Nerea García
The annual packaging report to MITECO is one of the main obligations introduced by Royal Decree 1055/2022, on packaging and packaging waste. All companies that place packaging on the Spanish market are obliged to submit this report before March 31, declaring the packaging marketed during the previous year.
Although most companies are already aware of this obligation, in practice it still generates many doubts, operational effort and internal tension. Not so much because of the form itself, but because of the difficulty of gathering, sorting and validating the necessary data.
In this article we explain what the RD 1055/2022 report actually requires, why its submission is still manual and how to organize the data efficiently to avoid last-minute problems.
What is the annual packaging report to MITECO?
The annual packaging report is the declaration that companies must submit to MITECO. MITECO as part of the extended producer responsibility obligations.
This report does not report amounts or payments, but rather physical quantities of packaging, expressed in weight and classified by material and type of packaging. The aim is to provide the administration with a complete overview of the packaging placed on the market and its environmental impact.
It is important to understand that this report is independent of the plastic tax and that its complexity is not in the platform, but in the quality and consistency of the data entered.
Reporting to MITECO is manual (and why that's not the problem).
Currently, the annual reporting of packaging to MITECO is done manually. The data is entered directly into the platform, following the format and level of detail required by the regulations.
This is not going to change in the short term. And assuming this is key.
The common mistake is to think that the challenge lies in automating the shipment. In reality, the real challenge lies much earlier: in how the data has been processed during the year.
When a company reaches March without having properly structured packaging information, the process becomes reactive. Excels, rushed estimates, inter-departmental discrepancies and last-minute validations appear. The problem is not the report. The problem is arriving without the data prepared.
What information does RD 1055/2022 actually require?
The annual report does not ask for interpretations, but for consolidated data. In order to complete it correctly, the company must be able to answer precisely to a very specific question: what packaging have I put on the market and what are they made of?
This involves identifying, for each marketed product, the packaging that makes it up and classifying it correctly by material. In addition, the regulations require differentiation between sales packaging, collective packaging and transport packaging, which adds an additional level of complexity.
Especially in the case of transport packaging, many companies must work with estimated calculation criteria, based on actual consumption, sales volumes and consistent methodologies. The aim is not to achieve impossible accuracy, but rather a consistent, defensible criterion that can be maintained over time.
The big mistake is to treat the report as an ad hoc formality
One of the most frequent problems is to approach the annual packaging report as an isolated administrative obligation.
When this happens, data are started to be collected at the end of the year, in haste and without a clear structure. The result is often a lot of effort to comply, but little real control of the environmental data.
In contrast, companies that manage RD 1055/2022 well understand that the report is only the end result of an ongoing process, not the process itself.
The key is to work the data throughout the year.
Even if the report to MITECO is manual, the preparation should not be.
Working the data correctly involves defining from the outset how the containers are identified, how the materials are classified, how the weights are calculated and how the data are consolidated throughout the exercise. When this work is done in a structured way, the time to complete the report is no longer an operational problem.
March should not be the month when you start thinking about data, but the month when you use data you have already worked on.
The i3s tool for the management of RD 1055/2022 obligations is designed precisely for this preliminary work. It does not automate the sending of the report to MITECO, because that process is still manual, but it does allow to collect, structure and consolidate during the year all the information required by the report, directly from SAP.
This makes it easier for companies to arrive at reporting time with data already prepared, consistent and traceable, reducing the risk of errors and last-minute effort.
The annual packaging report to MITECO is an unavoidable obligation for companies affected by RD 1055/2022. Its submission is manual, but its preparation should not be improvised.
Organizations that understand this turn a regulatory obligation into a controlled, repeatable and much more manageable process. It’s not just about compliance, it’s about compliance well and with control.
