EPR compliance requirements have been circulating for a long time. Since September, sellers have received compliance requirements documents from Amazon, requesting to upload the EPR registration number within the specified time. Starting from January 2022, if a seller opens a store in Germany or France to sell products, Amazon will be obliged to confirm that the seller complies with the (EPR) regulations in the country or region where the seller is selling, otherwise the related products will be forced to stop sales by Amazon.

BACL organizes practical knowledge points for you to help you quickly understand some useful and important information.

What is EPR (Extended Producer Responsibility)?

Extended Producer Responsibility (EPR) is an environmental policy that makes a producer responsible for the entire life cycle of the products that they introduce on the market, from their design until the end of life (including waste collection and treatment). Under EPR regulations, the liable entities must mitigate the environmental impacts of their products throughout the entire product life cycle.

Who is the "producer" in EPR？

According to the official statement, it belongs to the "producer" if it falls under any of the following conditions:

• If you manufacture a product subject to EPR requirements in the country, or

• If you import a product subject to EPR requirements into the country, or

• If you sell a product subject to EPR requirements in the country and you are not established in that country.

If you are a producer of products within the scope of EPR requirements, what do you need to do?

1. If you are a Producer and do not have an EPR registration number(s), you are required to register to obtain it. You will have to contact the respective Producer Responsibility organisation (PRO) for each EPR product category to obtain the EPR registration number(s). Refer to respective country sections below for detailed instructions on how to register.

2. If you are not a Producer but you sell product(s) subject to EPR requirements, you need to obtain the applicable EPR registration number(s) from your upstream supplier and provide Amazon with this EPR registration number(s) in respect of the product as proof of compliance.

3. If you are not a Producer and cannot obtain the applicable EPR registration number(s) from your upstream supplier, you are required to register and provide Amazon with your own EPR registration number(s).

What are EPR product categories?

Below are the categories of products in the scope of EPR obligations [for France and Germany] for which you need to provide EPR registration number(s) to Amazon.

What is the difference between the EPR policy and the existing German packaging law, WEEE, and battery law?

EPR is an environmental protection policy introduced by the European Union, and the German Packaging Law, WEEE and Battery Law are based on the regulatory requirements implemented in specific countries in accordance with this policy directive. These laws and regulations all require that products be properly handled in Germany, from packaging, products to batteries until they are discarded.

EPR registration upload process

Obtain EPR registration number → Upload EPR registration number (currently not required) → Put relevant marks on the product

German station: The registration number of the following regulations can be used as the EPR

registration number that meets the requirements:

• Packaging: Registrierungsnummer

• EEE: WEEE-Reg.-Nr.DE

• Battery: Batt-Reg.-Nr. DE2

France station: In the future, different product categories will be unified into one UIN ("Identifiant Unique"), which has not yet been unified. Sellers can contact the relevant Producer Responsibility organization (PRO) of each EPR product category to obtain the EPR registration number.

What information is required to register for EPR?

• Copy of business license

• Store Information

• Product information

• The number of products sold

• VAT tax number

How long does it take to register for EPR?

France: about 2-10 weeks

Germany: about 4-12 weeks

What other work needs to be done after obtaining the EPR registration number?

After registering for EPR, sellers also need to put relevant marks on the products for sale. Including but not limited to the following:

• Print the trash can logo on the electronic and electrical products and packaging sold;

• Print the recycling registration number on the sales invoice;

• Mark the French packaging recycling company logo on the packaging carton;

• French sellers of electronic appliances need to list environmental protection payments on their invoices.

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Is it necessary to register for EPR?

Starting from 2022, goods exported to Germany or France must obtain an EPR registration number, otherwise they will be deemed illegal and will be punished and suspended.

Is there a fee for EPR registration?

EPR registration fee varies according to different categories.

BACL Experts Caution:

Regarding the implementation date of the new Amazon EPR regulations in 2022, there are only less than 2 months left. Manufacturers are requested to complete EPR registration and upload as soon as possible! As the testing and certification service provider recommended by Amazon SPN and the Amazon Packaging Certification APASS testing laboratory, BACL has rich testing and certification experience and has already launched related services. Sellers who need to register are welcome to contact the BACL sales window at any time.

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