专业
为跨境电商提供欧洲落地服务
专业
欧盟授权代表ProdSG服务
专业
德国WEEE注册与认证

Extended Producer Responsibility EPR compliance

We conducted a comprehensive interpretation and analysis of the EPR registration issues that cross-border sellers are mostly concerned about.

What is EPR product classification?

EPR product classification is the basis for EPR registration. After understanding the product classification, sellers need to clarify which EPR product classifications they need to register. Each different product classification needs to go to different recycling operator for registration and declaration.

I have already fulfilled some EPR obligation, do I need to inform the platform?

Yes, please provide your EPR registration information to the platform. Amazon will share the link for uploading the EPR registration in the fourth quarter of 2021.

How do sellers calculate the quantity that their store needs to declare?

The seller needs to calculate the specific recycling volume that the agency company needs to declare to the recycling operator:

Recycling amount = the quantity/weight of the products sold in the store in the current year under the EPR category.

What information should be provided to buyers’ products after EPR registration?

  • After the seller has registered for the EPR, it is also necessary to place relevant information or marks on the products to the consumers, including but not limited to:
  • Print the trash bin logo on the electronic and electrical products and packaging sold.
  • Print the recycling registration number on the sales invoice.
  • Mark the French packaging recycling operator logo on the packaging cartons.
  • French electrical and electronic sellers need to list the term of environmental protection payments on their invoices.

What should I pay attention to when submitting the registration to the platform?

The seller receives the registration information of each EPR product category and submits it to Amazon backend for review.

Different EPR product categories have separate registration numbers.

The WEEE submission number in Germany is not a registration number for package and cannot pass the review.

What is the lead time for EPR registration?

  • German packaging law: 2 weeks
  • German electrical and electronic law and battery law: 6-12 weeks
  • German WEEE registration is generally slow.

What are information requirements for EPR registration?

  • Business license
  • Store information
  • Product information
  • The number of products sold
  • VAT tax number or tax identification number

What should the seller do after receiving the EPR registration reminder email from Amazon?

  • Check whether the products produced or sold by oneself meet the EPR commodity classification;
  • Confirm that the products you produce or sell involve several categories;
  • Calculate the quantity that needs to be declared for your related stores;
  • Registration of the relevant laws and regulations, and put relevant marks on the products and packaging, and declare regularly;
  • Fill in the registration confirmation on the platform (generally: registration certificate and registration number).

How should sellers respond to this EPR policy?

Some people might ask, the EPR regulations have only come into effect this year, so we don’t need to deal with it in a hurry now? Then answer is No. The number of sellers registration will increase at the end of this year, so the review time could be much longer. When the review peak period occurs, it is too late to register and update your EPR information.

What are the consequences of not registering for EPR?

  • This email notification clearly requires that starting from 2022, for products sold by sellers to Germany or France, Amazon will confirm whether the products sold by the seller meet the EPR requirements of the country/region,  collect and verify the seller’s EPR registration information.
  • If the seller’s products cannot prove that they meet the requirements of the EPR, Amazon will impose a suspension on the seller’s products listing.
  • If the German authority find that the seller’s goods do not meet the EPR requirement in Germany, they could face goods detention and fines.
  • There are only three months left until the implementation date of 2022. Amazon will also share the link for uploading the EPR registration information in the fourth quarter of this year. Please noted that sellers on the German site need to register for EPR as soon as possible to avoid products delisting.

Serviced Offices

For the majority of your working week it may be possible for you to run your European company from a virtual office, using internet-based communication links and audio or video conferencing. However, there will be occasions when you need to have a physical presence in the country concerned and for this reason Eulinx Consulting provides a comprehensive selection of serviced offices.

In order to cater for the individual requirements of our clients we offer a variety of European serviced offices, in various sizes and locations, which can be secured either on a temporary or permanent basis. All of our European serviced offices are fully furnished and available for immediate use, enabling you to open a European business very quickly. They also share the following features to promote your company in a professional manner:

Serviced Offices Europe

  • Telephone answering and forwarding, fax forwarding and messaging, using your company's name
  • Reception facilities
  • Meeting and conference facilities*
  • Secretarial assistance

Responsible Person for Amazon Sellers

Are you a seller on Amazon and have you been requested to ensure you have a Responsible Person for CE-marked products? You do not have a European Union office or subsidiary and you do not know how to fulfill this requirement from Amazon? We can help!

We located in Germany and offer this service to act as your Responsible Person for CE-marked products. We can provide you with a practical solution for this requirement. This service also includes the review and verification of test reports, certificates, and other conformity documentation you received from your manufacturers. This way you can rest assured that your files are complete, your product liability is minimized, and that you can continue to sell on Amazon.

