In response to the latest compliance requirements in the e-commerce space, Amazon has notified its sellers that effective April 1, 2024, it will enforce withholding obligations at its UK sites for sellers who comply with the UK's EPR packaging law.
This follows on the heels of the French and Spanish EPR regulations, where merchants involved in the UK EPR packaging law will be required to accept withholding and payment. Merchants who do not have a physical presence in the UK but sell packaging products on Amazon UK will be subject to reporting obligations by Amazon and will have sellers automatically enrolled in its withholding service.
From 2023 onwards, Amazon will proactively enable this service for merchants to register and report their sales, as well as pay for the eco-friendly aspects of their merchandise. Starting April 1, 2024, Amazon will reserve the right to charge sellers for the green fees they pay for the goods they sell.
New regulations promulgated! UK EPR Packaging Laws to be Mandatorily Withheld on Amazon's Behalf
I: Scope of Packaging Applicable to UK Packaging Laws
Packaging as defined in the UK Packaging Act means all materials used to protect and cover goods for the purpose of selling them to consumers, which is intended to simplify the handling and distribution of goods and to safeguard their security. It also includes any item designed to be filled at the point of sale, such as coffee cups.
Covering a wide range of areas, from the packaging of raw materials to the final product at the point of sale. Examples include apparel items, including but not limited to trays, boxes, bags, tapes, rolls, tubes, and hangers.
II: Types of Businesses Complying with Packaging Laws
The following companies are required to comply with the UK Packaging Act:
1. Manufacture of goods in the UK in empty packages or with packaging;
2. Importing goods into the UK that are manufactured in empty packages or with packaging;
3. Manufacture of goods in the UK in empty packages or with packaging and the company is not registered in the UK.
III: Producer's Obligations
The UK government categorizes businesses as "small producers" or "large producers" based on the weight of packaging materials they supply to the UK market each year and their annual turnover. As a seller, you can determine which type of producer you belong to according to the official regulations provided.
Under the new UK regulations, the type of producer determines the obligations they have to fulfill. Below is an overview of the obligations for small and large producers respectively:
Obligations of small-scale producers:
1: From January 2024 onwards, accounts should be created with the relevant organizations;
2: Record data on empty packages and packaged goods supplied or imported into the UK from 2023;
3: From 2025 onwards, submit a report on data on empty packages and packaging supplied or imported and pay the relevant fees to the environmental regulator.
Report Deadline:
1: No report is required for 2023 data;
2: 2024 data should be submitted by April 2025
Obligations of large producers:
1. Create an account with the relevant organization;
2. recording data on empty packages and packaged goods supplied or imported into the UK from 2023 onwards;
- Payment of waste management fees, program administrator fees, and environmental program administrator fees;
- Obtain a PRN (Packaging Recycling Note) or PERN (Packaging Export Recycling Note) to comply with the recycling mandate;
- Packaging data is reported every 6 months.
In England, Scotland and Northern Ireland, the reporting deadlines for large producers are:
1: October 1, 2023 reports data from January to June 2023
2: April 1, 2024 reports data from July through December 2023
In Wales, submit data for July through December 2023 by April 1, 2024, with an option to include data for January through June 2023
Note: Reporting deadlines for both small and large producers are affected by the country in which the organization is located, and late reporting will result in fines.
Data Reporting Submission Requirements:
1: Details of the packaging activity recorded, i.e. how the packaging was supplied;
2: Type of packaging, e.g.: determine whether it is for home use or non-home use;
3: Type of packaging, including primary packaging, secondary packaging, transportation packaging or three levels of packaging;
4: The material and weight used for packaging.
IV: How to confirm whether I need to accept the withholding obligation?
New UK regulations require all organizations that import or supply packaging in the UK to collect and report packaging data if the following conditions are met:
1: Commercial entities, subsidiaries and groups (other than charitable organizations);
2: Annual turnover of £1 million or more (based on latest annual financial statements);
3: Handle more than 25 tons of packaging within 2022;
4: Participate in packaging related activities.
If your organization engages in any of the following activities, you are required to take appropriate action:
1: Sells packaged goods under its own brand in the UK market;
2: Use of non-branded packaging in the sales process;
3: Goods in imported packages;
4: Have an online marketplace, e.g. selling products to UK customers via Amazon;
5: Provide reusable packaging rental or loan services;
6: Supply empty package.
Organizations that meet the above criteria will be billed by Amazon for the fees required by the UK EPR Packaging Act. Please ensure that you check to see if you have received a notification email from Amazon.
V: What should I do if my place of registration is not in the UK?
If your company is not registered in the UK but sells packaged goods or empty packages on Amazon.co.uk, Amazon will automatically offer you a Payment in Lieu service from 2023. By registering for the Payment in Lieu service, Amazon will submit sales data on your behalf and pay the corresponding environmental fees to its designated organizations and Producer Responsibility Organizations (PROs).
If you choose not to subscribe to Amazon's Payment by Delivery service, you must stop selling packaged goods on Amazon.co.uk. Otherwise, Amazon will continue to pay for the environmental costs incurred by your previous sales of packaged goods on Amazon.co.uk and will charge you for this cost.
Amazon is significantly stepping up the implementation of its EPR environmental policy. After Germany, France, and Spain, the United Kingdom has also come under its supervision. In the future, Amazon is likely to impose even stricter controls on EPR compliance. In order to maintain their advantageous position in the market, sellers must keep an eye on the policy and ensure that their operations are in line with the platform's requirements.
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