Exclusive interview with the French Ministry of Environmental Protection: Sellers who fail to comply with the EPR in January 2022 should be shut down
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This article has a total of 6248 words and takes 7 minutes to read. Table of contents 1/ EPR General Registration Questions 2/ EPR registration fees and declaration issues 3/ Triman Mark - Other Issues of Extended Producer Responsibility 4/ Examples of actual product classification 5/ About us Recently, Amazon, the world's largest e-commerce platform, issued regulatory requirements for France's Extended Producer Responsibility (EPR) in September , requiring sellers to provide valid EPR registrations before 2022 , otherwise the sellers' corresponding sales rights will be restricted. 🔍You can copy the following link to the browser in the seller platform to open it and go to the "Amazon Seller Code of Conduct" page to view more👇 https://sellercentral-europe.amazon.com/gp/help/external/GYDCAK9ZR6VJH2X3 As soon as Amazon released the rules, Weiyu Technology also made the first interpretation of the German and French EPRs. Please refer to the basic interpretation of the French and German EPRs: Attention to sellers on Amazon France and Germany: Failure to register for EPR will be considered illegal (qq.com) This article mainly starts from the interpretation of regulations to help sellers initially solve two problems: 🚩What is EPR? 🚩Do I need to do it? Sellers who do not understand EPR, please go to the above article link to read, or add our WeChat customer service number to inquire. As sellers of various categories have successively received emails about EPR from the platform, most sellers have already been relatively familiar with the German EPR because the rules were released and publicized two years ago; then for the French EPR , due to various reasons, the editor found in the daily communication with sellers that most sellers have only a superficial understanding of the French EPR, and the problems are very complicated due to the diversity of actual seller business scenarios. Many problems can no longer be given to sellers from the perspective of regulatory interpretation. An accurate answer, therefore, VISHTEC Wei Yu Technology (hereinafter referred to as V) made a special telephone interview with Mr. Sylvain Pasquier (hereinafter referred to as P) of the Circular Economy and Waste Department of the French Ministry of the Environment on the afternoon of October 21, 2021, and asked some representative questions from sellers in daily communication in the past two months. The following section summarizes the answers to Mr. Sylvain Pasquier's questions about French EPR sellers in this telephone interview. Some of the answers were re-arranged by VISHTEC Wei Yu Technology, hoping to help everyone ensure their own EPR compliance more clearly. 01 Detailed explanation of EPR general registration issues 1. When is the French EPR implemented? Sylvain Pasquier : According to Article 130 of the French Anti-Waste Law for a Circular Economy n°2020-105 and Article L541-10-13, which came into effect in February 2020, online sellers are required to comply with the EPR regulations by January 1, 2022. By then, the platform should take action against sellers who fail to fulfill their EPR obligations until they close their stores . French Anti-Waste Law for a Circular Economy n°2020-105 original reference link is 👇 https://www.legifrance.gouv.fr/jorf/id/JORFTEXT000041553759/ Article L541-10-13 Regulation 👇 h ttps://www.legifrance.gouv.fr/codes/article_lc/LEGIARTI000041583847/2021-09-19/ 2. I heard that the UIN system has not been established yet. Do we sellers need to register after the UIN system is established? Sylvain Pasquier: Regardless of whether UIN is issued or not, sellers need to fulfill their EPR responsibilities. Currently, sellers need to register with the recycling company. UIN is the unique identification code for each entity that fulfills production responsibilities. It is mainly a unique code generated to facilitate the management of each company's declared recycling situation. Whether UIN is issued has no actual connection with whether the seller fulfills EPR responsibilities . This coding system is currently being debugged. We expect that sellers reported by the recycling company on December 15 will be issued UIN numbers on January 2. 3. How long does it take for the seller’s store to receive the registration letter after registering the EPR? How to use the registration letter after receiving it? Each recycling company will send registration letters of different categories to sellers. Generally, the letters are issued within 4-8 weeks after the submission of materials . Different recycling companies have different issuance periods. For packaging recycling companies Citeo and Leko, the issuance period is about 3 weeks , and other recycling companies can generally issue the letters within 6-8 weeks . Amazon will release a link for uploading documents in the near future. At that time, sellers will upload the registration letter to the platform and update the UIN information after the UIN is issued next year. According to Sylvain Pasquier , sellers who submit information to recycling companies before December 15 will be issued a UIN number on January 2. All certificates will eventually be unified into one UIN code, and the registration and declaration status of each recycling category under the account can be queried on ADEME through the UIN . 