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This article applies to selling in: France

Extended Producer Responsibility (EPR) Education

What will change for sellers in FR and DE?

Starting 2022, if you sell in France and/or Germany, Amazon will be legally obliged to confirm that you are Extended Producer Responsibility (EPR) compliant in the country you sell. Amazon will therefore collect and validate your EPR registration number(s).

For Germany, please follow the link to the EPR Compliance portal in Seller central to upload the EPR Registration Number(s): EPR Compliance Portal Germany.

For France, Amazon will share the link to upload the EPR Registration Number(s) in the course of January 2022.

What happens if you cannot prove your EPR compliance to Amazon?

Germany

Amazon will be legally obliged to suspend your non-compliant listings under EPR product categories.

  • Packaging, both primary (i.e. product packaging) and secondary (i.e. shipping packaging) – all listings from July 1, 2022
  • Electric and Electronic Equipment (EEE) – all listings falling under EEE from January 1, 2023

France

If you are selling EPR applicable products on amazon.fr to customers with a shipping address in France, but do not provide Amazon with the valid EPR Registration Number(s) corresponding to those EPR applicable products, Amazon will by default pay corresponding EPR eco-contributions to the qualified Producer Responsibility Organizations(s) on your behalf and recover these amounts from you.

What is Extended Producer Responsibility (EPR)?

Extended Producer Responsibility (EPR) is an environmental policy that makes the party who first places a product subject to EPR requirements in the country (also known as “Producer” for EPR) responsible for the entire life cycle of the products that they introduce on the market, from their design until the end of life (including waste collection and take-back). Under EPR regulations, the liable entities must mitigate the environmental impacts of their products throughout the entire product life cycle.

Am I a Producer?

Please note that Producer is not an equivalent of a manufacturer. The Producer is the party who first places a product subject to EPR requirements (EPR product categories detailed below) in the country (France or Germany). You can be considered as a “Producer” if any of the below options apply to you:

  • if you manufacture a product subject to EPR requirements in the country, or/and
  • if you import a product subject to EPR requirements into the country, or/and
  • if you sell a product subject to EPR requirements in the country and you are not established in that country.

For packaging specific requirements, please refer to country-specific information section below.

What do I need to do?

If you are a Producer of products in the scope of EPR requirements, you will be obliged to provide your EPR registration number(s) to Amazon. See below the categories of products in the scope of EPR requirements for France and Germany for which you need to provide EPR registration number(s) to Amazon.

If you are a Producer and do not have an EPR registration number(s), you are required to register to obtain it. You will have to contact the respective Producer Responsibility Organization for each EPR product category to obtain the EPR registration number(s). Refer to respective country sections below for detailed instructions on how to register.

If you are not a Producer but you sell product(s) subject to EPR requirements, you need to obtain the applicable EPR registration number(s) from your upstream supplier and provide Amazon with this EPR registration number(s) in respect of the product as proof of compliance.

If you are not a Producer but cannot obtain the applicable EPR registration number(s) from your upstream supplier, you are required to register and provide Amazon with your own EPR registration number(s).

What are EPR product categories?

Below are the categories of products in the scope of EPR obligations [for France and Germany] for which you need to provide EPR registration number(s) to Amazon.

EPR Category France Germany
1 Packaging * *
2 Electric and Electronic Equipment (EEE) * *
3 Batteries1 * *
4 Furniture *

5 Tires *

6 Paper *

7 Textile *

8 Chemicals *
9 Medical Piercing Equipment for Auto-treatment *

1.Battery obligation in Germany: If you offer an EEE product containing a battery, you have to register for both EEE and Battery.

What does it mean to be EPR compliant?

If you are the Producer or you need to register because you cannot obtain the applicable EPR registration number(s) from your upstream supplier, follow this high-level description of the steps you need to take to become EPR compliant.

Step 1: Registration

  • Registration is a one-time process to obtain the EPR registration number(s) needed to prove compliance with EPR requirements.
  • Once you receive the EPR registration number(s), you will need to communicate it to Amazon as proof of compliance.
    • For Germany, please follow the link to the EPR Compliance portal in Seller central to upload the EPR Registration Number(s): EPR Compliance Portal Germany
    • For France, Amazon will share the link to upload the EPR Registration Number(s) during the course of January 2022.

