WEEE registration in Spain for non-EU sellers (RAEE, Registro Integrado Industrial)

If you sell electrical or electronic equipment (AEE) from outside Spain straight to buyers in Spain, Spain treats you as the producer (art. 3(h) 4.º). You register in the Registro Integrado Industrial through an authorised representative established in Spain, after you have joined a collective scheme or set up an individual one. Registration is free and gives you a number. Until you have it you may not sell, and the SOIVRE inspection service checks it before the goods are released (Real Decreto 993/2022). This page is only what Spain adds to the EU WEEE rule. The other Spanish rules are on the Selling in Spain as a non-EU company page.

Spain makes a distance seller from abroad the producer

Real Decreto 110/2015 defines the producer as anyone who, whatever the selling technique, sells AEE by distance communication directly to private households or to professional users in Spain, and is established in another EU state or in a third country. The text names no place the parcel leaves from, and professional buyers count as much as households. Spain sorts equipment into seven categories, with large photovoltaic panels as a seventh of their own (annex III).

If you sell to a distributor in Spain instead, and you have no representative there, the ministry says the distributor is the producer (ministry guide, section 4). A distributor may sell only equipment whose producer has a register number (art. 11(1)).

Appoint a representative in Spain

Appoint a person or company established in Spain, by written power of attorney, and register through it. The ministry’s registration guide says a producer with no seat in Spain registers through an authorised representative, and its producer guide says that for distance sales this is compulsory whether you sit in another EU state or in a third country (ministry guide, section 4; registration guide, section 3). A company with no seat but with a Spanish non-resident tax number registers through a representative as well (register FAQ). MITECO’s FAQ says a distance seller in a third country must appoint an authorised representative in Spain (question 4.4), and that having one is “indispensable and mandatory” (question 5.1) (MITECO FAQ).

• The representative takes over your producer duties in Spain: registering, declaring, and organising and financing the waste through a scheme.
• One representative may act for several producers, if it accounts for each one’s obligations separately (register FAQ; ministry guide, section 4).
• A collective scheme cannot be your representative. The representative is the producer for every duty, and it represents you inside the scheme (MITECO FAQ, question 5.2).
• The decree asks for a written power of attorney and sets no language or minimum term (art. 3(j)).

The registration decree itself (Real Decreto 110/2015) names a representative only for a seller established in another EU state (art. 3(j)), as the Directive’s Art. 17(2) does. Directive Art. 16(1) adds that a distance seller under Art. 3(1)(f)(iv)Directive 2012/19/EU, Waste Electrical and Electronic Equipment DirectiveArticle 3, paragraph 1, point (f), point (iv)Click opens the article on EUR-Lex. that is not registered in the state it sells to “shall be registered through their authorised representatives as referred to in Article 17(2)Directive 2012/19/EU, Waste Electrical and Electronic Equipment DirectiveThe whole regulationClick opens the law on the EU Publications Office.”. Whether that reaches a seller in a third country is read two ways. MITECO’s FAQ (question 5.1) reads it as covering third-country sellers, who must be registered where they sell, directly or through a representative. The EU WEEE guide reads it as covering EU sellers only, because it points back to Art. 17(2)Directive 2012/19/EU, Waste Electrical and Electronic Equipment DirectiveThe whole regulationClick opens the law on the EU Publications Office.. The one statute text read that names a representative duty for an importer not established in Spain is the last sentence of art. 5(3) of Real Decreto 993/2022, the import-control decree: “En caso de que el importador no esté establecido en España deberá nombrar un representante autorizado obligatoriamente” (an importer not established in Spain must appoint an authorised representative). Art. 4(2) gives the importer the producer status of art. 3(h) 3.º and 4.º of the registration decree. The scope is not stated: that decree defines no importer of its own, Real Decreto 219/2013 art. 3(9) defines one as established in the EU, and the text does not say whether a seller outside the EU that sells to buyers in Spain is the importer meant. Ley 7/2022 art. 40 says foreign producers “may” designate one. The register’s own guides apply the duty to a seller in a third country, and this is the rule the register works to. The role is explained in EPR authorised representative.

The register is the RII-AEE, and the planned move has not shown up in the texts

A WEEE producer registers today in the electrical-equipment section of the Registro Integrado Industrial, run by the Ministry of Industry and Tourism (art. 8(1); ministry page). The producer form on that site was open on 5 October 2026 (form).

Ley 7/2022 additional provision 12 says that within three years of its entry into force the electrical-equipment and battery sections of the Registro Integrado Industrial are to become sections of the Registro de Productores de Producto, and that the law’s references to the latter also mean the former “during this transitional period”. The law came into force on 10 April 2022, so the three years ended on 10 April 2025. Here is what the texts read show:

• The consolidated Real Decreto 110/2015, last updated on 1 April 2022, still names the Registro Integrado Industrial in art. 8. No later act that changes it turned up.
• MITECO’s page on the Registro de Productores de Producto lists four sections: packaging, plastic bags, replacement tyres and tobacco products with filters (MITECO). Electrical equipment is not among them.
• The ministry’s registration pages and form still send producers to the RII-AEE.

