Packaging artwork in Spain

Disclaimer: This document provides guidance and is not a legally binding interpretation and shall therefore not be relied upon as legal advice.

Spanish Royal Decrees

The Royal Decree 1055/2022 on Packaging and Packaging Waste, approved by the Council of Ministers on 27 December 2022, transposes Directive (EU) 2018/852 into Spanish national law and replaces the previous Act 11/97.

The packaging labelling of Royal Decree 1055/2022, Article 13 will be mandatory from January 1, 2025.

The previous voluntary labelling becomes mandatory, and new pictograms will indicate which disposal bins are for household packaging materials such as plastic, metal, paper, compostable packaging, and glass. For packaging made of different materials that can be easily separated, this must be specified for each component individually.

Four disposal symbols

Producer Responsibility Organisation Ecoembes published a comprehensive user manual for companies to guide them on providing the symbols and information.

Regarding the non-compliance of mandatory packaging labelling, no detailed information on penalties has been provided. However, Article 54 of the Royal Decree 1055/2022 mentions that violations will be sanctioned according to Law 7/2022 on Waste and Contaminated Land, Law 21/1992 on Industry, and Legislative Decree 1/2007 on Consumer and User Protection. In the event of non-compliance with packaging labelling regulations, Article 109 of Law 7/2022 is likely to be the relevant legislation, as it directly governs waste management and the corresponding labelling obligations.

The latest EU Packaging and Packaging Waste Regulation ‘PPWR” (EU) 2025/40 introduces new harmonised labelling requirements for all Member States replacing national rules in the (near) future.

 

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