In accordance with the compliance requirements of the European Union Extended Producer Responsibility (EPR) and the guiding framework for environmental protection systems, different EU countries/regions have gradually developed their EPR systems to determine producer responsibility. In this regard, this "Compliance Guideline for German EPR Policy" (hereinafter referred to as the "Guideline") is developed to provide compliance advice to Sellers to ensure that the goods they sell to Germany comply with the relevant German EPR requirements.
What is EPR?
EPR stands for Extended Producer Responsibility. Extended Producer Responsibility (EPR) is a European Union environmental policy requirement. Based on the "polluter pays" principle, producers are required to reduce the environmental impacts of their products throughout their life cycle, and to take responsibility for the entire life cycle of the products they put on the market (i.e. from the production and design of the products to the management and disposal of waste). Overall, EPR aims to improve the quality of the environment by preventing and reducing the environmental impacts of goods such as packaging and packaging waste, electronic goods, and batteries.
What product categories are covered by EPR Germany?
Sellers need to know which EPR product categories they need to register for after understanding their product categories. Each classification requires registration and reporting to a different Producer Responsibility Organization ("PRO").
1. Packaging: packaging of goods, shipping boxes, shipment labels, tapes and manuals, etc.; materials include but are not limited to paper, glass, plastic, metal, laminated packaging, etc. Common products are cardboard boxes, shipping labels, tapes, boxes and packaging of goods (e.g., boxes for toys).
2. Electrical and Electronic Equipment (EEE): ElektroG applies to all electrical and electronic equipment, with exceptions expressly excluded by law. Your goods are considered electrical and electronic equipment if they are designed for use with up to 1,000 volts alternating current or up to 1,500 volts direct current and are: a) dependent on electrical currents or electromagnetic fields for proper functioning; and b) used for generating, transmitting, and measuring electrical currents and electromagnetic fields.
Common products include monitors, televisions, lighting, air conditioners, refrigerators, fire extinguishers, household goods and professional electronics.
3 Batteries: automotive, industrial and portable batteries, common products are rechargeable batteries, button cell batteries
If the merchandise sold into Germany is electrical and electronic equipment containing batteries, it may be necessary to register the EPR number for both the electrical and electronic equipment and the batteries.
How are sellers to comply with EPR requirements?
Step 1: Determine whether the goods in question involve EPR.
Packaging laws apply to almost all goods, and sellers need to determine whether other EPR categories are involved based on the type of goods being sold.
Step 2: Statistics on the types of goods that require EPR registration and reporting
The types of EPR involved in each item are counted and recognized. Regardless of whether the seller is a producer or not, as long as the seller sells the applicable goods to Germany, the seller must report the types and quantities of EPR goods sold by the seller to the corresponding Producer Responsibility Organizations (PROs) within the required reporting period.
Step 3: Complete the registration process and obtain an EPR registration number.
For packaging categories, if the seller is a producer as defined by the German EPR requirements, the seller must apply for and obtain an EPR registration number from both the central packaging registration authority (ZSVR) and the Producer Responsibility Organization (PRO) in order to comply with the German EPR requirements. Sellers can apply for and obtain a packaging EPR registration number from the ZSVR through the LUCID Packaging Registration Organization and then register the packaging category with the Producer Responsibility Organization (PRO) for an EPR registration number.
For the EEE and Battery categories, sellers who are producers as defined by the German EPR requirements need to apply for and obtain an EPR registration number through the Stiftung EAR organization in order to comply with the German EPR requirements. Sellers of electronic goods located outside of Germany must appoint an authorized representative in Germany for the registration. Sellers need to apply on the website of the corresponding enforcement agency in the relevant country, or they can commission an external organization to assist them in completing the registration process in Germany and obtaining an EPR registration number.
EPR registration will generally require the following information, for reference only, the specific information required to the actual application requirements shall prevail: business license scanned copies, store information, product information, the number of goods sold, VAT tax number. The application for the relevant registration number will take a few weeks depending on the specific situation, German Packaging Law: 1-2 weeks, German Electrical and Electronic Equipment Law and Battery Law: 2-15 weeks, etc., just for reference.
After registering for the EPR, relevant information will be printed on merchandise and packaging, including but not limited to: a trash can logo on electrical and electronic appliances merchandise and packaging sold, and a recycling registration number printed on invoices sold.
Step 4: Payment of Recycling Fees to Producer Responsible Organizations (PROs)
The seller must pay the recycling fee to the corresponding Producer Responsibility Organization (PRO) during the applicable cycle. Regardless of whether the Seller is a Producer or not, as long as the Seller sends the applicable Goods for sale in Germany, the Seller is required to pay an environmental contribution to the relevant Producer Responsibility Organization (PRO), which will be determined by the Producer Responsibility Organization (PRO) on the basis of the EPR Goods' product category, material/attributes, weight/size, quantity, ecological design and other factors.
Step 5: Ensure compliance with recycling requirements
In addition to the above steps, the Seller may be required to comply with the relevant German recycling requirements. For example, if the Seller is a producer without a branch office in Germany, an authorized representative must be appointed from the Stiftung EAR's list of accredited authorized representatives. This authorized representative is responsible for fulfilling the Seller's legal obligations as a producer in Germany.
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