Isabel Goyena, Project Manager ENVALORA

July 28, 2023

«Envalora is created to give a collective response to the new legal obligations»

On December 28, 2022, the new Royal Decree 1055/2022 on Packaging and Packaging Waste entered into force, introducing new and relevant obligations for the vast majority of companies that sell packaged products on the market. Among them, the application of Extended Producer Responsibility (RAP) for industrial and commercial packaging stands out, which will mean a relevant change for companies in the management of packaging waste. With the aim of enabling companies to meet their new obligations, Envalora was born.

What is Envalora and why was it created?
Envalora is a new Collective System for Extended Producer Responsibility (SCRAP) for all types of industrial and commercial packaging, whether reusable or single-use and made of any material (wood, cardboard, plastic, etc.), which will serve all sectors of industry and construction.
Envalora is created to provide a collective response to the new legal obligations included in Royal Decree 1055/2022 on packaging and packaging waste, especially in relation to what is known as Extended Producer Responsibility (RAP). This new obligation is very relevant since it transfers the obligation to organize and finance the management of waste generated from industrial and commercial packaging to packaging companies, importers or intra-community and foreign purchasers that place containers and packaging in Spanish territory. Responsibility that previously fell on the end customer, who is the owner of the packaging waste. In addition, the RAP also affects ecodesign, that is, that the industrial containers that are put on the market are reusable and more recyclable.

To what extent does this new Royal Decree affect the packaging sector?
It especially affects the packaging sector with companies that are well acquainted with the application of Extended Producer Responsibility (RAP) for domestic packaging, which has been applied in Spain for years. Now, with the new Royal Decree, these companies must also comply with the RAP for industrial and commercial packaging.
The packaging sector has been working on more sustainable designs and innovating for some time to promote sustainability and the circular economy of packaging. With the new Royal Decree they will also have legislation favorable to this sustainability, however, this brings with it a long list of legal requirements that all packaging companies face, which translate into management hours and large investment of resources.

So, can the new legal obligations of companies be delegated to Envalora?
The new regulations allow collective compliance with Extended Producer Responsibility (RAP) by joining a SCRAP such as Envalora, but it also obliges companies to comply with other obligations (such as registration in the Registry of producers of product of the Ministry, or the annual declaration of containers placed on the market) individually. With this, the companies adhering to Envalora ensure, on the one hand, that they collectively comply with their RAP obligation, and on the other, they benefit from the technical and legal advice that Envalora makes available to them for any questions or concerns that may arise. with respect to their individual obligations.
There are many companies that are still unaware of their new legal obligations and the deadlines are very short. For example, next July 31 is the deadline for companies to declare the containers they put on the market in 2021 in the registry of product producers authorized by the Ministry, and Envalora also helps them with this.

Envalora claims to be a SCRAP that promotes the circular economy and sustainability. What actions are carried out in this regard?
Two of the main objectives of Envalora are to promote prevention in the generation of waste and increase the reuse and recycling of packaging, something for which it is essential to make a good separation of waste at source. Thus, Envalora will establish standards and training so that waste is separated correctly, increasing the recycling of packaging and reducing the use of non-renewable raw materials. Envalora is going to develop specific models and very focused on the reuse of industrial containers such as IBC, drums, or pallets.
In addition, Envalora eco will modulate the rates that member companies will have to pay for the containers they put on the market based on their recyclability or recycled content, among other aspects. The latter, to promote the manufacture and use of containers that perfectly fulfill their technical functions, but with the least amount of virgin raw material possible, with the highest recycled content and a design so that the container is as reusable and/or recyclable possible.

How many companies have already joined Envalora? Is there a specific requirement?
There is no requirement to join Envalora, we seek the adhesion of all types of companies and from all sectors so that they contribute critical mass to SCRAP and create a system that is as efficient as possible from an environmental, operational and economic point of view. Currently, more than 550 companies from different sectors and sizes have already joined SCRAP, understanding that it is the best option to comply with their collective obligations and receive advice from individual ones, saving on costs and gaining in efficiency.
It should not be forgotten that Envalora has been created from the industry in a proactive and solvent way, promoted by more than 20 sectoral and territorial associations that support the project as a solution for their companies. Among our companies, the chemical, construction, automotive, plastic, metal and graphic arts sectors stand out, but any industrial sector has a place at Envalora.

What would you say to companies that are not yet preparing to comply with the new packaging obligations?
I would tell them that the deadlines are very short and the legal obligations are very relevant, so they should not waste more time and get organized. In the case of the RAP, before December 31, 2023, the SCRAPS must submit the authorization request to the public administrations, including the affiliated packaging companies. Envalora will submit the application soon, which is why we encourage companies to join the SCRAP, thus ensuring that they comply with their RAP obligation once it is authorized (before December 31, 2024).

How can companies join Envalora?
For those companies that want information to join Envalora, they can contact us through our website or write to

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