EMPRESA ANTIGUA ADHERIDA QUE PREGUNTA POR RPP:

All companies that place packaging in Spanish territory must be registered in

the Registry of Product Producers, of the Ministry for the Ecological Transition
and the Demographic Challenge.
Furthermore, those who put packaging on the market that reach the final
consumer must manage them through a SCRAP (in this case the report you
make to Ecoembes).

What you will need to register in the Ministry's Producer Registry is a Spanish
certificate that allows you to access the headquarters and register your
company. For this, companies hire the services of others companies that act as
authorized representatives. These companies can be any natural or legal person
that will take responsibility for representing the foreign company, or also
companies that are exclusively dedicated to offering this service such as:

· GESTEC: https://www.gestecenvironment.com/blank-3

· AVASK: https://www.avaskgroup.com/green-transition/

The representative will be able to access the Ministry's headquarters and

register the foreign company as a product producer. In addition, the Ministry
will also be informed annually about the packaging that the company puts into
circulation in Spanish territory. For this last procedure you can use the report
resulting from your declaration in Ecoembes to help you.

EXTRANJERA QUIERE UNIRSE A ECOEMBES + MITECO

Good morning,

If you want to join Ecoembes, you will have to send us the completed
membership form. Keep in mind that you will need to have a company that acts
as an authorized representative in Spain, which will be a company with a
Spanish CIF and tax headquarters in Spain, and we will also need the
corresponding data.

After receiving this form, we will send you the contract with the data of your
company, and you will return it to us signed. We will then send you access
credentials to the private area so that you can submit your packaging
declarations.

In order to register in the Ministry's Registry of Product Producers, you must do

so through your authorized representative in Spain, who will be able to access,
with their electronic certificate, in the webistite of the Ministry for the Ecological
Transition and Demographic Challenge, and register.

If you have any other questions, you can contact us and we will support you.

APODERAMIENTO EXTRANJERAS:

If you want to take over Ecoembes, keep in mind that you must do so through
your authorized representative. Your representative will be the one who can
access the Electronic Registry of Powers of Attorney, and empower Ecoembes.

The first step would be to make a power of attorney to Ecoembes, for which you
can use the following guide:
https://www.ecoembes.com/sites/default/files/inline-files/empresas/guia-
servicio-ayuda-registro.pdf . You will have to enter the following electronic
office https://sede.administracion.gob.es/apodera/clave.htm and follow the
steps in the guide.

When you complete the authorization, you will be able to download a receipt of
it, which you will have to attach through the Form that we have enabled in the
private area of Ecoembes - Make a request - Request Form for the Registration
of Producers.

Within the form you will have to fill out the company information and the
services for which we take over.

You already know that as always, you can call us again if you want us to give
you a hand to finish the process and confirm that you have done it correctly. We
are in contact.

EXTRANJERAS PASAN A ORDINARIA:

Simplified declaration has disappeared. All companies have now to use the
ordinary declaration model. You can access the ordinary declaration from the
private area, in the Packaging Data Platform.

We send you to attached a very complete guide on how to start working on a

new declaration. You can also watch the following video:
https://www.youtube.com/watch?v=_LUQbIFU7L8
If you have any other questions, do not hesitate to contact us and we will
support you.

ACTUALIZACIÓN DEL CONTRATO EXTRANJERAS

We sent you an update of the contract with Ecoembes. The reason for the
update is the approval of Royal Decree 1055/2022 on Packaging and Packaging
Waste and Law 7/2022 on Waste and Contaminated Soil, which has meant that
we have to adapt it to the new legal framework.

The main variations that you will find in this new contract to adapt it to current
regulations are:

-Adaptation of the adhesion contract to the new authorization, such as SCRAP

for single-use domestic packaging.

-The duration of the contract will be one calendar year, instead of 5 years as
until now, which will be automatically extended for annual periods.

-Voluntary use of the symbol called “Green Dot” on packaging.

-The company may comply with the RAP for packaging not included in the
scope of Ecoembes, by virtue of Ecoembes' collaboration agreements with other
SCRAPS.

-In case of termination of the contract by the company, it must comply with the
financial obligations for full years. To do this, you must make a provisional
settlement and will continue to be obliged to make the annual packaging
declaration referred to in this contract. The parties are obliged to make the
corresponding regularization and the associated payments despite having
terminated the contract, as stated in article 17.4 of RD 1055/2022.

-Updating everything related to the General Data Protection Law (LOPD).

The rest of the billing and payment conditions remain exactly the same.

INFO GENERAL EXTRANJERAS, ADHESIÓN Y RPP:

First and foremost, the previously mentioned EPR number that is being required
and requested as proof of compliance for extended producer responsibilities is
directly provided by the Ministry of Ecological Transition, with the following
format : ENV/YYYY/12345678 not by Ecoembes. This number is provided once
the company has registered in the Register of Producers of Products of this
Ministry.

However, to proceed with such registration process, if the company is at the

moment responsible of putting in the Spanish market domestic packaging
(Packaging that reaches the end consumer with distribution such as e-
commerce implying a marketplace for example) then, prior to the registration it
is necessary to join Ecoembes, as of current law, The Royal Decree 1055-2022 of
Packaging and Packaging Waste indicates: companies as of current date must
declare their domestic packaging with Ecoembes with an annual packaging
declaration, in which, companies responsible for the waste generated by the
packaged goods they place in our markets must declare it to further inform the
public authorities about their compliance of the current law. Once the company
has joined Ecoembes, it will be possible to certificate, to the Ministry of
Ecological Transition, that the company is complying with this category of
packaging, and therefore, valid for the registration with the ministry as it would
be complying with the current law.

We remind you that If your company has already registered with Ecoembes, we
remember that you can download your Membership Certificate to use it in the
inscription with the Register of Producers in the private area by accessing this
link Ecoembes Private Area in the section “CERTIFICADO ADHESIÓN”
(Membership Certificate)

If you are not registered with Ecoembes, to do so, you must follow the following
steps:

1) First, Complete the Application Form, in the following link:

https://www.ecoembes.com/en/node/308. To complete the application, you
must have an Authorised Representative in Spain, this is necessary to both Join
Ecoembes, and be able to register your company with the Register of Producers
as it is a must to have a Spanish Electronic certificate and signature to do this
process with the public administration.

2) Once Ecoembes has received the Application Form, you will receive a
membership contract to sign it. Once the membership contract is signed, the
company will receive a user and a password, that will be used as credentials to
access a private area the company will use to do their packaging declaration
and obtain the membership certificate, among other functions.

3) Once the registration with Ecoembes has been completed, and after
obtaining its membership certificate, To register with the Ministry, the
Authorized Representative, will go on to the Ministry’s Electronic Portal to
proceed to request the inscription of the company in the Register of Producers
of Products.

4) Once this process has been finished, the company will receive shortly after,
their inscription number to proceed to use it as the confirmation of compliance
with the current packaging legislation.

Finally, and, in regards of the need of a Legal Authorised Representative, this

representative can be also a branch of the company stablished in Spain that acts
as the representative of the foreign in our national territory, this figure, can also
be another professional or company that can provide such legal services, we can
recommend the following companies, that are currently offering this service for
further help in environmental matters:

· GESTEC: https://www.gestecenvironment.com/blank-3

· OPEMED: https://gestionderesiduosonline.com/en/

· AVASK: https://www.avaskgroup.com/green-transition/

In case that you need more information about Ecoembes, our declaration
model, our website is fully translated in English by following this
link: https://www.ecoembes.com/en