In recent years, more and more companies are wondering what on earth SCRAP is, whether their business is required to adhere to it, and how to comply without getting lost in a sea of ​​rules, registrations, and acronyms. The reality is that Collective Extended Producer Responsibility Systems They have become a key element in complying with waste and packaging legislation in Spain.
From the industrial sector to small neighborhood shops, including e-commerce and large distributors, everyone is affected by the Extended Producer Responsibility (EPR) and by laws such as Royal Decree 110/2015 on waste electrical and electronic equipment (WEEE) or packaging regulations. If you want to understand what a SCRAP (Waste Electrical and Electronic Equipment Collection) is in Spain, how it works, what the law requires, and how to choose an authorized one, here is a very comprehensive guide explained in clear terms.
What is a SCRAP in Spain and where does this obligation come from?
In the waste management sector, SCRAP has nothing to do with scrap metal, even though that's what it means in English. In Spain, the acronym SCRAP refers to... Collective Extended Producer Responsibility SystemsThat is, organizations that bring together different companies so that, together, they can comply with their legal obligations regarding waste.
The underlying idea is simple: whoever puts a product on the market is also responsible for the waste it generates when its useful life ends. This philosophy is known as Extended Producer Responsibility (EPR) and is included in our environmental regulations, especially in the Law 22/2011, on waste and contaminated soils, and in various sectoral royal decrees (such as the one on WEEE or the one on packaging).
A SCRAP is, in essence, a non-profit entity whose sole purpose is to collectively assume the obligations of its affiliated producers: finance the collection, recycling, recovery and proper management of waste derived from the products that these producers put on the market.
Instead of each company setting up its own individual collection and treatment system (which would be a SIRAP or SRAP), SCRAP allows a collective and coordinated response: obligations are centralized, costs are optimized and all waste logistics are organized on a sectoral or multi-sectoral scale.
Legal framework: from Royal Decree 208/2005 to Royal Decree 110/2015 and Law 22/2011
The SCRAP system has been consolidated thanks to a regulatory evolution that began with the Royal Decree 208 / 2005, on electrical and electronic equipment and the management of its waste, and which was updated by the Royal Decree 110/2015, of February 20, on waste electrical and electronic equipment (WEEE), which transposes Directive 2012/19/EU.
This latest royal decree modifies the operating conditions of the former integrated management systems and redefines their obligations. Since its entry into force, existing collective systems have had to adapt to a new regulatory regime, as set out in the sixth transitional provision of Royal Decree 110/2015.
Under that provision, all active systems had to apply to the autonomous community where they have their registered office. adaptation of their authorizations to the new requirementsIn those applications, they had to demonstrate that they were implementing the necessary internal changes to comply with the new legal conditions.
Article 40 of Royal Decree 110/2015 establishes that collective systems must to establish and authorise in accordance with Law 22/2011 and that its sole objective is compliance with extended producer responsibility. The application for authorization and the authorization itself must comply with the content defined in Annex XVII of the Royal Decree.
The authorization is processed in accordance with the provisions of Article 32.3 of Law 22/2011. Furthermore, the Coordination Commission on Waste Management Analyze the content of the application and assess whether the collective system is adequate to ensure compliance with the RAP obligations imposed by the regulations.
Conditions for authorizing a SCRAP: transparency, non-discrimination and control
When reviewing an application to establish a SCRAP (Society for the Promotion of Unsanitary Uses), the Administration examines several key aspects. On the one hand, it assesses the transparency and objectivity in the incorporation of producers to the system, ensuring that there is no discrimination between operators and that all can join on equal terms if they meet the requirements.
The analysis also includes internal decision-making process of the collective system: it must be based on objective criteria, clear and known to the members, including issues such as the duration of the adhesion contracts and the mechanisms for exchanging information between the members of the system and with the rest of the actors in the waste management chain.
Another point that is valued is that the relations between the SCRAP and the rest of the waste operators (collectors, transporters, treatment plants, etc.) are governed by objective, transparent and non-discriminatory conditions, including agreements between different collective systems, to prevent abuses and market distortions.
