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​Amazon Germany has forced German WEEE compliance! Who is registered for German WEEE? How to be compliant?

09/24/2022
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​Amazon Germany has forced German WEEE compliance! Who is registered for German WEEE? How to be compliant?

Amazon Germany has forced German WEEE compliance! If you sell products in Germany that fall within the scope of the Waste Electrical and Electronic Equipment Directive (WEEE), you will be subject to Extended Producer Responsibility (EPR) requirements. It may take 7-8 weeks for the EAR to be issued. If the peak period may be longer, the platform recommends registering before the end of October 2022 at the latest, otherwise Amazon will be obliged to suspend the WEEE product classification from January 1, 2023. Non-compliant product. German WEEE is valid for the natural year, and it is recommended that you act now!

1. What is Extended Producer Responsibility (EPR) and WEEE?

Extended Producer Responsibility (EPR) is an environmental policy that holds producers accountable for the entire life cycle of the commodities they put on the market, from the beginning of commodity design to the end of the commodity's life cycle (including waste collection and disposal). The EPR clearly stipulates that the responsible parties (product manufacturers, importers and distributors) must reduce the environmental impact of their goods throughout the life cycle of the goods. Electrical and Electronic Equipment (EEE) is one of the EPR classifications.

The full name of WEEE is WasteElectricalandElectronicEquipment, that is, waste electrical and electronic equipment. In order to protect the environment, Germany introduced the ElektroG regulation to regulate the recycling of all electrical and electronic products in Germany.

(Source: Amazon)

2. Who registered the German WEEE? Can I register myself? How to be compliant?

Who needs to register? (One of the following is considered a producer)

①Products in Germany that comply with the German WEEE jurisdiction;

②Import products to Germany that meet the jurisdiction of German WEEE;

③ Sell products in Germany that comply with the German WEEE jurisdiction, and you have not established a company here.

Simply put, sellers who put electrical and electronic equipment on the German market must register for WEEE.

Note: Shipping method has nothing to do with whether you are a producer or not.

Can I register myself?

For Chinese sellers, no.

Foreign producers without a German company: If you, as a registered producer, do not have a domestic company in Germany that qualifies as an authorised representative, you must appoint an authorised representative who will be responsible for your legal obligations as a producer/distributor and It will apply for the necessary registrations on your behalf.

What does it mean to be truly compliant?

①Sellers who have completed the German WEEE registration

You need to log in to Seller Central and submit the WEEE-Reg.-Nr number on the [Producer Responsibility Extended Compliance Information Page]. Amazon is expected to open the upload link at the end of September or early October 2022. Xiao O will notify everyone at that time, please pay attention in time. Also, you need to comply with recycling requirements.

②Sellers who are not registered with German WEEE

The first step is to register for German WEEE; complete the WEEE registration process at one time and obtain the WEEE-Reg.-Nr number. After receiving the WEEE-Reg.-Nr number, self-upload it to the Amazon Compliance Portal. At the same time as registration, you need to pay environmental protection payments to the relevant production organization.

The second step, declaration; declare the sales volume of the products covered by the WEEE product classification to the relevant producer responsibility organization within the reporting period.

Important: Amazon recommends that sellers register by the end of October 2022 at the latest. It may take 7-8 weeks for the platform to notify the EAR down, and Amazon will start enforcing non-compliant products before the deadline of January 1, 2023, during which you will face a peak period if you do not register, which may be will be penalized for delay.

3. When will it take effect? When is it worthwhile to register?

Before the end of October 2022, Amazon will notify sellers to register in advance;

From January 1, 2023, Amazon, eBay, AliExpress, and Alibaba will fully enforce German WEEE compliance.

According to EAR officials, the normal application time is 6-7 weeks. Processing times may be extended if there is a high volume of business. At the same time, German WEEE takes effect in the natural year. No matter when you register in 2022, you will have to pay a full fee for one year, and it will expire on December 31, 2022. Buying early and complying with regulations is more cost-effective!

(Source: ear official website)

4. Consequences of not registering and not complying with German WEEE

1) The cross-border platform will deal with it, directly remove it from the shelves and stop selling in Germany, and if it is serious, the store will be closed;

2) The Federal Environment Agency will impose a fine of up to 100,000 euros;

3) More serious complaints will be reported by competitors or sellers, and corresponding criminal and civil liabilities will be retroactively imposed.

(Source: Amazon)

5. How to judge the product is within the scope of German WEEE?

There are 6 categories of detailed categories of products within the scope of German WEEE:

Class 6: Small IT and Telecom Equipment

Class 5: Small electrical and electronic equipment

Class 4: Large electronic equipment

Class 3: Lamps/Charging and Discharging Gas Lamps

Class 2: Display devices for private households

Category 1: Heat Exchangers

*Sort from high to low proportion, the vast majority of sellers have products of category 5 and category 6, which account for nearly 93%

Self-inspection method: first see if the product conforms to the 6 categories + then look at the sub-category

For details of sub-categories, please click "Hurry up and check yourself! 267 products of 3C and electrification must be German WEEE, it is recommended to collect~"

6. How many registration numbers do I need to provide? How is WEEE charged in Germany?

You will only get a WEEE-Reg.-Nr number. But if you have multiple different brands you need multiple registrations for German WEEE compliant products. If you refuse to cut leeks, the WEEE fee structure of Eurotax Pass in Germany is transparent, and the service content includes: registration + declaration + official fee + guarantee recovery.

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