Current Status on all EPR Categories and Countries in Europe (Subject to Regulatory Updates).
|Jurisdiction||Categories||Legislation Enforcement Date|
|Sports and Lesiure||01/01/2023|
|DIY & Gardening Articles||01/01/2023|
|Piercing Medical Equipment||01/01/2023|
|Single Use Plastics||01/01/2025|
Breaking News for e-commerce entrepreneurs: UK announces ban on single-use plastics from 1st October 2023
In a significant development for e-commerce entrepreneurs selling goods in the United Kingdom, the government has announced a comprehensive ban on single-use plastics, encompassing plates, bowls, trays, containers, cutlery, and balloon sticks.
This move aims to further combat plastic pollution and promote sustainability, aligning with the global effort to reduce the environmental impact of disposable plastics.
Changes in Northern Ireland: What is the Windsor Framework?
If you’re an e-commerce seller, the world of VAT and trade regulations can sometimes feel like a maze, especially when it comes to complex situations like Northern Ireland’s relationship with the EU.
To help you make sense of it all, let’s delve into the background of the Windsor Framework, its significance, and how it impacts your e-commerce business.
Navigating VAT in the Digital Age (ViDA) for E-commerce Sellers
The landscape of e-commerce is ever evolving and, as an e-commerce seller, it’s crucial to stay informed about changes in regulations that could impact your business.
Recently, the European Commission unveiled the VAT in the Digital Age (ViDA) initiative. Aimed at amending the European Union (EU) Value Added Tax (VAT) system, the proposal addresses the challenges posed by digitalisation.
If you’re an e-commerce seller, this initiative will undoubtedly impact your business operations. In this blog we’ll explore the key aspects of ViDA and understand how it might impact your e-commerce business.
EPR Process for DE WEEE Registration
Status Update on the WEEE Registration Process
FURTHER UPDATE ON DELAYS ON DE WEEE
We understand the frustration and challenges you have faced during this process. It is unfortunate that since our collaboration began with the authorities in January 2022, the process has undergone three significant changes, each time affecting service providers across the board and how we are able to service our sellers.
Regrettably, due to the nature of the process and the restrictions imposed on us as service providers, we are not allowed to call the authorities directly for updates. Any attempts to do so could result in our provider privileges being revoked or the registrations in question, being delayed even further. This restriction has undoubtedly added to the difficulties and delays experienced. Your case has been escalated internally, but there is nothing further we can do to expedite your registration as it’s in the hands of the authorities.
This current situation we face is not unique to AVASK. It is a widespread issue that affects numerous sellers, service providers and industries. We understand that the circumstances might evoke frustration or concern, however, our teams continue to work tirelessly to ensure that all our clients gain full compliance as soon as possible.
There are many service providers with thousands of sellers in the same position, so you can imagine the significant increase in demand on the small government department in Germany that is responsible for dealing with this. Hence there is no possibility to expedite.
AVASK have been working closely with our marketplace partners throughout this process with a shared visibility of all activity and application progress.
We genuinely appreciate your cooperation during these challenging times. We will continue to closely monitor the situation and keep you updated on the success of your application as soon as your number goes live.
Delays on DE WEEE
Unfortunately, the delays we have encountered with the DE WEEE authorities is a situation that has been encountered across the industry and not unique to AVASK. For the past year, we have been continuously working with the DE WEEE authorities to understand the current hurdles and their capabilities and processes. The main factors that have impacted turnaround time on registration approvals and numbers being released are:
• The authorities are not able to prioritise or expedite any registrations currently in progress.
• Although chronological order of processing has always remained their aim, due to demand, we are currently not seeing registrations being processed in this way by the authorities.
• Timeframes remain subject to the authority’s workload, internal efficiency, and capacity to process applications. An influx of registrations to Germany have inevitably affected the aforementioned.
The above is not an ideal situation for AVASK, fellow providers or marketplaces to be in, and we hope to have this rectified across the industry as soon as possible.
If your marketplace accounts have been affected by the upcoming deadline, guidelines have been released to support sellers in reinstating listings once the relevant numbers are live. Please see attached for an example of Amazon’s guidelines in assisting the reinstatement process.
A dedicated team has been implemented to handle any queries you may have on the above. Please reach out to AVASK.DE.WEEE@avaskgroup.com should you have any questions relating to this matter.
Any standard enquiries regarding any of your applications, please continue to reach out to your account manager.
We appreciate your co-operation and apologise for the inconvenience caused. We remain thoroughly committed to ensuring you are compliant as soon as we possibly can.
