According to the European Commission’s reply of 21 August 2026:

📦 When a manufacturer or importer sells packaging or packaged products to a distributor, this is legally considered “placing on the market.”

➡️ Therefore, packaging already held in a distributor’s warehouse is considered placed on the market.
The Commission also confirms that:

✅ There is no deadline to sell existing stocks.
✅ Packaging already manufactured does not have to be destroyed, remanufactured or re-labelled.
✅ Certain identification and labelling information may be provided through an accompanying document.

Planning to enter the Spanish market?

DAUSS Abogados Abogados can help you assess your PPWR, EPR and Spanish compliance obligations.