23 July, 2026

Amazon Is Demanding the RAP Number. The Obligation Is Not New. What’s New Is That It Can No Longer Be Ignored.

For months we have been receiving queries that all start the same way: a seller receives a notification from Amazon demanding the RAP number Amazon Spain requires, has no idea what it is, and assumes it must be some new regulation that just came into force. In most cases, the company has been selling in Spain for two or three years without one.

The obligation is not new. 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.

That is the point we want to make clear by the end of this article.

Amazon Is No Longer Just a Marketplace. It Is Also a Regulatory Enforcement Agent.

Importantly, this is, in our view, the most important reading of what is happening — and the one that appears least often in the commentary circulating about the RAP number Amazon Spain issue.

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. Amazon shifts that risk to where it belongs: the producer.

It has documented this in its own Seller Central (you can read it here), and this is no longer a one-off check. It is an established compliance policy. Indeed, TikTok Shop and other platforms are following the same path.

Consequently, the same pattern is visible across Europe. Amazon.de has been blocking listings without a valid LUCID number in Germany for years. In France, Amazon.fr requires the IDU. Similarly, Amazon.it rolled out category-by-category verification between late 2025 and March 2026 in Italy. What Amazon is now doing in Spain is not unusual: it is the normalisation of a control mechanism that has already been operating in other markets.

In short, the practical conclusion is clear: anyone who wants to sell on the major European marketplaces will need to demonstrate environmental compliance, just as they demonstrate product compliance. This is a structural shift, not a one-off check.

The consequences of non-compliance are concrete: immediate listing blocks, account suspension or restrictions, and administrative fines ranging from €2,000 to over €100,000 depending on sales volume and repeat offences. Furthermore, there is also a risk few companies consider: customs authorities also have the power to verify the RAP number and hold goods at the border.

The Case That Illustrates What We See Most Often

A few months ago we received a query from a cosmetics company that had been selling on Amazon Spain for over two years. Correct product, compliant labelling, up-to-date technical file. No issues until the notification arrived.

What they did not know was that for all that time they had not been enrolled in any collective packaging waste management system and had no producer number with the Ministry. When we analysed the situation to regularise it, the retroactive liability to ECOEMBES for previous financial years exceeded what they had budgeted for the entire compliance process.

This is the most common pattern. Moreover, there is also a variant we see regularly: European companies — German, French, Italian — selling on Amazon.es who believe their home-country registration number covers Spain. It does not. The German LUCID number, the French IDU and the Italian CONAI number are not interchangeable with the Spanish RAP number. This obligation arises in the country where the end consumer is located, not where the company is based.

The Obligation Has Existed Since 2022, Not Since the PPWR

One of the first misconceptions we correct when a query arrives is the timeline.

The RAP number originates from Royal Decree 1055/2022, which repealed the old Packaging Act of 1997 and incorporated into Spanish law the requirements of the European Directive on packaging and packaging waste. As a result, the obligation to register and join a collective management system has been in force since then.

Amazon has not created any new obligation. It has decided to verify compliance with one that already existed. The new European Packaging and Packaging Waste Regulation — the PPWR (EU Regulation 2025/40) — will harmonise this framework across Europe from 12 August 2026, but that does not change the fact that the obligation in Spain has been in place for over two years.

What Is the RAP Number Amazon Spain and Who Is Required to Have One

The RAP number (Responsabilidad Ampliada del Productor — Extended Producer Responsibility) is the official code that certifies a company has fulfilled its packaging waste management obligations in Spain. Its format is ENV/YEAR/9 digits — for example, ENV/2026/123456789 — and it must appear on invoices and commercial documents. It is also the identifier Amazon verifies in its system.

In particular, on who is required to have one, the definition in the Royal Decree is deliberately broad. A company has producer status if it:

• Manufactures and markets packaged products under its own brand in Spain.
• Imports or purchases from other EU countries packaging or packaged products for distribution in Spain.
• Sells at a distance — through Amazon or any other channel — directly to end consumers in Spain.

That last point is the one that catches most companies off guard. If your company is based in Germany and sells on Amazon.es, you are a producer in Spain and you need the Spanish RAP number. There is no volume threshold: the obligation applies from the first unit sold.

Furthermore, the PPWR consolidates this logic and requires registration in each Member State where the company first places packaged product on the market. For companies with multi-country distribution, this means managing the Spanish RAP number, the German LUCID, the French IDU and the Italian CONAI or RENAP separately, because none of them is valid outside its own country.

The Two Obligations: Order and Retroactivity

Complying with the RAP number Amazon Spain requirement involves two separate steps, in this order:

Step 1 — Enrolment with ECOEMBES

The producer must join a Collective Extended Producer Responsibility System. ECOEMBES is the most widely used system for domestic and commercial packaging, though other authorised systems exist. The annual fee is proportional to the weight and type of packaging placed on the market.

However, there is one aspect few companies think about before starting the process: retroactivity. If the company has been selling for years without being enrolled, regularisation does not start from the enrolment date — it starts from when the company began trading. We have seen cases where the retroactive liability quadrupled what the company expected to pay. Calculating that figure before starting the process is essential.

Additionally, another requirement that causes problems for foreign companies: to begin the ECOEMBES enrolment process, a Spanish tax identification number (NIF) is required. Companies without a tax presence in Spain need to obtain one first.

Step 2 — Registration with the Producer Register

Once enrolment in the collective system has been confirmed, the company can register with the Ministry for Ecological Transition’s Producer Register. On completion, it receives the RAP number. Without this number, Amazon listings remain blocked even if the company has been enrolled with ECOEMBES for years. We have seen this error too: company correctly enrolled, no registration number, listings down.