Decision-making and the flow of information within the system cannot be assumed to be increased risk of collusion neither among the producers of the SCRAP (Extended Producer Responsibility System) themselves nor between the SCRAP and other waste management operators. The aim is to avoid situations that could limit competition or lead to practices contrary to the public interest.
In addition, the competent authority checks that there is no conflict of interest among decision-making members and other operators (especially waste management companies with which contracts are established). The administration may include specific conditions in the authorization to ensure that recycling targets and the obligations of WEEE producers are met throughout the state.
The authorization of a SCRAP has a validity of four yearsThen it is reviewed and the evaluation process is restarted. Each year, while the authorization is in force, the autonomous communities monitor the system to verify that it complies with the requirements of its authorization.
If the system fails to meet the established conditions, the authority may apply the measures provided for in Article 59 of Royal Decree 110/2015, which includes everything from the modification of the authorization to its revocation. Only when the system is registered in the Waste Production and Management Register can it officially begin its activity.
Internal functioning of SCRAP and producers' rights
Once authorized, the SCRAP must approve its internal operating rulesThese rules must ensure the real participation of producers in key decisions, especially those affecting the categories and subcategories of products that they themselves put on the market.
All members of a collective system have the right to receive the Information derived from compliance with the royal decree Applicable data: collection, recycling, and recovery data, audit reports, etc. They can also submit comments and allegations to be taken into account in the management of the system.
If a SCRAP decides to cease its activity, it is obliged to give notice at least three months in advance to all producers that are part of it, in addition to notifying the administration that granted the authorization so that it can invalidate it and ensure that the producers continue to fulfill their obligations through another system.
The affected producers may, if necessary, switch to another extended responsibility system (collective or individual) in accordance with the regulations. The deposited financial guarantees are returned to the producers once the system's activity has ended and all outstanding obligations have been fulfilled.
SCRAP, SIRAP and types of packaging: how they differ and which one suits you best
When discussing compliance with the RAP, it is important to distinguish between the collective model (SCRAP) and the individual model (SIRAP or SRAP)In a SCRAP, several companies group together and delegate the management of their obligations to an external entity, sharing costs and resources.
SIRAP, on the other hand, is the option by which a company assumes on its own the individualized management of your wasteorganizing their own collection, processing, and reporting systems. This model is usually only viable for very large companies with sufficient volume and an internal structure capable of managing the associated logistics and bureaucracy.
In the area of ​​packaging, things get a little more complicated because it is necessary to differentiate between domestic, commercial and industrial packagingThis distinction is key to knowing which SCRAP you need to hire:
- Domestic scrapIt deals with the packaging that reaches the end consumer (bottles, cans, cartons, food containers, etc.), which end up in the selective collection containers in our homes and streets.
- Commercial scrap: covers packaging generated in the commercial environment (hospitality, restaurants, shops, services), such as delivery boxes, bags or packaging associated with the sale.
- Industrial scrap: manages packaging linked to B2B and industrial processes (pallets, transport boxes, drums, grouping films, etc.).
A single company may be required to adhere to more than one type of SCRAP if it puts products on the market packaging of different categoriesFor example, a manufacturer that sells to distributors (industrial packaging) and also sells online to the end consumer (domestic packaging) may need to cover both fronts.
Key dates and new obligations for commercial and industrial packaging
Until recently, packaging RAP focused almost exclusively on the household packagingHowever, the regulations have been tightened and extended to commercial and industrial packaging, which has had a direct impact on thousands of packaging companies, importers and intra-community purchasers.
From January 1, 2025, the regulation of commercial and industrial packaging is fully applicable, so companies that place this type of packaging on the market must organize and finance waste management that are generated when they become waste.
This is in addition to a number of individual obligations, such as the registration in the Register of product producers and the annual submission of the packaging declaration. This declaration must be submitted before March 31 of each year; for example, packaging placed on the market in 2025 must be declared by March 31, 2026 at the latest.
When submitting the declaration, the company must prove that it is a member of a SCRAP or to an individual system (SIRAP)providing membership certificates and other documentation that proves compliance with its RAP obligations regarding packaging.
