topic Re: Has anyone grappled with 'Extended User Responsibility' for sales to France and Germany? in Selling

Has anyone grappled with 'Extended User Responsibility' for sales to France and Germany?

padraicpaul91 — Fri, 10 May 2024 04:50:13 GMT

Just came across this yesterday whilst editing my business policies.

In a nut shell, ebay business sellers to German and French customers are now obliged to register and contribute fees for the life cycle of the sold items, especially disposal/recycling.

Whilst I generally support such initiatives, I am left unsure as to whether it applies in my case or for all sellers into these countries. I have read the relevant articles on ebay and the appropriate French site for recycling paper products, especially packaging (but it kept reverting to French when you follow links).

The fee for a small volume business re paper based packaging is a flat rate 80 euros p.a. in France, I think. But that is more than I would make in a year to France.

On the other hand, the only penalty that appears to apply is that listings that do not have my unique identifying number will be removed from ebay in those countries. This has not occurred to my items as yet. Confiscation or return of packages was not mentioned.

I have tried ebay CS but it's all new to them and it was suggested I contact ebay support in the respective countries.

Re: Has anyone grappled with 'Extended User Responsibility' for sales to France and Germany?

davewil1964 — Fri, 10 May 2024 08:12:34 GMT

Don't sell to countries where you would make a loss?

Re: Has anyone grappled with 'Extended User Responsibility' for sales to France and Germany?

digital*ghost — Sat, 11 May 2024 02:26:37 GMT

TL;DR - yeah, I've done it. Don't think it's worth it unless you have high volume sales to those countries.

Longer version - this is actually an EU-wide directive, with some countries having much higher thresholds that many sellers would never meet (UK's, for example, while no longer part of the EU, has a 50k kg / £ 2 mil threshold), is just that Germany & France have a 0 threshold (other countries do as well), but they are enforcing it through every means possible, so they've got online marketplaces on board with it. If you check here, it lists every member country and whether they also have a 0 threshold, and it doesn't just result in returned packages, there can be significant fines for non-compliance.
https://verpackungslizenz24.de/en/eu-packaging-licence/

France is no longer €80, AFAIK the minimum is €150 (annually), Germany is a lot cheaper, especially if you go through Activate by Reclay, which is what I did (you need to register and pay for each country where it's applicable through separate organisations, with Germany you register through Verapak, then select an agent to handle the disposal / recycling on your behalf, Activate by Reclay is one of the cheaper ones, assuming things haven't gone up like they did in France anyway, you can probably register for a total of around $50 AUD, annually).

Ultimately, however, it didn't help me even though I was fully compliant. So many returned packages from France and Germany I just stopped selling there all together and let my registration lapse. This is not the experience of every seller, as I know a few who are also compliant that send to both without issue so I don't know why mine had so many problems (all instructions were followed to a T, every required labelling was there, so I have no idea what made mine different).

JMO there are now also so many items on the EU's prohibited items list that navigating sending there has become an exercise in jumping a bunch of hoops, plus only France decided they also wanted online marketplaces to collect VAT on orders over €150 so a lot of marketplaces will just block buyers from there from even purchasing over that value, which makes it even more difficult to try and recoup the additional costs to send there.

Unsurprising ebay have no clue about it, it's only been in place (and most stringently enforced in Germany in particular) for 5 years lol.

Re: Has anyone grappled with 'Extended User Responsibility' for sales to France and Germany?

davewil1964 — Sat, 11 May 2024 08:34:12 GMT

G'day stranger.

Re: Has anyone grappled with 'Extended User Responsibility' for sales to France and Germany?

digital*ghost — Sun, 12 May 2024 04:42:25 GMT

Aloha, Dave 🙂

Re: Has anyone grappled with 'Extended User Responsibility' for sales to France and Germany?

padi*0409 — Sun, 12 May 2024 05:03:20 GMT

And G'day from me as well Digi - good to see you back.

Re: Has anyone grappled with 'Extended User Responsibility' for sales to France and Germany?

imastawka — Sun, 12 May 2024 05:41:43 GMT

Wow, Digi

Re: Has anyone grappled with 'Extended User Responsibility' for sales to France and Germany?

domino-710 — Sun, 12 May 2024 08:32:05 GMT

With a greeting like Aloha.

Go Digi.

Re: Has anyone grappled with 'Extended User Responsibility' for sales to France and Germany?

countessalmirena — Sun, 12 May 2024 10:45:14 GMT

📀👻, it is a pleasure to see you here again.

Re: Has anyone grappled with 'Extended User Responsibility' for sales to France and Germany?

padraicpaul91 — Tue, 14 May 2024 01:25:13 GMT

Thank you for such a detailed response. I was also surprised to find that these regulations have been in place for so long without any consequence to my parcels thus far. Yes, eBay is always way behind the play. I would think they have only reacted now due to hostile complaints by buyers and sellers when parcels are returned.

My major supplier, a small business, had been perplexed about why several, but not all, sales to France had been returned with no understandable explanation. How is a small time sole trader supposed to keep up with changing regulations around the planet? Yet another knock to small business. He and I have decided that our minimal trade with EU customers is not worth the bother and expense.

Re: Has anyone grappled with 'Extended User Responsibility' for sales to France and Germany?

sugar249 — Tue, 14 May 2024 04:37:10 GMT

@padraicpaul91 wrote:
Thank you for such a detailed response. I was also surprised to find that these regulations have been in place for so long without any consequence to my parcels thus far. Yes, eBay is always way behind the play. I would think they have only reacted now due to hostile complaints by buyers and sellers when parcels are returned.

My major supplier, a small business, had been perplexed about why several, but not all, sales to France had been returned with no understandable explanation. How is a small time sole trader supposed to keep up with changing regulations around the planet? Yet another knock to small business. He and I have decided that our minimal trade with EU customers is not worth the bother and expense.

Not sure why you are blaming Ebay for not being up with the latest requirements, Ebay is a listing platform, it is the sellers responsibility to know and understand the regulations of a market they are selling into.

A good business person will keep up to date with regulations of markets they are targeting,

Re: Has anyone grappled with 'Extended User Responsibility' for sales to France and Germany?

digital*ghost — Wed, 15 May 2024 03:28:55 GMT

Sure, but eBay should be able to inform their members how to comply with regulations they themselves are obliged to enforce.

The only reason I know as much as I do about it is because another platform who had to implement the same requirements:

Announced the changes in a way that couldn't be missed (i.e. a big banner on seller's home page)

Provided information on how to comply

Linked to resources to find out more

And then it became a collaborative community effort as well, where people researched, shared more resources, and other information from their own experiences... kinda like how forums like this will do that, occasionally.

eBay hasn't even made an announcement, near as I can tell (the EPR thing for France started being enforced by marketplaces Jan, 2022, Germany was earlier, it should not be "new" to ebay).