WEEE in Spain after the EU omnibus vote: non-EU sellers still need an authorised representative and an RII-AEE number

2026-10-30 · IberTrust Global

On 20 October 2026 the European Parliament adopted its position on the “environmental omnibus” proposals that would suspend the duty to appoint an authorised representative for extended producer responsibility (EPR). Some sellers read the headlines as “no more WEEE representative needed”. For a seller outside the EU, that is wrong.

Short answer

If you ship electrical or electronic equipment from outside Spain directly to customers in Spain, you are the producer under Spanish law. You need a registration in the RII-AEE (Spain's producer register for electrical and electronic equipment), normally through an authorised representative, and your products must be covered by a compliance scheme.

What the Parliament actually voted

• The relief would apply only to micro and small enterprises established in the EU (fewer than 50 employees and turnover or balance sheet total below €10 million).
• The Parliament wants the authorised-representative duty kept for sectors with fully operational EPR schemes, such as WEEE.
• Non-EU producers must still appoint an authorised representative in each Member State concerned.
• The suspension would cover only the appointment of a representative, not fees, reporting or other EPR duties.
• This is a negotiating position. The Council still has to agree, so nothing has changed in law yet.

Who is the producer in Spain

Royal Decree 110/2015 (article 3) treats as producer, among others, anyone who sells electrical or electronic equipment by distance selling directly to households or professional users in Spain while established in another Member State or a third country. Every appliance sold in Spain has a responsible producer, including distance sales to buyers in Spain.

Your RII-AEE number must be visible

• When the producer sells at a distance itself, the RII-AEE number must appear on the website or the instrument supporting the sale (for example the listing) and on the invoice issued to the buyer.
• The producer, or its authorised representative, is responsible for the data in the register being complete and true.
• Quantities placed on the market are declared to the register, and the same product cannot be declared in more than one scheme in the same calendar year.

Warning signs

• A marketplace asks for your Spanish WEEE number and blocks listings
• You hold a German or French WEEE number and assume it covers Spain (each country has its own register)
• Your product has a built-in battery, but only WEEE was handled; batteries are a separate EPR registration
• The invoice template shows no producer number

Next step

Send us your product list, the sales channels you use for Spain and any existing WEEE numbers. IberTrust Global S.L. will tell you whether you are the producer in Spain and what the RII-AEE registration needs.

Request a WEEE check for Spain →
Or email contact@ibertrust.info.

Sources: Royal Decree 110/2015 on WEEE (BOE); Ministerio de Industria y Turismo, RII-AEE frequently asked questions; European Parliament Research Service, “Suspending authorised-representative rules for extended producer responsibility” (12 October 2026); Legislative Observatory procedure 2025/0395(COD), plenary decision of 20 October 2026. General information, not legal advice.