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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.
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.
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 at the respective authority In some countries you need to register at 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.
