If you or your business are selling goods in France or Germany, then the 1st of January 2022 is a significant date. New EPR legislation comes into effect that requires Producers to register for EPR and file EPR returns, and for online marketplaces to collect and validate your EPR registration numbers and comply with new local requirements.
While much is still unravelling, we have put together the following blog about EPR and how it affects you and your business:
So, what is EPR?
EPR stands for Extended Producer Responsibility and although it is a new thing for Amazon and AVASK, it is not a new thing overall. This environmental policy originated in 1988 in Sweden, and it requires producers to take responsibility for the entire life cycle of the products that they put into the market, including their eventual disposal.
Who needs to register for EPR?
The Producer is the person or company who first places a product on the market which is subject to EPR requirements. EPR is currently only applicable in the German and French markets, with the view for other European countries, including the UK, to follow suit in the not-too-distant future.
You are considered a Producer:
- if you manufacture a product subject to EPR requirements in the country
- if you import a product subject to EPR requirements into the country
- if you sell a product subject to EPR requirements in the country and you are not established in that country.
If you are a Producer of products within the scope of EPR requirements, you will be obliged to provide your EPR registration number(s) to your Online Marketplace, for example Amazon or eBay.
What are the new requirements for registration?
If you are a Producer and do not have an EPR registration number(s), you are required to register to obtain one.
On the rare occasion that you are not a Producer but sell product(s) subject to EPR requirements, you need to obtain the applicable EPR registration number(s) from your upstream supplier and provide the OMP with the appropriate registration number(s) as proof of compliance.
If you are not a producer and cannot obtain the applicable EPR registration number(s) from your upstream supplier, you are required to register and provide the OMP with your EPR registration number(s).
How AVASK can help?
In line with new requirements, and the impending requirements from other countries on the horizon, AVASK have set up an EPR service which will keep you compliant, it includes:
- Registration of EPR numbers in each necessary category and country
- Monthly/ quarterly or annual filing and reporting in Germany and France (depending on the country and category)
- Authorised representation for Germany or France (currently for WEEE categories)