This FAQ was created for informational purposes only, and does not, nor is intended to, constitute or be construed as legal advice on any subject matter. Should merchants require assistance or have any questions concerning these regulations, their independent obligations/duties, or related to the subject matter or information in this FAQ, please reach out to legal counsel.
EPR Overview
To ensure compliance with Extended Producer Responsibility (EPR) program requirements, merchants selling certain categories of products in various European Union (EU) countries are required to have valid EPR registration number(s) for these product categories (and potentially take additional action, based on the country). See below for details.
A. France
To comply with France EPR program requirements and Merchant Policy, merchants selling into France must:
- Provide EPR registration number(s) (also known as Unique Identification Numbers (UINs)) to Wish for applicable France-bound products. In-scope product categories include packaging, batteries, electrical and electronic equipment (EEE), and more (see Question 6 below for a detailed list of in-scope product categories).
- Include the Triman Logo on these products (with related, dedicated information on the modalities of sorting the waste). For more information, see Triman Logo requirements.
B. Germany
To comply with Germany EPR program requirements and Merchant Policy, merchants selling into Germany must:
- Provide EPR registration number(s) to Wish for applicable Germany-bound products within the packaging product category.
- Provide EPR registration numbers to Wish for applicable Germany-bound products within the EEE.
Please note that per current Germany EPR program requirements, there is no deadline for submitting EPR registration numbers for products within the batteries category. However, merchants are strongly encouraged to procure EPR registration numbers for the batteries product category as soon as possible and submit these to Wish.
C. Sweden
To comply with Sweden EPR program requirements, merchants selling into Sweden must:
- Obtain EPR registration numbers from the Swedish Environmental Protection Agency for applicable Sweden-bound products. In-scope product categories include packaging, batteries, EEE, and more (see Question 6 below for a detailed list of in-scope product categories).
- Obtain proof of registration from a nationally approved collection and recycling system or a Producer Responsibility Organization (PRO) for the packaging, EEE, or batteries product categories.
- Provide EPR registration number(s) to Wish for applicable Sweden-bound products. In-scope product categories include packaging, batteries, EEE, and more (see Question 6 below for a detailed list of in-scope product categories).
D. Austria
To comply with Austria EPR program requirements, merchants selling into Austria must:
- Obtain EPR registration numbers and proof of registration from a PRO for applicable Austria-bound products in packaging, EEE, and batteries product categories.
- For merchants based outside of Austria, appoint an Authorized Representative in Austria.
- Provide EPR registration number(s) to Wish for applicable Austria-bound products. In-scope product categories include packaging, batteries, and EEE.
E. Spain
To comply with Spain EPR program requirements, merchants selling into Spain must:
- Obtain EPR registration number for packaging
- Provide EPR registration number for packaging to Wish via Merchant Dashboard
F. Other Countries
In the future, additional countries including Belgium, Portugal, and the United Kingdom, may be subject to EPR program requirements. We will update this article when/if that happens.
See the below FAQ for more information on EPR program requirements, including how to obtain EPR registration numbers.
Frequently Asked Questions
1. What is EPR?
2. How do I know if I am considered a producer according to EPR program requirements?
3. How do I comply with EPR program requirements?
4. How do I provide my EPR registration number(s) to Wish?
5. What happens if I don’t provide my EPR registration number(s) to Wish?
6. What product categories are covered by EPR program requirements and require an EPR registration number?
7. Which PROs can I register with to obtain my EPR registration number for applicable product categories?
8. Where can I find more information on EPR compliance?
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1. What is EPR?
EPR is an environmental program that makes a producer (see definition below) responsible for the entire life cycle of the products that they introduce into the market, from their production and design through waste management and disposal, and enables EU Member States to set up EPR programs 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. How do I know if I am considered a producer, according to EPR program requirements?
Producers are considered to be the party that first places a product subject to EPR program requirements within the applicable country, either by manufacturing this product domestically or importing products. Please note that being a producer is not directly equivalent to being a manufacturer.
For the packaging product category, merchants are considered producers if they first place packaging products that are filled with goods and typically accumulate as waste with private final consumers on the relevant local market on a commercial basis. Therefore, if a merchant’ products contain any type of packaging (including secondary packaging for shipment to the final customer), the merchant is considered a producer.
For other applicable product categories, merchants are considered producers if:
- A product that they manufacture is subject to EPR program requirements within the country they are selling to; OR
- They import a product subject to EPR program requirements into the country they are selling to; OR
- They sell a product subject to EPR program requirements in a country and they are not established in that country
France, Germany, Sweden, Spain, and Austria have implemented laws for producers to comply with EU Regulations and their EPR program requirements. Producers subject to EPR program requirements in France, Germany, Sweden, Spain, and Austria are required to register with the relevant PROs (also known as Producer Compliance Schemes or eco-organizations) and/or agencies for each applicable in-scope product type or category to be granted an EPR registration number.
