Overview

EPR can be implemented in many different ways. Thus far, in Europe, 30 countries have implemented EPR in their legislation and the industry has set up PROs. In some of these countries, the scheme has achieved great success, particularly due to clear legislation coupled with genuine cooperation between all of the actors involved in the waste management chain. Actors include governments, local authorities, producers and waste management organisations.
  
EPR schemes rely on either national regulations or specific legislation for the waste streams they are part of. For example, EPR schemes for household and municipal waste are generally based on the producers’ financial responsibility because they have been mostly introduced when the schemes were already in place and managed by local public authorities. By contrast, the EPR implementation for non-municipal waste varies significantly, and can for example be based on business-to-business arrangements. Solely in Belgium, the obliged industry has set up a specific PRO for industrial and commercial waste, VALIPAC. Its major role consists of monitoring packaging collection and recycling, in relation to the volumes brought on the market, collecting the respective data and motivating companies to separately collect their packaging waste. 

Not all PROs have the same functions. As EPR requirements differ between countries, the role of PROs vary as well. In Sweden, for instance, producers have to participate financially only in the treatment of end-of-life vehicles whereas they have full financial and organisational responsibility for graphic paper. 

Key differing features include the following: 

• Type of responsibility, either financial or organisational. 

• Presence of competition among PROs and among waste treatment operators. 

• Transparency and surveillance features such as free-riders’ surveillance, waste management activities and PROs  

EPR models vary  

• PROs in hands of obliged industry (Belgium, Czech Republic, Ireland, Italy, France, Netherlands, Norway, Portugal, Spain): Obliged industry creates one common non -profit entity that collects the necessary funding,cooperates with local authorities and ensuresrecycling in the most cost-efficient and environmental way.  

• Dual model (Austria, Germany, Sweden): Industry has full operational and financial responsibility over collection, sorting and recycling. There is a separate collection system designated to local authorities but their influence is minimal.   

• Shared model (France, Spain, Belgium, Netherlands, Italy, Czech Republic, Slovenia,): The responsibility is shared between industry and the local authorities based on common agreements regarding collection. Municipalities are responsible for collection, and often for sorting of packaging waste, arising on the municipal level, while industry’s financial responsibility differs from country to country. 

• Tradable Credits Model (UK, partly Poland): There is neither a link between industry and municipalities nor differentiation between commercial and packaging arising at the municipal level. 

• Vertical integrated systems (Germany, Poland, Slovenia, Romania, Bulgaria): Several, usually profit-orientedentities compete to attract obliged companies. In vertical integrated systems, waste management differs from country to country. 

• Sharing the collection infrastructure (Germany):Inhabitants have access to a common container and the collected packaging waste is split between the various PROs prior to being sorted. In this case, the cost distribution is established by a clearing house. 

• Competing on the infrastructure (Estonia): Every PRO offers its own container to inhabitants. 

• PROs only responsible for packaging arising at the municipal level (Belgium, Germany, France, Spain), for commercial packaging (Belgium), or for integrated packaging waste streams (Netherlands, Italy, Czech Republic). 

• Each PRO in a separate district (Poland, Romania, Bulgaria, Slovakia, Malta, Latvia, Lithuania): Each PRO signs up with as many municipalities as needed to fulfil targets according to market shares.

EPR Germany

EPR as a regulatory regime framework has been practiced by much legislation, but it is not a name for a regulation in itself. In contrast, the EU regulations such as the WEEE Directive, the Battery Law and the Packaging Law are equivalent to the regime in EU and German legislative practice. 

So the French and German WEEE, Packaging Law and Battery Law regulations are all part of the EPR and are the embodiment of the EPR in that country. 

In Germany, the EPR registration number(s) stands as proof of compliance. To get this number(s), you have to register with the relevant EPR registry (see table below). Once you receive the EPR registration number(s), you will need to communicate it to Amazon as proof of compliance. During Q4 2021, Amazon will share the link to upload the EPR registration number(s). 

The EPR categories and Producer Responsibility Organisations are detailed in the table below.  

The following registration numbers stand for your proof of compliance:  

• Packaging: Registrierungsnummer 

• EEE: WEEE-Reg.-Nr.DE 

• Battery: Batt-Reg.-Nr. DE2    

*Battery obligation: In Germany, if you offer an EEE product containing a battery, you have to register for both EEE and Battery. Amazon will only require the EEE registration number at this stage.

EPR France

With the law "to combat waste and promote recycling" of 10 February 20201, France has extended producer liability (EPR) to additional products and tightened it for existing products. In France, the principle of extended producer responsibility has been enshrined in law since 1975.The first nationwide system was introduced in 1992 for the collection of packaging waste from private final consumers. Later, similar systems were introduced for batteries and accumulators, paper, electrical and electronic equipment, etc. Meanwhile there are about 20 different EPR systems ("channels") in France.

In France, Amazon will require your EPR registration number(s). To get this number(s), you have to register with the relevant Producer Responsibility Organisation (see table below). Once you receive the EPR registration number(s), you will need to communicate it to Amazon. During Q4 2021, Amazon will share the link to upload the EPR registration number(s). 

Starting in January 2022, to be EPR compliant, a new registration number called the ‘Identifiant Unique’ (Unique Identification Number) will be available on your Producer Responsibility Organisation portal(s). You will also need to provide Amazon with this new EPR registration number. 

The EPR categories and Producer Responsibility Organisations are detailed in the table below.    

1. PACKAGING related obligation: In France, you are accountable for your primary packaging and the secondary packaging added by you.

Where can I find more information on EPR for France?  

For more information, we encourage you to refer to the websites of the Producer Responsibility Organisation as well as sites given below for more information:  
• https://www.legifrance.gouv.fr/jorf/id/JORFTEXT000041553759/

• https://www.ecologie.gouv.fr/cadre-general-des-filieres-responsabilite-elargie-des-producteurs

• https://www.ademe.fr/expertises/dechets/elements-contexte/filieres-a-responsabilite-elargie-producteurs-rep