So the move had not happened in the texts read on 5 October 2026, and none gives a date. If it does happen, the register’s name, form and number format may change. The decree names no transition rule for existing numbers.

The registration, in order

1. Sort your products by the seven categories and by household or professional use. The register has its own product codes (ministry guide, section 7).
2. Appoint your representative by written power of attorney.
3. Put an extended-producer-responsibility system in place first. Either join a collective scheme or communicate an individual system to the environment department of the autonomous community where your seat is (art. 39(1)). The register’s form lists twelve collective schemes: Ambilamp, Reinicia, Ecoasimelec, Ecoeche, Ecofimática, Eco-Raee’s, Ecotic, European Recycling Platform, Ecolec, Ecolum, Ecotic Clima and Sunreuse. The form asks for the scheme contract or the communication, and the application is not validated without one (form). A collective scheme can file for you if you agree it with the scheme (register FAQ).
4. File in the register, electronically, with the information of annex VI part 1: name and address of the producer and of the representative, tax identification number, category and type of equipment and whether it is household or professional, brand or company number, how you meet your producer duties and the financial guarantee, the selling technique, and a declaration that the information is true. A first-time registrant also gives an estimate of the weight and units it will place on the market that year. The form is in Spanish. Users identify through Cl@ve, a digital certificate, or a user name and password (form).
5. Receive your number. The register gives each producer, or its representative, an identification number (art. 8(2)), and tells a producer registering for the first time its estimated market share in the month after the month it registers (art. 8(7)(f)).

A producer may use one or several collective schemes, or an individual system for some products and schemes for others. The same product can be declared in only one system in a calendar year (register FAQ). A change of system is notified between 1 October and 31 December and takes effect on 1 January (ministry guide, section 9; register FAQ). Art. 8(3) words it as effective “from 31 December of the year of filing” (art. 8(3)).

The guarantee for household equipment

Producers of household equipment give a financial guarantee, valid for one year and then reviewed (art. 45). A producer in a collective scheme gives it through the scheme (art. 49(1)). The forms are an insurance policy with an insurer authorised to operate in Spain, a guarantee from a financial institution authorised to operate in Spain, a technical reserve fund, or the guarantees accepted under art. 96 of the public-contracts law (art. 46). The amount is 0.25 times the sum, over the categories and subcategories you sell, of your own annual minimum collection target for household WEEE, in kg or tonnes, times the average management cost per kg or tonne (annex XVII, part 2).

What it costs in Spain

• Registration: nothing. The ministry’s FAQ says registration in the RII-AEE is free (register FAQ).
• The waste: you finance the collection, transport and treatment of the household waste in proportion to your market share by category (art. 43). The register works out the share from your quarterly declarations and tells you before 31 January each year (art. 8(7)(d)). In a scheme you pay the scheme’s own contribution, and each scheme sets its own.
• The representative: its own price. No official figure exists.
• Audits: the register may order an audit of your declarations, at your cost (art. 8(5)).

Deadlines

The decree and the ministry pages read give no calendar day for the quarterly filing itself, only the 31 January close of the last quarter.

Your number goes on your sales page and your invoice

In a distance sale the producer shows its register number on the page or tool that supports the sale and on the invoice to the buyer (art. 9). Between a producer and a distributor the number goes on every invoice or commercial document. A buyer may ask a distributor for the producer’s number. If you sell as a distributor equipment that someone else produced, the number must be available on request (register FAQ).

The SOIVRE inspection service checks the number before the goods are released

Real Decreto 993/2022 puts imports of electrical and electronic equipment from third countries under a check before release into free circulation. The SOIVRE inspection service (Servicio Oficial de Inspección, Vigilancia y Regulación de las Exportaciones) of the trade directorates checks that the importer or its authorised representative is registered in the RII-AEE (art. 4(2)), and release is prohibited if the importer has not met the register duties (art. 4(4)). A missing registration number is a non-conformity that can be corrected, and release waits for proof of the correction (art. 9(3)). The registration number must be visible in the import documents, and the authorities designated under Real Decreto 330/2008 check it (art. 57(1)(b), as amended by Real Decreto 27/2021). The ministry’s guide, section 3, names the same inspection service. MITECO adds that the customs declaration must stay consistent with the data you send the register every quarter (MITECO note).

Take-back when you deliver

A seller that sells at a distance has the same take-back duty as a shop. When the buyer buys a new household appliance, it takes back, free of charge, an old appliance of an equivalent type, at the delivery point or at the buyer’s home (art. 22(1), (4)). There is no minimum sales area. If the old appliance is not handed over at the time of purchase, you say in writing how long the buyer has to hand it in, and not less than 30 calendar days. You give the carrier a collection slip for each delivery (art. 23(2)) and state the take-back on your sales website (art. 11(2)). The decree gives distributors no seat requirement, and a seller can be producer and distributor at once (art. 3(k)).

