Who is impacted by EPR?

First of all, a 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 and others). 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, and/or
  • if you import a product subject to EPR requirements into the country, and/or
  • if you sell a product subject to EPR requirements in the country and you are not established in that country.

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 Fulfilment by Amazon (FBA) or Self-Ship.

Why do I need to deal with it?

A good reason is that Amazon will shut you down.

What are EPR product categories?

Germany

Packaging

Electric and Electronic Equipment (EEE)

Batteries

France

Packaging

Electric and Electronic Equipment (EEE)

Batteries

Furniture

Tyres

Paper

Textile

Chemicals

Medical piercing equipment for auto-treatment

Do I need to register for different countries and different EPR product categories?

Yes. There are different registration requirements, processes and authorised bodies for each country and for the EPR product categories offered on amazon.de and amazon.fr.

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). For Germany, please follow the link to the EPR compliance portal in Seller Central to upload the EPR registration number(s): EPR compliance portal Germany. For France, Amazon will share the link to upload the EPR Registration Number(s) in the course of January 2022.

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 Organisations in each country.

Do I need to pay for both primary (product packaging) and secondary (delivery) packaging?

Primary packaging (products’ own packaging) – Yes, both Fulfilment by Amazon (FBA) or Self-Ship sellers need to pay for primary packaging. Primary packaging is the packaging unit used to wrap the product, for example, the branded box of a pair of shoes or the aluminium can containing a soft drink.

Secondary packaging (delivery packaging) – please refer to the country-specific section above for further information. Secondary packaging refers to delivery 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 Organisation(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 Organisation maintains its own list of prices as per contractual agreements.

What if my EPR number isn’t accepted within the EPR compliance portal in Seller Central?

Perform the following troubleshooting steps:

  1. Ensure that the number(s) you are providing is an EPR registration number;
  2. Double-check that the EPR registration number has been inputted correctly within the portal in Seller Central;
  3. Check that the EPR registration number corresponds to the right category that you are registering in;
  4. Connect with the appropriate agency to ensure that the EPR number has been correctly associated with the category.

What happens after I’ve submitted 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 will happen if you cannot prove your EPR compliance to Amazon?

Germany

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

  • Packaging, both primary (i.e. product packaging) and secondary (i.e. delivery packaging) – all listings from 1 July 2022
  • Electric and Electronic Equipment (EEE) – all listings falling under EEE from 1 January 2023

France

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 EPR registration number(s) corresponding to those EPR-applicable products, Amazon will by default pay corresponding EPR eco-contributions to the qualified Producer Responsibility Organisations(s) on your behalf and recover these amounts from you.

What is take-back?

The take-back service is a part of the EPR requirements that has already been mandated by the national laws in Germany and France. In line with the existing legislation, if you currently sell EEE products in Germany and France marketplaces, you must provide the customers with the possibility to return their old similar-type products for recycling at the customers’ doorstep and free of charge.