EPR Obligations on Amazon Germany

Category: Operations
Amazon EPR Pay EPR Obligations

Operators of online marketplaces in Germany are required to check whether selling partners comply with their EPR obligations for waste electrical and electronic equipment (WEEE) as part of the extended producer responsibility (EPR) under the ElektroG from July 1, 2023. Amazon has worked closely according to authorities’ guidance to help selling partners understand the requirements early on and provide assistance with registering their products, among others.

Amazon have announced the target date to supply them with the relevant compliance details for your EPR Obligations. Because the processing of WEEE registration numbers in particular requires lead time, selling partners should provide Amazon with the respective number(s) by Monday, the 5th of June 2023. After this date, Amazon may begin deactivating non-compliant listings in order to meet the legal EPR requirements in time.

You need to submit either your registration number (WEEE-Reg.-Nr.) or the WEEE-Reg.-Nr. of the producer in your supply chain to Amazon for all brand and type of equipment combinations listed on the Compliance Portal.

In addition, if you sell packaged goods on Amazon.de, to comply with Extended Producer Responsibility requirements, you need to submit your LUCID number to Amazon on the Compliance Portal. The legislation has been in effect since the 1st of July 2022. Again, if you don’t comply your non-compliant listings will be deactivated.

It’s worth noting the increased regulation (which inevitably increases costs for retailers) around the world. Indeed, Germany’s closest neighbour France has also introduced EPR Obligations since the 1st of January 2022. On Amazon France you either need to Submit your unique identification numbers (UINs) on the Compliance Portal, or you will be auto-enrolled in Amazon’s ‘Pay on Behalf’ service and Amazon will pay the appropriate eco-contributions and fulfil the required reporting obligations to producer responsibility organizations (PROs) on your behalf for your sales on Amazon.

As DHL said in their Global Connectedness Index, “The public policy environment has become less favorable for globalization, increasing the risk of a costly decline or fragmentation of international flows. Present challenges should motivate a focus on making globalization work better in order to preserve and expand the benefits of a connected world.”


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