4. I have many stores, but the products they sell are of the same brand or the same category. Can I register one EPR for these stores? No! The French EPR registration entity is the company that registers the store (the information is consistent with the backend), and the seller registers the French EPR based on the store. Accordingly, if the store sells products of multiple brands and these products are of the same type, then only the registration fee for one category is required. Supplement: Amazon stores correspond to one company for one store, and other platforms such as Ebay can have multiple stores. In this case, registering one company can be used by multiple stores. 5. After the registration letter comes out this year, will there be renewal fees, additional payment, etc. required next year like in Germany? After applying for the registration letter from VISHTEC, the recycling fees for 2020 and 2021 will be waived . The recycling fees for 2022 will need to be paid in February 2023. If the minimum recycling amount is exceeded, excess recycling fees will need to be paid. 6. I have already registered for WEEE, battery law and packaging law in Germany. Do I not need to register in France? The French and German EPRs are two independent systems and are not interoperable. Germany has already registered WEEE, and sellers of the battery law still need to register the categories of products covered by the French EPR accordingly. Compared with the three categories of German WEEE, battery law, and packaging law, France has more categories and covers a wider range of products . 7. EPR is a production responsibility system. If it is registered, would it be better to use factory registration? The regulations stipulate that the legal entity that puts the product on the French market must fulfill the obligation of extended producer responsibility. In simple terms, whoever sells the product is responsible . 02 Detailed explanation of EPR registration fees and declaration issues 8. My packaging materials include cardboard and textile fabrics. Do I need to register for textile recycling when registering? 9. The packaging registration requires a recycling volume of 10,000 packages. Is there any restriction on large or small packages? 10. I sold 11,000 products throughout the year, of which about 3,500 were clothes and the rest were toys. If I calculate based on the minimum recycling volume of 10,000 pieces of packaging, then I exceeded the limit by 1,000 packaging boxes. Since the size of toy packaging is different from that of clothing packaging, how should I calculate the recycling fee for the 1,000 excess packaging boxes? 12. Many products involve multiple categories. How is the final recycling fee calculated? 13. I sell textiles, including pillows, car seat cushions, clothes, etc. Which category do these belong to? 01 Electronic and electrical equipment Computer hardware/monitor/computer peripherals, motherboard, memory, CPU, sound card, graphics card, hard disk, keyboard, chassis optical drive/recording/DVD, cooling equipment, TV card/box/stick, brand LCD monitor, camera, handwriting input/drawing board, multimedia speaker, keyboard and mouse set, computer peripheral floppy drive graphic information/capture card, wireless computer peripheral products, computer dedicated MIC, UPS, power supply, CRT, CMMB, terminal/TV stick, computer peripherals/peripherals, headset, small fan, desktop power supply, assembled LCD monitor, network/HD player, solid state drive, drawing board accessories, electric/remote control toys, electric/remote control robots, electric/remote control cars, electric/remote control Control track, electric/remote control airplane, electric/remote control boat, electric/remote control animal/character, other electric/remote control toys, electric toy gun, electric tank/chariot, electronic keyboard toys/children's electronic keyboard, electronic toys, luminous toys, Bluetooth headset, MP3/MP4, charger, MP3/MP4, connecting cable, MP3/MP4, headset, Apple car charger, Apple car transmitter, Apple charger/power supply, Apple wire control headset, Apple remote control, Apple dedicated speaker, Apple stylus, Apple data cable, "digital camera/SLR camera/camcorder digital camera, ordinary digital camera, SLR lens, film camera point-and-shoot camera, 135, film SLR, Collectible cameras, rangefinder cameras, large and medium format cameras, special cameras, instant instant cameras, professional digital SLRs, LOMO, single-lens reflex cameras, kitchen appliances, projection clocks, timers, musical instrument speakers, sockets, base boxes, converters, switches, circuit breakers, wires, monitoring equipment and systems, LED equipment, telephone exchanges, fax machines, office phones, wireless pagers, telephone recording