MITECO says the seller designs its own free collection and states it on its website. It can ask a collective scheme or an authorised waste manager to handle the waste it collects (MITECO FAQ, section 8). The separate duty to take back very small waste without a purchase falls only on distributors with at least 400 m2 of sales area for equipment (art. 22(2)). The EU rule is in the WEEE guide.

Marking and information

Spain follows the EU marking: the crossed-out bin (annex V) and a mark showing the equipment was placed on the market after 13 August 2005, to standard UNE-EN 50419, both visible, indelible and legible on each appliance (art. 7(1), (2)). Spain adds that the instructions must say that batteries are removed and handed in separately before the appliance is deposited (art. 7(3)). Producers may tell buyers, at purchase, what collection and treatment of waste cost them in the year, but that information is not part of the invoice or the receipt (art. 7(4)). The symbol is in the WEEE symbol guide.

If you sell through a marketplace

If a producer from another state or a third country acts through an e-commerce platform and is neither in the extended-producer-responsibility registers nor meeting the other duties of those regimes, the platform takes over, as producer, the financial, information and, where relevant, organisational duties. It may make one registration for all the products concerned and must keep a record of them (Ley 7/2022 art. 2(ac)). The platform’s number then goes on the page and the invoice for the products it covers (register FAQ). The law describes this as the platform filling a gap. Your own registration is the way to avoid it. The platform rule for packaging is a different one and is on the Selling in Spain as a non-EU company page.

What happens if you do nothing

You cannot sell. Spanish distributors may sell only equipment whose producer has a number, and the SOIVRE inspection service checks the registration before the goods are released. Two laws carry the fines. Ley 7/2022 applies on its own terms (art. 108(1)). Art. 59(4) of the decree sends breaches of the decree to Ley 21/1992 and three other laws, and still names Ley 22/2011, which Ley 7/2022 repealed:

Where one act is typed in several laws, the one with the heavier sanction applies (Ley 21/1992 art. 34(5)). Art. 109(1) of Ley 7/2022 applies all or some of the listed sanctions. Arts. 22 and 23 of Ley 21/1992 list company and establishment data and do not name WEEE declarations; applying the Ley 21/1992 rows to RII-AEE data is this page’s reading. The autonomous communities inspect and sanction in their field (Ley 7/2022 art. 12(4)). The register can also order an audit of your declarations, at your cost.

What the texts leave open

• Where a seller in a third country is named. Real Decreto 110/2015 (art. 3(j)) and Directive Art. 17(2) name a representative only for sellers in other EU states. Directive Art. 16(1) says a distance seller not registered where it sells is registered through its representatives as in Art. 17(2)Directive 2012/19/EU, Waste Electrical and Electronic Equipment DirectiveThe whole regulationClick opens the law on the EU Publications Office.. MITECO’s FAQ 5.1 reads this as covering third-country sellers; the EU WEEE guide reads it as covering EU sellers only. The last sentence of art. 5(3) of Real Decreto 993/2022, read with art. 4(2), says an importer not established in Spain must appoint an authorised representative; the text does not say whether a seller outside the EU that sells to buyers in Spain is that importer. The ministry’s guides and MITECO’s FAQ apply the duty to third-country sellers, and the register will not register a producer with no seat in Spain without one. Plan on a representative.
• Where the register will be. Ley 7/2022 additional provision 12 plans to move the RII-AEE into the Registro de Productores de Producto. No text read shows it done, and none gives a date.
• Which law fines you. Art. 59(4) of the decree still names Ley 22/2011, which Ley 7/2022 repealed, next to Ley 21/1992 and three other laws, and Ley 7/2022 applies on its own terms. No official page says which an authority applies to an unregistered distance seller. The Ley 21/1992 rows read “the data referred to in articles 22 and 23” as covering RII-AEE data; the articles do not name it.
• Whether the Registro de Productores de Productos duties reach the RII-AEE. Ley 7/2022 art. 108(3)(ac) (failing to register, to give the number or to send information) and art. 12(3)(g) (the ministry for the ecological transition’s power to inspect and sanction those registration and information duties) name the Registro de Productores de Productos. Additional provision 12 makes the law’s references to it also mean the RII-AEE “during this transitional period”, three years from 10 April 2022. No text read says whether they reach the RII-AEE after it.
• Who fines a seller with no seat. The texts name the competent administrations and divide the powers, and name no single body for this case.
• When the quarterly filing is due. No calendar day for the quarterly declaration was found.

What does not apply

• No volume or turnover threshold: you register whatever the volume.
• No registration fee at the register.
• A collective scheme is not your representative, and its contract does not replace the representative.
• A registration in another EU country does not count in Spain. A registration counts in its own country only (EU WEEE guide).
• Batteries inside your equipment have their own section of the same register: see the Selling in Spain as a non-EU company page.