Spain's Packaging EPR on Amazon.es

In brief: Spain's packaging law requires anyone selling packaged goods to Spanish customers to meet EPR (extended producer responsibility) obligations. In October 2023 Amazon told sellers not established in Spain to prove compliance by submitting a packaging registration number (ERN, Número de Registro) by 31 December 2023. Without one, Amazon enrols you in Pay on Behalf: it reports and pays the eco-contributions on your Amazon.es sales from 2023 and deducts them from your seller account, along with a service fee. Two days later Amazon opened its paid EPR Services for Spain and Austria, with fees from €768 (Spain) and €580 (Austria).

Your options under Amazon Spain EPR

Situation	What to do
You're the producer	Register with Spain's environment ministry (MITECO) and submit your own ERN
You're a reseller	Get the ERN from the packaging producer upstream, submit it and confirm you're not the producer (required from March 2024)
You do nothing	Pay on Behalf: Amazon pays eco-contributions and deducts them plus a service fee
You want help	EPR Services on Amazon, from €768 in Spain or €580 in Austria

Pay on Behalf covers reporting and payment only — other duties such as waste prevention plans stay with you. Resellers had until 31 December 2024 to submit a valid ERN and the not-the-producer confirmation.

A worked example

A UK seller with €60,000 of Amazon.es sales a year has no Spanish ERN. Amazon enrols them in Pay on Behalf and deducts the eco-contributions on those sales plus its service fee. Eco-contributions are payable whichever route they choose, so the real comparison is Amazon's service fee against the cost of registering directly or using EPR Services (from €768) — worth reviewing once a year.

What it means for your bookkeeping

• Pay on Behalf deductions are costs, not refunds. Post them to a compliance or EPR cost account so your Spanish margin is accurate.

• EPR Services fees are a separate supplier cost. Record them against the provider's invoice.

• VAT: take the treatment of eco-contributions and service fees from the invoice.

• Keep the paperwork. The ERN, confirmation and any Amazon statements support the costs if questioned later.

• Where it shows up. Pay on Behalf deductions reduce the payout — see reconciling an Amazon settlement and why a payout may not match Xero.

How TrueBooks helps

TrueBooks posts every settlement line to Xero and keeps each marketplace in its own currency, so euro-denominated deductions from Amazon.es are easy to find. It doesn't handle EPR registrations or payments. See the Amazon Xero integration.