Amazon will enforce from Jan 1st, 2022 the full EPR compliance for German and France market. This affects all sellers in the platform. Today we provide a briefing on the German and French EPR process and cost structure. What is EPR? How can a seller get EPR done? How long does EPR take? How much does EPR cost?
What is EPR?
The full name of EPR is Extended Producer Responsibility. The launch of the EPR program by the European Union aims to promote producer responsibility for the product life cycle (including design and recycling) to reduce the impact of commodities on the environment during the entire life cycle.
Understand German and French EPR
EPR is an institutional guiding framework, not a name of a regulation, and its practice is established in the form of legislation in individual EU countries. For example, the German Electrical Products Law (ElektroG, German WEEE), Battery Law, and Packaging Law are the specific implementation of the EPR plan in Germany. So what products are involved in EPR for Germany and France?
German EPR categories
3 categories for German EPR: packaging (packaging law), electrical and electronic product (WEEE), batteries (battery law).
French EPR categories
7 categories for French EPR: packaging, electrical and electronic equipment, batteries, furniture, tires, paper, textiles.
How does a seller get EPR done?
In other words, sellers who sell the above-mentioned products in the corresponding country are obliged to complete the registration, declaration, and recycling obligations at the designated agency.
What are misunderstandings of EPR?
According to German battery law obligations: If you sell electrical and electronic products that contains batteries, you must register for both WEEE and the battery law.
EPR registration number is not just one. Sellers often mistakenly think that the EPR registration number is a unified registration number for the whole compliance obligation. However, in Germany, the registration numbers of WEEE, battery law, and packaging law differentiate from each other and do not affect each other. There is no unified EPR registration number for all products. The obligation to complete the corresponding registration is mandatory.
For example: if you do not sell electrical products in Germany, you only need to complete the packaging law registration, which means you have completed all EPR obligations for your case. France will issue a unified registration number UIN (“Identifiant Unique”) for different products in the future, but as of today (Dec 3th, 2021), it has not yet launched a registration number system for packaging law…
How long does EPR take?
German EPR process time
German package law registration: 1 week
German battery law registration: 1 month
German WEEE for electrical products: 1 -2 months
French EPR process time
Currently the French system is “digital transforming”. We have feedbacks from cooperative operators and other service providers that they filed the registration for furniture and textiles, waited three months, still got no clues. Package registration for normal products takes 1 -2 weeks. They plan to launch the unique identification number system at the beginning of 2022.
Currently a membership confirmation number of a recycle operator can be used for the transition as proof for EPR compliance. Compliance documents can help to demonstrate to Amazon that the seller is taking actions to conform to EPR compliance.
The French EPR categories are more complicated than German EPR. And the system is still opaque and not clear enough even for French companies.
How much does EPR cost?
The cost structure of any EPR can be categorized into fix and variable cost. Fix cost is registration fee (if applicable) and service fee (for example registration, data reporting monthly and/or yearly), variable cost is recycled license fee, insolvency guarantee annual fee (German WEEE), take back obligation fee (WEEE). In general, to get a quote, you need to provide quantitative product information for applicable registration. A standard package quote is not possible.
Want to get a quick and transparent quote estimate for German and French EPR? Contact us for a quick quote and actionable insights for your compliance demands.
More information about EPR:
EPR compliance for Germany and France?
How to obtain the German packaging law number? German Packaging Law registration tutorial
How to avoid the huge fines imposed by the new German packaging law?
Amazon requires EPR compliance for sellers to Germany or France from 2022