Ina Steiner is co-founder and Editor of EcommerceBytes and has been reporting on ecommerce since 1999. But there is an ongoing discussion thread in the community forums where Etsy sellers have offered tips and suggested service providers to other sellers that would enable them to be compliant with the new regulations. More info and faqs here:-> verpackungsregister.org/en/information-orientation/instructions-further-information/subject-specific-papers#c11359-> verpackungsregister.org/en/information-orientation/instructions-further-information/faq. Change). It implements the. Huh? We suggest you consult an accountant before you decide to go through that step. LUCID is a public register and makes it possible for everyone to see which manufacturer is registered for which trademarks/brands. The German Packaging Act, also known as VerpackG, came into force in January 2019. Both laws specify the product recycling responsibility for packaging materials. I don't want to stop selling to Germany, but I might have to if Etsy starts enforcing this. Anyone whosells product to the German economy/customer/end user. It is said that more countries will be regulating packaging. Failure to register can result in a fine up to $57,000 (50,000 ) and a ban on selling there. When licensing to your system partner, you need to sign with your registration number provided by the Central Agency. Maybe you were frustrated of this new system and wanted to stop selling to German customers alltogether? Update your buyers of return and recycling options. The German Packaging Act places the full responsibility on the producer, which now includes shipping materials used by international merchants and sellers as well. Lizenzero has streamlined the process for sellers and makes it easy to comply with the three steps required to be in compliance: eBay sellers will also receive a 5% discount through this partnership with Lizenzero. With the registration, however, the manufacturer confirms that he has correctly fulfilled his product responsibility. Your email address will not be published. All orders placed through CustomCat are associated with our registration number & responsible disposal of this packaging is paid for by CustomCat annually. Etsy outlined the steps sellers who registered as a business must take to comply with EU laws, including adjusting their return policies to offer a minimum of 14-day returns. Etsy said if you ship even one order to Germany, you must register. Many have mused that this is only applicable to large pallet large scale businesses. In an announcement on Tuesday, Etsy wrote: We wanted to let you know about a new consumer protection directive that has passed in the European Union and how it may impact your shop. Even if you receive a single order from a buyer in Germany, you are required to register with LUCID and report it. Not they dont, other European countries do not have similar licensing. To avoid getting banned from the market or facing tremendous fees, you should registeryour company.
Register to LUCID (German packaging register) free of charge here: lucid.verpackungsregister.org, Use your registration number (in the LUCID dashboard) to license your packaging using a Dual System partner. I understand this law came into effect in 2019, but it looks like some new regulations are coming into effect on July 1 of this year (article). The problem is, cost. Shippers from outside Germany were exempt. That is an average of just over 2 ordersPER YEAR to this country. A new law went into effect on January 1, 2019. To learn more about how to get your packaging licensed and why you need a license or any other questions related to this new law as it applies to your sales on eBay, visit Lizenzeros site in English here. That has been the fear since the EU Directive 94/62/EC on packaging and packaging waste was implemented as it applies to all EU member states. (LogOut/ service for entrepreneurs & individuals! If you dont register and/or dont carry out system participation for your packaging materials, your products can be banned from the German market. I try to source eco-friendly packaging as much as possible, but having to issue 'reports' to some German gov't dept. Is there a loophole I have missed? to ensure the packaging materials sent to Germany with your customers orders are responsibly recycled. Additionally, some non-EU member countries in Europe such as the UK, Switzerland, and Norway will have their own schemes as well, potentially adding to the complexities. The last couple weeks my attention was drawn to a concerning Facebook post about parcels that did not getdelivered to their destination in Germany. Stay tuned! These new regulations impact all merchants internationally, regardless if they sell on a marketplace or through their own website. Of course, big corporations love regulations they have buildings full of lawyers to deal with them. The legislator considered this freeloader behavior as no longer tolerable and created the, Foundation Central Agency Packaging Register, Increase surveillance and control over the compliance with product responsibility regulations. For this purpose, the Central Agency has set up the packaging register LUCID, which name stands for transparency. A system partner is a company to which you pay the licensing fee for your materials. Follow her on Twitter at @ecommercebytes and send news tips to ina@ecommercebytes.com. You can communicate this information to buyers using your shop policies, Message to Buyers, or a terms and conditions document. All of this is happening under the EU Packaging Waste Directive, so Germany might just be the first EU country to go this route. Note that the governmental authority specifically mentions that ". Blog about online vintage selling on Etsy. eBay has partnered with Lizenzero to help sellers license their packaging digitally through the Interseroh+ system. Does your Etsy shop need Privacy Policies? This fee depends on the type of packaging material and is typically a few cents per kilogram. If all the EU countries do like Germany, Ill stop selling to them too. Remember to take this extra cost into account in your shipping prices to Germany. While the amendment has impacted some producers and sellers in Europe already, starting on July 1, 2022, marketplaces such as eBay and Etsy must validate that their sellers globally hold a valid Extended Producer Responsibility (EPR) registration number or they will have to block sales to German addresses. He has over 17 