EU GPSR: Exxos, do you have an EU point of contact?

[exxos]

So starting over that I would need a full compliant service..

Upfront Pricing: They mention a one-time fee of €250 per EU member state for registration, which includes all related administrative tasks like obtaining EPR numbers. For their full-service package:
Annual Fee: An annual fee of €750 for managing your compliance in all EU countries.

or

Service: Specializes in EPR compliance as an authorized representative across Europe, handling obligations on your behalf.
Upfront Pricing: They provide a detailed pricing overview for each country, but for an all-in-one EU-wide service:
Packaging: Starts from €549 for the first country, with an additional €99 per country for each additional country, covering registration and compliance management.

or

Service: Manages licensing for packaging compliance throughout Europe, including registration.
Upfront Pricing: For their licensing service:
Base Price: €399 per year for the first country, with €150 for each additional country. This includes registration, reporting, and compliance management.

So basically any small business.. It is pointless even trying to go down this road the way things are.. Granted I could do all the registration and "booking keeping" myself, but it would still cost a lot and take up time I don't have.

The whole thing is just simply ridiculous. Frankly the people who thought all this stuff up need shooting because there is just no reasonable way for any small businesses like mine to comply with these regulations. They literally slit the throat of all small businesses with their current framework

Summed up in a single image..

GfuoG2SXcAAS70L.jpg (317.58 KiB) Viewed 1546 times

So God knows how other retro stores are continuing, presumably illegally as far as I can tell, as they would have to plough a lot of time and money into compliance.. Doing it for one country like Germany might be more realistic but for me with a few sales per individual country per year to just not worth the hassle or costs involved.

[exxos]

Got one reply..

HI Chris,

Thank you for reaching out to Lorax EPI!

It seems you're encountering a common challenge faced by small businesses across Europe. Keeping track of various Extended Producer Responsibility (EPR) regulations and ensuring compliance can indeed be complex. In some countries, small businesses are required to file an EPR report regardless of the volume of packaging they place on the market, while in others, you may fall under specific thresholds. To stay informed, we recommend regularly checking the official government websites for updates in the markets you're interested in.

Please note that, unfortunately, we are unable to provide guidance on shipping labels.

However, our experienced Consulting team can assist in determining whether you are obligated to report in specific markets. Our Compliance Assessment services start at £1,300 per market. If you’d like to schedule a meeting to discuss this further, please let us know—we’d be happy to help!

In the meantime, feel free to subscribe to our free newsletter and explore the posts on our blog for more valuable insights and updates.

We look forward to hearing from you!

Best regards,

Genoveva

Hello Chris,

Thank you for your message and your detailed feedback.

As described in my initial email, our Digital Service comprises to"provide you with all information needed for you to get registered and become compliant".
And further below: "We also offer to do all steps for you and take over your obligations in our Premium Compliance Service."

You are right, you still have to register with the systems and authorities in the different countries while using our digital service, but you receive all the required information, changes and news for a relatively low price.

Regarding the mandatory recycling labelling: You are right, there are plans to harmonize labelling in the EU. But nobody knows when they will come into effect. As of now, there are recycling labelling requirements in some (not all) countries that need to be fulfilled in order to be compliant. Further information regarding the different labelling requirements in the countries (if they apply), are also listed in our digital manuals.

I hope that clarifies it for you, and I wish you a nice afternoon.

It pretty much sums it all up really.

I read somewhere that for those who want to carry on regardless, I have seen that it would cost around £7,500 per law violation.

Under these conditions any small businesses operating within Europe might as well forget it at this point. That pretty much marks a brick wall of any start-ups ever getting anywhere as well.

[exxos]

Been thinking I could try and get compliant with maybe Germany and France and see how things go with that first. It may be easier than trying to tackle the entire EU at once.

Its all somewhat of a hassle to sign up with the places, then pay the fees, then mess around with numbers and labels which will have to be printed and stuck on the box. Its somehow bizarre that all this is because of recycling , and yet I'm going to have 27 boxes of different EPR numbers to stick on packages.. Was God knows how many recycling stickers.. It all adds costs and to me just defeats the object of reducing waste when it's caused me to buy a load of stickers which are going to be thrown away anyway

I think the setup costs is going to be the main killer either money or time or indeed both. I am getting quotations (or trying to) for companies to do absolutely everything for me, but I fear this will cost several thousand which is just not going to be realistic. I mean if I ship 10 packages to Germany, is going to cost me like £100 in fees, it is just simply not viable or sustainable.

