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2023 Amazon France EPR Regulation Update

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2023 Amazon France EPR Regulation Update

But what exactly is EPR? This regulation requires those selling on Amazon to comply with specific obligations to ensure the conformity of their products and share crucial information. In this article, we will examine the main aspects of EPR regulation in France and how Amazon sellers can fulfill these requirements.

In this article

  1. 1Who is obligated to provide environmental labeling?
  2. 2To which product categories does EPR regulation apply in France?
  3. 3How to obtain an EPR number in France?
  4. 4Who is considered a producer for the purposes of EPR regulation?
  5. 5How to fulfill EPR obligations on Amazon?
  6. 6What is the format of a UIN code?
  7. 7Conclusion

Who is obligated to provide environmental labeling?

In France, Amazon is legally required to collect valid UIN codes for products sold on the French marketplace to verify sellers' compliance with EPR obligations. This process involves collecting valid EPR registration numbers, known as UIN codes, on the Seller Central page dedicated to Extended Producer Responsibility compliance information.

As of 2023, this law applies to certain product categories sold on Amazon.fr. In the future, new categories may be added based on current regulations.

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To which product categories does EPR regulation apply in France?

Below you will find a list of categories updated since the beginning of 2022 subject to the Extended Producer Responsibility law, for which providing a UIN code is mandatory.

EPR product categories

How to obtain an EPR number in France?

If you are a producer, follow these steps to obtain an Extended Producer Responsibility number:

  • Register with a competent Producer Responsibility Organization for each EPR category of products you sell. These organizations are known as "éco-organismes" in France.

  • Make regular environmental payments to the competent organizations based on the quantity and type of products sold.

  • Once you have obtained the UIN codes from the competent organization and verified their visibility on SYDEREP, submit them to the EPR compliance information page on Amazon to demonstrate your compliance.

  • Offer a take-back service, which will be organized by your competent Producer Responsibility Organization. For further details, consult the frequently asked questions on the requirements page for the take-back of used products.

Keep in mind that obtaining a UIN code may involve costs, such as contract fees or environmental contributions for previous years.

If you prefer, you can also set up your own waste management system, but this option requires approval from the French agency ADEME and the creation of a take-back service for your customers. More information is available in the informative material provided by the Ministry for Ecological Transition.

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Who is considered a producer for the purposes of EPR regulation?

According to Article L541-10 of the French Environmental Code, you are considered a producer if you meet at least one of the following conditions:

  • You manufacture products subject to EPR requirements in France and sell them on the national territory.

  • You import products subject to EPR requirements into France.

  • You sell products under your own brand or name.

How to fulfill EPR obligations on Amazon?

On Seller Central, Amazon indicates 3 main solutions to facilitate the fulfillment of EPR compliance obligations in France:

1. Pay on Your Behalf Service

Amazon's so-called "Pay on Your Behalf" service is designed to help sellers meet the EPR obligations required in France for sales on Amazon.fr. Amazon handles paying the environmental contributions on your behalf and recovers these amounts from your Amazon account. If you do not have a valid UIN code for one or more EPR categories, Amazon will automatically enroll you in this service.

2. EPR Services on Amazon

Amazon also offers "EPR Services on Amazon," a comprehensive compliance solution that allows sellers to manage EPR obligations in France. You can register for this service and submit EPR declarations directly through Seller Central. Amazon benefits from partnerships that will simplify the process.

  1. Amazon Partnerships

Amazon has a network of service providers for Extended Producer Responsibility (EPR) offering support for EPR registration, filing declarations, and answering specific questions about Extended Producer Responsibility compliance requirements. The cost of these services varies based on the selected provider.

EPR Support

What is the format of a UIN code?

The UIN code (unique identification code) follows a specific format that starts with "FR" in uppercase, followed by a six-digit number, an underscore, and a six-character sequence that can be letters or numbers (for example: FR123456_123456 or FR123456_ABCDEF). Make sure to enter the UIN code correctly in the required format, otherwise it will be considered invalid.

For more information, you can consult the following links:

Conclusion

Complying with Extended Producer Responsibility legislation in France is essential for Amazon sellers operating on Amazon. By using the resources provided by Amazon and following the key steps to fulfill EPR requirements, you can ensure the compliance of your products and continue to sell successfully on Amazon.

Do you still have doubts about EPR regulation or anything regarding selling on Amazon?

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Book a free consultation with our team.

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