Since 2022, the EU, including Amazon, requires manufacturers and sellers to comply with Extended Producer Responsibility (EPR) regulations, which also apply to marketplaces.
What is EPR
EPR (Extended Producer Responsibility) is an EU environmental regulation that places the responsibility for the ecological cycle of a product on the manufacturer or reseller. This cycle encompasses the entire lifespan of the product, from its creation (manufacturing) through its entire lifespan to disposal and material collection.
Under EPR regulations, responsible entities must minimize environmental impact throughout the product's entire life cycle. This includes considerations from production to disposal, ensuring sustainable practices are followed at each stage.
Does This Obligation Apply to You?
According to the EU and Amazon, you are considered a "Producer" under the following scenarios:
Manufacturing Products:
You manufacture a product that falls under EPR categories in the respective country.
Importing Products:
You import products that are categorized under EPR in the respective country.
Selling Products Without Local Presence:
You sell a product that falls under EPR categories and your company does not have a registered office in the respective country.
What Needs to Be Done
If you are a manufacturer of products subject to EPR requirements, you are required to provide Amazon with your EPR registration number(s). Below are the product categories under EPR requirements for France and Germany, for which you must provide Amazon with the EPR registration number(s).
If you are a manufacturer and do not have an EPR registration number, you must register to obtain one. To acquire the EPR registration number(s), you must contact the relevant Producer Responsibility Organisation (PRO) for each EPR product category.
If you are not a manufacturer but sell products subject to EPR requirements, you must obtain the appropriate EPR registration numbers from your upstream supplier and provide these numbers to Amazon.
If you are not a manufacturer and cannot obtain the necessary EPR registration number(s) from your upstream supplier, you must register and provide Amazon with your own EPR registration number(s).
EPR Categories
When Do You Comply with EPR
If you are a manufacturer or need to register because you cannot obtain the appropriate EPR registration number(s) from your supplier, the process includes:
Step 1: Registration
Registration is a one-time process to obtain the EPR registration number(s) required to demonstrate compliance with EPR requirements.
After obtaining the EPR registration number(s), you must notify Amazon as proof of compliance.
In Q4 2021, Amazon will provide a link to upload the EPR registration number.
Step 2: Declaration and Reporting
You must declare your sales (of products falling under various EPR categories) to the relevant Producer Responsibility Organisation (PRO) for the respective reporting period.
Step 3: Payment
You must pay environmental contributions to the relevant PRO(s).
Environmental contributions are determined by the PRO based on the product category, such as EPR and type of device (e.g., refrigerator, children's clothing, chairs), product attributes (e.g., packaging material, furniture materials), and the number and/or weight of units sold.
How to Register for EPR
To assist you with the EPR registration process, we have prepared a manual.
FAQ
I am a seller only through FBM. Does this apply to me?
I am a seller only through FBM. Does this apply to me?
Yes, Amazon requires all sellers to comply with EPR, regardless of whether they use Fulfilment by Amazon (FBA) or FBM.
When does this apply to me?
When does this apply to me?
Before listing a product in France and/or Germany, manufacturers must complete the EPR registration process and obtain EPR registration number(s) for all relevant product categories.
Do I need to register for different countries and different EPR product categories?
Do I need to register for different countries and different EPR product categories?
Yes, different registration requirements, procedures, and competent authorities apply for each country and EPR product category offered on Amazon.de and Amazon.fr.
How often do I need to report my sales and pay EPR fees?
How often do I need to report my sales and pay EPR fees?
Reporting and payment of EPR fees are done monthly, quarterly, or annually, depending on the EPR categories and Producer Responsibility Organizations (PROs) in each country.
How much will it cost me?
How much will it cost me?
EPR registration fees vary by PRO and can range from 0 to over 250 EUR.
What other steps do I need to take to comply with EPR?
What other steps do I need to take to comply with EPR?
In France, if the EPR product category is electrical and electronic equipment (EEE) or furniture, you must transfer the eco-contributions listed on your supplier's invoice to your own invoice.
EPR Information Resources
FR
DE