What you need to know about EPR in Germany as an International seller
Extended Producer Responsibility (EPR) is an environmental policy that makes producers responsible for their products during the entire life cycle. The concept behind EPR is that companies should bear responsibility for their products from production to disposal in order to preserve resources. Governments are establishing legal regulations to encourage companies to take appropriate action. The goals of EPR include sustainable product design, minimizing resource use in production, packaging, transportation etc., and ensuring proper disposal, recycling or other recovery when the product is no longer used.
Since the start of 2022, online platforms and marketplaces such as Amazon or eBay need to collect the EPR registration numbers of all merchants that sell their products to Germany.
Who is affected by EPR in Germany?
Amazon merchants selling to Germany
eBay merchants selling to Germany
ecommerce shops selling to Germany
importers of goods for the German market
What are the duties?
Affected businesses are obliged to fulfill all legal EPR requirements. This includes mainly:
- Register your business in an official registry to get an EPR registration number
- Join a Producer Responsibility Organization (PRO) and report your affected volumes
- Pay an eco-contribution based on your annual volumes per EPR category
- for marketplace merchants in Germany (Amazon, eBay, etc.): enter your EPR registration number on the platform
EPR categories in Germany
There are some EPR categories that are relevant for international merchants. Each EPR category has its own law that defines legal obligations that producers/importers need to fulfill. Depending on the type of products you sell in Germany, you are obliged to comply with the regulations for the associated EPR category.
Packaging
All materials of packaged products put on the German market including the primary packaging of the products and any additional packaging for shipping (boxes, bubble wrap and other filling material).
WEEE
Batteries
There are 3 types of batteries in Germany: portable batteries (consumer products, can be hand-carried), industrial batteries (only industrial, commercial or agricultural purposes) and automotive batteries.
Get your German EPR registration number for packaging
Amazon already asks international merchants for a German EPR registration number for packaging. eBay will follow soon and will also demand this registration number from you. This will be a condition to be able to sell in Germany. We will show you step by step what you need to do to become fully compliant with the German law and to avoid bans from Amazon or eBay in Germany.
Step 1: Register your business in the LUCID register
Companies that put packaging filled with goods into circulation in Germany for the first time must register online with the German control authority Central Agency Packaging Register. This is done in the public register LUCID, which was set up especially for this purpose. Once the free registration is completed, you will receive your German EPR registration number for packaging. This is also called LUCID registration number in Germany.
Step 2: Join a Producer Responsibility Organization (PRO)
The second requirement is to join a Producer Responsibility Organization (PRO). These organizations are also called "dual systems" in Germany. They organize the collection and recycling of packaging materials on behalf of the producers. All packaging waste that ends up at private households or similar collection points will be collected by those companies and handled properly. Every producer pays an eco-contribution fee to them based on their volume of packaging material. After the payment, you receive your packaging license. We can help you here to find the best price among all PROs in Germany. Our free price calculation tool shows you which PRO has the best deal for your.
Step 3: Report your EPR registration number to Amazon or eBay
You need to enter your new EPR registration number for packaging in your seller account of the marketplace or platform
Amazon
To fulfill Amazon’s requirements regarding EPR in Germany, Amazon has created a new area in the Sellercentral account. On a new compliance dashboard, merchants can provide all EPR information in one place.
Navigate to the country Germany and enter your LUCID registration number for the EPR category packaging by 01.07.2022.
Price Calculator
Start the comparison of all German Producer Responsibility Organizations (PRO) also known as “dual systems” by typing in the quantities of packaging materials that you ship to Germany per year. You will then see the prices and all terms and conditions for all providers. From this list, you can choose the best offer.
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If you need further assistance on the German Packaging Act or your packaging license, we are there for you to help. If you want to contact us on social media, you’ll find all the information on our contact page.
