Extended Producer Responsibility (EPR) on Amazon: Key Information for Sellers

Extended Producer Responsibility (EPR) is a principle of environmental policy that places responsibility on producers for the entire lifecycle of products - from design to management after the end of its lifecycle. Under the EPR obligation, a producer can be not only the company that physically produces the product but also the one that first places it on the market and sells it to the end customer.

Amazon is obligated to confirm that the actions of sellers are in compliance with EPR regulations in the countries where they are selling. Here’s what you need to know to meet these requirements:

EPR registration in different countries

Germany (DE)

To sell in the German market, registration in the LUCID system is necessary. Without an active registration number, your products will not be visible to customers. In addition to registration in the LUCID system, the seller must have a valid dual licensing, where quantities of packaging placed on the German market must be reported annually, and based on these quantities, recycling fees must be paid.

France (FR)

For sales in France, compliance with EPR may require registration in several categories. Each seller must have a UNI number for product packaging and shipping packaging. Additionally, certain product categories, such as furniture, clothing, toys, chemicals, and electronics, require additional registration. Similar to Germany, sellers are obligated to report periodically and pay recycling fees.

If you do not provide Amazon with a valid EPR registration number corresponding to EPR-eligible products, Amazon will pay the appropriate environmental fees on your behalf to the organizations responsible for producers and will recover those amounts from you.

Spain (ES)

As of the end of 2023, the Spanish market requires EPR registration on Amazon. If you do not provide a valid registration number, Amazon will register and pay the appropriate fees for you, later recovering those costs. Waste regulations in Spain apply to sellers from the first product placed on the market. Sellers must also cooperate with recycling organizations in Spain through COOMBES, report the quantities placed on the market, and pay the appropriate fees.

Reporting EPR on Amazon

Amazon has created a dedicated EPR report that provides information on estimated packaging quantities. The report is divided into two categories:

Primary packaging: The packaging used to wrap the product, e.g., branded box.

Secondary packaging: Shipping packaging, e.g., cardboard for transport.

Information on secondary packaging quantities is particularly important for sellers using Fulfillment by Amazon (FBA) in Germany, where reporting the quantities of secondary packaging used during shipments has been required since July 1, 2022.

Summary

Managing EPR obligations is crucial for compliance with regulations in various Amazon markets. Make sure you have all required registrations and report the quantities of packaging placed on the market regularly. Adhering to these rules will help avoid legal and financial issues while ensuring compliance with environmental policy.

Need assistance in managing EPR obligations? Contact us, we can help!