Amazon SP-API Technical Issues
As we have now entered February, the January 2023 VAT period has opened for filing. If you are selling on Amazon, you will know that the Amazon VAT Transactions Report (AVTR) - the report used for VAT calculation - is made available by Amazon on the 3rd day of each month.
Due to a technical issue, the ability to automatically pull the AVTR, via the API connection, is temporarily unavailable. This will prevent AVASK receiving the AVTR automatically, leading to delays with processing data for VAT submissions.
Please note: this is a wider outage impacting all Amazon providers, and not isolated to AVASK.
Please be assured that the Senior Leadership Team at AVASK are meeting with the responsible Amazon teams to obtain updates regularly and we will revert back to you accordingly and with utmost priority.
It is unlikely that this technical issue will be resolved over the next coming days for this month’s VAT filing deadlines, we therefore require you to urgently download and submit your AVTR manually this month.
Act now to avoid penalties
Environmental taxation update
Extended Producer Responsibility (EPR) important & essential
From 1st January 2023, all businesses trading in Sweden will be affected by the EPR policy and be responsible for the entire lifecycle for the products that they introduce into the market, including their disposal. Further countries will also implement this policy between now and 2023.
Secondary liability and assessment notices and joint and several liability notices for Plastic Packaging Tax
What secondary and joint and several liability is, and when you may be liable for unpaid Plastic Packaging Tax.
US Sales Tax Deadline
**Standard Annual Filing Reminder**
The filing deadline to submit 2021 tax returns or an extension to file and pay tax owed is Monday, 18th April, 2022.
The due date is April 18, instead of April 15, because of the Emancipation Day holiday in the District of Columbia for everyone except taxpayers who live in Maine or Massachusetts.
Taxpayers in Maine or Massachusetts have until 19th April , 2022, to file their returns due to the Patriots' Day holiday in those states.
For more information and assistance connect here with our US office in New York
UK Plastic Packaging Tax
Following on from the launches of new EPR legislation in France and Germany, HMRC has recently announced the implementation a new indirect tax from the 1st April, 2022, the Plastic Packaging Tax, or PPT.
HMRC have introduced this new tax on plastic packaging in response to the ever-increasing need to reduce our environmental impact, worldwide.
This tax will also play an important role in encouraging and incentivising businesses to use more eco-friendly packaging and recycled plastics; the wider aim is to reduce our reliance on virgin plastics while consequently ensuring that less plastic will end up in landfill.
PPT will apply to any plastic packaging manufactured in, or imported into the UK, which does not contain at least 30% recycled plastic. However, if you are a manufacturer and/or importer who produces less than 10 tonnes of plastic packaging within a 12-month period, this will not apply to you.
Here are some crucial points to keep in mind:
- PPT guidance is subject to change until all legislation is approved by Parliament. It will continue to be updated.
- PPT in the UK is currently separate from EPR requirements that have been introduced in Germany and France – the UK is on track to introduce EPR from 2023.
If you have any questions about the new PPT legislation and other eco-compliance requirements, please connect with our dedicated Green Transition department.
Changes to Making Tax Digital in the UK
**Important Legislation Update**
All VAT registered traders must be signed-up and operating via MTD from April 1st, 2022. This practically means that the previously VAT threshold of £85,000 is abolished and all sellers (including non-UK established businesses and entrepreneurs) are required to operate under MTD.
In case any sellers are not authorised on HMRC account and are making taxable sales a unique Government Gateway will need to be in place. All AVASK clients are already signed up for MTD returns via the AVASK HMRC Account.
If you need any help or support with Making Tax Digital, please contact AVASK today:
What to look out for:
- Be compliant on EPR; if not yet compliant take all necessary steps to be compliant – AVASK is on hand to assist you.
- File your sales on OSS and ensure your Accountant is up to speed with all rules and regulations to that effect in terms of B2C sales, B2B sales, website and non-OMP transactions.
- Remember that when sending funds to Tax Authorities you need to ensure that all bank fees are fully paid – any underpayments can incur non-compliance issues with OMPs which may cause account suspension and put your investment at risk. Moreover, ensure that when using forex accounts there are no hidden costs or additional fees that may cause underpayments or raise queries with the Tax Authorities.
- EU One Stop Shop sales: next filing for Q1 in April 2022
Important note for EU-based sellers:
AVASK can provide you with sales data that can be provided to your local accountant for the OSS filing in your EU company of incorporation.
Important note for non-EU-based sellers:
when fulfilling goods via non-Online Marketplaces (OMPs) there is a requirement to register for OSS. This is equally the case if carrying out B2B and website sales.