Half of the EU countries may not be worth even bothering with. But the consultation fees don't really get any cheaper if I do the whole of the EU or just half of it anyway. The actual packaging fees I think will be around £20 per country per year. But it varies. Knowledge there is not much point in paying for Romania as we never ship there or have only shipped one package to some EU countries over the past four years anyway. So may not even be worth trying to ship to the entire EU just for the sake of maybe several packages a year in total.

I have been keeping track on data in the database for how many orders have been shipped to what country since 2020. So at least I have that information upfront because I will need it. I have been tweaking the store code base a lot recently because fees will have to be introduced individually per country, and I need a way of enabling or disabling individual EU states which I currently cannot do either.

The whole thing really isn't "RSI friendly" as it requires a lot of bashing away at the keyboard for endless hours to fix all this stuff. So I'm not really sure how much time I can invest in registering every single country per week. It will all take a colossal amount of time to get through it all, more unpaid work for me I suspect if this does go ahead then was going to keep me busy for the next several weeks easily have literally no time for anything else.

[alexh]

I've signed up with one of the multitude of companies offering a authorised representative, an address and a phone number in EU. I'm paying a flat rate of £16 pcm which I've no idea if that is a lot or a little. I only sell one product group. I am using an old fashioned ink stamp block to print onto the packaging the recycling information. I don't sell direct to the public only to EU resellers. The product is made of non-recyclable material and I have always had to pay a tax(?) towards recycling when selling in UK or EU. No idea if I am truly compliant.

[exxos]

The product is made of non-recyclable material and I have always had to pay a tax(?) towards recycling when selling in UK or EU. No idea if I am truly compliant.

Not sure I follow that how are you paying recycling tax ? Import taxes yes but the recycling tax is done by paying fees via LUCID etc.. and you have to register with each EU state.

I'm at the point of questioning my sanity with it all now. Customs can't even do the import tax half the time . They only seem to do random checks. Do they even have time to check every sticker on every box for GPSR / LUCID etc .. Plus all the stickers on the package will likely get destroyed on transit or by the user opening the box anyway. The whole system from start to end just seems broken to me.

[exxos]

Another quote for full compliance work, £14,000. I don't think that even includes the actual package fees. That's like half the value of my entire stock.Theres probably a bunch of regulations I'm unaware of as well.The whole thing is just ridiculous.

[alexh]

how are you paying recycling tax ?

I'm at work so I can't check but I *think* it is called "Activate" by Reclay. But that might be one I was considering and I went with someone else. Might have been Léko (I'm just guessing until I go home)

[exxos]

how are you paying recycling tax ?

I'm at work so I can't check but I *think* it is called "Activate" by Reclay. But that might be one I was considering and I went with someone else. Might have been Léko (I'm just guessing until I go home)

Yeah I've seen that. I'm supposed to sign up with that then LUCID for Germany. Not looked into that yet. But you have to sign up with all EU states if you want to ship to anywhere but Germany.. That's basically 27 sites and 27 sets of fees..

[alexh]

I think it covered France, Germany, Spain & Austria and I *maybe* had to do something else for Poland but I never get orders from anywhere else.

That's not true, I did get orders from Greece but I think that turned out not to be economically viable.

But what I imagine will be happening is the resellers in the countries I can ship to will resell to resellers in Greece? Who knows.

[exxos]

But what I imagine will be happening is the resellers in the countries I can ship to will resell to resellers in Greece? Who knows.

Then they would likely have to pay the fees as EU to EU shipping still applies AFAIK.

ACTIVE say 29EURO per country for consultation. But then you have to sign up with multiple EU states and pay fees onto of that which is around £20 per country. Calculation isn't simple but basically your looking at £1,000+ Per year. If you get the consultation company to deal with everything including stickers, EPR numbers etc, it's X10 the cost. It's just not realistic.