equipment, telephone management systems, conference phone products, fax servers, paging equipment, communication equipment accessories, fax machine accessories, recordable disks, floppy disk and CD duplicators, CD bags and CD boxes, floppy disk recordable disks, CD bags and CD boxes, CD duplicators, razors, nose hair trimmers, hair Hole cleaner, beauty spray machine, electronic beauty instrument, electric breast enlargement instrument, electric pedicure machine, women's hair removal/shaver, care nail device, electronic pedometer, electronic thermometer, blood pressure monitor, electronic blood glucose meter, electric toothbrush, water flosser, teeth whitening instrument, sealing machine, vacuum machine, coding machine, filling machine, shrinking machine, laminating machine, electronic components, wire/wire, network cable, extension cable, adapter cable, display signal cable, IC, integrated circuit/motor, electronic device, computer components/spare parts, card reader, data cable, other chargers, mini speaker/portable card speaker, notebook radiator/cooling card, flash card adapter sleeve, PDA network card, PDA dedicated camera, etc. 02 textile Pants, skirts, extra large and extra small clothing, sweaters, shirts, small vests/slings, lace shirts/chiffon shirts, jeans, T-shirts, sweaters, middle-aged and elderly clothing, suits and sweaters/fleece sweaters, down jackets, cotton-padded clothes/padded clothes, windbreakers, leather clothes, furs, Tang suits/ethnic costumes/stage costumes, sports shoes, Cosplay costumes/accessories, Cosplay women's clothing, Cosplay men's clothing, Cosplay accessories, fabric soft decorations, carpets, floor mats, tapestries/tapestry, cross-stitch kits/complete Products, small school bags for children, ordinary backpacks, weight-reducing school bags, bibs/sweat-absorbing towels/rice pockets/sleeves, bags, wallets and card holders, festive fabric products, bedding/cushions/towels/fabrics, quick-drying clothes and pants, warm cotton clothes, outdoor shoes and socks, tents/canopies, sexy lingerie, eye masks, gloves, sexy stockings, sexy pajamas, sexy suits, sexy accessories, bedding, sheets/bed skirts/bed covers/bed covers, mosquito nets/bed curtains, quilt covers, blankets/coral fleece blankets/thread blankets/towel blankets, pillows/pillow cores/health pillows/cervical pillows 03 Graphic printing waste paper Printing paper, copy paper, magazines, albums, books, festival/party celebration supplies, wedding characters/paper-cuts/stickers, seat cards, greeting cards/cards, invitation red envelopes/red envelopes, gift books/signature books, couplets, wedding character stickers, window decorations and paper-cuts, calendars/perpetual calendars/wall calendars, etc. 04 furniture Kitchen faucets, kitchen cabinets, urinals, wash basins, flushers, bathtubs, bathroom furniture, floors, doors, sinks, basins, commercial/office furniture, outdoor leisure furniture, residential furniture, shoe cabinets, shoe racks, dressing tables, filing cabinets/archive cabinets, reception desks, office desks, office chairs, screen partitions, newspaper racks, commercial furniture, shelves/display cabinets, hotel furniture, supermarket furniture, catering/baking furniture, clothing store furniture, entertainment/bar/KTV, furniture, sauna/foot bath/fitness furniture, hair salon/beauty furniture, campus teaching furniture, medical furniture, funeral industry furniture, office cabinets 05 DIY and Garden Tools High branch shears, hedge shears (hedge shears), pruning shears (pruning shears, pruning shears), multi-purpose shears, fruit picking shears, flower cutting shears, grass cutting shears, etc.; pastoral flower tool sets (garden flower tools, small sets of flower tools) include flower shovels, flower spades, flower rakes, flower hoes, flower forks, etc., specifically two-end hoes (two-end flower hoes), flat hoes, flat rakes, three-tooth flower hoes, three-tooth flower rakes, hoe rakes, hoe picks, large flower spades, small flower spades, three-shaped flower spades, one-shaped flower forks, six-tooth flower rakes, lawn mowers, brush cutters, hedge trimmers, chainsaws, water pumps, punchers, turf removers, pesticide sprayers and various garden tools, etc. 06 Sports and leisure products 1. Fitness equipment and apparatus: treadmills, steppers, etc. 07 Toy All children's toys and adult toys. 08 Battery Batteries, storage batteries, lithium-ion batteries, angular (gum-shaped) batteries, carbon-zinc batteries, nickel-cadmium batteries, nickel-iron batteries, lead-acid batteries, alkaline batteries, solar cells, sealed nickel-cadmium batteries, nickel-metal hydride batteries, lithium polymer batteries, fuel cells, button batteries, etc. 14. Do all French EPR products need to be registered? The products I sell are ceramics! There are 15 categories of products that need to be recycled in France , including packaging, printed waste paper, electrical and electronic products, furniture, textiles, batteries, diffused waste paint solvents, discarded tires, discarded vehicles, discarded ships, unused drugs, discarded medical devices, toys, leisure products, and DIY garden tools. Toys, leisure products, and DIY garden tools will be implemented in the second half of 2022. Among the 15 categories, packaging registration is the common recycling category for all sellers, and the others are divided according to the specific products and registered accordingly. 