What is EPR
EPR is the abbreviation of an EU policy called Extended Producer's Responsibility System. In the EU, the collection and recycling of most products after consumption waste is managed through the Extension of Producer Responsibility (EPR) regime. Producers must ensure the management responsibilities and obligations of waste generated by their products at the end of their service life by paying “ecological contribution” fees.
EPR is actually a management system framework and has been practiced by many legislative practices, but EPR is not the name of a regulation. The so-called EU WEEE Directive and German Electrical Law, Packaging Law and Battery Law are actually equivalent to the legislative practices of this system in the EU and Germany. From this point of view, German WEEE, German packaging law, and battery law all belong to the category of EPR. In addition, most European countries, not only EU member states, have always had corresponding regulations and regulations to control EPR. The reason why EPR has attracted much attention recently is that Amazon forces sellers of all German and French stations to provide EPR registration numbers.
EPR Product Category
The following applies to the product categories within the scope of extended liability obligations for French and German producers. For which products, sellers need to provide Amazon with the producer extension liability EPR registration number, please refer to the figure below:
| Serial number | category | B. | C. |
| 1 | EPR class | Y | Y |
| 2 | Package | Y | Y |
| 3 | Electronics and Electronic Equipment (EEE) | Y | Y |
| 4 | Battery | Y | |
| 5 | furniture | Y | |
| 6 | tire | Y | |
| 7 | Paper | Y | |
| 8 | textile | Y |
Responsibilities of different EPR entities
If you are a manufacturer and do not have an EPR registration number, you need to register to get 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, see the relevant sections below.
If you are not a manufacturer but sell products that are subject to EPR regulations, you must obtain the corresponding EPR registration number from the upstream supplier and provide Amazon with the EPR registration number for these products as proof of compliance.
If you are not a manufacturer and cannot obtain a valid EPR registration number from the upstream supplier, you will need to register and provide Amazon with your own EPR registration number.
How to complete EPR
1. Registration
2. Interpretation and Report
3. Payment of Fees
EPR and Amazon related issues
Yes. If you have registered all eligible products, please provide Amazon with your EPR registration number. In the 4th quarter of 2021, Amazon will provide links to upload EPR registration numbers.
I'm a self-delivery seller. Do these regulations apply to me too?
Yes. Amazon must confirm that all sellers are EPR-compliant, whether they use FBA or self-shipping.
When do I need to take action?
Before the product is provided in France and/or Germany, the manufacturer must ensure that the EPR registration process has been completed and that the EPR registration number has been received for all applicable EPR product categories.
Do I have to register in different countries and in different EPR product categories?
Yes. Each country and EPR product categories available for sale on Amazon.de and Amazon.fr have different registration requirements, procedures and authorization agencies.
How often do I need to report my sales and pay for my EPR?
EPR fees declaration and payment due monthly, quarterly or annually - depending on the EPR category/producer responsibility organization in their respective countries.
Do I need to pay for both primary packaging (product packaging) and secondary packaging (transport packaging)?
Primary Packaging (Product Packaging): Yes. Both FBA sellers and self-shipping sellers must pay for primary packaging.
Secondary Packaging (Transport Packaging): See the Country-Specific Section for more information.
Primary packaging is packaging that directly revolves around the product, such as B. shoe boxes or beverage cans. Secondary packaging is a shipping box or shipping bag that is used to protect the product during transportation to the customer. This also includes filler materials for protecting the product and tape for bundling packaging. Shipping labels are also part of secondary packaging.
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 and EPR product categories and vary by country. Each producer responsibility organization maintains its own price list as agreed in the contract.
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 charges listed on the seller’s invoice in your own invoice.
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