EPR Requirement (Extended Producer Responsibility)

Hi, Has anybody else received this mail from Amazon in the last few days regarding EPR obligations in France and Germany ???, I’ve just got off of a call with an Amazon associate I explained that I’m not manufacturer or producer of any of the items I sell, (I sell branded cosmetics etc, made by L’Oreal, Maybelline, Rimmel etc etc). I was told that as I use packaging i.e. envelopes, cellotape, bubble wrap then I’m still required to get an EPR number in both these Countries. Obviously, that means anyone who sells into France and Germany will be covered by this new bit of non-sense red tape and be required to get registered for this. What people opinions on this???

Dear Thomas,

Thank you for taking my call.

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). Under EPR regulations, the liable entities must mitigate the environmental impacts of their products throughout the entire product life cycle.

Starting in 2022, if you sell in 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). For more information, we suggest you visit the following help page https://sellercentral-europe.amazon.com/gp/help/GYDCAK9ZR6VJH2X3?referral=A1C0CEZJWEEPHT_AGGAAGCIRRY4M

If you are not a producer and 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).

Registration is a one-time process to obtain the 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. During Q4 2021, Amazon will share the link to upload the EPR registration number(s).

If you cannot prove your compliance to Amazon the following actions can be expected:

• Germany: Amazon will be obliged to suspend your non-compliant listings under EPR product categories.

o Packaging – all listings from 1st July 2022.

o Electric and Electronic Equipment (EEE) – all listings falling under EEE from 1st January 2023.

• France: Amazon is waiting for more information from French regulators. Amazon will communicate this information at a later stage. For more information, we suggest you visit the following help page https://sellercentral-europe.amazon.com/gp/help/GYDCAK9ZR6VJH2X3?referral=A1C0CEZJWEEPHT_AGGAAGCIRRY4M

The Producer is the party who first places a product subject to EPR requirements (EPR product categories detailed here) in the country (France or Germany). You are considered as a Producer:

• if you manufacture a product subject to EPR requirements in the country, or

• if you import a product subject to EPR requirements into the country, or

• if you sell a product subject to EPR requirements in the country and you are not established in that country.

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.

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).

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.

If you are not a Producer, and 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).

During Q4 2021, Amazon will share the link to upload the EPR registration number(s). For more information, we suggest you visit the following help page https://sellercentral-europe.amazon.com/gp/help/GYDCAK9ZR6VJH2X3?referral=A1C0CEZJWEEPHT_AGGAAGCIRRY4M

Once reviewed, please remember to reply to this case and advise of your application status: Not started yet, Work in Progress or Already Registered.

Primary packaging is the packaging unit used to wrap the product, e.g. the branded box of a pair of shoes or the aluminium can containing a soft drink.

Secondary packaging refers to shipping boxes/bags used to protect the product during the transport to the customers. 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.

• France: In France you are accountable for paying eco-contributions for your primary and secondary packaging, with the exception of FBA secondary packaging for which eco-contributions are paid by Amazon.

• Germany: In Germany you are accountable for paying eco-contributions for your primary and secondary packaging, with the exception of FBA secondary packaging for which eco-contributions are paid by Amazon. However, from July 1, 2022, you will also have to pay eco-contributions for FBA secondary packaging. Amazon will share with you the packaging use data/ report required to calculate and pay FBA secondary packaging eco-contributions. For more information, we suggest you visit the following help page https://sellercentral-europe.amazon.com/gp/help/GYDCAK9ZR6VJH2X3?referral=A1C0CEZJWEEPHT_AGGAAGCIRRY4M

Primary packaging is the packaging unit used to wrap the product, e.g. the branded box of a pair of shoes or the aluminium can containing a soft drink.

Secondary packaging refers to shipping boxes/bags used to protect the product during the transport to the customers. 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.

• France: In France you are accountable for paying eco-contributions for your primary and secondary packaging, with the exception of FBA secondary packaging for which eco-contributions are paid by Amazon.

• Germany: In Germany you are accountable for paying eco-contributions for your primary and secondary packaging, with the exception of FBA secondary packaging for which eco-contributions are paid by Amazon. However, from July 1, 2022, you will also have to pay eco-contributions for FBA secondary packaging. Amazon will share with you the packaging use data/ report required to calculate and pay FBA secondary packaging eco-contributions. For more information, we suggest you visit the following help page https://sellercentral-europe.amazon.com/gp/help/GYDCAK9ZR6VJH2X3?referral=A1C0CEZJWEEPHT_AGGAAGCIRRY4M

Thank you for selling with Amazon.