15. How and how much should be paid after exceeding the minimum recycling volume in 2023? What are the consequences if the payment is not made on time? Each recycling category has different recycling prices and the minimum recycling quantity is also different. The minimum recycling quantity for outer packaging is 10,000, and the global sales of textiles is 750,000 US dollars. If the sales do not exceed this, you only need to pay a minimum recycling fee of 75 euros. There is no minimum recycling quantity for other products. The recycling fee is calculated based on the sales volume. The service provider will pay the fee to the French recycling company. The French government will have a 15% chance of spot checking the sales volume of the store and whether there is a discrepancy between the declared volume. If a problem is found, it will result in fines, store closures and criminal penalties. In fact, many sellers will encounter this problem, which is also the one we are most exposed to at present: what category is my product classified according to. We have summarized the following table for sellers' reference. 03 Triman Mark Producer Extension System Other issues 16. After registration, will it be necessary to mark a specific logo on the color box like in Germany? French Decree No. 2014-1577 stipulates that from January 1, 2015, recyclable products and packaging sold to French consumers must be printed with the Triman logo. French environmental law (Article L541-9-3 of the Environmental Code) further updates the format for marking symbols on products and will come into effect on January 1, 2022. The new format requires a suggestion for the classification, which can be text (French!) or a symbol, or both. If the product is not specifically for the French market, the country code "FR" should also be used. This is to avoid confusion for customers in other countries (French-speaking countries), where different sorting rules may apply. 04 Actual product classification examples 01 Phone Cases 🔍Product features: ordinary plastic, plastic bag packaging 👇Judgment process: 1 🔍Is it "the products sold have product packaging and secondary packaging" → Yes 2 🔍Does it fall under "other circumstances" → No 3 👉Mobile phone cases need to be registered for packaging 02 Electric remote control toys (built-in lithium battery) 🔍Product features: Electric remote control car, equipped with 1000mAh lithium battery, rechargeable, with remote control, the remote control is equipped with dry batteries. 👇Judgment process: 1 🔍Is it "the products sold have product packaging and secondary packaging" → Yes 2 🔍Is it a "toy" → Yes 3 🔍Is it an "electronic and electrical equipment product" → Yes 4 🔍Does the product come with a battery or is it given away as a gift? → Yes 5 👉 Electric remote control toys need to register packaging, electronic and electrical equipment, batteries, and toys (implemented in the second half of 2022) 03 Nail polish 🔍Product features: nail polish, liquid, flammable, packed in a plastic bag 👇Judgment process: 1 🔍Is it "the products sold have product packaging and secondary packaging" → Yes 2 🔍Does it fall under "other circumstances" → No 3 👉Nail polish needs to be registered for packaging 05 VISHTEC French EPR pioneer Super detailed interpretation 01 Provide professional EPR registration and declaration services We are one of the earliest service agencies in China to provide EPR registration services in France and Germany, and we are the only global partner of the French recycling giant . ● Intelligent online platform registration and declaration ● System regular renewal and declaration reminders ● Check the registration status in real time 02 Provide professional product compliance services Our professional technicians are familiar with trade regulations, customs supervision policies and platform rules. We provide cross-border sellers with: ● Free REACH Declaration of Compliance Template and DoC Template ● Smart online application for DoC ● Free compliance manuals for toys and electrical appliances, compiled by Wei Yu Technology professionals based on the pitfalls most sellers have encountered. 03 For more information, please visit our official website https://www.vish-tec.com/service-item/WEEE/8.html 04 Contact Us Shenzhen Office Address: Room 716, E-Times Building, Heng Road, No. 159, North Pingji Avenue, Longgang District, Shenzhen Contact number: Peng Zhilei 15625292139; Email: [email protected] Contact number: Tang Xiaofeng 15800575787 Email: [email protected] Shanghai Office Room 227, Building 26, Phase 3, Vanke Qibao International, Minhang District, Shanghai Contact number: Jeff 18964995539 Email: [email protected] Shantou Office Room 206, Huamei Building, No. 69, Laimei Road, Chenghai District, Shantou City Contact number: Xie Jingna 13531240080 Email: [email protected] |
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