Amazon.de and amazon.fr: Extended Producer Responsibility (EPR). BatterieG, ElektroG, LUCID and others.
Amazon.de has been requiring confirmation of ElektroG registration in Germany from sellers offering electrical and electronic products for several months. Products for which registration cannot be confirmed are blocked.
In 2022, without confirmation of registration in the appropriate system, it will not be possible to sell qualifying products
As a reminder, ElektroG (German: Elektro- und Elektronikgerätegesetz) is the German electrical and electronic waste management system based on the EU WEEE directive (Waste Electrical and Electronic Equipment). The purpose of the ElektroG system is to ensure that used electrical and electronic equipment is not disposed of from households as ordinary waste, but is collected separately and recycled. Through precise control of electrical waste management, valuable raw materials can be recovered from waste and reused, and the negative environmental and human health effects of electrical waste management are to be significantly reduced.
Although the legal obligation to register with ElektroG has existed in Germany for a long time, it was only this year that most sellers learned about it, because Amazon began requiring confirmation of registration from sellers on a larger scale, both those operating in the FBA model and FBM. Until now, it happened that Amazon demanded confirmation of registration but only in the case of FBA trading.
The second mandatory register in Germany is the BatterieG register. BatterieG is a much simpler register than ElektroG and can even be completed on your own. The BatterieG register concerns, as the name suggests, batteries. Very often products qualifying for BatterieG also require registration with ElektroG.
The last register in which practically every seller in the German market has an obligation to participate is LUCID, also known as VarpackG. This is the packaging register. It’s the most well-known of all registers, and since the beginning of 2019, every seller must be registered in it. Registration is simple and quick. Due to the fact that this is a dual system, you need to register on the official LUCID system website
On amazon.fr, the situation looks a bit different. There are significantly more mandatory registers for sellers than in Germany.
Here you can see a comparison of which products are subject to mandatory registration in the appropriate system in France and which in Germany.
| Category | France | Germany | |
| 1 | Packaging | * | * |
| 2 | Electric and Electronic Equipment (EEE) | * | * |
| 3 | Batteries | * | * |
| 4 | Furniture | * | |
| 5 | Tires | * | |
| 6 | Paper | * | |
| 7 | Textiles | * | |
| 8 | Chemicals | * | |
| 9 | Medical products for self-therapy | * |
In France, however, at the moment Amazon will not require confirmation of registration with a given system, but will make appropriate settlements with the relevant authority on behalf of the seller, and then charge the seller with an appropriate fee. So by introducing products in packaging to the French market and not having registration with the appropriate system in that country, Amazon will charge the seller a fee appropriate to the amount of packaging introduced and transfer it to the relevant authority.
However, registration with the appropriate system in France is recommended by amazon.fr.
What to do to be able to sell in France and Germany in 2022?
First of all, you should take care of registration with the LUCID system in Germany, and in the case of qualifying products, with ElektroG and BatterieG. In the case of the French market, you can currently entrust the settlement to the Amazon platform.
The above registers are simply equivalents of the Polish BDO system. Except that depending on the country, instead of one register like in Poland, i.e., the mentioned BDO, there may be significantly more of these registers, and then one seller may have an obligation to register with several registers – in Germany up to 3. You should remember this when entering foreign markets, not only the mentioned French and German markets, because mandatory registers apply in practically all European Union countries, including Italy and Spain, and even if Amazon does not currently require confirmation of these registrations, the seller has an obligation to register and report.
Our company helps with registration to ElektroG and BatterieG in a comprehensive way. If your products qualify for registration, or you want to make sure they qualify, we invite you to contact us. We will prepare an attractive offer for you.