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EPR Registration
What is EPR?
EPR is the abbreviation of an EU policy called Extended Producer's Responsibility Extended Producer Responsibility System. In the EU, the collection and recycling of post-consumer waste for most products is regulated through the Extended Producer Responsibility (EPR) regime. Producers must ensure responsibility and responsibility for the management of waste generated by their products at the end of their useful life by paying an "ecological contribution" fee.
EPR is actually a management system framework, practiced by many legislations, but EPR is not the name of a regulation. The so-called EU WEEE Directive and the German Electrical Appliance Law, Packaging Law, and Battery Law are actually equivalent to the legislative practice of this system in the EU and Germany. From this point of view, German WEEE, German packaging law, and battery law all belong to the category of EPR. In addition, the vast majority of European countries, not only EU member states, have always had corresponding laws and regulations to control EPR. The reason why EPR has attracted much attention recently is that Amazon forces all sellers in Germany and France to provide an EPR registration number.
EPR Product Category
The following applies to the classification of goods within the scope of the French and German extended producer responsibility obligations. For which goods, sellers need to provide Amazon with the EPR registration number of extended producer responsibility, please refer to the following figure:
Responsibilities of Different Subjects of EPR
• If you are a manufacturer of products covered by EPR regulations, you will need to provide Amazon with your EPR registration number. Below are the product categories covered by the French and German EPR regulations, for which you must provide Amazon with the relevant EPR registration number.
• If you are a manufacturer and do not have an EPR registration number, you will need to register to get one. For each EPR product category, you will need to contact the relevant Producer Responsibility Organization (PRO) to obtain an EPR registration number. For detailed instructions on how to register in each country, see the relevant section below.
• If you are not a manufacturer but sell products subject to EPR regulations, you must obtain the appropriate EPR registration numbers from upstream suppliers and provide Amazon with the EPR registration numbers for those products as proof of compliance.
• If you are not a manufacturer and cannot obtain a valid EPR registration number from an upstream supplier, you will need to register and provide Amazon with your own EPR registration number.
EPR and Amazon Related Issues
I have met my EPR obligations. Do I have to notify Amazon about this?
Yes. If you have registered all eligible products, please provide Amazon with your EPR registration number.
I am a self-shipping seller. Do these rules also apply to me?
Yes. Amazon must confirm that all sellers are EPR compliant, whether they use FBA or Fulfillment by themselves.
When do I need to take action?
Before offering products in France and/or Germany, manufacturers must ensure that the EPR registration process has been completed and that they have received EPR registration numbers for all applicable EPR product categories.
Do I have to register in different countries and different EPR product categories?
Yes. Each country and the categories of EPR products available for sale on amazon.de and amazon.fr have different registration requirements, processes and authorities.
How often do I need to report my sales and pay the EPR fee?
Filing and payment of EPR fees are due on a monthly, quarterly or annual basis - depending on the EPR category/Producer Responsibility Organization in the respective country.
Do I need to pay for both primary packaging (product packaging) and secondary packaging (transport packaging)?
Primary Packaging (Product Packaging): Yes. Both FBA sellers and self-shipping sellers must pay the primary packaging fee.
Secondary packaging (shipping packaging): See the country-specific section for more information.
Primary packaging is packaging that directly surrounds the product, such as B. shoe boxes or beverage cans. Secondary packaging is a shipping box or shipping bag that protects the product during transportation to the customer. This also includes padding material used to protect the product and tape used to bundle the packaging. Shipping labels are also part of secondary packaging.
How expensive is it?
EPR Registration: You must pay the registration fee to the appropriate Producer Responsibility Organization. Environmental Fees: Environmental fees are calculated based on sales and EPR product category and vary by country. Each Producer Responsibility Organization maintains its own price list as contractually agreed.
What additional steps do I need to take to comply with the EPR?
If the EPR product category in France is "EEE" or "Furniture", you will need to include in your own invoice the environmental charges listed on the seller's invoice.
