From July 1, 2022, EPR registrations are mandatory on Amazon Germany. An EPR (Extended Producer Responsibility) registration is required for all sellers on Amazon Germany using cardboard packaging material. In short; (almost) all sellers must be EPR registered before July 1, 2022. Haven't completed the registration by this date? Then your listings will (likely) be taken offline by Amazon.
What is an EPR registration for?
Extended Producer Responsibility (EPR) is a recently introduced environmental policy principle that makes a seller responsible for the entire lifecycle of the products, including the end of life (including waste collection and processing). In Germany, EPR registrations are maintained in the LUCID packaging register of the Central Packaging Register Service (ZSVR), with the aim of having companies that circulate packaging in Germany also pay for the costs of recycling the packaging waste.
Who does the regulation apply to?
The mandatory EPR registration of Amazon stems from this new policy and currently applies to Germany and France. We do see a clear difference between the countries. For France, an EPR registration is not yet directly mandatory, while in Germany this obligation does apply from July 1. This blog will therefore mainly focus on Amazon Germany.
- If your products have packaging (including secondary packaging for shipping to the end customer) and you sell the products in Germany, an EPR registration is mandatory.
What can you do as a seller to comply with this new obligation?
In short, it must be shown that you comply with this regulation. This can be done via Amazon or another authority. A registration must be done where you receive a number to show that you comply with this regulation.
We explain the different situations and possible action points below.
Situation 1:
You are already registered as a seller on the German market for German packaging via the LUCID packaging register of Stiftung Zentrale Stelle Verpackungsregister (ZSVR).
Option: In this case, only your EPR registration number needs to be provided. The number can be retrieved via the ZSVR website and then entered on Amazon. The link below will take you directly to the relevant page: https://sellercentral-europe.amazon.com/spx/myc/epr-compliance?ref=email_compport_epr1_1-1comm&
Situation 2:
You are not yet registered as a seller on the German market for German packaging.
Option 1: You can register as a seller for EPR services on Amazon.
By registering for this service, you will receive special support from an EPR service provider for one-time registrations and receive ongoing reporting for the first 12 months. After the first 12 months, an annual fee will be paid to Amazon. The amount of this fee depends on the EPR service provider chosen.
Registration for this service can be done via: https://sellercentral-europe.amazon.com/ce-epr-registration/index.html#/sign-up.
After registering, your chosen EPR service provider will contact you to submit your registration applications and your reports to relevant EPR authorities (ZSVR).
Benefits
- No costs in the first year: Amazon covers the one-time fee for registration and Proxy services of the EPR service provider. Additionally, you will receive support as a seller in areas such as reporting and any adjustments to the registration
- Convenience: Amazon and the chosen EPR service provider take the complex, costly, and time-consuming processes off your hands. Amazon will guide you through the EPR registration and reporting. Amazon will request the necessary data and documentation.
Step-by-step plan:
- Step 1: Register via the link above for EPR services on Amazon for packaging.
- Step 2: Provide your business and contact details in the form you are redirected to. Your assigned EPR service provider will then contact you by email and guide you through the application process.
- Step 3: Work directly with the EPR service provider to gather and provide all the information and documents needed to prepare the registration application(s). This step takes place outside Seller Central.
- Step 4: Submit your application for the packaging category using the guidelines of your EPR service provider. For all other product categories, your EPR service provider will submit the application(s) on your behalf (other categories are currently not required for Germany).
- Step 5: Work directly with your EPR service provider to regularly prepare your EPR reports and submit them to the relevant EPR authorities. This step also takes place outside Seller Central.
Option 2: Support with the EPR registration from Amazon’s EPR Registration Support Office.
If this option is chosen, you will be assigned an Amazon contact person as a seller, who will guide you through the registration process by phone. Registration can be done via the following link: https://amazoneu.au1.qualtrics.com/jfe/form/SV_8D187KFokfoyA4e?ref_=rso_signup
Option 3: Apply for an EPR registration with the help of a Follo partner from the EPR Service Provider Network.
