What is EPR

EPR is the abbreviation of an EU policy called Extended Producer’s Responsibility. In the EU, the collection and recycling of post-consumer waste from most products is managed through the Extended Producer Responsibility (EPR) system. Producers must ensure responsibility and accountability for the management of waste generated by their products at the end of their useful life by paying an “ecological contribution” fee.

EPR is actually a management system framework and is practiced by many legislations, but EPR is not the name of a regulation. The so-called EU WEEE Directive and the German Electrical Appliances Law, Packaging Law, and Battery Law are actually equivalent to the legislative practice of this system in the EU and Germany. From this point of view, German WEEE, German Packaging Law, and Battery Law all fall into the category of EPR. In addition, most European countries, not just EU member states, have always had corresponding laws and regulations to control EPR. The reason why EPR has attracted much attention recently is because Amazon forces all sellers in Germany and France to provide EPR registration numbers.

Responsibilities of different EPR entities
If you are a manufacturer of a product covered by the EPR regulations, you need to provide Amazon with your EPR registration number. The following are the product categories covered by French and German EPR regulations 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 will need to register to obtain one. For each EPR product category you will 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, please 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 numbers from your upstream suppliers and provide Amazon with the EPR registration numbers for those products as proof of compliance.
If you are not a manufacturer and cannot obtain a valid EPR registration number from your upstream supplier, you will need to register and provide Amazon with your own EPR registration number.

How to complete an EPR
EPR is not complicated. You only need to provide company information and product sales information, report data on time (such as monthly/quarterly/yearly), and renew every year to maintain your EPR registration number for a long time.
1. Register
2. Interpretation and reporting
3. Pay the fee

EPR and Amazon related issues
I have met my EPR obligations. Do I have to notify Amazon about this?
Yes. If you have registered all eligible products, please provide Amazon with your EPR registration number. In Q4 2021, Amazon will provide a link to upload your EPR registration number.

I am a self-shipping seller. Do these rules also apply to me?
Yes. Amazon must confirm that all sellers are EPR compliant, whether they use FBA or self-fulfill.

When do I need to take action?
Before offering 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 a different country and in a different EPR product category?
Yes. Each country and EPR product category available for sale on amazon.de and amazon.fr has different registration requirements, processes, and authorizing authorities.

How often do I need to report my sales and pay EPR fees?
Declaration and payment of EPR fees are due monthly, quarterly or annually - depending on the EPR category/Producer Responsibility Organization in the respective country.

Do I need to pay for both primary packaging (product packaging) and secondary packaging (shipping packaging)?
Primary packaging (product packaging): Yes. Both FBA sellers and self-fulfillment sellers must pay for primary packaging.
Secondary Packaging (Transport Packaging): See the country-specific sections for more information.
Primary packaging is the packaging that directly surrounds the product, such as B. a shoe box or a beverage can. Secondary packaging is the shipping box or bag used to protect the product during transportation to the customer. This also includes padding materials used to protect products and tape used to bundle packaging. Shipping labels are also part of secondary packaging.

How high is the cost?
EPR registration: You must pay the registration fee to the appropriate producer responsibility organization. Environmental Fees: Environmental fees are calculated based on sales volume and EPR product category and vary by country. Each PRO maintains its own price list as agreed in the contract.

What additional steps do I need to take to become EPR compliant?
If the French EPR product category is "EEE" or "Furniture", you will need to include the environmental charges listed on the seller's invoice in your own invoice.