Help very confused about EPR
I am being asked to register to continue selling in Germany & France for EPR. I am very concerned and worried about the Extended Producer Responsibility (EPR) compliance for Germany/France. Nothing I sell is included in the products so why am I being asked to register? I can’t find any information of what to do if I don’t sell any of these products of use the packaging described. Please help
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Seller_sFEUMUfeW5484
When you ship an item to France, do you package it in a box, plastic bag, envelope etc? If you do, then you need to comply. And yes, it’s a minefield to get through.
Seller_ZjZ4slOF0jHpk
Germany - register with Lucid (free) - https://lucid.verpackungsregister.org/
Then pick a Dual Partner. i.e. Some company that you’re paying to deal with any waste packaging in that country. I went with https://activate.reclay.de/
Sign up with them (or https://www.citeo.com/) and input the amount of the different types of packaging you annually send to Germany. I just went with the minimum (e.g. 1kg of plastic, 2kg of paper/cardboard, etc) and it cost less than €9.
Once you’ve done that, go back to Lucid and under Data Report, enter the same info you did in Reclay - I did a Intra-Year report, and filled in for all of 2022.
You’ll get an ID by email.
France - Reclay also do France - https://activate.reclay.de/activate_germany_german/details-zu-leko
I haven’t tried that form, so can’t advise. But means you can have both managed by the one system. Citeo do France as well.
There is a category - sell less than 10k units to France - that costs €80/yr.
Don’t forget to enter your IDs on Amazon and any other marktplace.
Also FYI - France has it’s own recycling logo (Triman - man with three arrows) that has to go on recyclable material.
Then there’s the Green Dot - whole other set of rules and fees - https://www.pro-e.org/green-dot-royalty-free-licensing-agreement.html
And if you want to register with other EU countries, every one is different. Sending into the UK I think the threshold is 50 tonnes or above a certain £). Italy - you’re ok if outside Italy AFAIK. Spain €300. Portugal €120
As MonkeyBoy says, it’s a minefield.
And a final FYI - the reason it’s kicking off now is because the marketplaces are starting to be held liable if they don’t hold our IDs to show we’re registered and paying to deal with our waste - whether it’s recyclable or not.
Or you pay someone to keep you in check (doesn’t include all the fees) - https://www.ecosistant.eu/en/services/
Seller_ZjZ4slOF0jHpk
Seller_ZjZ4slOF0jHpk
And forgot to say, just because you register with Lucid, doesn’t mean you get the right to use the green dot. AFAIK, Germany is the only one excluded. i.e. If you register in a country that requires the green dot (it’s a registered mark and you need a licence to use it), then that covers the green dot reg for all the others. That’s how I read it anyway. Could be wrong.
Seller_ZjZ4slOF0jHpk
Marketplaces -
“The registration obligations for final distributors of service packaging and the extended registration obligation for obligated parties with information on all types of packaging they place on the market will only apply from July 2022 .”
And have a read around this. Your head will be spinning - https://www.pro-e.org/the-green-dot-trademark
PS. I was wrong earlier. Separate licence agreements are needed for each EU country you want to use the green dot in. Think in Spain it’s mandatory, but not for some of the packaging. Even the royaly free license requires at “least one valid trademark agreement with a ‘Green Dot’ system”, as long as it’s not Germany.
Again, it’s a red tape nightmare so I apologise if any info I’ve given is incorrect or I’ve picked up some things wrong.
Seller_OZmda7ZW7VfMk
Hi thank you very much for all the information I really appreciate it. Like you say such a minefield makes me wonder if it’s worth selling abroad. I’ll have a read through it all
Seller_ZjZ4slOF0jHpk
Oh, and one thing I forgot. If you don’t have a VAT number, your UTR number and putting HMRC as supplier worked for me.
Seller_ZjZ4slOF0jHpk
Sorry, keep forgetting bits. I also got myself a stamp made. Just to cover as many bases as possible. I put it on all my cardboard and paper packaging. (Handmade/FBM, so… easier than for some)
Although it doesn’t mean anything legally AFAIK, it is widely recognised compared to the Green Dot and is meant to indicate that a product can be recycled, but not necessarily that it has been itself produced from recycled materials.
And most of the regs around logos allow for them to go on just any included paper, like a manual, rather than the packaging itself. I put all the ones I need & reg’d with and some recycling info on the back of a simple comp slip.
Seller_yKwWOi0MX8lp8
What if your products are already manufactured in Germany for Volkswagen & the courier [DHL / Deutsche Post] is also German, then I guess we’re exempt?
Seller_2mXvaemgrVabX
Anyone know how to get UIN from Leko site to sort out France EPR requirements?
Thanks
