发表时间： 2021-11-05 18:23:30
New EPR regulations are coming for German and French sites! Any store closing risk if not registered！
Recently, a term ‘EPR’ has appeared frequently in the cross-border E-commerce field. The emergence of new EPR regulations can be head- scratching for sellers on European sites!
Recently，many sellers have received notice emails from Amazon starting from fourth quarter of this year. The content of email highlights: Starting from January 1, 2022, sellers who sell goods in Germany and France must upload their EPR registration numbers to Amazon, otherwise they will mandatory halt sales!
In this article， Sea&Mew will introduce you the new rules of EPR and how to prevent relevant risk in future sales.
EPR(Extended Producer’s Responsibility)即生产者责任延伸法规，是一项环境政策，要求生产者对其市场上所推出商品的整个生命周期负责，即从商品设计开始到生命周期结束（包括废弃物收集和处理）。
1. What is EPR？
EPR (Extended Producer's Responsibility) is an environmental policy that requires producers to be responsible for the entire life cycle of their products on the market, which is from the beginning of the product design to the end of the life cycle (including waste collection and dispose).
2. Products be involved in EPR
EPR Product categories
Packaging products（Carton，Plastic，Drink Bottle）
Electric and electronic equipment
Household appliances, Lamps, electronic device
Portable battery, Car battery, Industrial battery
Household furniture, Professional furniture
Car Tyre，Agricultural Tyre, Heavy construction machinery tires
Wasted paper, Print（Product user guide, Gift card, Wall paper）
√：EPR registration required
×：EPR registration non- required
3. Do you need EPR registration?
Normally, you’ll perform EPR obligations if you have matched any one of the following three conditions:
l Made products that need to meet the extended producer responsibility requirements in Germany and France ;
l Import goods that need to meet the extended producer responsibility requirements in Germany and France;
l Sell products that need to meet the extended producer responsibility requirements in Germany and France, and there is no company established in Germany and France.
Sellers on online platforms such as Amazon, eBay, and AliExpress usually meets the third condition.
Extended question: Do self-delivering sellers still need to fulfill the EPR obligation?
The answer is yes. The fulfillment of the EPR obligation does not depend on the sales method or sales volume. It’s necessary to register for EPR even there are only few sales per month.
4. How often does seller needs to declare the market volume?
It’s determined by the EPR commodity classification and EPR regulatory authorities in that country. In Germany, the packaging law is supervised by LUCID. They stipulate that sellers should declare twice a year and pay the recycling fee of the packaging according to the requirements of the recycling company. Waste Electrical and Electronic Equipment and batteries are supervised by the Stiftung ear, and they require the sellers who comply with the WEEE (ElektroG) regulations make declarations on monthly and year-end ; the sellers who comply with the Battery Law and Regulations (BattG) should make declarations twice a year.
Regarding the declaration and recycling of EPR in France, the current French policy is not very mature, seller might make declaration for previous year market value in current year.
5. What is the consequence if not register the EPR for relevant products?
The German and French authorities require that cross-border platforms need to notify sellers on their platforms to register EPR, and sales should be pause before obtaining the EPR certificate. If the seller violates obligations under the local environmental law, he will be punished as follows:
The maximum fine up to 1 million euros;
The income from the country (Germany and France) is considered to be illegal and will be confiscated;
Sales will be prohibited until the fine is paid.
At the end
Although this new EPR regulation will only take effect in 2022, but German sites is checking WEEE (ElektroG) regulations all the time. Sellers who have registered for WEEE know that the registration time in Germany is relatively long, and the number of registrations submitted usually increases in the later period of registration. The registration time may extended a lot due to high workload, so sellers should also consider the issue of registration time.
Is better to check early whether your products meet the requirements and register as soon as possible to avoid the risk of suspension of sales.
EU regulations is always complicated. Feel free to contact us if you have any question!