years of experience on eBay which includes tens of thousands of sales to buyers in over 100 countries and even has experience with eBays VeRO program enforcing intellectual property rights for a former employer. This means that producers are made responsible for recycling the packaging of their goods. As a seller to Germany, I would be required to inform my German customer as to how they can recycle the packaging material my product came in. What does this mean? Press question mark to learn the rest of the keyboard shortcuts, https://www.verpackungsregister.org/fileadmin/LUCID/Technical-guidelines-Declaration-of-completeness.pdf. If you use items like glassine bags and certain eco plastic stickers (mine are both made from cellulose), those go in the other materials. Obviously, for some sellers, this will not make much financial sense and according to information provided by eBay and Etsy, both marketplaces will automatically block orders to Germany if the seller did not provide proof of their LUCID registration. The law thereby creates an economic incentive for companies to use recyclable packaging and fewer resources altogether. If you don't want to ship to Germany, you only have to deselect ONE checkbox. The idea behind is that packaging sellers must ensure in advance that the packaging they put into circulation is correctly disposed of, whether used for product protection, marketing purposes or shipment packaging. All orders placed through CustomCat are associated with our registration number & responsible disposal of this packaging is paid for by CustomCat annually. However, this loophole began to create issues. Its more easy and cheap to register than you think and I will have a simple quide below how to do this As an example, I needed to register 4kg paper/cardboard + 1kg plastic + 1kg other materials and the total price for one year was 8.41 (~$9.17 today). Visit LUCID for additional information on this requirement, or reach out to a local legal expert. FinesBoth the participation in a dual system and the corresponding registration are determined by the Packaging Act as a legal duty. Please contact legal counsel for recommendations specific to your business. This directive requires professional sellers who ship to the EU to identify themselves to buyers as traders. Under EU law, traders are required to provide the right to withdraw to their consumers (also known as right of withdrawal). In your shipping settings on the browser, you can select and deselect by continent and country. Yeah, I'm wondering about this too. Register with LUCID. Press J to jump to the feed. With coronavirus, we have seen supply chain disruptions, stock market fluctuations, even companies temporarily stopping business. German law has shifted the responsibility to the shipper.https://www.haendlerbund.de/en/services/legal-texts/packaging-act8. I don't understand, if we send something that is completely recyclable, isn't it the buyers responsibility to recycle it? If your products are produced & shipped by CustomCat after being sold through an online marketplace like Etsy or Amazon, you can manually submit CustomCats LUCID ID number , If your products are produced & shipped by another production partner or are produced & shipped by you, CustomCats LUCID ID number may not be used to verify compliance with VerpackG. They really should have had an exemption for small, individual online shops. For people without European VAT number: I got an answer from the LUCID register that providing a VAT ID number is not mandatory when registering in LUCID, the taxpayer reference number is sufficient. Marketplaces that do not fulfill orders themselves have no way to monitor or certify packaging used by sellers and the law recognizes this fact. Information is only relevant to small businesses (who dont send crazy amounts of orders to Germany). Copyright 1999-2022 Steiner Associates, LLC. Non-participation in a dual system can be punished with a fine of up to 200,000.In addition, the publication shall serve the purpose of guaranteeing fair competition. No, I think it just means there's a third requirement if you produce that amount. But due to the absence of state surveillance and control, there have been many manufacturers that have not complied to the law and neglected their product responsibilities in the past. It is conceivable that competitors will enforce the distribution ban by civil law. To sum it up: it is responsible for monitoring compliance and system participation by the manufacturers. Every registered company will receive a registration number. (LogOut/ I cannot afford to spend $55-$100 per yearpaying license fees to a German recycling company just so I can shipmaybe 1-2 orders to that country annually. This also applies to so-called secondary packaging, in which packaged products are additionally packed. To add this information for your shop, visit Shop Manager > Finances > Legal and tax information and click on the Add LUCID ID number button under the Government registration section. The recycling companies I looked at paying the fee for them to do the recycling of packaging there had minimum payment amounts (the cheapest I saw was 35 for up to 1kg) and my small shop can't absorb that cost. Some sellers may even be fined up to 200000 Euros (although I dont know how that would be enforced on small international businesses, so I dont think the fines would apply to them). Sign 12"- 36" Round, Set of 4 Lake Coeur d'Alene, Idaho Slate Coasters, Dominoes Hub with Optional Case and/or Train Tokens. After the submission at your system partner, you need to immediately report your data to your LUCID account. She's a widely cited authority on marketplace selling and is author of "Turn eBay Data Into Dollars" (McGraw-Hill 2006). That said: I'm pretty sure the only thing to worry about is if Etsy starts enforcing it. 12 GPA). Has anyone here successfully registered through the LUCID Packaging Register yet? My head hurts already just reading that. That seems way less complicated than using the direct website Etsy links you to. Or a consumer protection agency might notice and take action. Both focus on the core principle of extended producer responsibility, or short EPR. In summary: Manufacturers need to pay a yearly recycling fee depending on the packaging amounts they sell to the German end-consumer market. When did we concede that we are subject to the extra-territorial jurisdiction of the EU? Please head over to ourFacebook Group for Small Business Sellersand