In a continued effort to address environmental challenges, the Spanish government has implemented Royal Decree 1055/2022, of December 27, on packaging and packaging waste, legislation that introduces significant changes to packaging and waste management with the aim to reduce its impact on the environment.

This new regulation, which is aligned with the extended producer responsibility regime of the European Union, establishes ambitious goals in terms of reuse, recycling and recovery of packaging. But how does it specifically affect the hotel industry?

Objectives and key measures

The first relevant aspect of the new legislation is found in its objectives and measures for prevention and reuse of packaging. The development of packaging designs that minimize waste production is promoted and the principle of waste hierarchy is reinforced, giving priority to prevention, preparation for reuse, recycling and other forms of recovery, before disposal.

For hotels, this means a review of their current packaging practices. They are expected to present fresh fruits and vegetables in bulk, with specific exceptions, and to inform their customers about the environmental impacts and waste management obligations of the packaging of the products they purchase.

In addition, the obligation to allocate at least 20% of the sales area to the offer of products without primary packaging is reinforced, which includes sales in bulk or through reusable packaging. Retailers have had until June 1, 2023 to adapt to this measure, allowing for a proper transition.

Reuse and marketing of packaging

The law also establishes specific objectives for the reuse of packaging, both in the hospitality and restaurant sector and in the domestic channel. Percentages are set that packaging must meet in terms of reuse, and measures are introduced to guarantee the availability of reusable packaging.

In this sense, food establishments that sell food and beverages in bulk must accept the use of reusable containers provided by consumers, who will be responsible for their conditioning and cleaning. Likewise, retail businesses with an exhibition and sales area equal to or greater than 300 m2 are required to ensure the availability of reusable packaging for the final consumer.

Beverage containers and compliance deadlines

A key part of the legislation focuses on beverage packaging, with specific deadlines for the introduction of references on reusable packaging. These deadlines vary depending on the size of the establishment, and it is expected that, by January 1, 2025, retailers will offer at least four beverage references in reusable containers if they have a commercial area of 300 m2 or more and less than 1,000 m2.

Additionally, criteria are established for the modulation of the financial contributions of producers, considering factors such as the ease of reuse, recycling and the incorporation of recycled materials. The "polluter pays" principle is reinforced, ensuring that the costs associated with packaging waste management are covered by producers.

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Extended producer responsibility regime

One of the most significant changes is the review of the extended producer responsibility regime. Detailed obligations are set out for those who professionally develop, manufacture, process, treat, fill, sell or import products. Producers must develop business prevention and eco-design plans, collect information on the packaging used and contribute to the fulfillment of the established objectives.

The possibility of meeting these obligations individually or through collective systems is contemplated, and the requirements for the creation and operation of these systems are detailed. The legislation also introduces the obligation to establish deposit, return and return systems for reusable packaging, as well as for certain single-use packaging, guaranteeing recovery throughout the entire distribution chain.

Impact of the new Law on hotels

For hotels, this regulatory change involves a comprehensive review of their waste and packaging management practices. The obligation to present certain products in bulk and the promotion of reuse will affect daily operations, from the kitchen to the product offering in the hotel store.

Furthermore, the introduction of reusable packaging and the obligation to accept ar packaging provided by consumers may require logistical and service adjustments. Hotels must guarantee the availability of reusable containers  and comply with the deadlines established for the introduction of beverage references in reusable containers.

In financial terms, hotels must prepare to assume the costs associated with packaging waste management, ensuring that financial contributions are proportionate and based on transparent and non-discriminatory criteria.

Conclusions

The new packaging and waste law represents a significant change in the way packaging is managed in Spain. For hotels, it implies operational, logistical and financial adjustments to comply with established obligations. However, it also presents opportunities to improve sustainability and environmental management, which can be a positive differentiator in the hospitality industry.

Early adaptation and full understanding of the legislation's requirements are key to minimizing the impact and reaping the long-term benefits. If you want to increase your commitment to the environment, at The Brand Company we are in charge of helping you with our sustainable merchandising.