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This article applies to selling in: Spain

Extended Producer Responsibility (EPR) Education

What will change for sellers in FR and DE?

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).

Amazon will share the link to upload the EPR Registration Number(s) before the end of 2021 for Germany, and in the course of January 2022 for France.

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 will need to pay eco-contributions on your behalf to the qualified Producer Responsibility Organization(s) as determined by Amazon for the EPR product categories missing EPR registration number(s). If you do not provide the EPR registration number(s), eco-contributions will be paid on your behalf and charged back to you if you sell EPR applicable products in France from amazon.fr.

What is Extended Producer Responsibility (EPR)?

Extended Producer Responsibility (EPR) is an environmental policy that makes the party who first places a product subject to EPR requirements in the country (also known as “producer” for EPR) 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?

Please note that Producer is not an equivalent of a manufacturer. 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 can be considered as a “Producer” if any of the below options apply to you:

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

For packaging specific requirements, please refer to country-specific information section below.

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. Amazon will share the link to upload the EPR Registration Number(s) before the end of 2021 for Germany, and in the course of January 2022 for France. For packaging specific requirements, please refer to country-specific information section below.

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. Amazon will share the link to upload the EPR Registration Number(s) before the end of 2021 for Germany, and in the course of January 2022 for France.

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. Amazon will share the link to upload the EPR Registration Number(s) before the end of 2021 for Germany, and in the course of January 2022 for France.

If you are not a Producer, but 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). Amazon will share the link to upload the EPR Registration Number(s) before the end of 2021 for Germany, and in the course of January 2022 for France.

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.

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

5 Tires *

6 Paper *

7 Textile *

8 Chemicals *
9 Medical Piercing Equipment for Auto-treatment *

1 Battery obligation in Germany: If you offer an EEE product containing a battery, you have to register for both EEE and Battery.

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. Amazon will share the link to upload the EPR Registration Number(s) before the end of 2021 for Germany, and in the course of January 2022 for France.

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 Producer Responsibility Organizations 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

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. Amazon will share the link to upload the EPR Registration Number(s) before the end of 2021 for Germany.

Starting July 1, 2022, as per the amended packaging law in Germany, you will be considered as producer for FBA-packaging used for shipment of your products, if applicable.

The EPR categories and executing agencies are detailed in the table below.

# EPR Categories Description Executing Agency
1 Packaging1 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 Batteries2 Automotive, industrial and Portable Battery

1Packaging: In Germany, you are responsible for both primary and secondary packaging. If your secondary packaging is provided by a fulfillment service provider, your provider will be responsible for secondary packaging until June 30, 2022. Starting July 1, 2022, you will be responsible both for the primary and secondary packaging. This applies to Fulfillment by Amazon and any other fulfillment service provider.

2Battery 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.

The following registration numbers stand for your proof of compliance:

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

France

Proof of Compliance in France

In France, to prove your compliance, Amazon will require to have your Unique Identification Numbers (UINs). To get a UIN, you have to register with the relevant Producer Responsibility Organizations (see table below) depending on your catalogue. UINs will be generated automatically from January 2022 onwards for all registered sellers and available to you via your Producer Responsibility Organization(s)s’ portal. You will need to provide these UINs to Amazon via Sellers Central. Amazon will share the link to upload the EPR Registration Number(s) during January 2022 for France.

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

# EPR Categories FR Product Description Examples Producer Responsibility Organisations (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://www.soren.eco/ (solar panel only)

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

8 Chemicals Chemical waste generated by household Glue, paint, car polish, acetone, vaseline, mastic https://www.ecodds.com/
9 Medical Piercing Equipment for Auto-treatment Waste generated by piercing equipment used by patient in auto-treatment Needles, micro-perfusion, catheter, pen with retractable needle https://www.dastri.fr/

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

EPR Requirements Policy for Third-Party Sellers in France

If you sell products in France from amazon.fr that fall under one or more of the EPR product categories, but did not provide Amazon with a valid UIN corresponding to those EPR product categories, Amazon will report the quantities of products you have sold in France from amazon.fr and pay the corresponding eco-contributions on your behalf for you to continue sales.

Frequently asked questions - General

I am already fulfilling my EPR obligations. Do I have to let Amazon know?

Yes, if you are already registered for all your EPR applicable 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.

Will Amazon provide help with EPR reporting?

Amazon is developing a reporting tool which will help you to download reports for EPR product categories in France and Germany. Information in these reports could be used to declare your sales of products covered by the different EPR categories.

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.

How many EPR registration numbers do I need to provide for each category?

Each seller needs to provide one EPR registration number for each relevant EPR product category.

