Containers Declaration for Foreign Companies

If your company sells directly to consumers in Spain, you must adhere to Ecoembes and declare the product containers you put in the market. 

Here we detail the terms and conditions and the different situations when it comes to applying the regulations. 

Is your company in Europe?

In this case, you must voluntarily declare the product containers you sell to Spanish distributors, except for distribution brands and any other brand of which Spanish clients are owners or licensees. Your Spanish clients should declare the containers. 

If the Spanish clients declares the products directly to Ecoembes, the European suppliers do not need to declare the amounts. And the sole declaration must group all the data from these clients. 

When to fill in the Appendix for Foreign Companies

The legal responsibility of declaring the containers falls on the Spanish importers. But, if on an exceptional basis, the importer agrees with its foreign supplier that it is the latter who declares the containers, the importer should inform Ecoembes in this regard. 

Therefore, every year, the foreign supplier adhered to Ecoembes should fill in the Appendix for Foreign companies, included in the Annual Containers Declaration, identifying the clients under whose name and behalf is declaring the containers and the brand subject to the declaration. 

Cases in which you do not have to request adhesion to Ecoembes

There are two cases: 

  1. When there are subsidiary companies or entities in the same group in Spain that have the status of packager for the purposes of the Containers Act (Ley de envases). This is, when these subsidiary companies trade products supplied by the foreign company. In this case, it would be the Spanish company the one adhering to Ecoembes. 

  2. When product containers of distribution brands or any other brand belong to their Spanish clients. In this case, it would be the Spanish client the one that would have to adhere to Ecoembes.