A. France
If merchants are unsure if they are considered to be a producer in France, please refer to the definitions as set out in the French Environmental Code , art. L. 541-10, R. 543-54, R543-125 and R543-174.
B. Germany
- If merchants are unsure if they are considered to be a producer in Germany, please refer to the definitions as set out in the below links:
C. Sweden
If merchants are unsure if they are considered to be a producer in Sweden after reviewing the above criteria, please see the legislation referred to on the Swedish Environmental Protection Agency's website.
D. Austria
If merchants are unsure if they are considered to be a producer in Austria after reviewing the above criteria, please see the legislation referred to on the Austrian government’s website.
E. Spain
As of March 29, 2023, Royal Decree 1055/2022 on packaging and packaging waste has established new EPR obligations for packaging materials. These obligations include responsibilities related to the end-of-life management, collection, and recycling of packaging waste.
Key points of Royal Decree 1055/2022 include:
- It applies to packaging intended for use or consumption by individuals.
- It covers packaging that is susceptible to being purchased by consumers in stores.
- These requirements are applicable regardless of the place of sale or consumption.
If merchants are unsure if they are considered to be a producer in Spain after reviewing the above criteria, please refer to Spanish government website for further clarification.
3. How do I comply with EPR program requirements?
To be compliant with EPR program requirements, applicable merchants shipping relevant France-, Germany-, Sweden-, Spain-, and Austria-bound products are required to take certain actions. See below:
Step 1: Registration
A. France
If merchants are considered to be a producer of applicable France-bound products, they must register for an EPR registration number(s) directly with the French administrative authority (i.e. “Ademe”) or indirectly through the relevant PROs (see Question 7 below) for applicable product categories now to comply with EPR program requirements for France. They must also provide their EPR registration number for applicable product categories to Wish. See Question 4 below for details on providing this number to Wish.
Wish has partnered with the PRO Itaxs to assist Mainland China-based merchants in complying with France EPR program requirements. Wish merchants will receive a discount for Itaxs' PRO services.
If merchants are NOT considered to be a producer of applicable France-bound products and they do NOT have an EPR registration number, they must obtain the EPR registration number from their direct supplier, the importer into France, and/or a locally registered producer from within their supply chain in France. Merchants must also provide the EPR registration number for applicable product categories to Wish. See Question 4 below for details on providing this number to Wish.
B. Germany
For packaging, merchants considered to be producers of applicable Germany-bound products are required to register with both the Central Agency Packaging Register (ZSVR) and a PRO to comply with EPR program requirements. Merchants may first register with the ZSVR via the LUCID Packaging Register to obtain their packaging EPR registration number. For a step-by-step walkthrough of how to register with LUCID, please see the document attached at the end of this article titled "How to guide_Registration in LUCID.pdf." After, merchants must register with a PRO (using their packaging EPR registration number). Wish has partnered with the LandBell Group, a PRO, to assist merchants in complying with associated EPR program requirements. Wish merchants are strongly encouraged to register with the Landbell Group as their packaging PRO, as they will receive a discount on Landbell Group’s services.
For EEE and batteries, merchants considered to be a producer of applicable Germany-bound products are only required to register through the Stiftung EAR agency to comply with EPR program requirements. However, we strongly recommend merchants utilize an Authorized Representative (AR) to register, as ARs offer significant support to merchants throughout the process. We strongly encourage merchants to utilize the Landbell Group as their AR to register, as Wish merchants will receive a discount on Landbell Group’s services. Merchants can initiate the registration process by filling out the downloadable template attached at the end of this article titled "EPR Compliance Onboarding Form_WEEE_Batt_Wish.xlsx" and sending it to wish-weeebatt-germany@landbellgroup.com. Merchants may reach out to the Landbell Group directly for more information on their fees and registration process. After successfully registering, merchants will receive their EEE and/or batteries EPR registration number.
Wish has also partnered with the PRO Itaxs to assist Mainland China-based merchants in complying with Germany EPR program requirements. Wish merchants will receive a discount for Itaxs' PRO services.
After successfully obtaining an EPR registration number for relevant product categories, merchants can submit EPR registration numbers to Wish via our Merchant Dashboard intake portal or API.
C. Sweden
Merchants considered to be producers of applicable Sweden-bound products must obtain EPR registration numbers from the Swedish Environmental Protection Agency.
Merchants considered to be producers of product categories including packaging, batteries, or EEE (see Question 6 below for a detailed list of in-scope product categories) must register with a nationally approved collection and recycling system or a PRO, for each applicable category.
