If you are in Europe or you are planning to sell products in Europe through Amazon, you need to understand what the Extender Producer Responsibility is.
According to the Organization for Economic Co-operation and Development: “EPR is s a policy approach under which producers are given a significant responsibility – financial and/or physical – for the treatment or disposal of post-consumer products. Assigning such responsibility could in principle provide incentives to prevent wastes at the source, promote product design for the environment, and support the achievement of public recycling and materials management goals. Within the OECD the trend is towards the extension of EPR to new products, product groups, and waste streams such as electrical appliances and electronics”
This means that they are applying policies that will force manufactures to slowly move to more eco-friendly products as well as be responsible for these products.
What is important is how now Amazon will implement these rules. IF you are not aware, starting this year, 2022, if you sell to France or Germany Amazon is now legally obliged to confirm that you are indeed following the EPR rule, this means that now Amazon will require you “Amazon Seller” to provide your EPR Registration number.
If you are not able to provide these numbers Amazon will suspend your non-compliant listings in Germany and France they will by default pay the corresponding EPR eco-contributions to the government on your behalf and then recover those amounts from you later.
How can you be sure you are responsible for this?
When we talk about who is responsible for the registration of the products, it does not necessarily the manufacture of the product. The term Product is the part that places the product into the market and sales to the end-user.
This means:
· 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.
What Products require this registration?
| Product Category | France | Agency |
| Packing | Apply | https://www.citeo.com https://www.leko-organisme.fr |
| Electronic and Electronic Equipment (EEE) | Apply | https://www.ecosystem.eco https://www.ecologic-france.com https://www.soren.eco/ (solar panel only) |
| Batteries | Apply | https://www.corepile.fr/ https://www.screlec.fr/ |
| Furniture | Apply | https://www.eco-mobilier.fr https://www.valdelia.org |
| Tires | Apply | http://www.gie-frp.com https://aliapur.fr |
| Paper | Apply | https://www.citeo.com |
| Textile | Apply | https://refashion.fr/pro/fr |
| Chemical | Apply | https://www.ecodds.com/ |
| Medical Piercing equipment for auto-treatment | Apply | https://www.dastri.fr/ |
| Product Category | Germany | Agency |
| Packing | Apply | https://lucid.verpackungsregister.org/ |
| Electronic and Electronic Equipment (EEE) | Apply | https://www.ear-system.de/ear-portal/#no-back |
As a small business, are you responsible?
If you are in Europe and you are manufacturing in China, you are still responsible for this registration as you are the importer of the products and the company responsible for placing the product in the market. However, there are currently many Chinese manufactures that are looking to get this registration done.
IF you are in Germany
These are the datelines
· 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
If you are in France
Amazon will start enforcing this on January 1st, 2022
If you are an Amazon seller, and you need more information, you can check Amazon Website.