Entities like ENVALORA have been created precisely to support companies in meeting these new requirements: advising on registration, managing the collective part of the RAP, and to provide daily guidance on packaging declaration and adaptation to regulations.
How a SCRAP works in practice: financing, collection and traceability
On a day-to-day basis, the operation of a SCRAP relies on three basic pillars: financing, waste management operations and data traceabilityEach participating producer pays a fee based on the type and quantity of product they sell; this money finances the entire system.
The funding is structured through rates or fees per unit of product or packageEach type of material (plastic, cardboard, glass, metal, multilayer, etc.) may have a different rate, and most systems apply ecomodulation criteria: packaging or products that are more recyclable or have less environmental impact are rewarded with lower rates, and those that are more complex or polluting are penalized.
Regarding operations, the SCRAP organizes the selective collection and shipment to treatment plants of the waste that falls within its scope. This includes agreements with authorized waste managers, transport companies, and recycling or recovery plants.
For example, a dairy company that sells milk cartons and drinkable yogurt containers can join a specific packaging recycling scheme. When these containers become waste, they enter the collection system: the cartons (a mixture of cardboard and plastic) are separated from the yogurt containers (usually plastic and aluminum), sent to the appropriate facilities, and processed. recycling or recovery depending on the type of material.
The third pillar is traceability and digitalization of waste managementCompanies adhering to the system and the SCRAP itself must record the products placed on the market, the waste managed and the recycling resultsThis information is then compiled into official reports and documents for environmental authorities, allowing for monitoring of compliance with the objectives set by the regulations.
Authorized SCRAP in Spain and known examples
Currently, in Spain there are more than about twenty authorized SCRAPThese companies handle both packaging and various types of waste. Many of them are widely known because they manage waste streams that are very common in daily life.
Among the most prominent systems related to packaging and other waste, we find, for example, Ecoembes (which manages domestic packaging and, since 2024, also commercial and industrial packaging within the framework of the RAP), Ecovidrio (glass containers), follow (medicine packaging and waste), Signus (end-of-life tires) and Sigaus (used oils).
There are also other specialized SCRAP products, such as sigphytum (agricultural product packaging), Ecopilas (batteries and accumulators), Echo-automation (office equipment and specific WEEE) and a long etcetera, all of them organized as collective extended responsibility systems.
The Ministry for Ecological Transition and the Demographic Challenge (MITECO) maintains a public list of authorized systemsOnly entities listed in that register can legally operate as SCRAP; contracting an unauthorized system means remaining in legal non-compliance even if a fee is being paid.
How to choose an authorized SCRAP in Spain according to your business
For many companies, the main question is not just what SCRAP is, but how to choose the right one among the various options available. Previously there was hardly any competition; now there are multiple systems that can manage the same type of waste, each with its own rates, services, and membership requirements.
The first filter is obvious: the SCRAP must be authorized and officially registered by MITECOAny entity that is not listed in the official directory cannot operate as a collective system, even if it claims to do so on its website or in its advertising.
Then it is advisable to evaluate the tariffs and pricing structureIt's not just about choosing the cheapest option, but about understanding what each fee includes, whether there are hidden costs, whether the pricing structure is appropriate for your actual volume of packaging or products, and whether the eco-modulation is well-suited to your type of packaging.
Another key aspect is the level of support: a good SCRAP should offer, in addition to basic management, Online tools for declarations, traceability reports and technical adviceIf support is poor or communication is opaque, you will find it more difficult to meet deadlines and formal requirements.
Finally, it is important that the system has experience in your specific sector (ecommerce, distribution, HORECA, heavy industry, etc.) and that understands your particularities well: types of packaging, sales channels, destinations of your products and specific reporting needs.
Common mistakes when hiring a SCRAP company and how to avoid them
One of the most common mistakes is choosing a system solely based on priceWithout checking the quality of service or the fine print of the terms and conditions, a very cheap SCRAP service can result in a lack of support, delays in reporting, or even the absence of official authorization.
Another mistake is not verifying whether the system is actually authorized by MITECO. Some entities present themselves as managers of packaging or certain types of waste, but They are not listed in the public registryIn these cases, even if you pay a fee, your company is still not in compliance with the law and is subject to penalties.
