Registering the fertilising product is no longer enough: the REGFER requirement to operate in Spain

Has your fertilising product already been registered in Spain or accessed the market through mutual recognition? That is certainly an essential first step. However, complying with product registration requirements alone is no longer sufficient to legally commercialise fertilisers in the Spanish market.

Following the entry into force of Order APA/1226/2025, economic operators must also comply with a new obligation: registration in the REGFER (General Register of Manufacturers and Other Economic Operators of Fertilising Products).

Many international companies are currently focusing on product registration while overlooking the fact that REGFER constitutes an independent requirement for operating legally in Spain.

What is REGFER and who does it apply to?

REGFER is not a product register, but a mandatory register for economic operators involved in the manufacture, import, distribution or placing on the market of fertilising products.

It applies, among others, to manufacturers, importers, companies providing fertilisation services, operators introducing products from third countries, and certain agents involved in the placing of fertilising products on the Spanish market, as well as to EU-based companies that do not have production facilities in Spain but intend to commercialise their products in the country.

Therefore, even where a product is already legally marketed under RD 506/2013, Regulation (EU) 2019/1009 or through mutual recognition, the economic operator must still assess its obligation to register in REGFER.

The “Responsible Declaration”: administrative simplification, but also responsibility

Access to REGFER is based on an electronic “Responsible Declaration” system submitted to the Spanish authorities.

This allows operators to start their activity immediately upon submission, without waiting for prior administrative approval.

However, the authorities retain powers of subsequent verification and control. If inaccuracies, essential omissions or non-compliance are identified, the registration may be declared ineffective and the operator may be prevented from submitting a new declaration for a certain period of time.

For this reason, it is particularly important to correctly assess:

• the classification of the operator,

• the scope of the declared activity,

• and the supporting documentation available.

Ongoing obligations

Registration in REGFER also involves ongoing compliance obligations, including:

• Annual reporting of sales, production and import data.

• Periodic confirmation of continuity of activity in order to maintain the registration active.

REGFER should therefore not be understood as a one-off administrative formality, but rather as a continuing regulatory obligation.

Relevant deadlines

Operators already active in the Spanish market will need to adapt to the new system before 1 July 2026.

Companies planning to place fertilisers or biostimulants on the Spanish market should assess their regulatory situation as early as possible in order to avoid administrative issues or disruptions in commercial activities.

An obligation independent from product registration

REGFER is independent from product registration or certification and should be assessed as part of the broader regulatory strategy for accessing the Spanish market.

At Rizarra Consulting, we support international fertiliser and biostimulant companies in:

• assessing their registration obligations,

• preparing the Responsible Declaration,

• reviewing the regulatory qualification of their activities,

• and managing ongoing compliance obligations.

If you would like to assess how REGFER may affect your activities in Spain, feel free to contact us for an initial discussion.