Sellers selling into France have received the following email from the Amazon Compliance Team regarding the French EPR registration requirements, and careful sellers have also seen some of the documented information regarding the French EPR in the seller's help page - Extended Producer Responsibility (EPR) training in the amazon account has also been updated.
I have read the content of French EPR in the Amazon backend help page - Extended Producer Responsibility (EPR) training, summarized in the following four points:
1
In January 2022, Amazon will provide French sellers with a link to upload their EPR registration number.
2
For sellers of PRS-extended merchandise categories that lack a PRS-extended registration number, Amazon will be required to make an environmental payment on behalf of the seller to a qualified producer responsibility organization selected by Amazon. In other words, if the seller does not provide a PRRO registration number and sells goods in France through amazon.fr to which the PRRO applies, Amazon will make the environmental payment on behalf of the seller and will debit the seller's account.
3
For sellers who have not yet uploaded their EPR registration number for the corresponding product category, Amazon will make payments for each EPR product category on a quarterly, semi-annual, or annual reporting cycle, as determined by the qualifying Producer Responsibility Organizations (PROs) selected by Amazon. This means that for quarterly reporting, at the end of each quarter, for semi-annual reporting, at the end of each six-month period, and for annual reporting, at the end of the year, Amazon will make EPR payments to these PROs on your behalf.
4
For sellers who have their EPR deducted, which EPR product categories amazon deducts quarterly, semi-annually or annually? The reporting tool for EPR reporting is available for download, and the deduction process has yet to be updated.
5
After amazon receives the EPR registration number (valid unique identifier) uploaded by the seller's back office, amazon will stop making environmental payments on behalf of the seller as of the reporting cycle (which may be quarterly, semi-annually, or annually, depending on the category of the extended producer responsibility product). Thereafter, sellers will be required to make their own environmental payments to the producer responsibility organization of their choice.
In view of the imminent entry into force of the above French EPR regulation, how should sellers respond to it?
(1) While Amazon may make French eco-payments on behalf of sellers and debit them to sellers, Amazon encourages all sellers to comply with the extended producer responsibility requirements on their own. This includes registration, declaration, reporting and payment of environmental credits. In particular, sellers with an annual sales volume of less than 10,000 products must register themselves with the French Packaging Act to minimize the cost of recycling compliance. Because according to amazon as a trader on behalf of the recycling fee account, the annual sales volume will be more than 500,000 pieces of merchandise, the reporting method must take into account the ecological adjustment of the declaration, amazon on behalf of the collection of recycling fees will be higher and more complex.
(2) France EPR except for Electrical and Electronic Equipment (EEE) and Batteries, which must be registered through a local agent as a representative of the recycling company, sellers of other categories such as packaging, textiles, tires, printing paper and furniture can register directly with the recycling company. However, considering the complexity and responsibility of the subsequent declaration, reporting and payment terms, we strongly recommend sellers to choose a reliable and professional agent. The reason is that EPR is not only a registration process, but also requires professional guidance and policy interpretation for subsequent reporting and calculation maintenance. If you only consider the cost of EPR registration and choose an unreliable service provider, you might as well sign a contract with a recycling company directly to reduce the cost. (I will popularize the knowledge of the French EPR packaging law).
(3) France EPR registration number (valid unique identifier) will be issued from January 2, 2022 for sellers who have submitted registration application to the corresponding recycling company, (some categories such as battery law and weeee may only start to be issued in February-March 2022 only). If there are agents in the market who say that they can get the EPR registration number before January 2, 2022, please be careful to distinguish, Amazon's French EPR registration number upload link from January 2022 will be provided.
(4) The French Packaging Act requires every seller who opens amazon.fr or delivers goods to French consumers to register under the name of each store company.
(5) If amazon chooses Leko as the recycling company for the packaging method, the recycling fee for the packaging method will most likely be withheld on March 31, 2022. Because Leko in the recycling fee payment billing terms, Leko has a clear provision for the first year of registration and recycling fee is higher than 10,000 (excluding VAT) traders can choose a one-time or at the end of each quarter to issue a recycling fee invoice. If sellers are considering registering their own packaging EPR number, please be sure to get the packaging EPR registration number (valid unique identifier) before March 31, 2022 and successfully uploaded and verified on amazon, which can avoid being deducted by Amzon for packaging recycling fees.
(6) A new EPR reporting tool will be added to Amazon's back office, which will provide the details required by the Qualified Producer Responsibility Organization selected by Amazon, such as the volume of sales (number or weight of goods) for which you are subject to an extension of the producer responsibility, and provide the details of the type of equipment (e.g., refrigerators, baby clothes, and chairs) and the attributes of the goods (e.g., packaging materials, furniture materials) that are required to be reported. The report is prepared by Amazon. To prepare this report, Amazon will use the information you provide in the Merchandise Information, or default values if such information is missing.
Stay tuned
In summary, I believe that you have some of the policies of the French EPR also have their own response strategy, in order to continue to provide you with professional EPR services, the green circle under the brand of Europe's intellectual property officially online, and then will provide you with more and more professional product compliance services, welcome to contact us for advice and understanding and communication.
The next article will focus on popularizing the French packaging law declaration, recycling fee calculation and reporting, as well as packaging law to consider the ecological adjustment of the labeling requirements and other knowledge points.
EPR Effective Soon, European Sellers Compliance Tips - French EPR Essential Readings
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