Amazon issued an announcement stating that if sellers sell electrical and electronic equipment (EEE) in Germany, they must comply with Extended Producer Responsibility (EPR) by the end of the year. Otherwise, starting January 1, 2023, Amazon will legally suspend sellers' non-compliant products.
Important note of YMS: WEEE is the abbreviation of Waste Electrical and Electronic Equipment, which refers to the recycling instruction of scrapped electrical and electronic equipment. The information for WEEE registration includes business license, product pictures (with LOGO), etc., and an application form needs to be filled out. Registration may take more than 10 weeks. Amazon recommends sellers to start registration in mid-October.
Introduction to Extended Producer Responsibility (EPR)
The concept of EPR first appeared in the late 1980s, designed and proposed by the German packaging industry. This is an environmental measure based on the "polluter pays" principle, according to which a supplier placing a packaged or externally packaged product on the market of a country is responsible for the packaging of the product it puts on, and the liability period extends until the packaging The end of the use cycle, including the process after the recycling of waste packaging materials. In addition to packaging, the extended producer responsibility regime usually covers electronic equipment and batteries, but in general the regime can be applied to any product type.
According to the ElectroG decree issued on March 16, 2005, all electronic products in the EU must be registered for recycling. A recycling company is set up under the local government. On the one hand, the recycling company is responsible for the pollution-free disposal of electronic products. After the merchant signs a recycling contract with the recycling company, the recycling company guarantees the disposal of electronic waste. After the data is submitted to the local government for review, the local government will issue a WEEE-Reg-Number.
If you want to know if you are a manufacturer, you can visit the Stiftung Elektro-Altgeräte (Foundation EAR) website. If you are not the manufacturer yourself, go to the EAR's Manufacturer Directory to verify that all WEEE (brand and equipment type combination) listings in the seller's Amazon EPR report are from a registered manufacturer or an authorized representative of a registered foreign manufacturer.
Frequently Asked Questions Q&A for Selling Electrical and Electronic Equipment in Germany
Q: I have fulfilled the extended producer responsibility obligation. Do I need to tell Amazon?
A: Yes. If you have fulfilled your Extended Producer Responsibility obligations, you should submit your registration number in the Extended Producer Responsibility (EPR) Compliance Information on Seller Central.
Q: I am a self-fulfillment seller. Does this rule apply to me?
A: Yes. Amazon must confirm that all sellers comply with the Extended Producer Responsibility requirements, whether using FBA or self-fulfilling.
Q: When will I be affected?
A: Before listing your product in the French or German marketplace, you must ensure that you have complied with the relevant regulations for all applicable EPR product classifications. We recommend that you refer to the appropriate Country Extended Producer Responsibility Information page for details on what you need to do.
Q: Do I need to register for different countries and different EPR classifications?
A: Yes. Each country and each EPR product category available on Amazon has different registration requirements, processes, and authorities. We recommend that you refer to the appropriate Country Extended Producer Responsibility Information page for details on what you need to do.
Q: Do I have to pay for primary packaging (product packaging) and secondary packaging (delivery packaging)?
A: Primary packaging refers to the packaging used to protect the goods. This might include shoe boxes or aluminum cans for soft drinks. Sellers who use FBA or self-fulfillment are charged for primary packaging.
Secondary packaging refers to delivery packaging. This includes boxes or bags that are used to protect merchandise during shipping to the buyer. Filling materials used to protect merchandise and tapes used to secure packaging can also be covered. Shipping labels are also secondary packaging.
Depending on country requirements, you may be required to report and pay for primary and secondary packaging usage. For example, starting July 1, 2022, in Germany, you will have Extended Producer Responsibility for the secondary packaging that Amazon uses to deliver your FBA products. Please refer to the country-specific extended producer responsibility information page for more information.
Q: How much do I need to pay?
A: You must pay the registration fee to the producer responsibility organization and/or government agency. This fee is a one-time fee ranging from €0 to €250 or more.
In addition, you may be required to pay extended producer responsibility fees on a regular basis. These fees are calculated based on your sales volume and related EPR commodity classifications, which vary by country. Each Producer Responsibility Organization maintains its own list of quotations based on contractual agreements, which may vary from year to year. Please refer to the country-specific extended producer responsibility information page for more information.
Q: Why can't I see all countries on the Extended Producer Responsibility Compliance Portal?
A: If a country is missing, then the collection of information about that country may not yet be available in Amazon's Extended Producer Responsibility Compliance Portal.
Q: What happens after submitting the registration number to Amazon?
A: After providing information on Seller Central, Amazon will verify your submission with the appropriate government agency or producer responsibility organization. Amazon may take up to 5 business days to complete the verification of the registration number.
Once verified by Amazon, the status next to your ID will change from "Submitted" to "Active" or "Inactive + Inactive Reason". If the status is "Active" and you don't need to take any further action, please ignore these notifications. However, if the status is "inactive", please see the reason we provided and take appropriate action.
If any of the above conditions are met, please resubmit the correct registration number. If none of the above conditions apply, you can contact Selling Partner Support through Seller Central. In June 2022, we will provide you with an option to appeal the suppression of your listings and will provide you with details later in Q2.
Q: I have already registered for the required extended producer responsibility classification, how do I provide Amazon with the registration number I received?
A: You will need to work with the appropriate producer responsibility organization and/or agency to obtain your registration number. You can then provide the relevant German and French registration numbers in the Extended Producer Responsibility Compliance Portal. Go to Extended Producer Responsibility (EPR) compliance information in Seller Central, click on the appropriate country, and follow the instructions.
Q: What is the difference between registering in France and registering in Germany?
A: In France, you only need to register the corresponding producer responsibility organization according to the corresponding producer responsibility extended commodity classification. In Germany, you also need to register with the appropriate administrative bodies: for packaging classification, with the Zentrale Stelle Verpackungsregister (ZSVR), for electrical and electronic equipment classification, with the Stiftung Elektroaltgeräte Register (EAR).
Q: Where can I find more information on the extension of producer responsibility in Germany?
A: For more information, we recommend that you familiarize yourself with the corresponding laws (ElektroG for electrical and electronic equipment waste recycling and VerpackG for packaging sorting). In addition, please see our country-specific help pages and websites of relevant government agencies:
· Extended Producer Responsibility Requirements: German Packaging Act
· Extended Producer Responsibility Requirements: German Waste Electrical and Electronic Equipment (WEEE) Directive
· Laws related to packaging classification: .
· Laws related to the classification of electrical and electronic equipment: