Digital marketplaces are legally obliged to check their customers’ EPR compliance in Germany from 1 July 2022.

EPR Compliance at a glance

Here we have summarized all the important internationally valid information on EPR compliance.

We also offer you the most important information for each country in a short and clear way to make your product EPR compliant in Germany, Austria, France, Slovakia and Spain.

 

Short information on other countries will follow shortly.

EPR Compliance international

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Extended Producer Responsibility (EPR) is an environmental policy, that obligates the party first introducing a product subject to EPR requirements to a market of the respective country, to take responsibility for the entire lifecycle of said product. This includes the disposal and recycling of the product. The goal of EPR is to mitigate the environmental impacts of a product throughout its entire life cycle.

The party who first places a product subject to EPR requirements in a country. A party can be considered to be a Producer if any of the following criteria applies:

– The party who manufactures a product subject to EPR requirements in the country, or/and
– The party who imports a product subject to EPR requirements into the country, or/and
– The party who sells a product subject to EPR requirements in the country and is not established in that country.

All of the points above depend on the respective country’s regulations. This information is not legally binding.

There are different regulations in each country. To determine if your product is subject to EPR requirements in the respective country you are introducing your product in, follow the quick and easy steps on EPR-Compliance. The following list contains an overview of the main categories of products in the scope of EPR obligations regardless of specific country regulations. New categories can always be added in different countries. Therefore the following list is not complete.
– Packaging
– Non packaging product (plastics, glass, paper, cardboard)
– Electric and Electronic Equipment (EEE)
– Batteries
– Furniture
– Tires
– Paper
– Textile
– Chemicals
– Medical Piercing Equipment for Auto-treatment
– Mattresses

A Producer Responsibility Organisation (PRO) is a professional organisation that takes over the responsibilities of an obligated party subject to Extended Producer Responsibility (EPR). The PRO manages the collection and recycling of products subject to EPR requirements on behalf of the obligated producers.

If you are a Producer of products in the scope of EPR requirements, you need to follow these high-level instructions to be EPR compliant. Please bear in mind that there are different regulations in each country. To determine the correct steps in your personal situation, follow the quick and easy steps on this website.

1. Licence your product and report to PRO
In some countries you need to licence your product subject to EPR requirements to a Producer Responsibility Organisation (PRO) responsible in the respective country. Therefore you must declare your sales (of products covered by the different EPR categories) to the respective Producer Responsibility Organisation (PRO) for the applicable reporting period.

2. Register of the respective authority
In some countries you need to register of the respective authority in the country you are introducing your product to. For example in Germany the authority for packaging products would be the „Zentrale Stelle Verpackungsregister (ZSVR)“ and its packaging register „LUCID“. In France the authority would be „ADEME – The French Agency for Ecological Transition“.
You will then obtain the EPR registration number(s) needed to prove compliance with EPR requirements, which you need to communicate to Electronic Marketplaces as proof of compliance in order to continue selling your products on these marketplaces.

3. Pay eco-contributions to your PRO
In some countries you need to pay eco-contributions to the PRO you licenced your product with. The PRO will then take responsibility for the collection and recycling of your product.

In France and in Germany starting in 2022, Electronic Marketplaces like Amazon, AliExpress, Ebay, Zalando and others will be legally obliged to confirm that their sellers are EPR compliant in the country they sell. If you sell your products on Electronic Marketplaces in Germany and can not prove your EPR compliance to said Marketplaces, they will be legally obliged to suspend your non-compliant listings under EPR product categories.

EPR Compliance in Germany

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To be EPR (Extended Producer Responsibility) compliant in Germany, you need to register of the relevant EPR registration authority, to obtain your EPR registration number(s). You need this EPR registration number(s) as proof of compliance. Additionally you need to licence your products subject to EPR requirements to a Producer Responsibility Organisation (PRO) responsible in Germany. Therefore you must declare your sales (of products covered by the different EPR categories) to the respective Producer Responsibility Organisation (PRO) for the applicable reporting period and pay eco-contributions to your PRO. The PRO will then take responsibility for the collection and recycling of your product.

From 2022, the German Packaging Act (Verpackungsgesetz or VerpackG) establishes a control obligation for online marketplaces, so that retailers who sell to end consumers in Germany must follow the guidelines and submit their EPR registration number(s) to the marketplace operators as proof of this. The German Electrical and Electronic Equipment Act (Elektrogesetz or ElektroG, WEEE) and the German battery law (Batteriegesetz or BattG) stipulate that all manufacturers of electrical and electronic equipment or batteries who want to sell their products on the German market must register of the authority „Stiftung Elektro-Altgeräte Register“ (Stiftung EAR).

In many countries, producers of products subject to EPR requirements will be prosecuted with fines, if they are not able to prove their EPR compliance. In many countries, Electronic Marketplaces are legally obliged to confirm that their sellers are EPR compliant in the country they sell. If sellers can not prove their EPR compliance to the respective Marketplaces, they can be suspended from selling their non-compliant listings under EPR product categories. These regulations vary from country to country and can possibly be dealt with differently by each Marketplace. To determine the specific consequences in your situation, we recommend to contact the respective PRO in the country you are selling your product in.

