Extended Producer Responsibility (EPR) is an environmental policy principle that holds producers responsible for the entire lifecycle of their products—from design to end-of-life management. According to EPR obligations, a producer can be not only the company that physically manufactures a product but also the one that first introduces it to the market and sells it to the end customer. Amazon is required to ensure that sellers’ activities comply with EPR regulations in the countries where they sell. Here’s 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 necessary. Without an active registration number, your products will not be visible to customers. Besides registering in the LUCID system, the seller must have a valid license in the dual system, where they must annually report the quantities of packaging introduced to the German market and pay recycling fees based on these quantities.

France (FR) For sales in France, EPR compliance 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. Like in Germany, sellers are required to periodically report and pay recycling fees.

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

Spain (ES) Starting 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, recovering these costs later. Waste regulations in Spain apply to sellers from the first product introduced to the market. Sellers must also cooperate with recycling organizations in Spain via COOMBES, report introduced quantities, and pay appropriate fees.

EPR Reporting 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: Packaging used to wrap the product, e.g., branded box.
• Secondary packaging: Shipping packaging, e.g., transport carton.

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

Summary

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

Do you need support in managing EPR obligations? Contact us to ensure full compliance with regulations in every market where you sell.