interact with other small business owners. Go straight away back to the LUCID platform and enter the same amount of packaging you registered with the Dual System partner in the Data Report. If you send only couple orders to Germany it might be better to just not ship there, but you need to calculate if its worth for you and if you can add the extra to your shipping prices. The Europeans love their bureaucracies. Small businesses receive a commercial taxpayer reference number that differs from the owner's private taxpayer reference number. I've updated my FAQ to say I won't be shipping to Germany, even though I have successfully registered with LUCID. These obligations generally also apply to online retailers because the new GPA explicitly states that it also applies to shipping packaging: If their packaging fulfils the conditions above, they must register their packaging and participate in a disposal and recycling system. Out of 44,000+ sales, if just 22 have come from Germany, it seems that may not be my target market. You must register before sending any products to the German market. This screenshot is from a quote I got for paying licensing fees to one of the main system partners for just 1kg (approx 2lbs) of cardboard packaging per year (I send things in small new cardboard boxes). If youre an Etsy seller, you are soon (July 1st 2022) also required to have registered your business (+ in many cases also packaging materials) if you wish to continue selling on Etsy. The term producer, however, includes importers and retailers, too. Follow us onFacebook,Twitter, andLinkedInto stay up to date with relevant news and business insights for your online business. I checked out several of thesystem partners and they were quoting anywhere from $55USD to $100+USD PER YEAR to license packaging products, even if I only inserted that I was sending 1kg of cardboard per year. Your email address will not be published. And those who fulfilled them and have complied with the law have helped paying for the others recycling duties. Fear not! I get less than a dozen German orders a year, and it's less than 10 euros (6 being the base fee) to register 1kg of paperboard and 1kg of plastic, which is covered by a portion of the s/h fee built into all of my orders. The. You would think that when a government creates restrictions for international businesses shipping goods into their country, those regulations would mostly only apply to large companies and corporations. document.getElementById( "ak_js_1" ).setAttribute( "value", ( new Date() ).getTime() ); Enter your email address to subscribe to this blog and receive notifications of new posts by email. Its very likely that Germanys way to comply with the EU directive may just pave the way for similar regulations in Europe that will impact sellers worldwide. In those years I've received an order from Germany a total of 22 times. You can simply register your brands on the Lucid Website.
Your email address will not be published. Even single shipments are subject to its provisions as there is no minimum threshold before compliance kicks in. CustomCat is compliant with the German Packaging Act. Fill in your details below or click an icon to log in: You are commenting using your WordPress.com account. If you are selling goods to German consumers via an online marketplace like Etsy or Amazon, you will be asked to provide a LUCID ID number to your marketplace to verify compliance with VerpackG. It's asking for VAT numbers and a bunch of Germany-specific things that I don't have. If they are not able to prove this properly, they themselves are obliged to carry out the licensing. The legislator considered this freeloader behavior as no longer tolerable and created theFoundation Central Agency Packaging Register(Central Agency) with the aim to: Since 1/1/19,every company will be obliged to register at the Central Agency. If you have no brand, adding your company name is sufficient. Sole proprietors should consider requesting a free EIN number from the IRS which will further separate your business finances from your personal finances but will also change how you file your taxes. Do you have a link to the website you used to register with for ReClay? Perhaps I don't understand this fully. Electronic marketplaces are required to verify whether retailers and sellers of goods are registered in the LUCID Packaging Register and whether they comply with the system participation requirement. For US sellers operating as sole proprietorships that would mean your social security number. The "Take-Back obligations" with reference to "participating in a system" is a huge flag here. So be careful: Since the register is open and accessible by anyone, it is easy for the authorities and your competitors to check if you comply with the law. A list of permitted system partners are listed on the VerpackG website. Beginning July 1, 2022, Germany will require online marketplaces to verify their retailers are complying with the German Packaging Act (VerpackG) a national effort to reduce the environmental impact of global packaging waste. Which is not a thing that's going to happen to you if you're sending 3 packages or envelopes per year to Germany. As an online retailer, sellers are required to register with the LUCID Packaging Register. Recorre nuestra galera de productos.Cuando encuentres un producto de tu preferenciaclickea en "Aadir"! When you register with LUCID, everything you put on there will be available publicly so make sure to provide them with your EIN and not your SSN. Both laws specify the product recycling responsibility for packaging materials. was having the same contemplation about this, have you find any solution for this. I googled, crowd-sourced, and searched for info about the newGerman Packaging Act, but mostly found people saying "I won't ship to Germany anymore" - "It's not worth the hassle" - "It's not worth the money". shipping, & custom fulfillment Many have mused that this is only applicable to large pallet large scale businesses. And for about two years Richard sold products on Amazon using Amazon FBA in the US. Thanks, I'm going to have to cease shipping to Germany, as well. You can find more info in this article by Etsy: etsy.com/seller-handbook/article/verpackg-packaging-act-requirements/501392119812. The German regulations only make the marketplaces responsible for ensuring they obtain valid EPR registration numbers from their sellers.
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