The EPR registration can also be arranged in collaboration with a partner of Follo. In this case, Follo will not mediate, but a partner can be chosen directly from the overview below to assist with the EPR registration. In this case, the partner service costs are for you as a seller. The current partners of Follo regarding the German market, who can support the registration, can be found via the following website: https://sellercentral-europe.amazon.com/gc/epr-spn-sellercentral-eu?ref_=epr_email_spn_11_5221
Option 4: Register your organization directly with the ZSVR without the help of Follo or an EPR partner of Follo.
For packaging in Germany, you can register yourself as a seller by following the steps below. Given that the ZSVR, as a supervisory authority, is not allowed to advise on an individual basis and cannot enter into contracts, you are also required as a seller to join one of the partners from step 2.
- Step 1: Register your organization with the ZSVR via the LUCID Packaging Register.
Your company must be registered using your VAT number via the following website: https://lucid.verpackungsregister.org/
Register your organization directly with the ZSVR without the help of Follo or an EPR partner of Follo.
For packaging in Germany, you can register yourself as a seller by following the steps below. Given that the ZSVR, as a supervisory authority, is not allowed to advise on an individual basis and cannot enter into contracts, you are also required as a seller to join one of the partners from step 2.
- Step 1: Register your organization with the ZSVR via the LUCID Packaging Register. Your company must be registered using your VAT number via the following website: https://lucid.verpackungsregister.org/
- Step 2: Join an EPR/PRO organization where you report your sales. Since it is not feasible to retrieve the packaging of your products from Germany yourself, you enlist a company to do this on your behalf. You pay the PRO/EPR partner for the 'packaging waste' you bring into Germany. For example, 'Der Grüne Punkt' can recycle 100 kg of paper for €25 per year (excluding VAT). The quote is requested from the partner and account registration is also done through the partner.
The available partners can be found via the following link: https://www.verpackungsregister.org/en/information-orientation/instructions-further-information/systems-overview#c3519
Benefits:
- Direct contact with the ZSVR, without intermediaries
- No additional mediation costs (only annual costs for registration and compensation)
Disadvantages:
- No mediation in the registration process and reporting
- Little to no help with questions
Consequences of not registering on time:
- If no EPR registration number is provided by July 1, 2022, Amazon will take all listings using cardboard packaging offline.
- This also applies to electronic devices by January 1, 2023.
Other EPR categories in Germany:
- In addition to packaging, EPR registrations for electronic devices and batteries will also become mandatory. At the moment, however, Amazon only asks for an EPR registration number for packaging.
EPR in France:
- For France, a different policy currently applies from Amazon.
- In France, Amazon will pay the eco-contributions to the respective PRO organizations for all sales from January 2022, if no EPR registration number has been submitted.
- This allows sales to continue on Amazon France without required registrations.
- However, you can always register yourself with a PRO for EPR categories applicable to your products and provide Amazon with valid UINs. Amazon will then stop paying eco-contributions.
Categories EPR France:
- Packaging, electrical and electronic equipment (EEE), batteries, printed paper, furniture, textiles, tires & chemicals, and medical equipment.
Conclusion
From July 1, 2022, an EPR registration will be mandatory for (almost) all sellers on Amazon Germany. In this blog, we have provided various options to comply with the new EPR requirements. If you are not yet EPR registered as a seller on Amazon Germany, we recommend addressing this in the coming period so that your listings remain active from July 1. In total, there are 4 options to complete the EPR registration: collaborate with Follo’s EPR services, request support from the EPR Registration Support Office, enlist one of Follo’s (registration) partners, or arrange the registration yourself. Currently, an EPR registration number is requested for packaging processing, but this will later be expanded to include EEE products (electronic devices and batteries). For France, an EPR registration is possible, but a registration is (not yet) mandatory.