Step 2: Declaration and Reporting

  • You must declare your sales (of products covered by the different EPR categories) to the respective Producer Responsibility Organization for the applicable reporting period.

Step 3: Payment

  • You must pay eco-contributions to the relevant Producer Responsibility Organization(s). The eco-contributions are defined by the Producer Responsibility Organizations depending on the EPR product category and device type (e.g. refrigerator, baby clothing, chair), product attributes (e.g. packaging material, materials of furniture) and number and/or weight of units sold.

Country-specific information

Germany

Proof of Compliance in Germany

In Germany, the EPR registration number(s) stands as proof of compliance. To get this number(s), you have to register with the relevant EPR registry (see table below). Once you receive the EPR registration number(s), you will need to communicate it to Amazon as proof of compliance. Please follow the link to the EPR Compliance portal in Seller central to upload the EPR Registration Number(s): EPR Compliance Portal Germany

Please note: at this stage, you can only add a LUCID number for Germany packaging. While you must be registered if you sell products in other EPR product categories, you can’t submit the registration number yet. We will keep you updated in 2022 on when you can submit additional Registration numbers for other EPR categories

Starting July 1st 2022, as per the amended packaging law in Germany, you will be considered as a producer for FBA-packaging used for shipment of your products, if applicable.

The EPR categories and executing agencies are detailed in the table below.
EPR Categories Description Executing Agency
Packaging1 All packaging types https://lucid.verpackungsregister.org/
Electrical and Electronic Equipment (EEE)
  • Temperature exchange equipment
https://www.ear-system.de/ear-portal/#no-back
  • Screens, monitors and equipment containing screens having a surface greater than 100 cm2
  • Lamps
  • Equipment with any external dimension more than 50 cm (Large equipment)
  • Equipment with no external dimension more than 50 cm (Small equipment)
  • Small IT and telecommunication equipment with no external dimension more than 50 cm
Batteries2 Automotive, industrial and Portable Battery

1Packaging: In Germany, you are responsible for both primary and secondary packaging. If your secondary packaging is provided by a fulfillment service provider, your provider will be responsible for secondary packaging until June 30th 2022. Starting July 1st2022, you will be responsible both for the primary and secondary packaging. This applies to Fulfillment by Amazon and any other fulfillment service provider.

2Battery obligation: In Germany, if you offer an EEE product containing a battery, you have to register for both EEE and Battery.

Amazon will only require the EEE registration number at this stage.

The following registration numbers stand for your proof of compliance:

  • Packaging: Registrierungsnummer
  • EEE: WEEE-Reg.-Nr.DE
  • Battery: Batt-Reg.-Nr. DE2

France

Proof of Compliance in France

In France, to prove your compliance, Amazon will require to have your Unique Identification Numbers (UINs). To get a UIN, you have to register with the relevant Producer Responsibility Organizations (see table below) depending on your catalogue. UINs will be generated automatically from January 2022 onwards for all registered sellers and available to you via your Producer Responsibility Organization(s)s’ portal. You will need to provide these UINs to Amazon via Seller Central. Amazon will share the link to upload the EPR Registration Number(s) during January 2022 for France.

The EPR categories and Producer Responsibility Organizations are detailed in the table below.

# EPR Categories FR Product Description Examples Producer Responsibility Organisations (PRO)
1 Electric and Electronic Equipment (EEE) Waste generated by Electrics and Electronics Equipment Household products, lamps, fire extinguishers and professional electronic products

https://www.ecosystem.eco

https://www.ecologic-france.com

https://www.soren.eco/ (solar panel only)

2 Batteries Used batteries and accumulators Portable, automotive and industrial batteries

https://www.corepile.fr/

https://www.screlec.fr/

3 Packaging1 Waste from households packaging Boxes and packaging of products (e.g. box containing a toy), shipping boxes, shipping labels, tapes, etc.

