Cross-border e-commerce compliance never stops, and the sales threshold is gradually rising!
In response to the long publicized EPR compliance requirements, seller friends on the French/German sites basically received an email from Amazon Compliance Requirements, which requires products sold in Germany/France to obtain an EPR registration number and have it uploaded within the required timeframe.
This article summarizes very useful points.
To facilitate quick understanding of the new EPR regulations and key points.
As a seller, EPR you are definitely not a bystander!
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classifier for clothes, luggage, decorations; piece of work; a matter, an event
The announcement said that from 2022 onwards Amazon will confirm that goods sold by sellers on its French and German sites comply with Extended Producer Responsibility (EPR) requirements.
Sellers, whether they use FBA or self-ship, are required to upload their EPR registration number on Amazon's backend, or else their products will face suspension.
Amazon has created a dedicated help page where you can find detailed information about the Extended Producer Responsibility (EPR) requirements and how to prepare for this regulation - https://sellercentral-europe.amazon.com/ap/help/GYDCAK9ZR6VJH2X3 If you haven't already done so. If you haven't already done so, we recommend that you review the above help page and take the appropriate steps to ensure that your products comply with the EPR requirements.
Extended Producer Responsibility (EPR)
It is an environmental policy that requires producers to be responsible for the entire life cycle of the goods they put on the market, i.e., from the beginning of the design of the goods to the end of the life cycle of the goods.
According to the Extended Producer Responsibility (EPR) regulation, the policy specifies that responsible parties must reduce the environmental impacts of their goods throughout the life cycle of the goods.
Note: Especially the collection and treatment of waste after product consumption. (Commonly referred to as packaging law, battery law, and WEEE are all within the scope of EPR.)
If a seller's item does not demonstrate compliance with the EPR, Amazon will suspend the seller's posting of the non-compliant item under the EPR product category and take appropriate action:
France: Amazon is awaiting further information from the French regulator and will provide further details on this information in a timely manner.
Packaging: All commodities from July 1, 2022 onwards;
Electrical and electronic equipment: all commodities that are electrical and electronic equipment as of January 1, 2023
EPR Definition
Entire Compliance Requirements Process
The producer is the first party to place goods in Germany/France that comply with the EPR commodity classification:
(1) Manufacture in Germany/France of goods subject to EPR requirements;
(2) Importation of goods into Germany/France that are subject to EPR requirements;
(3) Selling goods in Germany/France that require EPR compliance and you are not incorporated in that country/region.
These are the 4 scenarios that the seller will be looking at:
(1) If the Seller is a producer of goods covered by the Extended Producer Responsibility (EPR) requirements, then it will be obliged to provide Amazon with an EPR registration number.
(2) If the seller is a producer but does not have an EPR registration number, registration is required to obtain an EPR registration number. The relevant Producer Responsibility Organization (PRO) for each EPR commodity category must be contacted to obtain an EPR registration number.
(3) If the Seller is not the producer, but the Seller wants to sell goods that need to comply with the extended producer responsibility requirements, the Seller needs to obtain the applicable EPR registration number from the upstream supplier and provide Amazon with the EPR registration number of the relevant goods as proof of compliance.
(4) If the Seller is not a Producer and is unable to obtain the applicable EPR registration number from an upstream Supplier, the Seller will need to register and provide Amazon with its own EPR registration number.
The EPR compliance process is described below:
(1) Registration: After registering your EPR number, upload it to the link shared on Amazon.
(2) Reporting and reporting: Sales (of products covered by different EPR categories) are reported to the producer responsibility organization during the reporting period.
(3) Payment: Payment of environmental fees to the relevant producer responsibility organization. Note that "environmental fee" is defined according to the EPR product type, equipment type, product attributes, and number/weight of units sold.
Germany
Proof of Compliance
In Germany, the EPR registration number serves as proof of compliance. To obtain this number, registration in the relevant EPR register (see table below) is required, which details the EPR categories and producer responsibility organizations.
These include packaging, electrical and electronic equipment, and batteries. The following three types of registration numbers can be used as proof of compliance:
1. Package: Registrierungsnummer;
2. Electrical and electronic equipment: WEEE-Reg.-Nr.DE;
3. Battery: Batt-Reg. - Nr. DE2.
(i) Packaging waste
Applicable site countries: German sellers.
Applicable products: All packaging waste generated from household consumer products needs to be registered.
For example: wrapping paper, plastic, aluminum, beverage carton packaging, and other composite packaging.
(ii) Battery waste
Applicable site countries: German sellers.
Applicable products: Alkaline batteries, rechargeable batteries, button batteries, etc. embedded in, mounted on, or attached to products must be registered.
For example: rechargeable batteries, toys with batteries, industrial batteries, etc.
(iii) Electronic and electrical equipment waste
Applicable site countries: German sellers.
Applicable products: electrical and electronic equipment, all household electrical products need to be registered.
For example:
1. Refrigerators, air conditioners, and other heat exchange equipment;
2. Screens, displays and devices, including screens with a surface greater than 100 cm²;
3. Light bulb;
4、Washing machine, dishwasher and other large equipment;
5、Coffee maker, flashlight and other small equipments;
6, printers, USB cables and other small computers and telecommunications equipment (all external dimensions less than or equal to 50 cm).
France
Proof of Compliance
In France, from January 2022, in order to comply with the Extended Producer Responsibility (EPR) requirements, a new registration number called "Identifiant Unique" will be available on the portal of the Producer Responsibility Organization (PRO), and sellers will be required to provide this new EPR registration number to Amazon.
