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This article applies to selling in: Netherlands

Extended Producer Responsibility (EPR) Education

What will change for sellers?

Starting in 2022, if you sell in France and/or Germany, Amazon will be obliged to confirm that you are Extended Producer Responsibility (EPR) compliant in the country you sell. Amazon will therefore collect and validate your EPR registration number(s).

During Q4 2021, Amazon will share the link to upload the EPR registration number(s).

If you cannot prove your EPR compliance to Amazon the following actions can be expected:

  • Germany: Amazon will be obliged to suspend your non-compliant listings under EPR product categories.
    • Packaging – all listings from July 1, 2022
    • Electric and Electronic Equipment (EEE) – all listings falling under EEE from January 1, 2023
  • France: Amazon is waiting for more information from French regulators. Amazon will communicate this information at a later stage.

What is Extended Producer Responsibility (EPR)?

Extended Producer Responsibility (EPR) is an environmental policy that makes a producer responsible for the entire life-cycle of the products that they introduce on the market, from their design until the end of life (including waste collection and treatment). Under EPR regulations, the liable entities must mitigate the environmental impacts of their products throughout the entire product life cycle.

Am I a producer?

To know the recommended steps for you, check the Producer definition below:

The Producer is the party who first places a product subject to EPR requirements (EPR product categories detailed below) in the country (France or Germany). You are considered as a Producer:

  • if you manufacture a product subject to EPR requirements in the country, or
  • if you import a product subject to EPR requirements into the country, or
  • if you sell a product subject to EPR requirements in the country and you are not established in that country.

What do I need to do?

If you are a Producer of products in the scope of EPR requirements you will be obliged to provide your EPR registration number(s) to Amazon. See below the categories of products in the scope of EPR requirements for France and Germany for which you need to provide EPR registration number(s) to Amazon.

If you are a Producer and do not have an EPR registration number(s), you are required to register to obtain it. You will have to reach out to the respective Producer Responsibility Organization (PRO) for each EPR product category to obtain the EPR registration number(s). See respective country sections below for detailed instructions on how to register.

If you are not a Producer, but you sell product(s) subject to EPR requirements, you need to obtain the applicable EPR registration number(s) from your upstream supplier and provide Amazon with this EPR registration number(s) in respect of the product as proof of compliance.

If you are not a Producer, and cannot obtain the applicable EPR registration number(s) from your upstream supplier, you are required to register and provide Amazon with your own EPR registration number(s).

What are EPR product categories?

Below are the categories of products in the scope of EPR obligations [for France and Germany] for which you need to provide EPR registration number(s) to Amazon.

A B C
1 EPR Category France Germany
2 Packaging * *
3 Electric and Electronic Equipment (EEE) * *
4 Batteries1 * *
5 Furniture *

6 Tires *

7 Paper *

8 Textile *

1. Battery obligation in Germany: If you offer an EEE product containing a battery, you have to register for both EEE and Battery. Amazon will only require the EEE registration number at this stage

What does it mean to be EPR compliant?

If you are the Producer, or you need to register because you cannot obtain the applicable EPR registration number(s) from your upstream supplier, follow this high-level description of the steps you need to take to become EPR compliant.

Step 1: Registration

  • Registration is a one-time process to obtain the EPR registration number(s) needed to prove compliance with EPR requirements.
  • Once you receive the EPR registration number(s), you will need to communicate it to Amazon as proof of compliance. During Q4 2021, Amazon will share the link to upload the EPR registration number(s).

For more details please refer to each country section below.

Step 2: Declaration and Reporting

  • You must declare your sales [of products covered by the different EPR categories] to the respective Producer Responsibility Organization for the applicable reporting period.

Step 3: Payment

  • You must pay eco-contributions to the relevant Producer Responsibility Organization(s). The eco-contributions are defined by the PRO depending on the EPR product category and device type (e.g. refrigerator, baby clothing, chair), product attributes (e.g. packaging material, materials of furniture) and number and/or weight of units sold.

Country-specific information

France

Proof of Compliance in France

In France, Amazon will require your EPR registration number(s). To get this number(s) you have to register with the relevant Producer Responsibility Organization (see table below). Once you receive the EPR registration number(s), you will need to communicate it to Amazon. During Q4 2021, Amazon will share the link to upload the EPR registration number(s).

Starting in January 2022, to be EPR compliant, a new registration number called the “Identifiant Unique” (Unique Identification Number) will be available on your Producer Responsibility Organization portal(s). You will also need to provide Amazon with this new EPR registration number.

The EPR categories and Producer Responsibility Organizations are detailed in the table below.