https://www.citeo.com

https://www.leko-organisme.fr

4 Print Paper Waste from graphics papers Printed items such as user manuals, wall papers, gift cards, advertising inserts https://www.citeo.com
5 Furniture Waste generated by furniture equipment Household and professional furniture

https://www.eco-mobilier.fr

https://www.valdelia.org

6 Textiles Textiles, household linens, shoes, etc. Clothing textiles, household linens and shoes https://refashion.fr/pro/fr
7 Tires Waste generated by tires Automotive, agrarian and heavy handling civil tires

http://www.gie-frp.com

https://aliapur.fr

8 Chemicals Chemical waste generated by household Glue, paint, car polish, acetone, vaseline, mastic https://www.ecodds.com/
9 Medical Piercing Equipment for Auto-treatment Waste generated by piercing equipment used by patient in auto-treatment Needles, micro-perfusion, catheter, pen with retractable needle https://www.dastri.fr/
1. PACKAGING related obligation: In France, you are accountable for your primary packaging and the secondary packaging added by you.

EPR Requirements Policy for Third-Party Sellers in France

If you sell products in France from amazon.fr that fall under one or more of the EPR product categories, but did not provide Amazon with a valid UIN corresponding to those EPR product categories, Amazon will report the quantities of products you have sold in France from amazon.fr and pay the corresponding eco-contributions on your behalf for you to continue sales.

Take-back requirements

What is take-back ?

The take-back service is part of the EPR requirements which has already been mandated by the national laws in Germany and France. In line with the existing legislation, today if you sell EEE products in Germany and France marketplaces, you must provide the customers with the possibility to return their old similar type products for recycling, at the customers’ doorstep and free of charge.

Am I eligible for take-back?

If you are currently offering EEE products in Germany and France, you have already been obliged to provide the customers with EEE take-back services. As of 1st January 2022, the following additional categories will be included in France take-back obligations; furniture, chemicals and single use gas fuel cartridges.

What will change?

As of 1st January 2022, you will need to display take-back information when selling on amazon.de and/or amazon.fr.

What do I need to do for take-back?

If you sell take-back eligible EPR product categories, you must offer take-back services to enable customers to return their old similar equipment with free of charge.

As of 1st January 2022, you will need to display take-back information when selling on amazon.de and/or amazon.fr. In order for you to understand customers’ intention to recycle their old product, Amazon will display the following question on the product detail page of the respective categories: “Want to recycle your electrical or electronic appliance for free? (In Germany: Do it here. And in France: Do it here)”. Customers will be requested to contact the sellers via Seller Storefront Page.

We recommend you to display your take-back information on your Seller Storefront Page considering to use the following wording. Please do not make any amendment on the We recommend to use the following wording text apart from seller name, authorized representative name (if applicable) and registration number.
  • Germany:

    WEEE: To recycle your old waste electrical and electronic equipment, please notify the seller using the “Ask a question” button on the top right-hand corner. XXX (seller name) is registered with Stiftung ear for Electrical and Electronic Equipment sold in Germany. The registration number is DE12345678 (WEEE registration number). XXX’s (seller name) authorized representative is XXX (authorized representative’s name, if any). For more information about recycling with Amazon, visit Recycling at Amazon.

  • France:

