What is EPR and how does it work?

What is Extended Producer Responsibility?

Extended Producer Responsibility is an environmental policy that requires companies to pay an eco-contribution for certain products that have an impact in the environment. This obligation applies at post-consumer stage, once the product’s life cycle is ended. The acronym in English is EPR.

EPR policies imply that the producer is made responsible for recuperating and treating certain products once their life-cycle ends, and this way mitigating the environmental impact of the products they put on the market. In practice, EPR obligations consist of a payment made to an authorized organization who manages waste.

The EPR policies in the European Union are harmonized and cover waste from electrical and electronic equipment (WEEE), batteries and packaging.

What are the EPR obligations for Amazon sellers and online suppliers?

EPR obligations exist since 2012. As a rule, all companies need to comply with EPR, but only recently Germany and France started making sure that Amazon and other online sellers paid their eco-contribution. Additional countries may follow this example in the future.

The eco-contribution regulations are important for many marketplace sellers since 2022. Marketplaces like Amazon, Zalando, or Cdiscount, oblige sellers to provide their EPR registration numbers in France and Germany.

Particularly for Amazon sellers, it is important to obtain the EPR number because Amazon suspends the accounts of sellers that are considered non-compliant with the EPR regulations both in France and Germany.

EPR and marketplaces in Germany. LUCID registration and eco-payment

If you sell your products in Germany, you will need to comply with German EPR regulations. You should get a LUCID number and make your periodic eco-contributions.

How do I get a LUCID number in Germany?

In Germany, you can get your EPR number from an organization called LUCID. In fact, we often refer to LUCID registration number for German EPR registrations.

At Marosa we can handle the entire process of registration and compliance with EPR obligation for packaging and other materials in Germany. We will follow these steps:

1. We register your business in the LUCID packaging register. After the registration, your LUCID number is issued.
2. We enter your LUCID number into a system participation contract with a Producer Responsibility Organization (PRO). Marosa has a dedicated PRO organization with whom we coordinate the process.
3. We provide your LUCID number to you so you can update your Amazon seller account, as well as other accounts in other online platforms like Zalando.

How do I calculate my EPR payments in Germany?

Once the registration is finalized, Amazon sellers must calculate their periodic eco-contribution due. The payment is made to an authorized organization in Germany. In this list you can find the all authorized organizations.

You will download from their central seller the EPR report, containing the net mass amounts per each product category sold and falling into the scope of EPR. Here you can find the link to the definition of the report fields.

With your EPR report, you will need to calculate your EPR amount due periodically. There are different ways of calculating this amount:

• Initial planned volume report: You would confirm the planned volume for the calendar year before the year starts. This method cannot be used if the activity has already started for the relevant reporting period.
• Intra-year volume report: This method consists of submitting an estimate of the annual amounts onto the submission platform, which will calculate the payable tax by the 30 June of the reporting year. This method requires the submission of a final reporting by end of the year with the actual amounts of mass for each category and, therefore, correcting the previously reported tax amount and paying any extra liability. At Marosa we use this method for our clients when it is possible to submit the estimate report before 30 June.
• Year-end volume report: Following this method you submit your year-end volume report. The year-end volume report of the previous year can be submitted up to 15 May of the following year. After this date, the year-end report must be submitted as a supplementary volume report. At Marosa we will do this one for our clients before 15 May each year.
• Supplementary volume report: Following this method you can only submit supplementary volume reports, these always refer to a calendar year. Supplementary quantities are always positive, i.e. the aim of this report is to supplement the previous reported periods. For example: 10,000 kg were reported as the year-end volume of paper for 2018. In 2020, an audit showed that 25,000 kg of paper actually had to be included in a system. A supplementary volume of 15,000 kg must be reported and included in a system. It is important to note that corrections are not possible. If a report does not give the correct value again, a new supplementary volume report must always be made. 
• Deduction volume messages: Here, you can only make deductions due to damage or unsalability for which you have reclaimed the system participation fee.

EPR and marketplaces in France. UIN number and contributions

Like in other countries, in France you first need to register for EPR and get an UIN that will be communicated to your seller platforms like Amazon, Zalando or ManoMano.

The EPR number is also known as the UIN or Unique Identification Numbers in France.

There are 18 categories of products for which Amazon will request an UIN number, although for the moment the legal requirement on Amazon to check the compliance of the EPR obligations extends to 14 in the current year. You will find them here.

What happens if I do not communicate the UIN to Amazon?

For Amazon Sellers, when they are selling goods to final customers with a shipping address in France and have not provided Amazon with a UIN, Amazon will pay by default the eco-contribution on behalf of the seller for sales made from January 2022. The tax amount will be claimed to the Seller for payment; however, in this scenario, the Seller does not need to register for EPR if selling through amazon.fr.

On the contrary, the Seller is obliged to provide Amazon with an UIN number for the sales shipped out of France from amazon.fr. This means that if the client is selling goods through amazon.fr to final customers in different EU countries (Belgium, Austria, etc.), then they are liable to pay the local tax, so registration is mandatory. Most of the Paneuropean clients are in this scenario.

How do I get an UIN in France?

Marosa will get your UIN from an authorised organization in France (PRO). You can check the full list of PRO organizations in this link.

We will submit the registration form and set you up in their system. In a few days, you will receive your UIN number that you can communicate in Amazon and other marketplaces.

At Marosa we will follow up until your application for a UIN is successful, providing an end-to-end solution to your EPR obligations.  

How do I calculate my periodic eco-contributions in France?

Your eco-payment in France depends on the number of Consumer Selling Units (CSU) that you sell in the country each year. CSU refers to the number of items sold in France.

• More than 500,000 CSU per year: You must submit a declaration of the various CSUs marketed split by weight by material. The calculation method is the following: Total contribution = (Contribution by material weight + Unit contribution) x (Bonus - Malus).
• Between 10,000 and 500,000 CSU per year: Your declaration is made by product category. The calculation method is the following: Total contribution = Contribution for a category of products = Number of Consumer Units (CU)2 x Price per CU of the product category concerned. 
• Less than 10,000 CSU per year: You will pay a flat rate of 80 € per year. This is a method without declaration: once the registration is finalized the company needs to make the payment of the invoice generated because the amount of CSU is reported at the moment of the registration.

Marosa will indicate your correct method according to the data extracted from your EPR data in your seller account. We will then ask you to make the required payment and, if applicable, submit the eco-tax return to the French authorities.

How can Marosa help you with your EPR obligations?

Marosa will handle all your EPR obligations in Europe with a single team for all countries.

Our team will receive your details to prepare the EPR registration forms. These applications will be submitted and followed up by our team until you receive your EPR number (UIN in France LUCID number in Germany).

We will advice on how you can communicate your EPR number to each platform where you are currently operating. This communication will allow you to continue selling  your products in each country.

When your time comes to pay your eco-contribution, our team will help you indicating which data we need to receive from you and where you can find it. Once we receive your input, we will calculate the amount due and prepare the eco-tax return in each country. We will use our hassle-free reporting software to make things as smooth and easy as possible for your team.