Wish co-hosted a webinar with the Landbell Group, a trusted Professional Responsibility Organization (PRO) in Europe. The purpose of the webinar was to explain and address Extended Producer Responsibility (EPR), and how to make sure merchants are prepared to continue selling into certain European countries with the new regulations.
We’ve embedded an on-demand version of the entire webinar below to share with merchants who couldn’t attend. Additionally, we’ve compiled an FAQ of the most commonly asked questions during the presentation. Watch the webinar and read through the FAQ for additional information!
No Legal Advice or Attorney-Client Relationship: the information provided below does not, and is not intended to, constitute legal advice; instead, all information, content, and materials available on this site are for general informational purposes only. You should contact an attorney to obtain advice with respect to any particular legal matter.
1. What is EPR?
EPR is an environmental scheme that makes a producer (see definition below) responsible for the entire life cycle of the products that they introduce on the market, from their production and design through waste management and disposal, and enables European Union (EU) Member States to set up EPR schemes for determining producer responsibility. Overall, EPR program requirements aim to improve the quality of the environment by preventing and reducing the impact of packaging and packaging waste, electronic products, batteries, and other types of products on the environment.
2. Is it necessary to renew the EPR number every year after getting it? Or is it one time?
Our understanding is that EPR registration number will need to be renewed on at least an annual basis (i.e., it is not a one-time fee only), but the timing will depend on (1) the EU country EPR law; and (2) the PRO that merchants work with. Landbell will have the timing for their scheme on renewal in France.
3. As this is only concerning France and Germany, are there any thresholds involved with these regulations or any of the EPR regulations? For example: if we sell one battery per year to Germany. Do we still need to be EPR compliant?
We are currently unaware of any thresholds for France or Germany EPR, unlike some other EU jurisdictions.
4. What’s the definition of producer? Is a producer someone who buys unbranded electronics from outside Europe, for example, and resells them in Europe under his own brand?
You are considered a producer if:
A product that you manufacture is subject to EPR program requirements within the country you are selling to; OR
You import a product subject to EPR program requirements into the country you are selling to; OR
You sell a product subject to EPR program requirements in a country and you are not established in that country
In the scenario given, that someone would be considered a producer, to the extent the unbranded electronic products are not already registered under the existing EPR scheme.
5. What about the packaging of the products we already have in the warehouse that don’t have a number?
These will need to be registered if the packaging is placed on the French or German market.
6. How are the numbers reflected on the packaging and products?
To our knowledge, EPR numbers do not need to be physically printed on packaging or products.
***You can learn more about EPR in our Help Center article here.