    • WEEE: To recycle your old waste electrical and electronic equipment (WEEE), please notify the seller using the “Ask a question” button on the top right-hand corner. If you have any issues with notifying the Seller regarding your take-back request, please proceed to the Amazon Help Page. XXX (seller name) is registered with XXX (name of the scheme) for Electrical and Electronic Equipment sold in France. The registration number is 12345678 (seller’s UIN). XXX’s (seller name) authorized representative is XXX (authorized representative’s name, if any). For more information about recycling with Amazon, visit Recycling at Amazon.
    • Furniture: To recycle your old furniture, please notify the seller using the “Ask a question” button on the top right-hand corner. If you have any issues with notifying the Seller regarding your take-back request, please proceed to the Amazon Help Page. XXX (seller name) is registered with XXX (name of the scheme) for Furniture sold in France. The registration number is 12345678 (seller’s UIN). XXX’s (seller’s name) authorized representative is XXX (authorized representative’s name, if any). For more information about recycling with Amazon, visit Recycling at Amazon.
    • Chemicals: To recycle your old chemicals, please notify the seller using the “Ask a question” button on the top right-hand corner. If you have any issues with notifying the Seller regarding your take-back request, please proceed to the Recycling at Amazon. XXX (seller name) is registered with XXX (name of the scheme) for Chemicals sold in France. The registration number is 12345678 (seller’s UIN). XXX’s (seller name) authorized representative is XXX (authorized representative’s name, if any). For more information about recycling with Amazon, visit Recycling at Amazon.
    • Single use gas fuel cartridges: To recycle your old single use gas fuel cartridges, please notify the seller using the “Ask a question” button on the top right-hand corner. If you have any issues with notifying the Seller regarding your take-back request, please proceed to the Recycling at Amazon. XXX (seller name) is registered with XXX (name of the scheme) for single use gas fuel cartridges sold in France. The registration number is 12345678 (seller’s UIN). XXX’s (seller name) authorized representative is XXX (authorized representative’s name, if any). For more information about recycling with Amazon, visitRecycling at Amazon.

What are the types of take-back obligations?

There are two types of take-back obligations that result from the Germany EEE Act and the French Circular Economy Law:

  • 1:1 obligation: taking back a used product from a customer on the condition that the customer has purchased a new product only for selected categories in scope.
  • 1:0 obligation: taking back a used product even if the customer has not purchased a new product.
You are subject to 1:1 take-back obligation by default if you sell take-back eligible EPR product categories. 1:0 take-back obligation is subject to a case-by-case assessment depending on the characteristics of your physical stores, if applicable.

Country-specific information regarding take-back requirements

What do I need to do in Germany?

If you offer customers EEE products via Amazon in Germany, you need to offer a take-back service free of charge for EEE products of the same type on a 1:1 basis by default. The old product can come from any sales channel (i.e. from either Amazon or any other online/offline shops). This needs to include a free pick-up service at the household level. EEE categories 1), 2), and 4) must be picked up at the household level of the customers free of charge whilst category 3), 5), and 6) must be taken back in reasonable proximity to end user free of charge (e.g. via service providers, collection points, etc.). Please refer to table above for EEE categories in Germany.

In addition, you can display your take-back and WEEE registration number information on your seller storefront page using the recommended text above.

What do I need to do in France?

If you offer customers EEE products, furniture, chemicals, single use gas fuel cartridge products via Amazon in France, you need to offer a take-back service free of charge for these products of the same type on a 1:1 basis by default. This needs to include a free of charge pick-up service at the point of delivery or at a local collection point in case of transportable products. The old product can come from any sales channel.

In addition, you can display your take-back and UIN information on your seller storefront page using the recommended text above.

Frequently asked questions - General

I am already fulfilling my EPR obligations. Do I have to let Amazon know?

Yes. If you are already registered for all your EPR applicable products, you should provide Amazon with your EPR registration numbers(s). For Germany, please follow the link to the EPR Compliance portal in Seller central to upload the EPR Registration Number(s): EPR Compliance Portal Germany. For France, Amazon will share the link to upload the EPR Registration Number(s) in the course of January 2022.

I am a Self-Ship seller. Does this apply to me?

Yes. Amazon has to confirm that all sellers are EPR compliant irrespective of using Fulfilment by Amazon (FBA) or Self-Ship.

When am I impacted?

Before a product is listed in France and/or Germany, the producer must ensure that the EPR registration process is completed and he received the EPR registration number(s) for all applicable EPR product categories.

Do I need to register for different countries and different EPR product categories?

Yes. There are different registration requirements, processes and authorized bodies for each country and for the EPR product categories offered on amazon.de and amazon.fr.

How often do I need to report my sales and pay the EPR contributions?

Declarations and payments of EPR contributions are conducted monthly, quarterly or yearly – depending on the EPR categories/ Producer Responsibility Organizations in each country.

