Extended Producer Responsibility 

(EPR)

Extended Producer Responsibility

Become compliant now: new EPR requirements effect in France and Germany sellers.

What is Extended Producer Responsibility (EPR)?

Extended Producer Responsibility (EPR) is an environmental policy that makes producer responsibility for the entire life cycle of the products that they introduce on the market EPR scheme, from their design until end of life. 

Starting in 2022, if you sell in France and/or Germany. Marketplaces must confirm that you are complying with Extended Producer Responsibility (EPR) regulations in the country where you are selling. This applies even when you distribute via third parties like eBay or Amazon.

For packaging, marketplaces like Amazon must have completed these checks by no later than July 2022. Merchants unable to provide an EPR number for their packaging by this date are prohibited from using the marketplace to sell to German customers.  From January 2023, these duties of control for marketplaces will be extended to electrical appliances and batteries.

In the context of Extended Producer Responsibility (EPR) according to German  legislation, this includes in particular packaging, electrical appliances and batteries.

What do I need to do to be EPR compliance?

 Registration

Registration – to obtain the EPR registration number(s) needed to prove compliance with EPR requirements – is a one-time process. Once you receive the EPR registration number(s), you will need to communicate it to your Marketplace as proof of compliance.

Reporting

You must declare your sales to the respective Producer Responsibility Organisation (PRO) for the applicable reporting period.

Payment

You must pay eco-contributions to the relevant PRO(s). The eco-contributions are defined by the PRO depending on the EPR product category and device type (e.g. refrigerators), product attributes (e.g. packaging material) and the number and/or weight of units sold.

EPR Compliance

What is the relationship between EPR and German WEEE, German packaging law, and German battery law?

EPR is actually a management system framework and is practiced by many legislations, but EPR is not the name of a law

The so-called EU WEEE Directive and German Electrical Appliance Law, Packaging Law, and Battery Law are equivalent to the legislative practice of this system in the EU and Germany. From this point of view, German WEEE, German packaging law, and German battery law all belong to the category of EPR.

Packaging, both primary (i.e., product packaging) and secondary packaging (i.e., shipping packaging): Evidence must be received no later than July 1, 2022

Electrical and Electronic Equipment (EEE): For all offers that fall under electrical and electronic equipment, proof must be available by January 1, 2023, at the latest

Batteries: so far, German legislation has not yet stipulated any obligation to provide evidence for internet marketplaces

What should I pay attention to when uploading an EPR registration number?

  • Different EPR product categories have separate registration numbers.
  • Germany can use the following registration numbers as proof of your compliance:

Packing: Verpackungregistrierungsnummer

Electrical and electronic equipment: WEEE-Reg.-Nr. DE

Battery: Batt-Reg. -Nr.DE2

  • France will unify a UIN (“Identifiant Unique”) for different product categories in the future, but it has not yet implemented.