From 2022, e-commerce platforms such as Amazon, eBay, AliExpress, etc. will be obliged to check whether you comply with the Extended Producer Responsibility (EPR) policy, and they will ask you to provide and verify your EPR registration number. If the seller does not meet the requirements, the e-commerce platform has the right to remove related products.

Introduction to Extended Producer Responsibility (EPR)

In the EU, the collection and recycling of post-consumer waste for most products needs to be regulated through the Extended Producer Responsibility (EPR) regime. Producers must ensure responsibility and liability for the management of waste generated by their products at the end of their useful life by paying an "ecological contribution" fee.

In layman's terms, when a seller sells a product in Germany/France, creating waste like cardboard, plastic, batteries, e-waste, etc. Sellers are required to pay an "ecological contribution" fee to ensure responsibility and responsibility for the management of waste generated at the end of the product's useful life.

EPR commodity classification and registration declaration details

Below are the categories of products that apply to [France and Germany] Extended Producer Responsibility Obligations for which you will need to provide Amazon with your Extended Producer Responsibility registration number.

1. Packaging waste EPR (Germany & France)

Packaging categories include: paper, glass, plastic, aluminum, ferrous metal, beverage carton packaging, other materials and composite packaging, etc.

Differences between German and regulatory packaging regulations registration:

After the German registration certificate, find a recycling company in France and sign a contract with the recycling company, and then register the UIN

Time limit for registration: 1-3 working days in Germany, 1-2 weeks in France

The difference between declarations: France has a fixed minimum recycling fee, Germany declares according to actual use

The French packaging law is declared once a year: the end of March is the deadline for declaration, and March 31 is the deadline for payment;

The German packaging law declares 1-2 times a year. The first declaration is to directly purchase the minimum recycling declaration amount after the registration number is down, and then the declaration can be adjusted around March of the next year to re-purchase more recycling amounts.

The EPR is just a general term, including three bills: packaging law, battery law, WEEE, including the following commodity categories:

Germany is divided into 3 categories: packaging electrical and electronic equipment batteries France is divided into 7 categories: packaging electrical and electronic equipment batteries furniture paper tires textiles

For the German market, EPR in Germany requires registration of the Packaging Law (Packaging Waste Recycling Directive), WEEE (Electronic and Electrical Waste Recycling Directive), and the Battery Law (Battery Waste Recycling Directive) ;

For the French market, the French government has not yet determined what kind of recycling instructions EPR needs to register in the French market.

Beginning in 2022, if sellers are selling in France and/or Germany, Amazon will be obligated to confirm that sellers are eligible for Extended Producer Responsibility (EPR) in the country where they are selling.

1. How do we define the producer mentioned above? Who belongs to the category of this producer?

According to Amazon's official statement, if it falls under any of the following conditions, it belongs to a "producer":

Products subject to Extended Producer Responsibility requirements if manufactured in the corresponding country. Goods subject to extended producer responsibility requirements if imported into the corresponding countries. If goods subject to Extended Producer Responsibility are sold in the corresponding country and the company is not established in that country.

Many Amazon sellers are actually "producers" in the third category.

2. How to deal with the arrival of new regulations?

1) If you are a seller within the scope of EPR requirements, you must provide Amazon with an EPR registration number.

2) If you are a seller within the scope of EPR requirements but do not have an EPR registration number, you need to register yourself to obtain the registration number. NOTE: The relevant Producer Responsibility Organization (PRO) for each EPR commodity classification must be contacted to obtain an EPR registration number.

3) If not the producer, but the goods sold meet the EPR requirements. Then you need to obtain the EPR registration number used from the supplier, and provide Amazon with the EPR registration number of the relevant product as proof of compliance.

4) If you are not a producer and cannot obtain the applicable EPR registration number from the supplier, you will need to register yourself and provide Amazon with your own EPR registration number.

3. What should I pay attention to when uploading the EPR registration number?

① Different EPR commodity classifications have separate registration numbers.

② Germany can use the following registration numbers as proof of your compliance:

Packaging: Registrierungsnummer Electrical and Electronic Equipment: WEEE-Reg.-Nr.DE Battery: Batt-Reg.-Nr.DE2

Battery Obligations: If we sell electrical and electronic equipment products that contain batteries, we must register for both categories of electrical and electronic equipment and batteries. Currently, Amazon only requires electrical and electronic equipment registration numbers.