Will Amazon provide help with EPR reporting?

Amazon is developing a reporting tool which will help you to download reports for EPR product categories in France and Germany. Information in these reports could be used to declare your sales of products covered by the different EPR categories.

Do I need to pay for both primary (product packaging) and secondary (shipping) packaging?

Primary packaging (products’ own packaging) – Yes, both Fulfilment by Amazon (FBA) or Self-Ship sellers need to pay for primary packaging. Primary packaging is the packaging unit used to wrap the product, for example, the branded box of a pair of shoes or the aluminum can containing a soft drink.

Secondary packaging (shipping packaging) – please refer to country specific section above for further information. Secondary packaging refers to shipping boxes/bags used to protect the product during transport to the customer. This can be extended to filling material to protect the product and tapes to secure the package. Shipping labels are also a part of secondary packaging.

How much will it cost me?

EPR registration: You will have to pay registration fees to the different Producer Responsibility Organization(s). This may range from €0 - €250+.

Eco-contributions: Eco-contributions are calculated based on the sales and the EPR product categories which vary from country to country. Each Producer Responsibility Organization maintains its own list of prices as per contractual agreements.

What if my EPR number isn't accepted within EPR Compliance portal in Seller Central?

Perform the following troubleshooting steps:

  1. Ensure that the number(s) you are providing is an EPR registration number;
  2. Double check that the EPR registration number is input correctly within the portal in Seller Central;
  3. Check that the EPR registration number corresponds for the right category you are registering in;
  4. onnect with the appropriate agency to ensure that the EPR number is correctly associated with the category.
If your issue continues to persist, then you can reach out to Selling Partner Support through Seller Central.

Why can't I see all categories on the Collection page of the EPR Compliance portal where I need to provide my registration numbers?

Germany and France will not have the same listed categories within the collection page. Check the "Country Specific Information" above for the relevant categories. Amazon will continue to add categories to the collection page as they become available for collection.

France categories will be available for collection in January of 2022. German WEEE will be available for collection in March of 2022. Amazon will not require the German Battery registration number at this stage.

Why can't I see all countries on the Collection page of the EPR Compliance portal where I need to provide my registration numbers?

Amazon is only collecting EPR numbers for Germany and France at this time. If a country is missing, then the collection feature for that country may not be available within Amazon's EPR Compliance portal yet.

What happens after I submit a registration number to Amazon?

Amazon will validate this number with the appropriate government agency. We will notify you when the validation result is available.

I'm registered for the necessary category, how do I provide Amazon with the registration numbers I have received?

You will need to work with the respective agency to access your registration information and locate the correct EPR number. The EPR registration number can then be provided within the EPR Compliance portal. For Germany, please follow the link to the EPR Compliance portal in Seller central to upload the EPR Registration Number(s): EPR Compliance Portal Germany . For France, Amazon will share the link to upload the EPR Registration Number(s) in the course of January 2022.

What are the differences between registering in France and Germany?

In France, you will only need to register with the Producer Responsibility Organization in the appropriate EPR product category. In Germany, you will additionally need to register with the applicable executing agency (ZSVR, EAR).

Where can I find more information on EPR for France?

For more information, including reporting, frequencies and payment of EPR fees, we encourage you to refer to the websites of the Producer Responsibility Organization as well as sites given below for more information:

Where can I find more information on EPR for Germany?

For more information, we encourage you to get familiar with the respective laws (ElektroG and VerPackG) and refer to the websites of the Producer Responsibility Organization as well as sites given below:

Frequently asked questions – Take-back

What are the EPR product categories subject to take-back?

  • Germany: EEE
  • France: EEE, Furniture, Chemicals, and Single Use Gas Fuel Cartridges

If I don't offer a take-back service, what will happen?

It means that you are not compliant with the applicable regulation in Germany and France.

I am a reseller. Does this apply to me?

Yes, if you offer the product categories subject to take-back, you need to provide customers with take-back free of charge.

When am I impacted?