 

Frequently Asked Questions:

What is a ‘Responsible Person for CE-marked Products’?

The Responsible Person for CE-marked Products is a natural or legal person that is appointed to communicate with the market surveillance authorities of the EU Member States in which CE-marked products are sold. This person is not a sales representative or distributor. S/he will also not take over your product liability. The Responsible Person’s role is primarily to be a single point of contact for the authorities, and to communicate on your behalf about questions related to regulatory conformity and CE compliance. For that reason, you are best served with a person that is an expert on CE marking and the CE marking regulations, standards, and approval procedures.

Why is Amazon requiring a ‘Responsible Person for CE-marked Products’?

In 2020, the European Union institutions have adopted a regulation (Regulation 2019/1020) that intends to strengthen market surveillance in the European Union. The Regulation prohibits sales from outside the European Union directly to end-users in the EU Member States. Such sales are only allowed if the exporter has a subsidiary office in the EU, works through importers, has an authorized representative or ‘responsible person for CE-marked products’, or uses a fulfillment service provider. Read more about the Regulation and what it means for non-EU-based manufacturers and sellers here.

Is the ‘Responsible Person for CE-marked Products’ a kind of sales agent?

No. The Responsible Person’s role is only to operate as a single point of contact for regulatory inquiries. It is not intended to take over communication regarding sales inquiries.

Does the ‘Responsible Person for CE-marked Products’ have to be indicated on the product label and on the Declaration of Conformity?

The requirement to appoint a Responsible Person for CE-marked Products is a requirement from Amazon if you want to sell CE-marked products through their platform. It is not a legal requirement for CE marking. The CE marking regulations require the label to show the name and address of the manufacturer and importer if that is relevant. If the manufacturer is located outside of the EU and sells through Amazon directly to end-users in the EU, it is wise to appoint an authorized representative. The authorized representative can then be listed with Amazon as the Responsible Person for CE-marked Products.

How can we help you to meet the Amazon ‘Responsible Person for CE-marked Products’-requirement?

Since 2009 we offer a dedicated service for manufacturers and exporters that require an authorized representative for regulatory conformity matters in the European Union.  Our experts have a longstanding experience with the European directives, regulations, standards, and procedures for a great variety of products. We will handle any inquiry from the authorities professionally and accurately.

Introduction to Company Incorporation Germany

If you are a foreign investor and wish to consider German company formation, you have a broad spectrum of options. You could take a cautious view and start with a one-person sales office based within a serviced office (we can help you with this). If it doesn't work out, you can easily withdraw without having invested very much capital. Or you could have the courage of your convictions, and set up business in Germany in a manner that makes it clear that you really mean business. Our German company formation service makes it easy for you to establish whatever kind of company you want, from a Sole Trader through to a Partnership or Corporation.

What are the main types of German company formation?

There are four main forms of German Company Registration:

  • Limited Liability Corporation (GmbH)
  • Stock Corporation (AG)
  • Partnerships
  • Sole Proprietor

What are the main features of a Limited Liability Corporation (GmbH)?

A GmbH is the most common form of company in GermanyThe minimum share capital is €25,000 It has a simple structure designed for private companies onlyThe minimum number of shareholders is one

What are the main features of a Stock Corporation (AG)?

An AG is the standard corporate form for major public companiesThe minimum share capital for an AG is €50,000The minimum number of shareholders is oneIt is subject to heavy regulation as a listed company

What are the main features of a Partnership?

Available either as a General (oHG) or Limited (KG) PartnershipForeign investors tend to prefer limited-liability KG PartnershipsMinimum of two partners, one of which can be a GmbH companyWidely used in for small and family-owned businesses

What are the main features of a Sole Proprietor company?

The simplest and least-regulated form of business entityRegistration required with the commercial register and local trade officeSole Trader has unlimited liability for all liabilities and debtsProfits are subject to German Income Tax at individual rates

European Authorized Representative Service

Independent, confidential Authorized Representative Service in the EU that:

  1. Provides an EU name and Address, required to be placed on your devices
  2. Device notification to the Competent Authority
  3. Maintains your technical files with a high degree of confidentiality, making the contents available to the Competent Authorities only

Authorized Representative (AR) service:

Contents:

Declaration of Conformity

Registration of class I / low risk devices with an EU Competent Authority (if applicable)

Keep technical documentation available to the Competent Authority, on requestCEpartner

Eulinx's name and Address in Europe on your devices, labels and product information

Interface on your behalf between Competent Authorities, Notified Body, distributor and/or end-users for Regulatory Affairs

Documents:

Signed European Authorized Representative Agreement

Duration: Ongoing, annual renewal

 

Interested in us? Please fill in the form below, we will send you the quotation soon:

Go to top