FAQ

Extended Producer Responsibility (EPR) is an environmental protection policy that makes the party that first places a product subject to EPR requirements in a country responsible for the entire life cycle of the products it places on the market. From their design to the end of their life (including waste collection and recycling). According to EPR regulations, obliged entities must mitigate the environmental impact of their products throughout the product's entire life cycle.

Note that producer is not equivalent to manufacturer. The producer is the party that first places the product subject to the EPR requirements on the market in the country (France or Germany).

When am I considered a producer?

1. If you manufacture a product subject to EPR requirements in that country.
2. If you are importing a product subject to EPR requirements into the country.
3. If you sell a product subject to EPR requirements in a given country and you do not have a registered office in that country.

Starting in 2022, if you are selling in France or Germany, marketplace operators will be required by law to certify that the country you are selling in is EPR compliant. Marketplace will therefore verify your EPR registration numbers.

If you do not demonstrate EPR compliance to your marketplace, you can expect the following actions.

Germany: Marketplace will be obliged to suspend your non-compliant listings falling under the designated EPR product category:

Packaging: all listings from July 1, 2022

Electrical and Electronic Equipment (EEE): all listings falling under EEE from 1 January 2023.

France: If you sell EPR products on the Marketplace to customers with a delivery address in France, but you do not provide your Marketplace with valid EPR registration numbers corresponding to your product categories. Marketplace will pay the corresponding amount to the qualified Producer Responsibility Organization(s) (PRO) and collect that amount from you + you will pay the higher fees on the goods sold. In most cases, it pays to register EPR directly to avoid Amazon's higher fees.

If you are a producer of products within the scope of EPR requirements, you will be required to provide your registration number/numbers to your Marketplace.

If you are a producer and do not have an EPR registration number, you must register to obtain one. 

If you are not a manufacturer but sell product(s) subject to EPR requirements, you must obtain the appropriate EPR registration numbers from your supplier and provide them to your Marketplace.

If you are not a manufacturer but cannot obtain the appropriate EPR registration numbers from your supplier, you must register and provide your Marketplace with your own EPR registration number(s).

The product categories listed below are subject to EPR obligations (for France and Germany) for which you must provide the EPR registration number(s) on your Marketplace.

If you are a producer or need to register because you cannot get the appropriate EPR number/number from your supplier, please follow this description of the steps you need to take to become EPR compliant.

Step 1: Registration

Registration is a one-time process to obtain EPR registration numbers needed to demonstrate compliance with EPR requirements. Once you receive your EPR registration number(s), you will need to provide them to your Marketplace as proof of EPR compliance.

Step 2: Declaration and reporting

You must declare your sales (of products included in the various EPR categories) to the relevant Producer Responsibility Organization (PRO) for the relevant reporting period.

Step 3: Payment

You must pay environmental contributions to the relevant Producer Responsibility Organization (PRO). Environmental contributions are defined by PRO organizations depending on the EPR product category and equipment type (e.g. refrigerator, children's clothing, chairs), product attributes (e.g. packaging material) and the number or weight of units sold.

Yes, if you have already registered all products falling under the EPR, you should provide your Marketplace with your registration numbers/EPR number.

Yes. Marketplace must certify that all sellers are EPR compliant regardless of shipping method.

Before a product is listed in France or Germany, the producer must ensure that the EPR registration process is completed and that he has received the EPR registration number/numbers for all relevant product categories.

Yes. There are different registration requirements, processes and authorized bodies for each country.

Declarations and payments of EPR contributions are made monthly, quarterly or annually, depending on the EPR category and the Producer Responsibility Organization (PRO) in each country.