For WEEE in Germany only: each Seller will need to register and provide each brand/device type they sell within the category.

What information do I need to provide for DE WEEE?

Each seller will need to provide their own DE WEEE EPR number which will include multiple brand/device type registrations.

International sellers will need to register all products they sell on the German marketplace.

Domestic sellers can provide their supplier's registration number in cases where the supplier is based in Germany and is already registered for those brand/device types.

What happens after I submit a registration number to Amazon?

Amazon will validate this number with the appropriate government agency. We will notify you when the validation result is available.

What are the differences between registering in France and Germany?

In France, you will only need to register with the Producer Responsibility Organization in the appropriate EPR product category. In Germany, you will additionally need to register with the applicable executing agency (ZSVR, EAR).

Where can I find more information on EPR for France?

For more information, including reporting, frequencies and payment of EPR fees, 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:

Frequently asked questions - France

If I sell EPR Applicable Products on amazon.fr to customers with a shipping address in France, but do not provide Amazon with the valid Unique Identification Number, what actions will Amazon take on my behalf?

If you are selling EPR Applicable Products on amazon.fr to customers with a shipping address in France, but do not provide Amazon with the valid Unique Identification Number corresponding to those EPR Applicable Products, Amazon will by default take the following actions on your behalf:

  • Prepare declaration reports on your behalf, with details requested by the qualified Producer Responsibility Organizations selected by Amazon, such as quantities (number of units or weight of products) of your EPR applicable sales with mandatory details such as device type (e.g. refrigerator, baby clothing, chair), and product attributes (e.g. packaging material, materials of furniture). To prepare the reports, Amazon will use information provided in your listings or use default values in the absence of such information;
  • Submit reports for each applicable EPR product category at the end of reporting cycle (which may be quarterly, semi-annual or annual as per the category of the EPR Applicable Product);
  • Pay the applicable environmental eco-contributions in accordance with these Producer Responsibility Organization’s list of prices and the quantity (number of units or weight of products) on your behalf; and
  • Recover these amounts from you.

When will Amazon pay eco-contributions on my behalf to the qualified Producer Responsibility Organization(s) as determined by Amazon?

Amazon will follow a quarterly, semi-annual or annual reporting cycle for each EPR product category as defined by the qualified Producer Responsibility Organization(s) selected by Amazon. This means that at the end of each quarter for quarterly reports, six months for semi-annual and the year for annual reports, Amazon will pay eco-contributions on your behalf to these Producer Responsibility Organizations.

Will Amazon recover the eco-contributions paid on my behalf from me?

Yes, Amazon will recover from you the eco-contributions paid on your behalf at the end of each reporting cycle as per the EPR product category. Eco-contributions depend on the list of prices of the qualified Producer Responsibility Organization(s) and the quantity (number of units or weight of products) of your EPR applicable sales. We will communicate the details of the charge back process at a later stage.

Will Amazon pay eco-contributions on my behalf after receiving my UIN?

No, Amazon will only pay eco-contributions on your behalf to qualified Producer Responsibility Organization(s) selected by Amazon for reporting cycles in which Amazon does not hold your valid UIN(s) for EPR product categories applicable to you. Amazon will thus discontinue paying eco-contributions on your behalf from that reporting cycle (quarterly, semi-annual or annual as per the EPR product category) onwards. You will thereafter yourself pay your environmental eco-contributions to the Producer Responsibility Organization of your choice.

I have registered with a Producer Responsibility Organization to get my UIN, but have not received it yet. What should I do?

Please keep checking the portal of your Producer Responsibility Organization for your UIN. Once you receive the UIN, provide it to Amazon immediately. Amazon will pay eco-contributions on your behalf to the qualified Producer Responsibility Organization(s) as determined by Amazon for reporting cycles in which Amazon does not hold your valid UIN for EPR product categories applicable to you.

Will Amazon pay eco-contributions on my behalf for sales off Amazon too?

No, Amazon will only pay eco-contributions on your behalf for EPR applicable sales on amazon.fr.

Will Amazon need to pay eco-contributions on my behalf for EPR applicable sales shipped out of France from amazon.fr?

No, Amazon does not need to pay eco-contributions on your behalf for EPR applicable sales shipped out of France from amazon.fr. Amazon will only pay eco-contributions if you sell EPR applicable products to customers with a shipping address in France from amazon.fr. This also includes French overseas territories.

Is it mandatory for me to be registered with a Producer Responsibility Organization?

While Amazon can pay eco-contributions on your behalf and recover them from you, we encourage all sellers to be EPR compliant by themselves. This includes Registration, Declaration and Reporting and Payment of eco-contributions.

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