DEV Community: FZCO Accountants

EPR Authorised Representative and EPR Audits in Germany: A Complete Compliance Guide for Producers and Online Sellers

FZCO Accountants — Mon, 01 Jun 2026 13:15:22 +0000

EPR Compliance in Germany: Framework

Germany has one of the most advanced environmental compliance systems in Europe, built around the principle of Extended Producer Responsibility (EPR). Under this framework, producers, importers, brand owners, and online sellers are legally responsible for managing the environmental impact of products they place on the German market.
EPR obligations in Germany primarily apply to packaging, electrical and electronic equipment (WEEE), and batteries. Businesses that fail to comply with these regulations may face significant penalties, sales restrictions, marketplace account suspensions, and legal enforcement actions.
For companies based outside Germany, appointing an EPR Authorised Representative and maintaining proper compliance records have become increasingly important to ensure uninterrupted market access.
This article explains the role of an EPR Authorised Representative, the purpose of EPR audits, and the requirements surrounding the Declaration of Completeness in Germany.

Extended Producer Responsibility (EPR)
EPR is an environmental policy approach that makes producers financially and operationally responsible for the collection, recycling, and disposal of products once they become waste.
The primary objectives of EPR are to:
• Reduce environmental pollution
• Increase recycling and recovery rates
• Encourage sustainable product design
• Shift waste management costs from taxpayers to producers
• Support the circular economy
In Germany, EPR obligations are regulated through several laws, including:
• Packaging Act (Verpackungsgesetz – VerpackG)
• Electrical and Electronic Equipment Act (ElektroG)
• Battery Act (BattG)

Who Must Comply with German EPR Regulations?
EPR requirements may apply to:
• Manufacturers
• Importers
• Brand owners
• Distributors
• Online marketplace sellers
• E-commerce businesses
• Foreign companies selling directly to German consumers
Even companies with no physical presence in Germany may be subject to EPR obligations if they place products on the German market.

Understanding the Role of an EPR Authorised Representative:
An EPR Authorised Representative acts on behalf of a foreign producer or seller to fulfill specific legal obligations under German environmental legislation.
As EPR regulations continue to evolve, many international businesses appoint an authorised representative to manage registration, reporting, communication with authorities, and ongoing compliance obligations.

Key Responsibilities of an EPR Authorised Representative:
The representative may assist with:
• Registration with relevant German authorities
• Compliance monitoring and reporting
• Submission of mandatory declarations
• Communication with regulatory bodies
• Record keeping and documentation management
• Support during inspections and audits
• Ensuring ongoing compliance with legal requirements
For foreign businesses selling into Germany, an authorised representative can provide valuable local expertise and help reduce compliance risks.

EPR Audits in Germany:
EPR audits are conducted to verify that producers and manufacturers are complying with their legal obligations regarding waste management, recycling, and environmental reporting.
These audits are an important part of Germany's regulatory framework and help ensure that businesses accurately report the quantities of products and packaging they place on the market.

Purpose of EPR Audits:
The main objectives of EPR audits include:
• Verifying reported sales and packaging data
• Confirming participation in approved recycling systems
• Ensuring accuracy of environmental declarations
• Detecting underreporting or non-compliance
• Maintaining fairness among market participants
• Supporting national recycling targets
Audits may involve reviewing financial records, sales reports, import documentation, packaging specifications, and recycling system contracts.

Declaration of Completeness (Vollständigkeitserklärung)
One of the most important compliance requirements under Germany's Packaging Act is the Declaration of Completeness, known in German as the "Vollständigkeitserklärung."
This declaration is designed to provide transparency regarding the quantity and type of packaging materials introduced into the German market.

What is a Declaration of Completeness?
The Declaration of Completeness is an annual verified report submitted by obligated companies that exceed specific packaging volume thresholds.
The declaration confirms:
• Packaging quantities placed on the market
• Material categories used
• Accuracy of reported packaging data
• Compliance with packaging licensing obligations
The declaration must generally be reviewed and certified by an authorised expert, auditor, tax consultant, or certified public accountant before submission.

Why is the Declaration Important?
The Declaration of Completeness helps authorities:
• Monitor packaging waste streams
• Verify producer reporting accuracy
• Improve recycling performance
• Prevent free-riding within the EPR system
• Ensure equal compliance obligations across industries
Failure to submit an accurate declaration when required can result in regulatory action and financial penalties.

