial contribution for the same.
Include the information related to the contribution in digital format (QR, redirection to web pages, etc.).

Should the amount to be indicated on the invoice for the SCRAP contribution be itemized for each packaged product?

It is not mandatory that the contribution paid by the producer to SCRAP in the invoice be itemized for each packaged product. The producer may (optional) transfer to customers, if required, the data on the contribution in the invoice broken down product by product.

Example:

Example:

MANDATORY

Article	Quantity	Unit Price	VAT	TOTAL
Product A	1	200 €	21%	242
Product B	1	300 €	21%	363
Contribution SCRAP ECOTIC ENVASES		100 €	21%	121
TOTAL				726

VOLUNTEER

Article	Quantity	Unit Price	VAT	TOTAL
Product A	1	200 €	21%	242
Contribution SCRAP ECOTIC ENVASES		50 €	21%	60,5
Product B	1	300 €	21%	363
Contribution SCRAP ECOTIC ENVASES		50 €	21%	60,5
TOTAL				726

Should the amount to be indicated on the invoice for the SCRAP contribution be broken down by packaging material?

It is not mandatory that the contribution in the invoice be itemized according to the packaging material.

Example:

Example:

MANDATORY

Article	Quantity	Unit Price	VAT	TOTAL
Product A	1	200 €	21%	242
Product B	1	300 €	21%	363
Contribution SCRAP ECOTIC ENVASES		100 €	21%	121
TOTAL				726

VOLUNTEER

Article	Quantity	Unit Price	VAT	TOTAL
Product A	1	200 €	21%	242
Product B	1	300 €	21%	363
Contribution SCRAP ECOTIC ENVASES Plastic		50 €	21%	60,5
Contribution SCRAP ECOTIC ENVASES Aluminum		50 €	21%	60,5
TOTAL				726

How can the SCRAP contribution paid for the products invoiced be calculated?

Applying a system that makes it possible to obtain the individualized contribution for the containers that are the object of the commercial transaction.

Example: multiply the total weight of the containers – by material – covered by the transaction, by the rate approved by SCRAP for the current fiscal year for that type of container (€/weight).

Case:

Packaging subject of the transaction: 5 commercial cartons.
Weight 5 commercial cartons: 1 kg.
Tariff 2025 cardboard material -carton box-: 0.02 €/kg of package
Financial contribution to SCRAP for 5 commercial cartons subject to the commercial transaction: €0.02.

Is the financial contribution to SCRAP invoiced with VAT?

Yes, the financial contribution to SCRAP on the invoice is subject to VAT. It is subject to the same tax rate to which the packaged product that is the subject of the transaction is subject.

Example:

Example:

CORRECT

Article	Quantity	Unit Price	VAT	TOTAL
Product A	1	200 €	21%	242
Product B	1	300 €	21%	363
Contribution SCRAP ECOTIC ENVASES		100 €	21%	121
TOTAL				726

INCORRECT

Article	Quantity	Unit Price	VAT	TOTAL
Product A	1	200 €	21%	242
Product B	1	300 €	21%	363
Contribution SCRAP ECOTIC ENVASES		100 €	-	-
TOTAL				605

From what point onwards is it mandatory to reflect the amount paid to SCRAP on the invoices?

Since joining SCRAP (regardless of whether or not the SCRAP contribution has actually been paid, in accordance with the billing schedule agreed in the Subscription Agreement).

About labeling and marking

Do the labeling and marking obligations provided for in Article 13 of the Royal Decree on Packaging and Packaging Waste apply to all packaging?

No, there are obligations that only apply to household household packaging (not commercial or industrial): indicate on the packaging the fraction or container in which the packaging must be deposited once it becomes waste (it is not indicated whether it must be shown in color or in black or white).

There are also obligations that only apply to reusable packaging (include the DRS membership symbol), or to compostable plastic packaging, or to service packaging.

NoteECOTIC ENVASES has decided not to include an identification symbol on single-use containers placed on the market by producers adhered to SCRAP, as it understands that the inclusion of a symbol of this nature could entail an additional cost and effort that would be unnecessary for producers and, in turn, for container manufacturers.

How should labeling and marking be reflected on packaging?

The containers must bear the markings:

On the container itself
Right on the package label

The markings should be:

Clearly visible
Easily readable
They should have adequate persistence and durability, even after opening the container.

The Royal Decree on Packaging and Packaging Waste does not detail nor does it specify how these guidelines should be complied with.