To obtain this number, you will need to register with the relevant Producer Responsibility Organization (PRO) (see table below) detailing the EPR classification and PRO.
The French EPR includes seven categories: packaging, electrical and electronic equipment, batteries, furniture, tires, paper and textiles.
(i) Packaging waste
Applicable site countries: French sellers.
Applicable products: All packaging waste generated from household consumer products needs to be registered.
For example: wrapping paper, plastic, aluminum, beverage carton packaging, and other composite packaging.
(ii) Battery waste
Applicable site countries: French sellers.
Applicable products: Alkaline batteries, rechargeable batteries, button batteries, etc. embedded in, mounted on, or attached to products must be registered.
For example: rechargeable batteries, toys with batteries, industrial batteries, etc.
(iii) Electronic and electrical equipment waste
Applicable site countries: French sellers.
Applicable products: electrical and electronic equipment, all household electrical products need to be registered.
For example:
1. Refrigerators, air conditioners, and other heat exchange equipment;
2. Screens, displays and devices, including screens with a surface greater than 100 cm²;
3. Light bulb;
4、Washing machine, dishwasher and other large equipment;
5、Coffee maker, flashlight and other small equipments;
6, printers, USB cables and other small computers and telecommunications equipment (all external dimensions less than or equal to 50 cm).
(iv) Furniture waste
Applicable site countries: French sellers.
Applicable products: Furniture.
For example: tables, chairs, sofas, stools and so on.
(v) Tires
Applicable site countries: French sellers.
Applicable products: Automobile tires.
Specific examples: car tires, etc.
(vi) Printing paper waste
Applicable site countries: French sellers.
Applicable products: Paper with a grammage less than 224 g/m2, sellers with an annual turnover of no more than 5 tons do not need to register.
For example: newspapers, magazines, letterheads, posters, decorative papers, news publications.
(vii) Textile Waste
Applicable site countries: French sellers.
Applicable products: Clothing, fabrics, shoes.
For example: T-shirts, down jackets, sweaters, sneakers, tablecloths, curtains and so on.
EPR Compliance Mark
In a nutshell, the EPR is the seller's passport to sell their products in France and Germany, without which your products will not be allowed to be sold in either country.
German Packaging Law Mark
Printed packaging, packaging laws recognize this logo, remember to print it directly on the product packaging, not on a label.
WEEE logo
This logo is commonly used in the EU and is required to be printed on the product, not just on the packaging, but also requires the seller to register for WEEE in order to comply with the use of the WEEE logo.
Battery Logo
Similar to WEEE, the Battery Law Label is also common in the EU for sellers of battery products or products with batteries to Germany/France.
The Battery Logo shall be printed on the battery and requires the seller to be registered with the Battery Act in order to be in compliance with the use of this logo!
French Recycling Logo
From 2022 onwards, all products sold in France are required to print this recycling symbol, which applies to packaging/paper/textiles/furniture, etc. Sellers of products sold in France should remember to print this symbol on the product packaging. Sellers of products sold in France should remember to print this logo on their packaging. Of course, EPR must be registered at the same time as this logo.
Ask
What should sellers do about the new EPR regulations?
echo
1. Confirm whether EPR registration number is required;
2. Check if the product meets the EPR commodity classification;
3. Make sure that the product involves several categories;
4. Calculate the number of products that need to be declared for all stores;
5. After registering EPR, the information will be printed on the products and packaging;
6. Fill in the registration certificate information on the platform and report regularly.
Ask
What information does a seller need to register for EPR?
echo
1. Application form;
2. Energy efficiency test report;
3. EUROGENE information;
4. English product manual (if possible).
Ask
Does each country need to register a different EPR?
echo
Yes, the EPR registration number is not common to all European Union, each country/region has different registration requirements, procedures and authorization bodies for this, and it needs to be registered individually.
Ask
EPR Policy Compliance for Self-Shipping Sellers?
echo
Yes, Amazon requires that sellers, whether using FBA logistics or self shipment, comply with the Extended Producer Responsibility Policy, which has nothing to do with the shipping method and everything to do with the type of merchandise being sold.
Ask
How long does it take for an EPR to be issued?
echo
The EPR issuance time is 3-8 weeks in France and 2-3 months in Germany, which is relatively long, and with only 1 month left, it is already very tight.
Ask
What are the implications of a seller not registering with EPR?
echo
According to Amazon, Amazon officials are obligated to suspend sellers from posting non-compliant items under the EPR merchandise category if they cannot prove that the item meets the requirements of the EPR.
Ask
Do I need to apply for every type of EPR?
echo
It is necessary to analyze the products sold in the store, and generally the seller sends more than one category of products to Germany:
For example, textiles: the product itself does not need to be registered for any classification, but the packaging of the product needs to be registered for Packaging Act classification;
For example, remote control car toys: if the product has a battery, then the three classifications of electronic and electrical products + packaging law + battery law need to be registered.
Ask
What if the Triman logo doesn't print on the package?
echo
The surface of the largest side of the package is less than 10cm, either directly on the product page or on a separate product page.
Ask
What countries/product categories will be added to the EPR in the future?
echo
It is not yet known, France and Germany have been included in the station, perhaps later such as Spain, Italy and other stations will also be implemented, if there is a new addition, the green circle will be the first time to inform the seller.
Write at the end
Nowadays, the European Union has formulated more and more new laws and regulations to protect the local environment. Amazon collects and verifies the EPR registration number of sellers according to the new regulations of the European Union, and it is natural for sellers to bear the responsibility and obligation of environmental protection when they open up territory in cross-border e-commerce.
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