What is EPR and who is considered a producer?
What is EPR and who is considered a producer?
Extended Producer Responsibility (“EPR”) is a policy approach under which producers accept significant responsibility – financial and/or physical – for the treatment or disposal of post-consumer products. Assigning such responsibility could provide incentives to prevent wastes at the source, promote product design for the environment and support the achievement of elevated public recycling and material management goals.
A producer can be differentiated from other companies, given the following criteria are met:
- If you manufacture products or import goods that need to meet the EPR requirements in the corresponding country or region.
- If you sell products that need to meet the EPR requirements in the corresponding country or region, and you have not established a company in that country or region.
- For reference, most non-EU-based sellers fit the definition of a producer.
A producer takes the responsibility for financing collection, recycling and end-of-life disposal of various EPR categories that include packaging, WEEE, and batteries.
What has changed and what do sellers need to do?
Starting in 2022, if you sell in France and/or Germany, Amazon will be legally obliged to confirm that you comply with EPR regulations. This applies to all sellers, irrespective of the fulfilment channel. You can prove your compliance on the Compliance Information for EPR page by submitting your registration number(s) and confirming that you comply with all relevant legal requirements.
Amazon reserves the right to contact you for additional information. If you are considered non-compliant, Amazon may need to suspend your non-compliant offers or comply on your behalf.
Germany EPR Obligations in Packaging, WEEE & Batteries
For packaging, you must prove your compliance to Amazon by submitting a registration number (LUCID number) on the Compliance Information for EPR portal by June 14, 2022. Amazon will start blocking non-compliant listings starting June 15, 2022, to comply with the EPR legal requirement – effective July 01, 2022.
For WEEE, in the coming months, you will need to prove your compliance to Amazon by submitting a registration number (WEEE-Reg.-Nr.) on the Compliance Information for Extended Producer Responsibility (EPR). The deadline to register and submit your number for WEEE is January 01, 2023.
For Batteries, you must register with the German Clearing House (“EAR”) and commission a recycling company with disposal before placing the batteries on the market. The German law covers both non-rechargeable batteries, also termed “primary” batteries, as well as rechargeable batteries, also termed “secondary” batteries. The deadline to register and submit your number for batteries is January 01, 2023.
How can TBA Global help sellers to become compliant?
What type of organisation is TBA Global?
Amazon has established the EPR Services Provider Network (SPN) which is a store on the Amazon Seller Central partner network that allows sellers access to agencies to ensure that they can effectuate compliance within the tight deadlines given by authorities (for example, July 01, 2022 for DE packaging).
TBA Global (“TBA”) is an Amazon Seller Central partner that offers EPR services, including but not limited, to guiding and inspecting your company through the whole EPR process.
How can TBA help companies?
TBA Global assists sellers with EPR registration and reporting obligations, thus acts as the point of contact for all questions on EPR compliance. TBA Global also offers local VAT regulation checks to ensure that the process goes smoothly no matter the location of the international client; Preventing local rules from interfering with international rules. For more information, get in touch with TBA Global.
TBA Global
TBA Global work competitively and ambitiously to partner with leading e-commerce platforms and businesses. Our breadth of industry and regulatory knowledge position us to help businesses achieve strategic goals.
TBA Global
TBA Global work competitively and ambitiously to partner with leading e-commerce platforms and businesses. Our breadth of industry and regulatory knowledge position us to help businesses achieve strategic goals.