For more information as to how OSS or IOSS works, see further information here:
Extended Producer Responsibility (EPR) important & essential
Germany and France
From 1st January 2022, all businesses trading in Germany and/or France are responsible for the entire lifecycle for the products that they introduce into the market, including their disposal. The overall purpose is to ensure long term planning and investment into sustainable material use and recycling infrastructure, and to fulfil the ‘polluter pays principle’. EPR focuses on different aspects on packaging, electrical and electronic equipment, batteries, furniture, tyres, paper, textiles, certain medical equipment etc.
|Waste Electronic & Electrical Equipment (WEEE)||Waste Electronic & Electrical Equipment (WEEE)|
|Piercing Medical Equipment (NEW)|
Amazon announce expansion of EU delivery network
Amazon have announced plans to open their first logistics centre in Belgium, with the aim to be operational by the end of 2022.
According to Amazon, the new logistics centre aims to meet the growing demand and expand their delivery network capacity within Europe.
It is expected that the logistics centre will operate as sorting house, receiving parcels from fulfilment centres in France and Germany. Once received, they will be prepared, passed on to local couriers and delivered to Belgian customers. The move to build the facilities in Belgium comes after the success of the same type of logistics centre opened by Amazon in The Netherlands last year. Amazon have also announced that they will be building 8 new warehouse locations in Germany during the first half of 2021.
The expansion of Amazon's European delivery network comes out of necessity to meet the demand of the platform's continued growth and customer delivery expectations when using Prime. Amazon have also highlighted the requirement for further warehousing in order to widen the range of products on offer to Amazon customers.
HMRC and bank transfers to NETPs for VAT repayments
As we are all well aware, HMRC have only ever issued VAT repayments for NETPs via bank transfer if the NETP has a UK bank account. Otherwise, a cheque will be sent by HMRC and the NETP will need to cash this in their resident country.
Since Brexit and the outbreak of COVID-19, more and more banks from varying countries around the world have started rejecting HMRC cheques. To give HMRC credit, they have recognised this and are doing something about it. NETPs will now be able to provide HMRC with the bank details of their overseas account and HMRC will issue a CHAPS payment to this account.
In order to provide HMRC with the overseas bank account details, a form will need to be submitted within the trader's Government Gateway account. Please use the gov link for HMRC's official release on this.
Amazon launch buy now pay later
In December, it was announced that Amazon have partnered with Barclays to offer customers in the UK the option to utilise a new payment option: buy now, pay later (BNPL). It is no surprise that Amazon have introduced this, with BNPL becoming extremely popular - spending via BNPL tripled in 2020. Here is what we know so far following the announcement:
- 'Instalments by Barclays' will mean shoppers can use BNPL for millions of items
- Amazon shoppers will be able to spread the cost of their purchases over months
- The minimum spend per order is £100 and can be repaid between 3 and 48 months
- Barclays will charge a 10.9% APR on these purchases
The BNPL sector is dominated by companies such as Klarna and Clearpay. The move by Barclays is being seen by many as early indications that the big banks will look to move into this space and reap the benefits, clawing back the business from the companies that currently dominate in this area.
AVASK is able to help you to exit your business
We can assist with the following:
- Identifying a suitable exit strategy
- Preparing your business for the sale
- Recommending the right broker to assist towards the actual acquisition
- Post-acquisition support
Please get in contact with an AVASK representative here:
Are you ready for the Customs Declaration Service (CDS)?
The new Customs Declaration Service (CDS) is mandatory for all UK import clearances from 1st October 2022. Until recently, HM Revenue and Customs’ (HMRC) Customs Handling of Import and Export Freight (CHIEF) system has been at the forefront of customs declarations in the UK. But the existing CHIEF customs declaration system is closing in the UK, with the last day of operation being today, September 30th. All import declarations from October 1st onwards will need to be submitted via the new Customs Declaration Service (CDS).
Forward Plan - What to watch out for:
1st April 2022 - UK Introduces Plastic Packaging Tax (PPT)
The UK Tax Authorities (HMRC) have recently announced the implementation of a new indirect tax from the 1st of April 2022, the Plastic Packaging Tax, or PPT.
PPT will apply to any plastic packaging manufactured in, or imported into the UK, which does not contain at least 30% recycled plastic. EPR rules are also to be introduced as of January 2023 in the UK.
Environmental Taxation 2022/23 deadlines:
- July 2022: Germany – EPR packaging
- January 2023: Germany – WEEE
- January 2023 (tbc): Portugal – single-use plastic or aluminium packaging
- January 2023 (tbc): Spain/Italy – non-reusable plastic packaging
- January 2023 (tbc): Poland – EPR/ non-reusable plastic packaging