# EPR Categories FR Product Description Examples Producer Responsibility Organizations (PRO)
1 Electric and Electronic Equipment (EEE) Waste generated by Electrics and Electronics Equipment Household products, lamps, fire extinguishers and professional electronic products

https://www.ecosystem.eco

https://www.ecologic-france.com

https://pvcycle.fr

2 Batteries Used batteries and accumulators Portable, automotive, and industrial batteries

https://www.corepile.fr/

https://www.screlec.fr/

3 Packaging1 Waste from households packaging Boxes and packaging of products (e.g.: box containing a toy), shipping boxes, shipping labels, tapes, etc.

https://www.citeo.com

https://www.leko-organisme.fr

4 Print Paper Waste from graphics papers Printed items such as user manuals, wall papers, gift cards, advertising inserts https://www.citeo.com
5 Furniture Waste generated by furniture equipment Household and professional furniture

https://www.eco-mobilier.fr

https://www.valdelia.org

6 Textiles Textiles, household linens, shoes, etc. Clothing textiles, household linens and shoes https://refashion.fr/pro/fr
7 Tires Waste generated by tires Automotive, agrarian and heavy handling civil tires

http://www.gie-frp.com

https://aliapur.fr

1. PACKAGING related obligation: In France you are accountable for your primary packaging and the secondary packaging added by you.

Germany

Proof of Compliance in Germany

In Germany, the EPR registration number(s) stands as proof of compliance. To get this number(s) you have to register with the relevant EPR registry (see table below). Once you receive the EPR registration number(s), you will need to communicate it to Amazon as proof of compliance. During Q4 2021, Amazon will share the link to upload the EPR registration number(s).

The EPR categories and Producer Responsibility Organizations are detailed in the table below.

# EPR Categories Description Executing Agency
1 Packaging All packaging types https://lucid.verpackungsregister.org/
2 Electrical and Electronic Equipment (EEE) Temperature exchange equipment https://www.ear-system.de/ear-portal/#no-back
3 Screens, monitors, and equipment containing screens having a surface greater than 100 cm2
4 Lamps
5 Equipment with any external dimension more than 50 cm (Large equipment)
6 Equipment with no external dimension more than 50 cm (Small equipment)
7 Small IT and telecommunication equipment with no external dimension more than 50 cm
8 Batteries* Automotive, industrial and Portable Battery

The following registration numbers stand for your proof of compliance:

  • Packaging: Registrierungsnummer
  • EEE: WEEE-Reg.-Nr.DE
  • Battery: Batt-Reg.-Nr. DE2

*Battery obligation: In Germany, if you offer an EEE product containing a battery, you have to register for both EEE and Battery. Amazon will only require the EEE registration number at this stage.

Frequently asked questions

I am already fulfilling my EPR obligations, do I have to let Amazon know?

Yes, if you are already registered for all your eligible products, you should provide Amazon with your EPR registration numbers(s). During Q4 2021, Amazon will share the link to upload the EPR registration number(s).

I am a Self-Ship seller, does this apply to me?

Yes, Amazon has to confirm that all sellers are EPR compliant irrespective of using Fulfillment by Amazon (FBA) or Self-Ship.

When am I impacted?

Before a product is listed in France and/or Germany, the producer must ensure that the EPR registration process is completed and he received the EPR registration number(s) for all applicable EPR product categories.

Do I need to register for different countries and different EPR product categories?

Yes, there are different registration requirements, processes, and authorized bodies for each country and for the EPR product categories offered on amazon.de and amazon.fr.

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

Declarations and payments of EPR contributions are conducted monthly, quarterly or yearly - depending on the EPR categories/ Producer Responsibility Organizations in each country.

Do I need to pay for both primary (product packaging) and secondary (shipping) packaging?

Primary packaging (products’ own packaging)- Yes, both Fulfillment by Amazon (FBA) or Self-Ship sellers need to pay for primary packaging.

Secondary packaging (shipping packaging) – Please refer to country specific sections for further information.

Primary packaging is the packaging unit used to wrap the product, for example., the branded box of a pair of shoes or the aluminum can containing a soft drink. Secondary packaging refers to shipping boxes/bags used to protect the product during transport to the customer. This can be extended to filling material to protect the product and tapes to secure the package. Shipping labels are also a part of secondary packaging.

How much will it cost me?

EPR registration: You will have to pay registration fees to the different Producer Responsibility Organization(s). This may range from €0 - €250+.

Eco-contributions: Eco-contributions are calculated based on the sales and the EPR product categories which vary from country to country. Each Producer Responsibility Organization maintains its own list of prices as per contractual agreements.

What additional steps do I need to take to be EPR compliant?

In France, if the EPR product category is EEE or Furniture, you need to carry-on the eco-contributions listed on your seller’s invoice onto your own invoice.

Where can I find more information on EPR for France?

For more information, we encourage you to visit the websites of the Producer Responsibility Organization as well as sites given below for more information:

Where can I find more information on EPR for Germany?

For more information, we encourage you to get familiar with the respective laws (ElektroG and VerPackG) and visit the websites of the Producer Responsibility Organization as well as sites given below:

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