Additionally, registered producers must submit an annual declaration of packaging placed on the market before 31 March each year.

What the PPWR Adds to the RAP Number Amazon Spain Framework from 12 August 2026

Specifically, EU Regulation 2025/40 enters into application on 12 August 2026 and, unlike the Directive it replaces, applies directly across all 27 Member States: no national transposition is required, and the same text applies throughout the EU. The most relevant obligations for companies working with packaging:

Mandatory EU Declaration of Conformity. No packaging may be placed on the market without a DoC confirming compliance with recyclability, recycled content, traceability and restrictions on hazardous substances requirements. Technical documentation must be retained for 5 to 10 years.

PFAS ban in food contact materials. A limit of 25 ppb for any individual PFAS and 250 ppb for the total. This directly affects paper cups with fluorinated coatings, pizza boxes, and fibre packaging with grease-barrier coatings. In addition, there is no transitional period for existing stock: from 12 August, non-compliant new units cannot be produced or placed on the market. And supplier self-declarations are not sufficient: accredited laboratory certificates are required per packaging type.

Eco-modulated fees based on recyclability. Contributions to the collective system will be calculated on the basis of an A–C recyclability rating: the less recyclable the packaging, the higher the contribution. This turns packaging design into a decision with direct financial consequences. Companies that audit their packaging portfolio now will be better positioned.

Registration in each Member State. Registration with the national register in each country where the company markets its products is also mandatory before 12 August 2026.

Authorised representative in each destination Member State. Article 45.3 of the PPWR requires anyone selling at a distance in a Member State other than where they are established to designate an authorised representative for EPR in each destination country — via a written mandate — with functions similar to those of a tax representative but in environmental matters.

Ongoing Legislative Process: Article 45.3

There is a piece of legislation worth knowing about because it is currently in motion: in December 2025, the European Commission submitted proposal COM(2025) 982, which would suspend the application of this article for EU-established producers until 1 January 2035. The stated rationale is to avoid the burden of designating a representative in up to 26 countries. However, the European Parliament’s report of May 2026 proposes restricting that exemption to micro and small enterprises only. The final decision is expected around October 2026.

What does this mean in practice? Until the proposal is adopted — and whatever its final scope — the prudent position is to prepare on the assumption that Article 45.3 applies from 12 August 2026. In any event, the suspension would not affect national registration obligations or enrolment in collective systems, which remain in force. And for companies established outside the EU, the authorised representative obligation remains unconditional.

The Timeline Beyond August 2026

The PPWR does not end in August 2026. For companies working with packaging, these are the dates that should already be on the radar:

August 2028. Mandatory harmonised labelling enters into force: packaging must include information on materials, percentage of recycled content and consumer sorting instructions. The Digital Product Passport (DPP) for packaging also starts, which will involve digital traceability of each unit.

2030. Plastic packaging in food contact made from PET must contain at least 30% recycled content; all other plastics, at least 10%. In the B2B segment, at least 40% of transport packaging must be reusable.

Moreover, companies that begin auditing their packaging portfolios now — not in 2027 — will be the ones with real room to manoeuvre when those deadlines arrive.

What to Do When Amazon’s Notification Arrives

The most common reaction when the RAP number Amazon Spain notification arrives is to look for the fastest way to get the number. This is understandable, but it is not always the right first step.

That said, registering without a prior assessment can mean taking on miscalculated retroactive liabilities, joining the wrong system, or spending time trying to process something that falls to another party in the supply chain — the distributor, the importer, the manufacturer. Before starting any process, four questions are worth answering:

1. Does my company actually have producer status, or does that responsibility fall to someone else?
2. What packaging have I placed on the Spanish market and since when? What is the actual retroactive liability?
3. Do I have a Spanish NIF to begin the enrolment process?
4. Which other European countries do I sell in? Do I have LUCID, IDU and CONAI/RENAP where I need them?

At LegaleGo Regulatory we first analyse each company’s situation and determine the right strategy; then, where appropriate, we manage the execution. If you have received a notification from Amazon or have questions about how this regulation affects you, you can contact us here.

You may also be interested in our article on how to sell food supplements on Amazon FBA, where we analyse the regulatory requirements for operating on the marketplace.

Regulatory sources: Royal Decree 1055/2022, of 27 December · EU Regulation 2025/40 — PPWR · Producer Register — MITECO · Amazon Seller Central — RAP

Frequently Asked Questions About the RAP Number Amazon Spain

What is the RAP number and what is it for?
It is the official code that certifies a company has fulfilled its packaging waste management obligations in Spain. Its format is ENV/YEAR/9 digits. Amazon verifies it against the Ministry’s Producer Register; without it, listings are blocked.

Since when has the RAP number been mandatory?
Since Royal Decree 1055/2022, of 27 December, came into force. It is not an obligation created by the PPWR or by Amazon. Amazon has decided to verify compliance, but the rule has been in force since 2022.

Does my German LUCID, French IDU or Italian CONAI number cover Spain?
No. Each national number is valid only in the country that issued it. If you sell on Amazon.es, you need the Spanish RAP number regardless of what registrations you hold in other countries.

Does the obligation apply if I only sell online?
Yes. The sales channel does not affect the obligation. Anyone selling at a distance — including through Amazon — directly to consumers in Spain has producer status and is subject to the same requirements.

What happens if I have been selling for a while without a RAP number?
Regularisation is possible, but it involves a retroactive enrolment with ECOEMBES for the years in which the company placed packaging on the market without being enrolled. Calculating that amount before starting the process is essential to avoid surprises.

What does the PPWR add to what already exists?
The PPWR harmonises the framework across Europe from 12 August 2026 and introduces new obligations: 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. It does not eliminate national registers: registration in each Member State where products are sold remains necessary.