by Renee

3 min reading time

EPR law explained

earnings

An important step toward corporate sustainability is the introduction of Extended Producer Responsibility (UPV), also known by the English term Extended Producer Responsibility (EPR). This concept, which places responsibility for managing the life cycle of products not only on consumers but also on producers, has been gaining ground worldwide.

In this article, we dive deeper into European EPR law, with a focus on the specific implementations in Germany and France, and clarify the obligations and categories covered.

What is EPR?

Extended Producer Responsibility (UPV) is an environmental policy strategy that aims to make producers responsible for the entire life cycle of their products, especially for take-back, recycling and final disposal. The concept of UPV originated in the 1990s as a way to make waste management more efficient and reduce the environmental impact of products by encouraging manufacturers to develop more recyclable and more sustainable products.

When does EPR law apply to you?

EPR law applies to producers and importers who market products that fall under the EPR categories. This legislation requires companies to register and report on how their products are recycled or disposed of. The specific requirements and when a company is required to have a registration may vary by country and type of product.

EPR comprehensive product responsibility EPR law concept illustration.

Why is EPR law suddenly so important?

UPV is important because it encourages manufacturers to think about the environmental impact of their products throughout their life cycle. Placing end-of-life responsibility on producers encourages them to design products that are easier to recycle, produce less waste, and are less harmful to the environment. This not only contributes to better waste management, but also promotes the transition to a circular economy.

Examples: what about in Europe?

Now let’s look at how UPV has been implemented in two European countries: Germany and France.

EPR law in Germany

In Germany, EPR law has three categories:

  • The first is known as the “Verpackungsgesetz,” or VerpackG (Packaging Act), strict and covers virtually all types of packaging that reach consumers. Manufacturers and importers of packaged goods are required to register with the central packaging register“Zentrale Stelle Verpackungsregister” and must prove that their packaging is recycled in accordance with the law.
  • The second category is ElektroG, also known as the WEEE (Waste Electrical and Electronic Equipment). This category focuses on electronic and electrical waste.
  • The third EPR category in Germany is the Batteriegesetz, or BattG. And as the name suggests, this category focuses on battery recycling.

Do you sell products that fall into any of these categories? Then you are required to enroll in the registries. And you soon are, given that the VerpackG refers to (almost) all types of packaging material. Do you need help with your registration, or do you have questions? If so, you can contact us for that.

EPR law in France

If you are going to sell products online in France (for example, through Amazon FBA), which may be packaged in plastic or cardboard, you must register for EPR. After this registration, you are required to report annually on the amount of packaging you ship to France (in kilograms). For companies selling less than 10,000 products annually, French law does not require a detailed report of packaging materials used. If that is the case, you only have to pay an annual fee of €80 to the French recycling organization where you are registered.

Note: France specifically distinguishes between printed paper and other packaging. Registration under the EPR regulations for printed paper, such as manuals, is only required if your company puts more than 5,000 kilograms of paper on the French market each year.

What if you don’t register?

It’s legislation, so if you don’t comply with it, there are consequences. Just to mention one thing: If you don’t follow EPR rules in Germany, you face a fine of up to €200,000. And if you manage to make it even crazier, it could even lead to a sales ban. No one wants that!

What can Staxxer do for EPR?

Do you think you are EPR liable? Have questions about UPV, the OSS, VAT, or would you prefer to outsource? Then schedule a free demo with Staxxer. Then you also get advice that is completely tailored to your business!

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Yonis Brander

VAT consultant

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