According to food compliance expert Martín Salcedo, from Madrid-based consultancy LegaleGo, the platform has started to take a hardline approach to the requirement for a RAP (translated to ‘Extended Producer Responsibility’) number, catching many vendors off guard.
The RAP number is the official code that certifies a company has fulfilled its packaging waste management obligations in Spain.
The obligation for sellers to have a number has been in force since 2022 but Salcedo said many vendors who have been selling on the platform for several years have only received notification in recent months.
“The obligation is not new,” he said. “It has been in place since Royal Decree 1055/2022, of 27 December. What changed is that Amazon decided to start verifying compliance. In doing so, it turned a regulatory risk that many companies had been ignoring into a commercial problem with immediate consequences.”
The consequences of non-compliance include: Immediate listing blocks, account suspension or restrictions, and administrative fines ranging from €2,000 to over €100,000 depending on sales volumes.
Amazon taking role of ‘regulatory enforcement agent’
“Amazon has access to the Producer Register held by Spain’s Ministry for Ecological Transition. It can verify in real time whether a RAP number is valid. And it has decided to do this systematically because Article 2(t) of Royal Decree 1055/2022 could make it subsidiarily liable for its sellers’ non-compliance. By enforcing RAP number verification, Amazon shifts that risk to where it belongs: the producer.”
This brings the Spanish site in line with other European territories. German sellers require a LUCID number to sell on Amazon.de, while the French require an IDU for Amazon.fr, and Amazon.it recently rolled out category-by-category verification in Italy.
Salcedo noted that it is common for sellers from these other territories to assume their home-country registration number covers Spain.
“These numbers are not interchangeable with the Spanish RAP number,” he clarified. “This obligation arises in the country where the end consumer is located, not where the company is based.”
He added that there is also no volume threshold, so the obligation applies from the first unit sold.
Key steps for compliance
Complying with the RAP number requirement involves two steps – enrollment with a collective extended producer responsibility system and registration with the producer register.
Instead of acting alone, businesses join a Producer Responsibility Organization (PRO) to pool fees, fund local recycling programs, and meet national environmental target.
ECOEMBES is the most widely used PRO for domestic and commercial packaging, though other authorized systems exist and the annual fee is proportional to the weight and type of packaging placed on the market.
Importantly, if the company has been selling prior to enrollment, regularization will start from when the company began trading, pushing up fees considerably.
“We have seen cases where the retroactive liability quadrupled what the company expected to pay,” said Salcedo. This is where administrative fees can reach in excess of €100,000.
However, he noted some PROs will allow phased payment plans for historic non-compliance rather than requiring a lump sum for all prior years at once.
Additionally, for companies without a tax presence in Spain, a Spanish tax identification number (NIF) is required before they can begin the ECOEMBES enrollment process.
Once enrollment in the collective system has been confirmed, the company can register with the Ministry for Ecological Transition’s Producer Register. On completion, it will receive a RAP number.
Registered producers must then submit an annual declaration of packaging placed on the market before March 31 each year.
Salcedo advised that if the cost of the fees genuinely can’t be resolved, the responsible interim step is to pause the affected listings, rather than risk fines.
Obligation harmonized under PPWR
The new European Packaging and Packaging Waste Regulation (PPWR) will harmonize this framework across Europe from 12 August 2026.
It will additionally introduce new obligations, notably: a mandatory EU Declaration of Conformity for all packaging, a ban on PFAS in food contact materials, a 50% empty space limit in packages, and eco-modulated fees based on recyclability.
This will not eliminate national registers - registration in each Member State where products are sold will remain necessary.
