The eBay Fall 2022 seller update has new information regarding regulatory and compliance issues that will impact shipments sent to France and the UK.
Important Note: the following info for France goes into effect October 1, 2022 - giving sellers just 2 days notice!
That's sure to send sellers scrambling today and absolutely unacceptable for eBay not to provide more of a heads up on this. 🤦♀️
It's time to get compliant with EPR France
Extended Producer Responsibility (EPR) legislation is part of a Europe-wide initiative to protect the environment by improving waste management, limiting the use of landfills, and stimulating innovation in recycling. These measures make sellers responsible for the entire life cycle of their products.
To comply with French EPR laws, business sellers who sell in, or into, France, need to register with the relevant éco-organismes* covering the categories they are selling in, including packaging. A list of the categories that these laws apply to can be found here.
Since July 1, 2022, all marketplaces, including eBay, have been legally required to make sure that sellers are complying with EPR regulations. By getting in line with these laws, you’ll be showing your customers that you’re supporting recycling initiatives in France and playing your part in contributing to a circular economy.
Make sure that you add the information detailed below to your listings as soon as possible. From October 1, 2022 we will take action on listings that don’t comply with the regulations, including paying the ‘eco-participation fee’ on your behalf and invoicing it back to you, as mentioned in our User Agreement update in August.
What do I have to do?
First and foremost, if your listings fall under EPR law, you’ll need to get compliant as a matter of urgency. You can find a list of products and categories that these laws apply to here, under ‘Eligible categories’.
If you’re selling these items in, or into France, you’ll need to:
- Provide the Unique Producer Identification Numbers (UPINs) as item specifics in the ‘Regulatory compliance’ field of your listings
- To obtain your UPINs, you’ll need to register with the relevant éco-organisme if you are the producer of the product in, or first importer into France. For a list of appropriate éco-organismes by category, see the ‘Eligible categories’ drop down on our help page. Otherwise, contact your suppliers.
- Provide the Eco Participation Fee as an item specific
- Enter the fee you are charged for each item in the ‘Furniture’ and ‘Electrical/ Electronic devices’ category into the separate field of the listing tool to display it on your listing.
- Display the Repair Score as an image in your picture gallery
This ranks the repairability of a product from 1-10 and needs to be displayed as an image in your picture gallery. Please note that this should not be the first picture.
Your supplier should be able to provide your Repair Score. See the help page for more details.
- Arrange your Take-back procedure
- If you sell in the Electrical / Electronic devices and Furniture categories, you’ll need to provide buyers with details about how you will collect their existing product at delivery, known as ‘one-for-one take-back’. Take-back policies can be found in the ‘custom policies’ section of My eBay.
- Please contact your shipping carrier and/or your éco-organisme to arrange the take-back procedure.
For further information on EPR in France, please visit our dedicated help page, which offers comprehensive information and support to guide you through the process.
*An Eco-organisme is a French company empowered by the French public authorities, within the legal framework of Extended Producer Responsibility (EPR), to manage the end-of-life of the equipment they put onto the market (collection, sorting, recycling, and recovery of waste).
I would not be at all surprised if sellers decided to simply block France rather than deal with sorting out these regulations, just as they did when similar regulations were announced for Germany.
I'll be keeping an eye out for how this will impact shipments sent through eBay's new international shipping option - previously we were told sellers who use eBay Global Shipping still had to comply with the German regulations, but that may or may not change with the new program.
New UK goods regulatory requirements
Following the UK’s departure from the EU, the UK now has its own domestic regulations covering most goods previously subject to the EU’s CE marking. The CE marking shows that these products meet EU safety, health or environmental requirements. It’s important you prepare your business for these changes so you can continue to sell your items in the Great Britain (GB) and Northern Ireland (NI) markets.
What you need to know
As a result of the new regulations, there are two new types of marking to be compliant with for selling in Great Britain and in Northern Ireland:
The UKCA (UK Conformity Assessed) marking is the new product marking required to demonstrate that certain goods are compliant with the UK rules and can be placed on the market in Great Britain (England, Wales, and Scotland). It covers all goods that previously required the CE marking.
The UKNI (United Kingdom Northern Ireland) marking is the new conformity marking for products placed on the market in Northern Ireland but only where a UK-based conformity assessment body has been used. It also covers goods that continue to require the CE marking.
What action do you need to take?
Make sure to review your listings and update the impacted items with the new markings by 1 January 2023. If you haven’t made the necessary updates by this date, any non-compliant listings may be removed.
You’ll find all the information you need to prepare your business for the new UK goods regulatory requirements in the four guides produced by the UK government below, including FAQs on how to attach the new markings to your goods.
eBay provided a bunch of links to various resources for these new regulations - if you ship internationally, you should definitely review them all here: