EPR – Extended Producer Responsibility

Compliance with EPR regulations is crucial for anyone marketing products in the EU. In Germany, laws such as the Packaging Act, ElektroG and BattG regulate take-back and recycling. Other EU countries have similar but different regulations.

Manufacturers and online retailers on platforms such as Amazon, eBay and Etsy must provide specific evidence in order to avoid sanctions. Find out how to master the EPR requirements and what support we offer.

To the free EPR consultation appointment

What is the extended producer responsibility?

The EPR obliges manufacturers, distributors and retailers throughout the EU to take responsibility for the entire life cycle of their products, from design to take-back, disposal and recycling. This includes the product itself as well as all packaging and product components that are placed on the market. It is the responsibility of the distributors to ensure the proper disposal and recycling of these materials.
In Germany, the EPR affects all initial distributors of packaging (VerpackG), electrical and electronic equipment (ElektroG) and batteries and accumulators (BattG). Manufacturers and distributors of the products concerned are therefore obliged to comply with the statutory regulations. This is accompanied by registration with the relevant competent authority. In addition, end-of-life vehicles, waste oil and used tires fall under the extended producer responsibility.

What is the EPR number?

An important part of EPR compliance is the EPR number (European Product Registry Number). Manufacturers, importers and online retailers who wish to sell their products in Europe are obliged to apply for and provide this identification number. It enables authorities to uniquely identify and trace the origin and distribution channel of products placed on the market. Without this number, the necessary proof of compliance with EPR regulations cannot be provided. This can lead to trade restrictions, sales bans or even legal sanctions such as fines.

Packaging licensing in Germany 

As part of the EPR, packaging licensing in Germany ensures that packaging is disposed of and recycled in a professional and environmentally friendly manner. The German Packaging Act (VerpackG) obliges distributors of packaging that is filled with goods and ends up with the end consumer to license it. This applies to sales packaging, shipping packaging, outer packaging, service packaging, shipping cartons, product packaging and filling materials. The aim is to achieve the recycling rates stipulated by the Packaging Act and to reduce the environmental impact of packaging waste. 

With zmart.de, we make packaging licensing quick and uncomplicated for you. You can use our online calculator to record your packaging quantities and calculate the packaging license costs directly. Our digital processes make licensing easier - it takes just a few minutes to complete. We offer a cost-effective solution for legally compliant packaging licensing. 

 

WEEE - The Electrical and Electronic Equipment Act 

WEEE stands for Waste Electrical and Electronic Equipment. In Germany, waste electrical and electronic equipment is subject to the Electrical and Electronic Equipment Act (ElektroG). The law has been in force since 2005 and is intended to implement the European WEEE Directive regulating the placing on the market, return and disposal of electrical and electronic equipment. The ElektroG only applies in Germany, as each EU country has its own legislation in relation to the WEEE Directive.  

The ElektroG applies to any company that manufactures and sells equipment under its brand name or resells equipment from third parties under their brand name. Online retailers and companies that sell appliances directly to consumers in private households in another EU member state using distance communication technology are included. Manufacturers and importers must register with stiftung ear before they are allowed to place their devices on the market. 

 

The Batteries Act (BattG) 

The BattG has been in force in Germany since 2009 and implements the EU Battery Directive (BATT) to regulate the placing on the market, taking back and proper and environmentally sound disposal of batteries and accumulators. Manufacturers, distributors and importers of batteries and accumulators are obliged to *register with stiftung ear*. We are happy to assist you in meeting your legal obligations and keeping the recyclable materials from your batteries and rechargeable batteries in the cycle. In addition to production, the BattG also covers the import and sale of private labels. This also applies to foreign suppliers without a registered office in Germany. Each EU country has its own battery legislation, so the Battery Act only applies in Germany. 

 

Packaging licensing in Europe 

The EPR includes packaging licensing in Europe. It obliges manufacturers and importers to take responsibility for the environmentally sound disposal and recycling of their goods and packaging. EPR directives are implemented individually by each EU member state. Companies that sell their products in several European countries should know and observe the respective legislation of the target countries.  

Important to know: The EPR number is not necessarily a uniform marking throughout Europe. The EU member states have their own EPR systems and the corresponding designation of the identification number. In Germany, the EPR number for packaging corresponds to the LUCID number and for electrical appliances and batteries to the registration number of stiftung ear. 

Applying for an EPR number: how it works

As already clarified, the EPR number is required for marking and identification when selling goods affected by the EPR in Germany and Europe. You can obtain this by registering with the relevant competent authority. If you place packaging on the market, register it with the Packaging Register LUCID of the Central Agency Packaging Register. If you place electrical appliances, batteries or rechargeable batteries on the market, register with stiftung ear.
This is where we come into play for you. The legislation of the ElektroG and the BattG allows manufacturers to use third-party providers like us to fulfill the legal requirements. We assume the obligations laid down by the BattG and ElektroG. Our services make it easier for our customers to register electrical appliances. We take care of all the necessary deposits with stiftung ear

  • from registration to the provision of the insolvency-proof guarantee. We are also recognized by stiftung ear as an authorized representative and are entitled to take on all tasks for foreign manufacturers.