If you offer EEE in Germany and France, you have take-back requirements as of today. Starting January 2022, if you sell the following categories in France: Furniture, Chemicals, Single Use Gas Fuel Cartridges, you will need to extend your take-back services to these categories.

Do I need to provide take-back services for different countries and different EPR product categories?

Yes, if you have offers in Germany and France, you are obligated to have take-back services free of charge in both countries.

Frequently asked questions - France

If I sell EPR Applicable Products on amazon.fr to customers with a shipping address in France, but do not provide Amazon with the valid Unique Identification Number, what actions will Amazon take on my behalf?

If you are selling EPR Applicable Products on amazon.fr to customers with a shipping address in France, but do not provide Amazon with the valid Unique Identification Number corresponding to those EPR Applicable Products, Amazon will take the following actions on your behalf:

  • Prepare declaration reports on your behalf, with details requested by the qualified Producer Responsibility Organizations selected by Amazon, such as quantities (number of units or weight of products) of your EPR applicable sales with mandatory details such as device type (e.g. refrigerator, baby clothing, chair), and product attributes (e.g. packaging material, materials of furniture). To prepare the reports, Amazon will use information provided in your listings or use default values in the absence of such information;
  • Submit reports for each applicable EPR product category at the end of reporting cycle (which may be quarterly, semi-annual or annual as per the category of the EPR Applicable Product);
  • Pay the applicable environmental eco-contributions in accordance with these Producer Responsibility Organization’s list of prices and the quantity (number of units or weight of products) on your behalf; and
  • Recover these amounts from you.

When will Amazon pay eco-contributions on my behalf to the qualified Producer Responsibility Organization(s) as determined by Amazon?

Amazon will follow a quarterly, semi-annual or annual reporting cycle for each EPR product category as defined by the qualified Producer Responsibility Organization(s) selected by Amazon. This means that at the end of each quarter for quarterly reports, six months for semi-annual and the year for annual reports, Amazon will pay eco-contributions on your behalf to these Producer Responsibility Organizations.

Will Amazon recover the eco-contributions paid on my behalf from me?

Yes, Amazon will recover from you the eco-contributions paid on your behalf at the end of each reporting cycle as per the EPR product category. Eco-contributions depend on the list of prices of the qualified Producer Responsibility Organization(s) and the quantity (number of units or weight of products) of your EPR applicable sales. We will communicate the details of the charge back process at a later stage.

Will Amazon pay eco-contributions on my behalf after receiving my UIN?

No, Amazon will only pay eco-contributions on your behalf to qualified Producer Responsibility Organization(s) selected by Amazon for reporting cycles in which Amazon does not hold your valid UIN(s) for EPR product categories applicable to you. Amazon will thus discontinue paying eco-contributions on your behalf from that reporting cycle (quarterly, semi-annual or annual as per the EPR product category) onwards. You will thereafter yourself pay your environmental eco-contributions to the Producer Responsibility Organization of your choice.

I have registered with a Producer Responsibility Organization to get my UIN, but have not received it yet. What should I do?

Please keep checking the portal of your Producer Responsibility Organization for your UIN. Once you receive the UIN, provide it to Amazon immediately. Amazon will pay eco-contributions on your behalf to the qualified Producer Responsibility Organization(s) as determined by Amazon for reporting cycles in which Amazon does not hold your valid UIN for EPR product categories applicable to you.

Will Amazon pay eco-contributions on my behalf for sales off Amazon too?

No, Amazon will only pay eco-contributions on your behalf for EPR applicable sales on amazon.fr.

Will Amazon pay eco-contributions on my behalf for EPR applicable sales shipped out of France from amazon.fr?

No, Amazon will not pay eco-contributions on your behalf for EPR applicable sales shipped out of France from amazon.fr. Amazon will only pay eco-contributions if you sell EPR applicable products to customers with a shipping address in France from amazon.fr. This also includes French overseas territories.

Is it mandatory for me to be registered with a Producer Responsibility Organization?

While Amazon can pay eco-contributions on your behalf and recover them from you, we encourage all sellers to be EPR compliant by themselves. This includes Registration, Declaration and Reporting and Payment of eco-contributions.

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