EPR Taxes for Online Sellers In Europe: Core Facts

The abbreviation of EPR stands for Extended Producer Responsibility—a type of environmental policy requiring businesses to contribute when selling products that impact the environment in a way covered by the policy. EPR is typically accounted for on the impact of the product once it is used or when its life cycle ends.

More broadly, EPR aims at extending the producer’s responsibility to post-usage of the product, would that be recuperating the item, recycling it, or reducing its impact on the environment in other ways. However, in most cases, it is difficult to put these actions to practice, so there exists a payment system based on contributions to certified waste management organizations.

Paying EPR fees are crucial to online sellers using online marketplaces in Germany and France, even though the regulation is harmonized in the EU. EPR is due on sales of electrical and electronic equipment, batteries, and certain types of packaging.

It is the duty of the seller to stay compliant with the EPR. However, Germany and France have made online marketplaces jointly liable for EPR. This is why online marketplaces require sellers to fill in their EPR numbers into their systems. In Amazon’s case, sellers that fail to fill in their EPR numbers when using the platform in Germany or France are suspended.

In a nutshell, EPR compliance covers three main steps:

• Getting registered for EPR and receiving the EPR number in the country where the sales happen. The German EPR registration happens via the LUCID organization, so the EPR number is often referred to as the LUCID number. In France, the EPR is known as UIN (Unique Identification Number).
• Sharing the EPR registration number with the online marketplace.
• Paying the EPR contribution periodically. The payments go to authorized organizations in the countries where the sales happen. In Germany, the amount due depends on the net mass of the product based on its category. It is possible to report planned volume if the sales haven’t started; intra-year volume; or year-end volume. If the estimates are incorrect, the sellers are responsible for submitting supplementary or deduction reports. In France, the EPR contributions are calculated based on the number of consumer selling units (CSU) sold in France. The reports for CSUs sold differ based on how many CSUs were sold per year. If a company sells less than 10 thousand CSU a year, the EPR rate is flat at EUR 80, and no declaration is needed.

From the beginning of 2022, in France, Amazon pays EPR on behalf of the seller. This means that sellers using amazon.fr do not need to register for EPR if the sales happen only in France (no goods are shipped to other EU countries).

If you want to find out more about EPR in France, Germany, and other countries—please reach out to our team. We will help you register, declare, and pay the EPR if needed.