Confusion over EPR Regulations
Basically as title says no matter what I read on the EPR I just seem to get more and more confused. Different countries seem to have implemented it differently and information often seems contradictory.
Often Amazon says things like 'If you list on Amazon FR DE ES etc then you need to be compliant.
But what if I only list on UK site with international postage settings? Do I still need to submit UINs or be registered with LUCID? I removed my international postage settings months ago thinking I was now unable to sell anymore to Europe but re-reading Amazon notifications I am now under the impression it is only if listing directly on the EU sites I need to register and provide these numbers.
The UK has its own EPR legislation - but also seems to have a clause saying only businesses with a turnover in excess of 1M need licensing. But I see no mention of such a clause on the other EU sites - because if that was the case I would have no need to worry anyway.
So basically I want to know:
If I am only listing on UK site - do I need to register anywhere or provide Amazon with any numbers if I allow international orders?
If I do allow international orders - will Amazon charge me under their Pay On Behalf service (and if so how much) or again is this only when listing directly on the EU sites and not when only listing on the UK site with international postage?
Confusion over EPR Regulations
Basically as title says no matter what I read on the EPR I just seem to get more and more confused. Different countries seem to have implemented it differently and information often seems contradictory.
Often Amazon says things like 'If you list on Amazon FR DE ES etc then you need to be compliant.
But what if I only list on UK site with international postage settings? Do I still need to submit UINs or be registered with LUCID? I removed my international postage settings months ago thinking I was now unable to sell anymore to Europe but re-reading Amazon notifications I am now under the impression it is only if listing directly on the EU sites I need to register and provide these numbers.
The UK has its own EPR legislation - but also seems to have a clause saying only businesses with a turnover in excess of 1M need licensing. But I see no mention of such a clause on the other EU sites - because if that was the case I would have no need to worry anyway.
So basically I want to know:
If I am only listing on UK site - do I need to register anywhere or provide Amazon with any numbers if I allow international orders?
If I do allow international orders - will Amazon charge me under their Pay On Behalf service (and if so how much) or again is this only when listing directly on the EU sites and not when only listing on the UK site with international postage?
8 replies
Seller_hOZNPw7G8FIjl
Quote:
"If I am only listing on UK site - do I need to register anywhere or provide Amazon with any numbers if I allow international orders?"
Even if you did not allow international orders you would still need to be registered (see 1 below) - but only if the EPR categories apply to you (namely packaging, electrical and electronic equipment (EEE) and batteries)
It says in the EPR FAQs : As simple guidance, you are considered a producer in a country if you:
1. manufacture a product in the country and sell it domestically, or
2. import a product into the country where you are established, or
3. sell a product in a country where you are not physically established."
From what you have said, 1 and 3 would apply to you - if you produce packaging, electrical and electronic equipment (EEE) and batteries)
Probably best to look at the videos on Seller University
Seller_ZjZ4slOF0jHpk
I found the map on this site useful for determining what the requirements are if you're selling products to EU countries.
Note, the new forum doesn't allow external links, so remove spaces - verpackungslizenz24 . de / en / eu-packaging-licence/
I only do UK on Amazon. But on my own site and Etsy I have basically removed all the EU countries that have low limits and/or high fees for registering and paying and kept the ones that have high limits or no (as yet) restrictions as it was not economically viable for me as a small seller.
For the UK, that's mostly if you're selling from outside the UK and putting/selling products onto the UK market. The threshold is high, so unlikely to affect many, at the moment.
If you sell on the UK site, say to Germany, then yes, you need to register in Germany - you're putting waste (usually packaging) onto the German market. But Germany has a fairly low starting fee (under 10 euros if I remember right) and I'm registered with Lucid. I've stopped selling to France and will let my registration lapse as it wasn't worth the fees.
Seller_hOZNPw7G8FIjl
Quote
"The UK has its own EPR legislation - but also seems to have a clause saying only businesses with a turnover in excess of 1M need licensing."
I have just come across this (see "Extended Producer Responsibility: United Kingdom") which may be of interest. All 4 criteria must be met for the need for compliance
Q. I am established in the UK. Do I need to collect and report data under the Packaging Waste (Data Reporting) (England) Regulations 2023?
A. You are required to collect and report packaging data if all of the following apply:
You are established in the UK and import or supply packaging into the UK.
You are an individual business, subsidiary or group (but not a charity).
You have an annual revenue of £1 million or more (based on your most recent annual accounts).
You were responsible for more than 25 tons of packaging in 2022.
It would be useful if Amazon clearly outlined the requirements for UK sellers selling on the other sites
Sarah_Amzn
Dear sellers,
I see a lot of valuable information being shared here regarding EPR!
It seems @Seller_xO8b4TMIEiBcj might also benefit from this conversation, as they have some related questions in this thread .
Would you be open to addressing them as well?
Thank you!
Sarah.
Seller_tRuvBEHDedp4q
I see Amazon have now created a Pay On Behalf service for items listed on .fr
I am assuming from this I could take holiday mode off amazon.fr and Amazon will pay any fee due for EPR (and obviously charge me for it). This would be better for me than paying an annual fee for my own EPR number.
Does anyone know where I can find a price list of these EPR fees?
Also, Amazon say this is for items listed on the .fr site - what about items sold on the .uk site with international shipping to France? Will there be a Pay On Behalf fee for these too? Presumably, if there is (and I know what it is) I will have to add it to any shipping fee.
Ive tried finding out if EPR is ONLY for items sold in that country (or on a site registered to that country) or whether it also covers items listed on a UK site but then exported but cannot find this answer anywhere.