D. Austria
Merchants considered to be producers of applicable Austria-bound products must obtain EPR registration numbers and proof of registration from a Producer Responsibility Organization (PRO).
If applicable merchants are based outside of Austria, they must appoint an Authorized Representative in Austria.
E. Spain
Register with a PRO.
If your business address is outside Spain, you have to appoint an authorized representative from Spain’s Registry of Powers of Attorney portal. The representative will choose a PRO from Miteco’s list and create a contract with the PRO on your behalf.
Step 2: Declaration & Reporting
Regardless of producer status, merchants shipping applicable France-, Germany-, Sweden-, Spain-, or Austria-bound products are required to declare sales of applicable products covered by the various EPR categories to the respective PROs or nationally approved collection and recycling systems for the applicable reporting period.
Merchants shipping in-scope Sweden-bound products that do not fall under packaging, batteries, or EEE categories can choose to declare directly to the Swedish Environmental Protection Agency or indirectly through a PRO or nationally approved collection and recycling system.
Step 3: Payment
Regardless of producer status, merchants shipping applicable France-, Germany-, Sweden-, Spain-, or Austria-bound products are required to pay eco-contributions to the relevant PROs or nationally approved collection and recycling systems. The PRO or nationally approved collection and recycling system will define eco-contributions based on the EPR product category and device type (e.g., refrigerator, chair, TV, etc), product attributes (e.g., packaging material), and number and/or weight of units sold.
Merchants shipping in-scope Sweden-bound products that do not fall under packaging, batteries, or EEE categories can choose to pay the eco-contributions directly to the Swedish Environmental Protection Agency or indirectly through a PRO or nationally approved collection and recycling system. Merchants considered to be producers of Sweden-bound products must also pay a yearly fee to the Swedish Environmental Protection Agency.
Please reach out to associated PROs for more information on the above actions and EPR program requirements, including deadlines and potential consequences for not being in compliance.
4. How do I provide my EPR registration number(s) to Wish?
Submit France, German, Austria, Spain, and Sweden EPR numbers through the Merchant Dashboard's Product Compliance Center. France and Germany EPR numbers can be submitted via API. See how to submit EPR registration numbers for more information.
5. What happens if I don’t provide my EPR registration number(s) to Wish?
A. France
Merchants selling applicable France-bound products who fail to provide relevant EPR registration number(s) to Wish are considered to be in violation of Merchant Policy. Merchants in violation may be blocked from selling products into France and are subject to other consequences until they provide relevant EPR registration number(s) to Wish. Additionally, merchants may face infractions imposed by the French regulatory authorities if they do not have EPR registration number(s) for applicable France-bound products.
New Wish merchants joining Wish are automatically blocked from selling in-scope products (within applicable categories) into France, unless they provide relevant EPR registration number(s) to Wish via the Merchant Dashboard or API. (See how to submit EPR registration numbers).
B. Germany
Merchants who do not submit their Germany EPR registration numbers to Wish for packaging and EEE are in violation of Merchant Policy. These merchants may be blocked from selling in-scope products into Germany until they provide an EPR registration number to Wish. Additionally, merchants may face infractions imposed by the German regulatory authorities if they do not have an EPR registration number(s) for these product categories.
C. Sweden
Merchants who do not submit their Sweden EPR registration numbers for applicable categories to Wish by August 3, 2023, will be in violation of Merchant Policy. Merchants not meeting the August 3 deadline, may be blocked from selling in-scope products into Sweden until they provide an EPR registration number to Wish. Additionally, merchants may face infractions imposed by the Swedish regulatory authorities if they do not have an EPR registration number(s) for relevant categories.
D. Austria
Merchants who do not submit their Austria EPR registration numbers for applicable categories to Wish by August 3, 2023, will be in violation of Merchant Policy. Merchants not meeting the August 3 deadline may be blocked from selling in-scope products into Austria until they provide an EPR registration number to Wish. Additionally, merchants may face infractions imposed by the Austrian regulatory authorities if they do not have an EPR registration number(s) for relevant categories.
E. Spain
Merchants selling applicable Spain-bound products who fail to provide relevant EPR registration number(s) to Wish are considered to be in violation of Merchant Policy. Merchants in violation may be blocked from selling products into Spain and are subject to other consequences until they provide relevant EPR registration number(s) to Wish. Additionally, merchants may face infractions imposed by the Spain regulatory authorities if they do not have EPR registration number(s) for applicable Spain-bound products.
New Wish merchants joining Wish are automatically blocked from selling in-scope products (within applicable categories) into Spain, unless they provide relevant EPR registration number(s) to Wish via the Merchant Dashboard.
