Stop selling! Off the shelf! Mandatory! Amazon and AliExpress have recently jumped out of the propaganda, and sellers must register the German EPR before June 30, 2022, and the German packaging law bears the brunt. Platforms such as Wish, Lanting Jishi, and Dunhuang.com also require compliance. Otherwise, sellers will face bans, competition complaints, product removals, and even fines of up to 200,000 euros. There are only 3 months left before the entry into force, registration is urgent!
In response to the German compliance crisis, this article provides a comprehensive analysis of the German EPR. How to register? How to label? What to pay special attention to?
1. Packaging method of German EPR
As an environmental policy, German EPR requires sellers to be responsible from product design to the end of the product life cycle (including waste collection and disposal).
German EPR has three categories: packaging method, battery method, and WEEE.
All cross-border sellers selling to the German market will be involved in registering the German EPR, such as the German Packaging Act.
The three major categories of German EPR will take effect as follows:
Every product sold in Germany must have a lot of packaging, so all sellers in Germany must register the German packaging law, and declare the packaging material, type and weight of the pre-sale product, otherwise the product will be banned from sale or even fined up to 200,000 yuan Euro fines.
Which products require registration? details as follows:
1. Paper skin
4. Ferrous metals: iron, manganese, chromium, vanadium, titanium
6. Beverage carton packaging
7. Other composite packaging
8. Other materials such as wood, cloth, etc.
(Note: Packages contaminated with toxic substances, such as pesticide bottles, are excluded.)
The seller will have a packaging law registration number starting with DE after registration, and the product must also be printed with a recycling sign (signage). At present, the German official does not force the printing of the packaging law logo, but the products in the German market basically carry it.
The German Packaging Law recycling symbol is printed with three circular arrows, available in black and white and green.
(German Packaging Law Recycling Mark)
Second, the German EPR battery law
Germany turned the European Battery Directive /66/EG into national law, called the Battery Act (BattG).
Note: From January 1, 2021, BattG has been upgraded to a new version of the battery law, BattG2, which will take effect on January 1, 2022. The new battery law is charged on a calendar year basis, that is, no matter when a seller registers, the expiration date is December 31 of each year.
Therefore, sellers who need to register the German battery law should register as soon as possible, and get the certificate early and feel at ease!
Who wants to register? The German battery law applies to all types of batteries and accumulators. Therefore, sellers selling batteries or products containing batteries must register with the Battery Act.
What specific product to register?
1. Types of batteries and accumulators (eg: AAA battery)
2. Products with built-in batteries (eg mobile phones)
3. Products containing batteries (eg: electric toys with batteries)
How to print recycling signs?
The German battery law recycling mark is as shown below, the seller must label according to the requirements of BattG2, and provide the corresponding capacity indication. If the battery exceeds the limit for heavy metals mercury, cadmium or lead, the corresponding chemical abbreviation must also be specified next to the label. Usually, if the battery size is less than 0.5 x 0.5 cm, there is no need to print on the battery, but a 1 x 1 cm battery recycling logo is printed on the packaging.
(German battery law recycling mark)
Consequences of sellers not registering with German battery law:
1. Delete the ASIN and remove the product link.
2. When the goods arrived in Germany, they were detained by customs.
3. Confiscate all profits of the seller in Germany.
4. Competitors complain, and the products face the whole store being removed from the shelves.
5. The maximum fine is 100,000 euros.
3. WEEE of German EPR
In addition to packaging law, German WEEE has recently become a category that sellers pay great attention to. German WEEE refers to waste electrical and electronic equipment, and this policy stipulates that sellers must process and recycle their waste electrical and electronic products sold in Germany.
Applicable people? Sellers placing electrical and electronic equipment on the German market must be registered with WEEE.
The applicable products are very wide, divided into 6 categories:
1. Heat exchanger
2. Display devices for private households
3. Lamp/Charging and discharging gas lamp
4. Large electronic devices (over 1250px)
5. Small electrical and electronic equipment
6. Small IT and telecommunications equipment
Domestic sellers mostly apply Category 5, but there are exceptions. For example, the power bank with USB cable needs to be registered in 2 categories, the power bank belongs to Category 5, and the USB cable belongs to Category 6.
WEEE and battery law are often confused, and Xiao O focuses on it. Although WEEE and battery law control categories are similar, there are still essential differences between the two.
1. Different recycled products
WEEE is the Waste Electrical and Electronic Recycling Directive, which only recycles electrical appliances, not batteries.
The battery law is a battery recycling directive, specifically recycling batteries, not electrical appliances.
2. The scope of registration is different
WEEE is aimed at all electrical and electronic equipment in the EU, and all goods related to electrical appliances need to be registered.
The battery law is relatively limited, only for electronic products with batteries.
Does the German WEEE label have to be printed? yes.
WEEE is a trash can with a solid line at the bottom of the cross. (This is a whole, and none of them can be leaked during printing) Note that the signage should be distinguished from the German battery law.
(German WEEE recycling mark)
Pay special attention when printing:
1. The height of the black solid line must be greater than 0.3a or 1mm, and the height of the entire logo must not be less than 7mm.
2. You can adjust the line of the icon, such as thickness or smoothness, etc., but the basic appearance of the original icon must be maintained, and the color is recommended to be black.
3. The standard WEEE logo must be clearly visible and cannot be easily erased, and must keep the logo from curling after use. (Tested according to the method developed by EN50419: the WEEE mark should be rubbed with a damp cloth dampened with water for 15 seconds, and then rubbed with a damp cloth dampened with denatured alcohol for 15 seconds)
4. If the product is too small, or other reasons hinder the printing, it can be printed on the manual and packaging.
If the seller does not meet the German WEEE requirements, there will be the following consequences:
1. The EU regulators can impose fines of up to 100,000-200,000 euros.
2. Direct confiscation of all profits generated from this sale.
3. Directly stop the account or all sales in Germany.
4. In a more serious case, the lawyer will be reminded to sue you for this violation, and the corresponding criminal and civil liability will be retroactive.
4. Frequently Asked Questions about German EPR
Q1: What should I do after registering for the German EPR?
The first is to print the logo as required, the second is to upload the registration number to various platforms such as Amazon, the third is to report on time, and the fourth is to pay environmental protection fees to the relevant production organizations.
Q2: Do I need to register for German EPR as a self-delivery seller?
Compliance registration has nothing to do with the shipping method. As long as the product is put on the German market, you need to check whether the attributes of the sold product conform to the EPR category. Basically, all sellers in Germany must register with the German Packaging Law.
Q3: Can German WEEE be registered without a tax ID?
Yes, the tax number can be omitted but the brand must have it. As long as the brand is in the store, it does not have to be a German trademark.
Q4: After registering for EPR compliance, how is the validity period calculated?
After the German EPR is registered, the validity period is calculated according to the calendar year. That is, no matter when the seller registers, the expiration date is December 31 of each year. Compliance should be as early as possible, and Baili will do no harm.
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