EPR – Extended Producer Responsibility
What is EPR (Extended producer responsibility)?
Extended Producer Responsibility or EPR, is a new policy enforced by an increasing number of countries under which the producer’s responsibility for the treatment/disposal of post consumer products is increased. This policy attaches a financial responsibility to the producer which aims to create better waste management and an incentive to reduce waste at its source.
In other words, EPR is an environmental policy that makes producers of products subject to EPR requirements responsible for the entire life cycle of the products that they introduce on the market, from product design until 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
Beginning of 2022 Marketplaces must confirm that sellers are complying with Extended Producer Responsibility regulations in France and/or Germany.
So far, only German and French marketplaces are obliged to make sellers comply with EPR regulations, for example, Amazon fr and Amazon de.
In 2023 Austria will also make marketplaces to ask for EPR compliance information.
As marketplaces will start enforcing EPR, sellers will be obliged to register in the appropriate scheme for the type of product they are selling, in order to avoid being suspended.
How to calculate packaging materials for EPR?
- Download the Amazon EPR reports and check what was the previous year or the first Quarter of 2022 usage.
- Estimate 2022 yearly usage of packaging material for the corresponding country.
- License 60%/70% of usage.
- At the end of the year, download the final report and license the difference.
In the first filing of each year, we suggest licensing less amount of materials since any licensed material is not refundable. You will be able to settle the difference in the last report by the end of the year.
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