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What is EPR

EPR stands for Extended Producer's Responsibility, a policy of the European Union. In the European Union, the collection and recycling of waste from most products after consumption are managed through the Extended Producer Responsibility (EPR) system. Producers must ensure their responsibility and obligation to manage the waste generated at the end of their product's useful life by paying an "ecological contribution" fee.

EPR is actually a management system framework that has been implemented in many legislative practices, but EPR is not the name of a regulation. The so-called EU WEEE Directive and the German Electrical, Packaging, and Battery Laws are actually equivalent to the legislative practice of this system in the EU and Germany. From this perspective, German WEEE, German packaging law, and battery law all fall within the scope of EPR. In addition, the vast majority of European countries, not just EU member states, have always had corresponding regulations and laws to control EPR. The reason why EPR has received a lot of attention recently is that Amazon requires all sellers on its German and French sites to provide an EPR registration number.

EPR product category

The following applies to the classification of products within the scope of extended producer responsibility obligations in France and Germany. For which products do sellers need to provide Amazon with extended producer responsibility EPR registration numbers? Please refer to the following figure:

Responsibilities of different entities in EPR

If you are a manufacturer of products covered by EPR regulations, you need to provide Amazon with your EPR registration number. The following are the product categories covered by EPR regulations in France and Germany, and you must provide Amazon with the relevant EPR registration number.

If you are a manufacturer and do not have an EPR registration number, you need to register to obtain one. For each EPR product category, you 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/region, please refer to the relevant sections below.

If you are not a manufacturer but sell products subject to EPR regulations, you must obtain the corresponding EPR registration number from upstream suppliers and provide Amazon with the EPR registration number of these products as proof of compliance

If you are not a manufacturer and cannot obtain a valid EPR registration number from upstream suppliers, you will need to register and provide Amazon with your own EPR registration number.

How to complete EPR

EPR is not complicated, just provide company information and product sales information, declare data on time (such as monthly/quarterly/annual), renew and maintain annually, and you can use the EPR registration number for a long time.

1. Register

2. Explanation and Report

3. Payment fees

EPR and Amazon related issues

I have fulfilled my EPR obligations. Do I have to inform Amazon about this matter?

Yes. If you have registered all eligible products, please provide Amazon with your EPR registration number. In the fourth quarter of 2021, Amazon will provide a link to upload EPR registration numbers.

I am a self shipping seller. Do these regulations also apply to me?

Yes. Amazon must confirm that all sellers comply with EPR, whether they use Amazon logistics or self shipping.

When do I need to take action?

Before providing products in France and/or Germany, manufacturers must ensure that they have completed the EPR registration process and have received EPR registration numbers for all applicable EPR product categories.

Do I have to register in different countries and EPR product categories?

Yes. Each country/region and EPR product category that can be sold on amazon.de and amazon.fr have different registration requirements, processes, and authorization agencies.

How often do I need to report my sales and pay EPR fees?

The declaration and payment of EPR fees are due on a monthly, quarterly, or annual basis - depending on the EPR category/producer responsibility organization of the respective country.

Do I need to pay for both primary packaging (product packaging) and secondary packaging (transportation packaging) at the same time?

Primary packaging (product packaging): Yes. Both FBA sellers and self shipping sellers are required to pay for primary packaging fees.

Secondary packaging (transport packaging): For more information, please refer to the specific country/region section.

Primary packaging is the packaging that directly surrounds the product, such as B. shoe boxes or beverage cans. Secondary packaging is a transport box or bag used to protect products during transportation to customers. This also includes filling materials used to protect the product and adhesive tape used for bundling packaging. The shipping label is also part of the secondary package.

How high is the cost?

EPR registration: You must pay the registration fee to the corresponding producer responsibility organization. Environmental fees: Environmental fees are calculated based on sales revenue and EPR product categories, and vary by country/region. Each producer responsibility organization maintains its own price list in accordance with the contract agreement.

What additional steps do I need to take to comply with EPR?

If the EPR product category in France is "EEE" or "Furniture", you will need to include the environmental fees listed on the seller's invoice in your own invoice.