These are relevant categories and executing authorities:

Packaging
The Packaging Register LUCID (Verpackungsregister LUCID) is the online platform of the Central Agency Packaging Register (Zentrale Stelle Verpackungsregister or ZSVR) for the implementation of the Packaging Act. Producers of products of the category packaging must be registered of the Packaging Register LUCID. Proof of compliance: EPR Registrierungsnummer (EPR registration number)

Electrical and Electronic Equipment (EEE) and Batteries
The authority „Stiftung Elektro-Altgeräte Register“ (Stiftung EAR) is a joint body according to ElektroG and executing authority according to BattG. Producers of products of the category Electrical and Electronic Equipment (EEE) and/or Batteries must be registered of the Stiftung Elektro-Altgeräte Register. Proof of compliance:
EEE: WEEE-Reg.-Nr. DE (WEEE registration number Germany)
Battery: Batt-Reg.-Nr. DE (Battery registration number Germany)

EPR Compliance in France

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To be EPR (Extended Producer Responsibility) compliant in France, you need to register at a Producer Responsibility Organization (PRO) to obtain your Unique Identification Number(s) (UINs). After the registration, the UINs will be automatically generated via ADEME (l’Agence de la transition écologique) and issued to the respective PRO. The PRO will transfer the new number to its registered members. You need this UIN(s) as proof of compliance. Once registered of a PRO, you must declare your sales (of products covered by the different EPR categories) to the PRO for the applicable reporting period and pay eco-contributions to your PRO. The PRO will then take responsibility for the collection and recycling of your product.

The legal basis for EPR regulations in France is the Code de l’environnement and the AGEC law.

In many countries, producers of products subject to EPR requirements will be prosecuted with fines, if they are not able to prove their EPR compliance. In many countries, Electronic Marketplaces are legally obliged to confirm that their sellers are EPR compliant in the country they sell. If sellers can not prove their EPR compliance to the respective Marketplaces, they can be suspended from selling their non-compliant listings under EPR product categories. These regulations vary from country to country and can possibly be dealt with differently by each Marketplace. To determine the specific consequences in your situation, we recommend to contact the respective PRO in the country you are selling your product in.

EPR Compliance in Austria

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To be EPR compliant in Austria, producers of products subject to EPR (Extended Producer Responsibility) requirements can register of a Producer Responsibility Organisation (PRO). Producers have to submit a packaging declaration for each year. Eco-contributions must be paid to the respective PRO.

The legal basis for EPR regulations in Austria is the Waste Management Act (Abfallwirtschaftsgesetz – AWG) which was updated with an amendment in the year 2021, as well as the packaging regulation (Verpackungsverordnung – VerpackVO) which was updated with an amendment in the year 2021.

In many countries, producers of products subject to EPR requirements will be prosecuted with fines, if they are not able to prove their EPR compliance. In many countries, Electronic Marketplaces are legally obliged to confirm that their sellers are EPR compliant in the country they sell. If sellers can not prove their EPR compliance to the respective Marketplaces, they can be suspended from selling their non-compliant listings under EPR product categories. These regulations vary from country to country and can possibly be dealt with differently by each Marketplace. To determine the specific consequences in your situation, we recommend to contact the respective PRO in the country you are selling your product in.

An authorized representative is a natural or legal person who assumes the EPR obligations in Austria for, among others, a company that does not have a registered office in Austria but distributes goods (packaging, disposable plastic products, fishing gear or vehicles) to private end consumers or goods (WEEE, batteries) to private or commercial end consumers.

Companies must appoint an authorized representative in order to be able to place the aforementioned EPR products on the market in Austria in a legally compliant manner from 01.01.2023 (unless a corresponding regulation is already in force, e.g. WEEE + batteries).

EPR Compliance in Slovakia

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To be EPR (Extended Producer Responsibility) compliant in Slovakia, producers of products subject to EPR requirements need to be registered in the Register of Specified Products. In addition producers need to licence their products subject to EPR requirements to a Producer Responsibility Organisation (PRO) responsible in Slovakia.

The legal basis for EPR regulations in Slovakia is the 79 ACT of 17 March 2015 on waste and on amendments to certain acts.

In many countries, producers of products subject to EPR requirements will be prosecuted with fines, if they are not able to prove their EPR compliance. In many countries, Electronic Marketplaces are legally obliged to confirm that their sellers are EPR compliant in the country they sell. If sellers can not prove their EPR compliance to the respective Marketplaces, they can be suspended from selling their non-compliant listings under EPR product categories. These regulations vary from country to country and can possibly be dealt with differently by each Marketplace. To determine the specific consequences in your situation, we recommend to contact the respective PRO in the country you are selling your product in.

EPR Compliance in Spain

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To be EPR (Extended Producer Responsibility) compliant in Spain, producers of products subject to EPR requirements need to register of the collective System of Extended Producer Responsibility (SCRAP). Producers have to submit a packaging declaration for each year, and must inform the Collective System of Extended Producer Responsibility (SCRAP), about the packaging placed on the market the previous year. Producers have to pay eco-contributions to the respective Producer Responsibility Organisation (PRO).

The legal basis for EPR regulations in Spain is the Law 11/1997, of April 24, 1997, on Packaging and Packaging Waste.

In many countries, producers of products subject to EPR requirements will be prosecuted with fines, if they are not able to prove their EPR compliance. In many countries, Electronic Marketplaces are legally obliged to confirm, that their sellers are EPR compliant in the country they sell. If sellers can not prove their EPR compliance to the respective Marketplaces, they can be suspended from selling their non-compliant listings under EPR product categories. These regulations vary from country to country and can possibly be dealt with differently by each Marketplace. To determine the specific consequences in your situation, we recommend to contact the respective PRO in the country you are selling your product in.

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