Amazon and other marketplaces will need an EPR registration number from you starting July 1. If you sell products on Amazon Germany, you have probably already received notification of this. If you do not follow this up risk that your products will be taken offline and your German Amazon sales will be lost from the summer. But action is also required for France since the beginning of this year to avoid costs. You can use this link request support for this.
What is the EPR registration number?
EPR stands for "Extended Producer Responsibility" and is mandatory for all sellers who use cardboard packaging. Amazon describes it as "environmental policy" because it makes the seller responsible for the entire life cycle of the products sold, including waste disposal The basis for EPR is not a law, but a composite of various laws and directives. In German law, this includes the laws on the packaging register (VerpackG), as well as the laws on electronic registration requirements (ElektroG) and battery registration requirements (BattG).
In Germany, EPR registrations are kept in the LUCID packaging register of the Zentrale Stelle Verpackungsregister (ZSVR). If you sell in multiple countries, things can get complex. This is because the problem is that each country has its own rules regarding waste legislation. Anyone selling their products through Amazon, for example, must fulfill different obligations in each country and have a unique EPR number for each country.
To whom does this apply?
The registration requirement initially applies only to producers who use cardboard packaging. So if your brand is on the packaging, it is very likely that you are responsible for recycling and registration. This includes both primary and secondary packaging (shipping packaging). For example, consider shoes in a shoe box. The shoe goes into a shoebox; this is the primary packaging. A number of shoe boxes are then placed in a large outer box, the secondary packaging. From Jan. 1, 2023, EPR registration will also apply to producers of electrical and electronic equipment from the ElektroG, and producers of batteries from the BattG.
If you are not a manufacturer, but you do sell products covered by the EPR regulations, you must request the EPR registration number from the supplier. This is, for example, the wholesaler who has already imported the products. If you do not get the EPR registration number from the supplier, but still sell the products in question, you must register the registration number yourself.
Mandatory legislation extends further
It doesn't stop there. If you market packaging in Germany, there are further obligations in addition to EPR registration. The German ZSVR agency launched the LUCID packaging register in January 2019. Since then, all companies selling products to German consumers have been required to register and declare their annual packaging weights.
This means that you must report the amount of packaging you put on the German market per year to this register. This proof must be made by May 15 of each year for the previous calendar year in the form of a report.
If you fail to do so as a company, you risk fines of up to 200,000 euros or even an export ban. But don't worry, it's a quick fix. You can register for this for free at the website www.verpackungsregister.org. In doing so, you are required to indicate a responsible employee of your company. You can also outsource the mandatory administration and recycling to one of the Dual Systems in Germany.
Through Dexport, you can join one of the Dual Systems at an advantageous price.
What should you do if you already have an EPR registration number?
As a seller on the German market, are you already registered for German packaging? Then you just need to provide your EPR registration number to Amazon. You can do that via this link. You can find the number on the ZSVR website.
What if you don't have an EPR yet?
- Register for free with the website www.verpackungsregister.org.
In doing so, you are required to indicate a responsible employee of your company. At this link you will find a YouTube video guiding you step by step through LUCID registration. - Register with a Dual system in Germany
Through Dexport, you can join a Dual system at a discount.
To do so, request email with instructions through Dexport. - Enter the chosen Dual system at www.verpackungsregister.org
After you outsource the job to Zentek, you can add them to your account at www.verpackungsregister.org. - Enter your EPR number in your Amazon seller account
After registering on www.verpackungsregister.org, you will receive the required EPR number. You enter this number into your Amazon seller account. This must be arranged no later than July 1, 2022.
As of Jan. 1, 2022, action is already required in France
In France, new rules around the EPR have already been in place since Jan. 1, 2022. If you have not yet submitted a registration number to Amazon France, but are selling products to customers within France that are covered by the EPR, Amazon will pay an eco-contribution to the organizations they work with.
But that doesn't mean this is free. Amazon will reclaim these payments from you at the end of each quarter or year, depending on the EPR category. So it's important to arrange your EPR registration in France as well, so you don't incur unnecessary costs.
Take action and don't miss out on sales
So make sure you get your EPR registration done by July 1, 2022. Don't wait too long, otherwise you run the risk of Amazon Germany taking your products offline. That's a shame, of course you don't want to lose sales! Not quite getting there? Feel free to contact us, we will be happy to help you.
You can here request an instructional email with a discount code to join a Dual system in Germany.
