In the Royal Decree of batteries and accumulators 106/2008, regardless of whether it is a natural or legal person, the following types of producers are distinguished:
Manufacturer: manufactures in Spain (unless it manufactures for third parties under the brand of another company, in which case the latter may, by agreement between the parties, assume the status of producer).
White label seller: own brand or distribution brand. You can assume the condition of producer of the batteries and/or accumulators that you sell, even if they are manufactured in Spain by another company in your name.
Importer: imports batteries and/or accumulators from a Member State of the European Union or from a third country for sale in Spain.
Distributor: if you import batteries and/or accumulators that you sell, you become a producer (importer) in relation to those batteries and/or accumulators. If all the batteries and/or accumulators that it sells have been purchased from manufacturers or importers that are already producers in Spain, the distributor is not a producer.
Remote seller: if you are established outside of Spain and sell batteries and/or accumulators by means of distance communication directly to private households or professional users in Spain, you are a producer.
[Note: it is also valid if you are established in Spain and fall into any of the above cases. For example, if you import batteries and/or accumulators to sell them at a distance over the Internet, you would be an importer].
In all these cases, the producer must register and declare his condition as a producer.