Amazon notified sellers that from January 1, 2022, products sold to France and Germany must obtain an EPR registration number and fill in Amazon seller portal, otherwise it will be forced to stop selling products.
Amazon will share the link used by sellers to upload the EPR registration number in the fourth quarter of 2021. What is this EPR policy and what impact does it have on sellers? How to judge that the seller is a producer? How to register for EPR? What are the consequences of not registering for EPR? Don’t worry, follow eu-rep-service.de and we help you understand the EU EPR policy.
“You are receiving this email as we have identified you as a Producer selling into Germany and/or France marketplaces, impacted by Extended Producer Responsibility (EPR)regulations. 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)
Starting in 2022, if you selling France and/or Germany, Amazon will be obliged to confirm that you are (EPR) compliant in the country you sell. Amazon will therefore collect and validate your EPR registration number(s).Amazon has created a dedicated Help Page where you will find detailed information on the Extended Producer Responsibility(EPR)requirement and on how to prepare for this regulation . If you have not already done so, we recommend you review the above help page and take appropriate steps to ensure your products meet the EPR requirements.”Original notification email from Amazon to seller who sell products to Germany and France
What is EPR?
EPR is the abbreviation of an EU policy called Extended Producer’s Responsibility.
In the European Union, the collection and recycling of post-consumer waste for most products is managed through the Extended Producer Responsibility (EPR) system.
Producers must pay for “ecological contribution” to ensure that their products are responsible and obligated for the management of waste generated at the end of their service life.
What is EPR product classification?
The following is applicable to the classification of products within the scope of the extended liability obligations of French and German producers.
For Germany: packages, electric and electronic equipment and battery are required EPR product categories. Furniture, tires, paper and textiles are not required.
For France: not only packages, electric and electronic equipment and battery are required EPR product categories, also furniture, tires, paper, and textiles.
How does the seller determine whether it is a producer?
Amazon defined the producer is the first to place products that need to meet the extended producer responsibility requirements of a certain country/region (France or Germany) to the country/region.
In the following cases, it is a “producer”:
If you manufacture products that need to meet the extended producer responsibility requirements in the corresponding country/region;
If you import goods that need to meet the extended producer responsibility requirements to the corresponding country/region;
If you sell products that need to meet the extended producer responsibility requirements in the corresponding country/region, and you have not established a company in that country/region;
If one of the above conditions is met, it is recognized as a producer. For most non-EU based sellers, it fits the definition of a producer.
If you are not a producer and sell products that need to meet the extended producer responsibility requirements on Amazon, you need to obtain the applicable EPR registration number fromyou’re your upstream supplier and provide Amazon with the EPR registration number of the relevant product as a proof of compliance.
If you cannot obtain the applicable EPR (Extension Producer Responsibility) registration number from the upstream supplier, you need to register and provide Amazon with your own EPR registration number.
What is the relationship between EPR and German WEEE, German packaging law, and German battery law?
EPR is actually a management system framework and is practiced by many legislations, but EPR is not the name of a law
The so-called EU WEEE Directive and German Electrical Appliance Law, Packaging Law, and Battery Law are equivalent to the legislative practice of this system in the EU and Germany. From this point of view, German WEEE, German packaging law, and German battery law all belong to the category of EPR.
What should I pay attention to when uploading an EPR registration number?
- Different EPR product categories have separate registration numbers.
- Germany can use the following registration numbers as proof of your compliance:
Electrical and electronic equipment: WEEE-Reg.-Nr. DE
Battery: Batt-Reg. -Nr.DE2
- France will unify a UIN (“Identifiant Unique”) for different product categories in the future, but it has not yet implemented.
What are the consequences of not registering for EPR?
The Amazon notification clearly requires that starting from 2022, for products sold by sellers to Germany or France, Amazon will confirm whether the products sold by the seller meet the EPR requirements of the country/region and collect and verify the seller’s EPR registration number.
If the seller’s products cannot prove that they meet the requirements of the EPR, Amazon will impose a penalty on the seller’s products for suspension.
If the French or German competent authority checked that the seller’s goods do not meet the EPR requirements of the country, it will face cargo detention and fines from the custom or market supervision agency.
In less than four months before the implementation date of 2022, Amazon will share the link for uploading the EPR registration number in the fourth quarter of this year. Seller who sell products in Germany or France should register for EPR as soon as possible, to avoid the risk of delisting of your products by Amazon.
We are glad to guide and assist you to apply for the EPR relevant registration numbers and manage the reporting obligation. Contact us for free consultation.