6. What product categories are covered by EPR program requirements and require an EPR registration number?
Product categories covered by EPR program requirements are notably:
France
- Packaging
- Primary packaging (products’ own packaging)
- Secondary packaging (shipping packaging)
- Domestic packaging waste
- Batteries*
- Waste portable batteries and accumulators
- Automotive batteries and accumulators
- Industrial batteries and accumulators
- EEE
- Domestic waste EEE
- Professional waste EEE
- Furniture
- Garden/DIY
- Tires
- Toys
- Paper
- Textiles
*If merchants sell an EEE product containing a battery, they may need to register for both EEE and Battery EPR registration numbers.
Germany
- Packaging
- Primary packaging (products’ own packaging)
- Secondary packaging (shipping packaging)
- Domestic packaging waste
Required starting January 1, 2023:
- EEE
Currently not required:
- Batteries*
*If merchants sell an EEE product containing a battery, they may need to register for both EEE and Battery EPR registration numbers.
Sweden
Required starting January 1, 2023:
-
Packaging
- Primary packaging (products’ own packaging)
- Secondary packaging (shipping packaging)
- Domestic packaging waste
- Batteries
- EEE
- Tires
- Cars
- Fishing gear (of plastic material)
- Tobacco products (including filters)
- Balloons
- Wet wipes (of plastic material)
Austria
Required starting January 1, 2023:
- Packaging
- Batteries
- EEE
Spain
-
Packaging
- Primary packaging (products’ own packaging)
- Secondary packaging (shipping packaging)
- Domestic packaging waste
7. Which PROs can I register with to obtain my EPR registration number for applicable product categories?
A. France and Germany
Wish has partnered with the LandBell Group, a PRO, to assist merchants in complying with associated EPR program requirements. Wish merchants will receive a discount for Landbell's PRO services for Germany EPR product categories. Register with the Landbell Group at a discounted rate for the Germany packaging product category - see Question 3 above for more details on receiving a discount when registering for Germany EEE and batteries product categories.
Wish has also partnered with the PRO Itaxs to assist Mainland China-based merchants in complying with associated EPR program requirements. As noted in Question 3 above, Wish merchants will receive a discount for Itaxs' PRO services for France and Germany EPR product categories.
Wish has partnered with Avask to provide you with additional EPR support. Wish merchants will receive a discount for Avask' PRO services for France and Germany EPR product categories. For more information, please visit: https://avask.com/wish/?utm_source=wish&utm_medium=referral&utm_campaign=wish_referral
For a list of relevant PROs and agencies per EPR Product Category for France and Germany that merchants may register with to obtain an EPR registration number(s), see the below tables.
France:
|
EPR Product Category |
Producer Responsibility Organization |
|
EEE |
|
|
Batteries* |
|
| Garden/DIY | |
|
Packaging |
|
|
Paper |
|
|
Furniture |
|
|
Textiles |
|
|
Tires |
|
|
Toys |
*If merchants sell an EEE product containing a battery, they may need to register for both EEE and Battery EPR registration numbers.
Germany:
|
EPR Product Categories |
German Government Agency |
|
Packaging |
https://lucid.verpackungsregister.org/ |
| EEE | https://www.ear-system.de/ear-portal/#no-back |
|
Batteries* |
*If merchants sell an EEE product containing a battery, they may need to register for both EEE and Battery EPR registration numbers.
B. Sweden
For a list of relevant nationally approved collection and recycling systems for Sweden that merchants may register with to obtain EPR registration numbers, see the below table:
|
EPR Product Category |
Nationally Approved Collection Systems |
|
Packaging |
|
|
EEE |
|
|
Batteries |
|
|
Tires |
|
|
Balloons |
C. Austria
For a list of relevant PROs for Austria that merchants may register with to obtain EPR registration numbers, see the below table:
D. Spain
Please visit the PRO’s website at https://procircular.es/.
8. Where can I find more information on EPR compliance?
For more information on EPR compliance for France, refer to the following websites:
- LOI n° 2020-105 du 10 février 2020 relative à la lutte contre le gaspillage et à l'économie circulaire
- Cadre général des filières à responsabilité élargie des producteurs
- Les filières à Responsabilité élargie des producteurs (REP)
For more information on EPR compliance for Germany, we encourage merchants to get familiar with the respective laws (ElektroG and VerPackG) and refer to the following websites:
For more information on EPR compliance for Sweden, refer to the following websites:
- Extended Producer Responsibility (EPR)
- Producer responsibility for packaging
- Producer responsibility for electrical equipment
- Producers responsibility for batteries
- Producer responsibility for tires
For more information on EPR compliance for Austria, refer to the following websites:
- Austria EPR Overview
- Waste Management Act
- Six Big EPR Changes in Austria
- How To Fulfill Your Obligations as a Marketplace Seller in Austria
For more information on EPR compliance for Spain, refer to the following websites:
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