New EPR Compliance Obligations for Amazon Germany Begin July 1st
This announcement is for UK/EU sellers with listings on Amazon.de (Germany). 🇩🇪
In a move to comply with the upcoming changes to the Extended Producer Responsibility (EPR) Packaging Law in Germany, Amazon has started checking seller compliance with this environmental policy. đź‘€
Effective July 1, 2022, all packaged goods distributed in Germany, including those available for purchase on Amazon.de and other eComm marketplaces, must be registered in the LUCID Packaging Register. This process enables you to put your product packaging (see infographic below) into circulation and share the costs of recycling them.
Previously, this registration requirement only applied to sellers subject to system participation, a process that requires them to enter into an agreement with a Producer Responsibility Organization (PRO) who will collect their packaging from customers and take care of its sorting and recycling for a fee.
⚠️ IMPORTANT: If you fail to register, your listing will be blocked on Amazon.
Note: As of June 15, 2022, the eComm giant has already started blocking non-compliant listings to ensure it doesn’t violate the amended EPR Law that comes into force on July 1st. You can view your listing status on your account’s Manage Inventory page>Inactive (Blocked). Read on to learn how to become EPR-compliant.
What is EPR?
EPR is an environmental protection strategy to reduce waste from a product and its packaging by making all producers, including online sellers or importers, responsible for the entire life cycle of the packaged goods they sell, from introduction to the market through to disposal, including waste collection and recycling of cartons, bubble wraps, foam fillers, among other packaging materials.
How to Comply with the EPR Packaging Law?
EPR guidelines differ by product category: (1) packaging and (2) Electrical and Electronic Equipment such as batteries. This article focuses on your compliance requirements for packaging, which under Germany’s updated EPR law, you must:
Register in the LUCID Packaging Register
Register as a “producer” and enter the requested information to get a LUCID number. You can do this process yourself through this link (free of charge) or sign up for a paid service called Amazon Solutions for EPR Compliance.
After completing registration, you will receive a LUCID number that you’ll need to submit to Amazon (see Step #2). You’ll also need this registration number to enter into a system participation contract with a PRO in Germany, if necessary (see Step #3).
Again, a PRO is a company who will act on your behalf to administer an EPR-compliant waste recycling program, including calculating the costs incurred for the collection, sorting, and recycling of your product packaging.
Send Your LUCID Number to Amazon
Once registered, make sure to submit your LUCID number to Seller Central.
Amazon may also contact you for further verification or additional information. For instance, if your packaging is subject to system participation, a representative may reach out to validate your LUCID registration details.
If Required, Enter into a System Participation Agreement
In Germany, packaged products that accumulate as waste with consumers after use are subject to system participation.
If you’re responsible for items that are subject to system participation, you need to pay a fee for the recycling of your waste materials. The rates depend on the type of packaging material (typically a few cents per kilogram).
Work closely with your packaging suppliers, FBA representatives (if fulfilling via FBA), and PRO to accurately identify your packaging volumes. Consider using this Packaging Volume Calculator to determine your fees.
⚠️ IMPORTANT: If system participation is required, packaging volume and fee calculations may take a few of weeks (up to 20 days for some sellers). Amazon also needs 5 business days to verify your LUCID registration details during this process. So, if you haven’t registered yet, act now to prevent getting your listings blocked.
Conversely, if your packaged goods are not subject to system participation, you don’t need a system participation contract. However, you’ll still need to register in LUCID.
Read this checklist to learn more.
Report Your Packaging Volumes
Send your packaging data reports and pay fees to your designated PRO regularly.
Go to EPR Requirements: Packaging in Germany for more details.
Final Thoughts
♻️ Compliance with the EPR Packaging Law is a move toward more sustainability in eCommerce. It is going to be an added expense that your business will have to absorb or offset elsewhere. I suggest checking out our master carton calculator to see if there are ways you can optimize efficiencies elsewhere to help to recover profit in other parts of your business to make up for the added costs of EPR.
It may also be a good time to see if reducing your product packaging can help to reduce your potential PRO fees.
On the brighter side, the EPR law helps to lessen your environmental impact, and can also offer good business opportunities. Marketing your product as eco-friendly can help you to stand out among your competitors, thereby attracting new (eco-minded) customers and potentially driving more sales.
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Chelsea Cohen is an Amazon seller, speaker & consultant. An Amazon expert, her regular clients include 7 & 8-figure sellers. She has been featured on AM/PM Podcast, 7-Figure Sellers Summit, and the Prosper Show & Amazing Summit stages, among others.