EPR requirements on online marketplaces

To comply with the EPR requirements, merchants on popular online marketplaces such as Amazon, eBay and Etsy must ensure that they submit all required registrations and documentation in a timely manner.

Compliance with these regulations is crucial to avoid penalties, trading restrictions or the suspension of seller accounts. Below is a brief overview of the requirements on these platforms that are necessary for smooth business operations.

Amazon

Retailers must submit specific EPR evidence, including EPR numbers for packaging, electrical appliances and batteries, in the EPR compliance portal. Amazon will block sales offers if the evidence is not submitted on time to prevent penalties and sales bans.

eBay

eBay requires EPR registration numbers and proof of packaging licensing from its merchants. On the French market ebay.fr, UPINs and environmental contributions in product listings are also required to prevent penalties and sales bans.

Etsy

Etsy requires sellers to provide EPR registration numbers and proof of recycling fees, especially for shipments to Germany and France. The relevant information must be stored in the Etsy Shop Manager.

Special notes on EPR for Alibaba, eBay, Etsy and co.

Online platforms and online marketplaces may be subject to certain special requirements in relation to the EPR. Examples of this are

  • Division of responsibility: The clear allocation of responsibility in the context of the EPR is not always clear, as the platforms are generally not the physical manufacturers of the products. They merely facilitate the sale. It can be difficult to determine whether the responsibility lies with the seller, the platform itself or possibly both parties.
  • Policies and regulations: Platforms such as Alibaba, eBay and Etsy often have their own policies on product listing and quality. They themselves take measures to ensure that products meet certain standards, although the exact implementation of EPR may be complex.
  • Environmental impact and transparency: Although the direct implementation of EPR is challenging for these platforms, they can still launch initiatives to minimize environmental impact. They could incentivize sellers to use environmentally friendly packaging or support recycling efforts.

EPR full service throughout Europe

Our EPR Full Service relieves you of all obligations arising from the EPR. We offer free personal advice and support your company with legally compliant exports abroad, including taking on administrative tasks.

Thanks to our strong network in the European recovery and recycling market, we develop individual solutions for efficient packaging disposal for every company. You benefit from a personal contact person and transparent communication.

To the free EPR consultation appointment

Why was the EPR launched? 

The EPR was introduced to promote an effective circular economy. It is intended to be the answer to the shrinking resource base and the increasing damage caused by inappropriate waste disposal. Its main aim is to create a functioning circular economy in which products and packaging do not simply end up as waste, but can be reused, repaired or recycled. The reasons in favor of EPR are:

  • Addressing resource scarcity: increasingly limited resources meant that a response to the uncontrolled handling of waste was urgently needed. The EPR is intended to help ensure that products and packaging are not simply disposed of, but kept in a cycle.
  • Producer responsibility: The concept is based on the principle of polluter responsibility. Manufacturers who place products and packaging on the market are also responsible for the raw materials and their future recycling. They have the greatest influence on the choice of resources and their recyclability.
  • Influence on product design: The EPR goes far beyond the disposal process and urges companies to take action right from the product design stage. This includes the use of recycled materials, design for reparability and the creation of recycling options. 

 

Measures as part of the EPR:

  • Product design: designing products so that they are more easily recyclable or reusable. This includes the use of environmentally friendly materials and the design of products that are durable and easy to repair.
  • Financial responsibility: Manufacturers also bear financial responsibility for the collection, recycling and safe disposal of their products after use. For example, they can invest in take-back systems or pay fees to cover the costs of disposal.
  • Regulatory requirements: In many countries and regions, there are legal requirements for EPR that oblige manufacturers to meet certain recycling quotas, register or set up specific take-back systems. 

FAQ on the EPR requirements

Zentek’s 360° Service: Your one-stop provider

With our 360° service, we aim to support you in all areas, offering comprehensive and modern solutions from a single source. Through our nationwide services in Germany, we assist our customers with:

EPR compliance

  • Packaging licensing in Germany
  • Packaging licensing across Europe
  • WEEE – Electrical and Electronic Equipment Act (ElektroG)
  • Battery Act (BattG)

Nationwide site disposal

  • Digital waste management – Zentek Connect
  • CSRD reporting
  • Providing a waste management officer
  • Container services via Containerdienst.de

Additional services, including:

  • Document destruction
  • Food waste disposal
  • Disposal of transport packaging
  • clozed loop™