Extended Producer Responsibility (EPR) is a new type of environmental policy that places responsibility on the shoulders of the manufacturer to manage the waste caused by the different types of products they market in order to reduce their environmental impact.

In accordance with the EU Extended Producer Responsibility (EPR) Directives, all EU countries have started to introduce strict waste management regulations since the end of 2022. Thus, starting in 2023, producers will be responsible for managing waste from products at the end of their life cycle, and everyone must comply with them or face severe sanctions.

All EU countries have introduced EPR compliance liability for all manufacturers and sellers without a minimum threshold. This means that even if you sell 1 unit of goods, you automatically become obliged to comply with the required standards. Currently, the EPR covers almost all areas of activity, not just packaging.

The EPR registration rate starts from as low as €150 for full registration service!

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Packing

What types of packaging for EPR?

Steel	Aluminium
PET	HDPE
Other rigid plastics	Film and flexible plastics
Compostable packaging	Cardboard for food and beverages
Paper and cardboard	Ceramic
Wood and cork	Other materials

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Who must comply

Legislative acts of all countries stipulate that all producers must comply with these rules. What does a producer do?
Producers are defined as companies or individuals who first introduce a product subject to the EPR program in a given country. This can be through domestic production or imports. It is important to understand that being a producer does not necessarily mean being a manufacturer.

Traders, companies, and other persons are recognized as producers subject to the EPR program if:

The product they produce is subject to the requirements of the EPR program in the country where they sell it.
They import a product subject to the EPR program into the country where they sell it.
They sell a product subject to the EPR program in a country where they are not registered.
Essentially, all manufacturers, sellers, distributors, intermediaries, and importers who place a product on the market in a particular country are considered to be producers.

So, according to the rules, everyone is a producer:

Manufacturers
Sellers
Distributors
Intermediaries
Importers

Those who sell goods on the territory of a country.

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EPR number

The EPR registration number is a unique number, which in most cases is assigned by the central government agency that directly deals with environmental issues, for example, in France it is ADEME (French Environment and Energy Management Agency) and in Belgium IRPC (Interregional Packaging Commission). The EPR certificate has no expiration date and it is updated every year if the company complies with all the necessary rules.

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Eco-operators (PRO) and license fees

Companies must comply with the rules by establishing their own waste management organization or, as is done in most cases, delegating these obligations to approved PROs (Eco Operators).

The Producer Responsibility Organization is responsible for ensuring that you meet all the necessary requirements of the rules and are responsible for the management of the waste generated by your company after its life cycle. If you comply with all the rules, you will receive your compliance license, which is accompanied by the payment of an eco-fee, which varies by country and starts from 40 euros to 2000 euros. But in general, it is 200 euros per category.

After you register a Lovat account, you will be able to access the license calculator at the beginning of each reporting period.

How to get it

Fill out the application form
Provide additional information
Sign a power of attorney (if necessary)
Pay for the license
Obtaining the EPR number

How to stay compliant

Obtain an EPR number for the categories in which you operate
Collect all information about the type and amount of waste
Submit an annual EPR report
Pay the eco-fee

Registration is more profitable with a subscription to electronic reporting for traders.

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Reporting deadlines

In most countries and categories, reporting is annual. But sometimes it is quarterly for companies that sell a large number of products on the market in the field of electronics and batteries. The reporting deadlines are set by the licensees, so they depend on your license agreement, usually this period lasts from January 1 to August 1 depending on the country. Lovat users don’t have to worry about missing the deadline because they can always check their EPR deadline in their Lovat dashboard. You will also receive reminders about EPR deadlines and never miss your EPR deadline.

Subscriptions for registration and annual reporting start at 190 euros (net) per year for the packaging category and 250 euros (net) per year for all other categories. Submit a request for registration or reporting.

Apply for EPR

If you have questions, you can get extended producer responsibility consultation from our experts. Just send your question to our contact form. Or get community support in our telegram chat.

For Amazon sellers, we have unique benefits – auto-filling and auto-submission features. As Lovat software has an App at Amazon you can install our app to your store and authorize Lovat to process all your packaging data. If you set auto-submitting mode – Lovat software will prepare a full EPR report and send it to you for approval. After you click the button “Agree” your EPR report would be submitted online via the Lovat platform.

Frequently asked questions

I see that Amazon indicates that my EPR category is "primary packaging". Needs LUCID number, not EPR agreement?

Primary packaging is a material used to protect the product. When you as a seller ship your goods to amazon each item might be somehow packed – for example shampoo in plastic bottles, earings in boxes etc. Both FBA sellers and self-fulfilled sellers need to be compliant with primary packaging. An example of primary packaging for fragrances – is a perfume box. Secondary packaging is shipping packaging. This includes a plastic mail envelope, box, or bag used to protect the product during postal delivery to the customer.

I’m an online seller and sell through my website to customers in Germany. What type of data to collect to be able to fill EPR report.

You need to collect type of package, quantity for bottles, weight for carton and plastic.

I sell computers through eBay in France. In which EPR category do I need to register?

The specific EPR category for selling computers through eBay in France depends on the type of computers you sell. However, in general, because the device contains a rechargeable battery, you need to register in three categories: Packaging, Electrical and Electronic Equipment (EEE), and Batteries.

We are selling refurbished electric scooters and e-bikes in France and Spain. Which EPR categories will be required?

Because the device contains a rechargeable battery, you will need to get EPR registered in the following categories: Packaging, Electrical and Electronic Equipment (EEE), and Batteries.

I sell products on Amazon from Germany to Spain. Do I need to obtain a Spanish NIF tax number to obtain an EPR number? Also, if I receive this NIF number, do I have to submit any reports?

If you are selling on Amazon and need an EPR number, it is indeed necessary to obtain a Spanish NIF (Número de Identificación Fiscal) tax number. The fee for obtaining a NIF is €150. Additionally, it's important to note that if you already possess a VAT (Value Added Tax) number, this indicates that you have a NIF. Therefore, in this scenario, you do not need to obtain a separate NIF. Please remember, if you have a VAT number and are conducting business across EU borders (for example, shipping products from Germany to Spain), you are typically required to make VAT reports. Lovat software has integration with Amazon, which allows you to automatically create and send reports on EPR and VAT.

Is it necessary to register for textile EPR if you sell second-hand clothes?

If you only sell second-hand items, you are not subject to eco-organization. On the other hand, if you sell new textile products, you are obligated to register.

EPR registration