Food traceability and the Envalora declaration (RD 1055/2022): the full guide

The IBC left the plant. The lot is on the delivery note. In the spreadsheet, the return cell is empty.

Until renting close you do not see the units that have not come back. Even when they are outside, you pay for them. In returnable circuits you lose between 5 and 10% a year. They do not break. They sit at the customer, at the wash, on a carrier's dock. And you buy them again. That is cash. It is also the number two different papers will ask you for — about that IBC, not about “packaging” in the abstract.

Two fixes that do not work.

The first: wait until March and rebuild the year in Excel. A WhatsApp to the customer, loose delivery notes, a figure you cannot sign.

The second: buy sensors on day one, before you know which IBC sits and where. Hardware without the blind spot is CAPEX. First the IBC. Then the point. Technology last.

Step by step.

What they will ask about that IBC

About that one. Not about the category.

Food traceability — Regulation (EC) 178/2002, articles 18 and 19, mandatory since 2005 — asks which handling unit the lot left on. One step back, one step forward: immediate supplier, immediate customer, available to the authorities without delay. If tomorrow you have to withdraw, you need to know whether lot 2024-C left in that IBC or in the one next to it.

The AESAN guide splits it in three: what comes in, what happens inside, what leaves and on which unit. The point that breaks most often is not the product. It is the IBC that leaves toward a third party and whose custody nobody records.

The Envalora declaration — Royal Decree 1055/2022, in force since 2023, fully enforceable from 1 January 2025 — asks how many containers you have, how many rotations they do and how many you replace. 2025 data was due 31 March 2026. 2026 data is filed between January and March 2027. Envalora channels EPR for industrial and commercial packaging: more than 2,600 companies.

And the MITECO note on reuse systems: a reusable is waste only when it can no longer circulate. While you can show that IBC circulates — who has it, how many turns, when it is reconditioned — it stays in reuse. If you cannot, it does not rotate, it does not count, and you replace it.

Two papers. One IBC. The same question: it left / it has not come back.

How you record it on the plant

Four things. Technology last.

1. Identity. That IBC needs a name. A QR is enough. No identity, no record. If two IBCs could have had different histories, they have to be distinguishable.

2. Checkpoints. Goods-in, off the line, dispatch, return. At each: what, where, when, who. If it is on paper today, digitize that point and validate it against what you already have: TMS, SAP, matrículas. One, then the next.

3. Records you can query. Not a March spreadsheet. Something you can ask today: has this IBC come back? For animal origin, same day (Reg. 931/2011). Keep them for the product's life; private standards often ask life + 12 months. If you sell to retail, BRC wants the full exercise in 4 hours.

4. The matrix. Which lot left in which IBC, to which customer. If the supplier flags lot L-4471, in minutes: which IBCs, who has them. That is the mock recall. That is what the auditor asks for. The traceability plan is not the PDF: it is this matrix running.

QR on the IBCs. BLE where in and out of the plant matter, without asking the shift for another gesture. GPS only where the risk pays. WhatsApp to coordinate with the customer or the driver: the phone is already in the hand. Not another app.

The rest — fill sensors, what happens inside the container — I say it with pinzas. If it is not validated, leave it for later. Buying hardware on day one is the second fix that does not work.

HACCP (Reg. 852/2004) asks for lots at every stage. The plan does not hold in an inspection if the IBC leaves without a name.

What Envalora asks and what we do not file

If you place product in IBCs, drums, sacks, crates, film or pallets on the Spanish market, you fund their end of life and you declare it. Who fills, who imports filled, the distributor. Registration in MITECO's Product Producers Register (ENV/AAAA/XXXXXXXXX). Annual declaration — weight, units, material — before 31 March of the following year (to your PRO, before the end of February). Join a PRO (SCRAP) or an individual system. For industrial and commercial the reference is Envalora.

The Envalora RAP 2026 tariffs split two worlds. Single-use is paid per tonne: from €15/t on industrial plastic or wood, €80/t for metal, up to €130–900/t if there is hazardous content (drums ≥60 l, IBCs, aerosols). A reusable on deposit (SDDR), in open loop, pays €0.30 per IBC and €0.10 per pallet, plus deposits of €0.50 and €0.20. Annual minimum: €250. Joining: €500.

The reading is not “look at the tariff”. It is this: the reusable IBC only pays less if you can prove it circulated. If you cannot, single-use and the “disappeared” one both cost you.

The declaration asks, among other things: stock in circulation, replacements (new versus reconditioned), rotations — how many times it is filled, distributed, collected and cleaned — and average service life before it is taken out. Exactly what you do not have if the return cell is empty.

We do not file the Envalora paper. You sign that, or your PRO does. What we do is make the rotations real: real enough to sign. One family — the IBCs. It left / it has not come back. Hardware only on the blind spot.

The same record closes both papers

Traceability: which IBC lot 2024-C left in. Envalora: how many turns it did, whether it still circulates, whether you replace it. Cash: the 5–10% that sits outside and is bought again. Renting, until the checkpoint, you pay the same.

Three problems. One fact. Every time that IBC changes hands, you keep who has it and since when.

From that you get the recall, the March rotations, and “this customer has been holding the IBCs for 60 days”.

You do not need another software category. You need the record of that IBC. In food and in chemicals the order is the same: QR on the IBCs, BLE where it goes in and out, GPS only where the risk pays.

Outside food the rule changes, not the IBC.

If you cannot point to it

If you cannot point to which customer has the IBCs sitting, you are guessing the declaration and the recall.

Art. 19 of Regulation 178/2002: withdrawal. If you cannot bound the lot, you stop withdrawing three lots and you withdraw a month. That is commercial and reputation.

Packaging, Law 7/2022: up to €3.5 million at the very-serious grade. Serious: €2,001 to €100,000; with hazardous waste, €20,001 to €600,000. It can rise to twice the benefit. Closures, disqualifications. Not declaring, or declaring what you cannot back, is the most expensive avoidable risk on the plant.

And renting: even when they are outside, until the checkpoint you pay for them.

If you never buy anything from us, keep this. Point to the IBC. The rest is Excel.

FAQ

Does Vitum file the Envalora declaration?

No. We do not file that paper. We make the rotations real: stock, turns, replacements. You sign. Or your PRO does.

Do I need GPS on every IBC?

No. For most, QR and a custody record are enough. BLE where in and out matter. GPS where the risk or the value pays. First the IBC. The sensor, when it is validated.

When is the declaration filed?

Before 31 March, with the previous year's data, in MITECO's Product Producers Register. To your PRO, before the end of February. Envalora helps you file. Rotations and stock you supply.

See your savings

Before you buy sensors, measure the hole. How many IBCs have not come back. What real rotation you have. What you are missing to sign.

See your savings → In 30 days, with your numbers: what has stayed outside, what TCO each IBC has, what you are missing for the next declaration. A first estimate, in 2 minutes, with the Vitum Agent.