It is also common to underestimate the importance of a Clear and transparent reportingThe SCRAP must provide you with adequate reports on your declarations, the deadlines you have to meet and the management results associated with your activity; if it does not, you will be in trouble when the administration asks for an accounting.
To minimize risks, it's advisable to review a basic checklist: verify official authorization, sign a formal contract with a certificate of adherence, analyze what reporting tools they offer, and assess whether they are accustomed to working with companies of your size and sector.
Ultimately, choosing a SCRAP system isn't just a formality; it's a central piece in your environmental compliance and sustainability strategyand it affects both your legal risks and your image with clients, suppliers and administrations.
Which companies are required to adhere to a SCRAP
The key question: Is my company really obligated to adhere to a SCRAP? In general terms, if your company markets products that generate regulated waste (for example, packaging, electrical and electronic equipment, batteries, tires, oils, etc.), you are very likely to have RAP obligations.
In the specific case of packaging, the following are considered subject to extended responsibility: packers, importers or intra-community acquirers that place packaging on the Spanish market, whether for domestic, commercial or industrial use. This affects both large manufacturers and small businesses that sell under their own brand.
Even small neighborhood shops that deliver products in bags, boxes, or wrappers can fall into the category of Product producers for the purposes of the Packaging Law. In many cases, it is advisable to consider whether part of the obligation can be assumed by the distributor, but it is not always possible to transfer it completely.
E-commerce businesses and sellers on marketplaces like Amazon are also required to manage the packaging they place on the Spanish market. In fact, platforms like Amazon They already require proof of compliance with the RAP to be able to sell in Spain, which includes being affiliated with a suitable SCRAP.
In the case of distributors, importers and companies with their own brands, the obligations can be even more complex, combining the need to choose a suitable SCRAP with compliance with other procedures, such as registration in official registers and the submission of periodic declarations.
Environmental, economic and social benefits of SCRAP
Beyond being a legal requirement, SCRAP plays a fundamental role in the circular economy and in reducing environmental impactBy organizing large-scale collection and recycling systems, the amount of waste ending up in landfills is reduced, soil and water pollution is prevented, and associated emissions are lowered.
By promoting reuse, recycling, and recovery, these systems contribute to reduce dependence on virgin raw materialsThis is especially relevant in resource-intensive sectors such as metal, plastics, or paper-cardboard.
Furthermore, RAP and SCRAP promote the ecodesign of packaging and productsWhen the cost of waste management falls on producers and distributors, a clear economic incentive emerges to design products that are easier to recycle, with fewer problematic materials and, in general, with a smaller environmental footprint.
These systems also ensure a stable funding for waste managementThis relieves some of the burden that would otherwise fall on public administrations and, therefore, on society as a whole through taxes. Responsibility is distributed more fairly among those who profit from bringing products to market.
Finally, SCRAPs must be accountable to the authorities, which requires maintaining high levels of transparency and efficiency in the processesThis regulatory pressure contributes to achieving the recycling targets set at national and European levels, as it improves the overall quality of waste management.
The role of management and service companies in the SCRAP sector
Around the SCRAP sector there exists a whole ecosystem of companies dedicated to the operational management, traceability and consultingCompanies specializing in waste management, such as Urbaser, offer comprehensive services so that businesses can comply with regulations efficiently.
These types of companies are responsible for the collection, recycling and data reporting For companies adhering to certain systems, helping them to control in detail the packaging they put on the market and the destination of the waste generated.
Their added value usually lies in the ability to offer tracking platforms, customized reports, and technical support, so that the producer not only complies, but can optimize their packaging and improve their sustainability indicators, something highly valued by investors, clients and administrations.
In a context where regulatory and social pressure on waste is ever-increasing, the support of these specialist companies can make the difference between a compliance by the skin of one's teeth and a solid and well-managed environmental strategy.
Taking all of the above into account, it is clear that SCRAP in Spain is much more than a legal acronym: it constitutes the structure that allows for a reasonable distribution of responsibility for waste, provides legal cover for companies of all sizes and, at the same time, promotes a real transition towards a circular economy in which producers, distributors, managers and administrations row in the same direction.
