Control Procedures: Report on agreed-upon procedures

What is their purpose?

These control mechanisms' aim is to confirm:

  • The quality of the information we will eventually be required to provide to the public administrations and other organisations to which we owe an obligation of disclosure.

  • That all Ecoembes member companies uphold their legal obligations.

  • That the number of packaged goods they sell on the market directly relates to their contribution.

What must you, as a business, do?

According to the Membership Agreement, by May 31 of each fiscal year, all businesses who are legally required to audit their annual financial statements must submit an agreed-upon procedures report that examines Clause 11 (a) of the annual packaging declaration.

However, in order to lessen the impact that the current financial crisis is having on a significant part of the business fabric, the Ecoembes Board exempts from submitting the Agreed-Upon Procedures Report those companies whose declaration is less than €5,000 (increasing the exemption limit previously established at €3,500). Additionally, the board stipulates that the last report submitted without incidents validates a declaration of less than that amount.

Regardless of the requirement to submit the Agreed Procedures Report, Ecoembes may employ auditing methods of its choosing to check the records supporting the total quantity of packaging placed on the market (Clause 11 c).

Due to this, all member companies are required to maintain the records necessary to calculate the Annual Packaging Declaration for the last four years and make them accessible to any auditing methods that Ecoembes may deem necessary (Clause 11 (b)).

Through the following links, you will be able to access the technical area of ICJCE and REA Auditors where the models of agreed-upon procedures reports are located, both for the Ordinary Declaration and the Simplified Declaration of Packaging by ECOEMBES:

Revision of the regulations



The Spanish Institute of Chartered Accountants and the Registry of Audit Economists have discussed the standards for the creation of this report with the auditing companies.

The following are the reports' significant novelties:

  • We have made the report models simpler.

  • To make your assessment faster, we provide a questionnaire of prior information with the Audit Companies, which you may access through the Companies Portal.

  • According to the total number of formats stated, we adjusted the number of formats to be assessed, assuming 1% of the formats (the maximum number of formats to be reviewed being 200).

  • When the time of the Annual Accounts and the period of the Annual Declaration overlap, we eliminated the review of the cut-off of operations.

Basis Documentation

  • Membership Agreement (Ordinary) Clauses 9 and 11.

  • The Annual Packaging Declaration, provided by the Member Company, detailing the packaging that was placed on the market between 1 January and 31 December of the corresponding year.

  • Report Model on the Limited Review of Ordinary Annual Packaging Declarations.

  • Royal Decree 1055/2022 of 27 December, on packaging and packaging waste.

  • Law 7/2022, of April 8, 2022, of waste and contaminated soil for a circular economy.