MITERD has not issued any Note offering technical guidelines to help the affected parties to comply with these rules.

Thus, there is freedom in the way containers are labeled, while complying with the above-mentioned guidelines.

From when does the new labeling and marking regime have to be complied with?

Packaging manufactured as of January 1, 2025 must comply with the new labeling and marking regime provided for in the Royal Decree on Packaging and Packaging Waste.

There are two possible plausible interpretations of the standard for containers that were or are manufactured before January 1, 2025, and have not been placed on the market prior to that date:

They are subject to the labeling and marking regime provided for in the Royal Decree. Therefore, all the stock existing at that moment should be adapted prior to its commercialization, in case it does not already comply with the new regime.
They are not subject to the labeling and marking regime provided for in the Royal Decree. Therefore, all the stock existing at that time could be marketed without having to adapt to the new regime.

Will the labeling and marking regime provided for in the Royal Decree on Packaging and Packaging Waste be modified by the future European Packaging and Packaging Waste Regulation?

In early 2025, the new European Packaging and Packaging Waste Regulation is expected to be approved, which establishes more ambitious guidelines for labeling and marking of packaging, promoting the mandatory use of digital mechanisms.

The application of the European Regulation will not be immediate (an adaptation period of more than one (1) year is foreseen).

NoteECOTIC ENVASES will organize in the coming months a specific Webinar to analyze the most relevant innovations introduced by the new European Regulation on Packaging and Packaging Waste, which will address the new labeling and marking obligations.

RPP envelope number on invoice

On the obligation for the producer’s registration number in the Register of Product Producers to appear on invoices and any other documentation accompanying commercial transactions of packaged products from their placing on the market to the points of sale of the goods/products to consumers or to the end user.

Which party is required to register in the Register of Product Producers?

General ruleThe “product producer” is obliged to register in the Register. A single registration number is assigned for all packaging, without distinguishing between categories (household, commercial or industrial).

Special rules:

Service packaging and in articles 35.3 and 41.3 of Royal Decree 1055/2022, of December 27, when producers introduce into the market service packaging and less than 50,000 kg of commercial and industrial packaging: the manufacturers, importers or purchasers of this packaging, or the distribution companies of the service packaging, will be obliged to register in the Register in a unique way for all of them.
Producers established outside Spain: their authorized representatives shall be registered in the Register.

NoteSCRAPs are not registered in the Register of Product Producers.

Does the obligation to indicate the producer's registration number in the Register on the documentation accompanying commercial transactions of packaged products apply to all packaging?

Yes, it applies to all packaging, regardless of its category (domestic, commercial or industrial).

Which parties must comply with the obligation to indicate the producer's registration number in the Register of Product Producers on the commercial documentation of packaged products?

A. The product producerA. The product producer: with respect to the commercial documents he issues for the placing on the domestic market of the packaged products.
B. The following subjects in the distribution chainCommercial documents issued on packaged products placed on the market by the producer of the product, in the various transactions that take place until their sale to the consumer (domestic packaging) or end user (commercial and industrial packaging). They must “copy” the registration number that appears on the invoice of the previous commercial transaction for the product in question.

Case 1A packer (product producer) issues an invoice for packaged products to a distributor 1, who in turn issues an invoice to another distributor 2. Both in the invoices issued by the packer to distributor 1 and in the invoices issued by distributor 1 to distributor 2, it will be necessary to specify the registration number of the product producer in the Register.

Case 2Distributor 1 issues an invoice to distributor 2 for an order containing products from two different packers. The invoice must show the registration numbers of the two packers, listing each packaged product with the registration number of its respective producer.

On which documents must the product producer's registration number appear in the Register of Product Producers?

Invoices
Delivery notes
Delivery notes
Purchase orders
Any other commercial documentation on the product

The number must appear on all commercial documentation issued in the domestic market in commercial transactions involving packaged products (from the time they are placed on the market until they are sold to the consumer or end user).

How should the registration number of the product producer be indicated in the commercial documentation of the packaged product?

The chosen format (free) must allow easy legibility and identification of the registration number.

Example:

“Product Producer Registration” followed by the registration number (ENV/YEAR REGISTRATION/XXXXXXXXXXXXX).

From what moment is it mandatory to indicate the registration number on the commercial documentation of packaged products placed on the Spanish market?

It is mandatory as of March 29, 2023.