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

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

Amazon is obligated to ensure that sellers' actions comply with EPR regulations in the countries where they sell. Here is what you need to know to meet these requirements:

EPR Registration in Different Countries

Germany (DE)
To sell on the German market, registration in the LUCID system is required. 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 license in the dual system, where they must report the quantities of packaging placed on the German market every year and pay recycling fees based on those quantities.

France (FR)
In the case of selling 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, some product categories, such as furniture, clothing, toys, chemicals, and electronics, require additional registration. Similarly to Germany, sellers are required to report periodically and pay recycling fees.

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

Spain (ES)
From 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 collaborate with recycling organizations in Spain through COOMBES, report the quantities placed on the market, and pay the appropriate fees.

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

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

• Secondary packaging: shipping packaging, e.g., box for transport.

Information on the quantities of secondary packaging 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 the 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 policies.

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