As a retailer selling to European consumers, staying compliant with Extended Producer Responsibility (EPR) regulations is not just a legal obligation, but a strategic necessity. The EU’s EPR framework requires businesses to take responsibility for the environmental impact of their products throughout their lifecycle, from production to disposal. There are EPR areas for packaging, batteries, electrical appliances, furniture and tyres, among others. For retailers operating in Europe, understanding the key requirements and navigating the complex landscape of packaging licensing is crucial. In this article, we will outline the most important aspects of EPR compliance in the field of packaging and show you how to meet these obligations efficiently with the right support of our partner LIZENZERO.
Understanding EPR Compliance in the EU
The EPR is a policy approach that places the responsibility for the disposal of products on producers, incentivizing them to create more sustainable products and reduce waste. In the European Union, EPR is not just a concept –it’s a legal requirement. Every retailer, whether based in the EU or selling to EU consumers, needs to understand and comply with these regulations to avoid significant fines and reputational damage.
For retailers targeting Europe, it is crucial to grasp the nuances of EPR regulations in each EU country, such as Germany, France and Spain. These countries have implemented stringent requirements that vary in scope but share the common goal of reducing waste, promoting recycling, and ensuring that producers bear the financial and environmental costs of their products’ end-of-life.
Key EPR Requirements for Retailers in Europe regarding packaging
Retailers selling in Europe must comply with several core EPR obligations. Each country has its unique set of rules, but the following are common across most jurisdictions:
- Registration and Reporting Obligations: Retailers must register with national authorities to sell products in most European countries. This often involves submitting detailed product information, including quantities, materials used, and the packaging types. In Germany, for instance, the LUCID Packaging Register is mandatory for all companies introducing packaging to the market. Failure to register can result in heavy penalties or bans on selling within the market.
- Financial Contributions to Waste Management Schemes: Retailers are usually required to contribute financially to national waste management schemes, which fund the collection, sorting, and recycling of packaging waste.
- Labelling requirements: In some European countries, such as France, separation instructions and recycling labels must be affixed to packaging. This labelling is intended to ensure that consumers can dispose of the packaging correctly so that it can be recycled.
Navigating Packaging Licensing: An Important Component of EPR
Packaging licensing is one of the most important aspects of EPR compliance for retailers in the EU. Under EPR laws, businesses must ensure that all packaging materials – whether used in shipping, marketing, or the product itself – are licensed according to local regulations. Here’s what retailers need to consider:
- Country-Specific Packaging Regulations: Different countries have varying rules about packaging materials and recyclability standards. For example, some countries set volume or turnover thresholds regarding the licensing obligation.
- Recyclability and Eco-Modulation Fees: Many countries, such as France and Italy, have introduced eco-modulation fees. These fees vary based on the environmental impact of the packaging materials used, with lower fees for more recyclable or compostable options. This approach encourages retailers to select packaging that aligns with local sustainability goals, ultimately reducing costs and improving compliance.
- Documentation and Proof of Compliance: Retailers must maintain accurate records of their packaging materials, including the quantities and types used, to demonstrate compliance. In some countries, audits by local authorities are common, and failure to provide sufficient documentation can lead to fines or trading restrictions.
Stay Ahead with Proactive EPR Compliance
EPR compliance is not just a legal requirement; it is an opportunity to demonstrate your commitment to sustainability and build trust with consumers in key European markets. By understanding the local regulations, investing in sustainable packaging solutions, and choosing the right partner, you can ensure compliance while positioning your brand.
To give you an additional overview, we have summarised the most important rules for Germany, France and Spain:
Germany
In Germany, all distributors of sales packaging are obliged to license with a dual system from the first packaging put into circulation (this can be done conveniently and completely digitally, for example directly via lizenzero.de, the online shop of the dual system Interzero). Retailers must license all packaging that accumulates at private individuals and so-called comparable sources of waste generation. You need to report the packaging volumes annually in advance, based on your planned quantities and confirm them in the end. In addition, distributors must register with the Central Agency Packaging Register (ZSVR) in the LUCID register and also report their data there.
France
In France, licensing costs for all sales packaging are calculated in consumption units. The consumption unit refers to the product item itself. For up to 10,000 consumption units per year, micro-distributors pay a flat rate. Sustainable and recyclable packaging can become cheaper to license through ECO fees. In addition to licensing, retailers are also obliged to label their packaging with the so-called Triman logo as well as labelling with separation information for the French market. Since October 2023, a prevention plan to reduce the environmental impact of packaging must also be submitted to the dual system.
Spain
Companies that bring household packaging into circulation are obliged to license their packaging from the first packaging placed on the market. If your company also has a branch OR tax number in Spain, there is also a registration obligation for all types of packaging. Foreign companies must appoint an authorised representative for registration and volume reporting. In addition to the licensing fees, there are also membership fees for the recycling system.
How to Ensure Your Packaging EPR Compliance with LIZENZERO
Achieving full compliance with EPR regulations across multiple countries can be a complex and time-consuming process. Partnering with an experienced service provider can simplify compliance and help you navigate the various legal landscapes.
With LIZENZERO, you have a strong partner at your side for all your packaging licensing needs.
For packaging compliance in Germany simply use lizenzero.de. With many years of expertise and an on-demand customer account, lizenzero.de offers you simple and digital packaging licensing in Germany from just €39 per year.
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Do you also ship to other European countries and need support with licensing? LIZENZERO also supports you here with lizenzero.eu. As part of the licensing service, our experts will take care of all your requirements from start to finish. You can just sit back and hand over all your duties.
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*Valid until 31/12/2024 Discount on the net value of goods. No payment possible. One voucher redeemable per order and customer. Cannot be combined with other discount promotions. Subsequent redemption not possible. Legal recourse is excluded.