German EPR to extend to Electricals in 2023

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Amazon are warning sellers that if you sell Electrical and Electronic Equipment (EEE) in Germany, you will need to comply with the next round of German EPR (Extended Responsibility Producer) obligations by the end of this year. You already need to be compliant for packaging as of the 1st of July.

Otherwise, on the 1st of January 2023, Amazon will be legally obliged to suspend your non-compliant listings. The registration process may take more than 10 weeks, so best to you to review the information below and start your registration today.

For more information on EPR and requirements, see Amazon’s Extended Producer Responsibility (EPR) Education. Also, you can review the Guide to become compliant with EPR (Extended Producer Responsibility) packaging requirements in Germany.

German EPR obligations for EEE

To determine if you’re a producer, see the Stiftung elektro-altgeräte (Stiftung EAR) website. You will be considered a producer by selling electrical and electronic equipment that does not originate from Germany but from a third country (or another EU member state) for the first time on the German market.

It’s also worth noting, that even if you are based in Germany and white label German produced products then you become liable as a producer under the German EPR rules, as the products will then be attributed to you and not necessarily traceable to the OEM.

If you are not a producer, go to the EAR’s Producer Directory to check if all your EEE listings (brand and type of equipment combinations) on Amazon EPR Reports are from registered producers or from foreign producers whose authorised representatives are registered.

If the products are not registered, you will have to register as the producer of those products or ask your EEE product supplier to register and provide you with their Registration Numbers (also referred to as WEEE-Reg.-Nr.). If you require support on the WEEE Authorised Representative appointing and registration process, you can contact one of Amazon’s approved service providers through their EPR Service Provider Network.


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