EPR – Extended Producer Responsibility
What is EPR (Extended producer responsibility)?
Extended Producer Responsibility (EPR) is a policy increasingly enforced by many countries. Under EPR, producers are held responsible for the treatment and disposal of post-consumer products. This policy imposes a financial obligation on producers, aiming to improve waste management and encourage waste reduction at its source.
In other words, EPR is an environmental policy that holds producers accountable for the entire life cycle of the products they introduce to the market, from product design to the end of their life cycle, including waste collection.
GVC can help you with your EPR registration and filing. Read all about EPR in our comprehensive page below.
Who is affected by EPR
Since the beginning of 2022, marketplaces have been required to ensure that sellers comply with Extended Producer Responsibility (EPR) regulations in France and Germany. This includes major platforms such as Amazon.fr and Amazon.de. The scope of these regulations has expanded to include additional countries and stricter enforcement policies by marketplaces.
Key Updates:
- France and Germany: Initially, only marketplaces in France and Germany were mandated to enforce EPR compliance, requiring sellers to adhere to national EPR schemes.
- Austria: Starting in 2023, Austria has also implemented regulations requiring marketplaces to verify EPR compliance information from sellers.
- Additional Countries: As of 2024, other European countries, including Italy and Spain, have begun enforcing EPR regulations. Sellers operating in these countries must now ensure compliance to continue their operations on local marketplaces.
Marketplace Enforcement: Marketplaces will increasingly enforce EPR regulations, obliging sellers to register with the appropriate EPR scheme for their product categories. Non-compliance can result in account suspension and other penalties.
However, it’s important to note that EPR compliance is mandatory for all sellers, not just the ones on marketplaces.
If you are selling your products in France or Germany you should comply with the new EPR regulations.
 |
 |
 |
Why do you need to report your packaging usage?
- By law, all sellers who introduce a product in the German territory, need to license or declare in advance the materials that will be used for packaging.
- To be able to do so, sellers need to declare, buy and report packaging material usage in the appropriate agencies.
- In addition, marketplaces might share information about packaging materials usage, which need to be in line with the reported quantities.
What happens if sellers do not comply with EPR?
- The consequences for not compliance might differ between marketplaces, but Amazon, being the largest marketplace, will move forward to suspend all sellers accounts who do not comply with the packaging category in Germany starting July 2022.
- Sellers trading Electric and Electronic Equipment (EEE) who do not comply with the new EPR policy will also be suspended as of January 2023.
Global VAT Compliance offers a dual registration and reporting service, both in the ZSVR LUCID system and with an approved EPR agency, to license all your packaging material and comply with your EPR obligations.
Our service includes:
- Dual Registration (ZSVR LUCID system, Approved EPR Packaging Agency)
- Licensing of Packaging materials (‘buying the right to introduce Kilograms of packaging materials into Germany) These can be: Glass paper, carton, cardboard, Tinplate, Aluminium, Plastics, Liquid packaging board, Other composites, Other materials
- Dual Reporting (ZSVR LUCID system, Approved EPR Packaging Agency) Reporting is done twice per year
You can learn more and apply for EPR in Germany by clicking on the button below.
France EPR (Extended Producer Responsibility Services)
Why do you need to report your packaging usage?
- By law, all sellers introducing products in the French territory, need to comply with EPR regulations and, in the case of Packaging, present the applicable type of declaration according to the total number of Consumer Sales Units (CSU)* to be sold in France
- In addition, marketplaces might share information about packaging materials usage, which will
need to be in line with the reported quantities
* A Consumer Sales Unit is a unit of packaged product which a consumer can buy separately from others
Example A pack of 6 bottles of yogurt is 1 CSU and 6 CUs (Consumer Units)
Our EPR services for France
GVC offers 3 types of declarations depending on the number of CSUs to be placed in France throughout a calendar year.
Our service includes:
-
- French EPR Representation Flat scheme (10 000 CSUs)
- UIN number and Certificate
- If a Sectorial or Detailed declaration applies, the fees will be determined by the end of the year according to the
number of CSUs