EPR registration

What is EPR?

EPR stands for Extended Producer's Responsibility, a policy of the European Union. In the European Union, the collection and recycling of waste from most products after consumption are managed through the Extended Producer Responsibility (EPR) system. Producers must ensure their responsibility and obligation to manage waste generated at the end of their product's useful life by paying an "ecological contribution" fee.

Starting from January 2022, if a seller opens a store in Germany or France to sell goods, they must upload their EPR registration number within the specified time. Amazon will have an obligation to confirm that the seller complies with the EPR regulations in the country or region they are selling, otherwise the relevant goods will be forcibly suspended by Amazon. BACL compliance experts remind manufacturers to complete EPR registration and upload actions as soon as possible! As a testing and certification service provider recommended by Amazon SPN and an APASS testing laboratory for Amazon packaging certification, BACL has launched related service projects. Sellers who have needs are welcome to contact us!

Who is the 'producer' in EPR?

According to the official statement, if any of the following conditions are met, it belongs to the "producer":

If goods that meet the extended producer responsibility requirements are manufactured in the corresponding country/region;

If importing goods that require compliance with extended producer responsibility requirements to the corresponding country/region;

3. If goods that require extended producer responsibility are sold in the corresponding country/region and no company is established in that country/region.

Most Chinese sellers belong to the third category of "producers".

If you are a producer of products within the EPR requirements, what do you need to do?

If you are a manufacturer and do not have an EPR registration number, you need to register to obtain it. You must contact the corresponding producer responsibility organization (PRO) for each EPR product category to obtain an EPR registration number;

If you are not a manufacturer but the products you sell meet EPR requirements, you need to obtain the applicable EPR registration number from the upstream supplier;

If you are not a manufacturer and cannot obtain an applicable EPR registration number from upstream suppliers, you will need to register your own EPR registration number.

Which products require an EPR registration number to be provided to Amazon?

What is the difference between EPR policy and Germany's existing packaging, WEEE, and battery laws?

EPR is an environmental protection policy introduced by the European Union, while German packaging laws, WEEE, and battery laws are regulatory requirements implemented in specific countries based on this policy directive. These regulations require products to be properly disposed of in the German region, from packaging, products, batteries to disposal.

EPR registration upload process:

Obtain EPR registration number → Upload EPR registration number (currently not required) → Mark the product with relevant tags

German station: The registration numbers of the following regulations can be used as EPR registration numbers that meet the requirements:

• Packaging: Registrierungsnummer

Electronic and electrical equipment: WEEE-Reg-Nr.DE

• Battery: Batt-Reg. - Nr.DE2

France Station: In the future, different product categories will be unified into one UIN ("Identity Unique"), which has not yet been unified. Sellers can contact the relevant producer responsibility organization (PRO) for each EPR product category to obtain an EPR registration number.

What documents are required to register EPR?

• Scanned copy of business license • Store information • Product information

• Product sales quantity • VAT number

How long does it take to register EPR?

• France: about 2-10 weeks • Germany: about 4-12 weeks

What other tasks do I need to do after obtaining the EPR registration number?

After registering for EPR, sellers also need to put relevant marks on the products they sell. Including but not limited to the following:

Print the trash can logo on the electronic and electrical products and packaging sold;

Print the recycling registration number on the sales invoice;

Print the logo of a French packaging recycling company on the packaging paper box;

French electronic appliance sellers are required to list environmental protection payments on their invoices.

Is it necessary to register for EPR?

Starting from 2022, goods exported to Germany or France must obtain an EPR registration number, otherwise they will be considered illegal and punished with suspension of sales.

Is there a fee for registering EPR?

EPR registration is charged based on different product categories.