EPR Compliance for Packaging:
Under the Packaging Act (VerpackG), businesses placing packaged products on the German market must:
• Register with the LUCID Packaging Register
• Participate in a licensed dual recycling system
• Report packaging quantities accurately
• Maintain supporting documentation
• Submit a Declaration of Completeness when applicable

Packaging covered by the law includes:
• Product packaging
• Shipping packaging
• E-commerce packaging
• Service packaging
• Secondary packaging

EPR Compliance for Electrical and Electronic Equipment (WEEE)
Companies selling electrical and electronic equipment in Germany must comply with WEEE regulations under the Electrical and Electronic Equipment Act (ElektroG).
Requirements include:
• Product registration
• WEEE identification numbers
• Collection and recycling obligations
• Consumer information requirements
• Reporting of equipment volumes

Covered products may include:
• Household appliances
• Consumer electronics
• IT equipment
• Lighting products
• Telecommunications devices
• Electronic tools

EPR Compliance for Batteries:
Germany's Battery Act (BattG) requires producers and sellers of batteries to participate in approved collection and recycling schemes.
Businesses must:
• Register before placing batteries on the market
• Finance collection and recycling activities
• Report battery quantities
• Ensure proper product labelling
• Maintain compliance documentation
The regulations apply to:
• Portable batteries
• Industrial batteries
• Automotive batteries
• Battery-containing products

Risks of Non-Compliance:
Failure to comply with German EPR regulations may result in:
• Significant administrative fines
• Product sales bans
• Marketplace listing removal
• Suspension from online platforms
• Legal proceedings
• Reputational damage
Major marketplaces increasingly require proof of EPR registration before allowing products to be sold to German consumers.

Benefits of Professional EPR Compliance Support:
Working with experienced compliance specialists can help businesses.
• Reduce regulatory risks
• Ensure timely registrations
• Maintain accurate reporting
• Manage annual declarations
• Prepare for audits
• Navigate changing legal requirements
• Access the German market with confidence

Compliance Summary:
Germany's Extended Producer Responsibility framework places significant obligations on producers, importers, and online sellers. Whether dealing with packaging, electrical equipment, or batteries, businesses must ensure full compliance with registration, reporting, recycling, and audit requirements.
The appointment of an EPR Authorised Representative, combined with proper management of EPR audits and Declaration of Completeness obligations, can help businesses meet regulatory requirements efficiently while supporting Germany's environmental and sustainability goals.
As environmental regulations continue to expand across Europe, proactive EPR compliance is no longer simply a legal requirement, it is an essential component of responsible and sustainable business operations.

Sales tax registration and filing in the USA

FZCO Accountants — Sat, 08 Jul 2023 00:06:44 +0000

In the United States, businesses are often required to register for sales tax purposes and file regular sales tax returns. Here is an overview of sales tax registration and filing in the USA:

Sales Tax Registration:

Nexus Determination

Nexus refers to a sufficient connection or presence in a state that triggers the obligation to collect and remit sales tax. Businesses need to determine if they have nexus in a particular state based on factors such as physical presence, economic activity, or click-through agreements.

State Registration

Once nexus is established, businesses must register for sales tax with the appropriate state tax authority. Registration can typically be done online through the state's tax agency website. The process may involve providing business information, such as entity type, EIN, and contact details.

Multiple State Registration

Businesses that have nexus in multiple states may need to register for sales tax in each state where they meet the nexus criteria.

Sales Tax Filing:

Collection and Reporting

Registered businesses are responsible for collecting sales tax from customers on taxable sales and reporting it to the state tax authority.

Filing Frequency

Each state sets its own filing frequency requirements, such as monthly, quarterly, or annually. The frequency is based on factors like sales volume or liability. Some states may also offer options for businesses to file on a prepayment basis.

Sales Tax Returns

Businesses need to file sales tax returns with the relevant state tax authority, reporting the sales made, taxable transactions, and the amount of sales tax collected during the reporting period.

Payment and Remittance

Along with the sales tax return, businesses may be required to remit the collected sales tax to the state tax authority. Some states provide online portals for payment and remittance, while others accept checks or electronic funds transfer.

It's important to note that sales tax regulations and procedures can vary among states, including exemptions, tax rates, and thresholds. Therefore, businesses should consult the specific guidelines and requirements of each state where they have sales tax obligations. Utilizing sales tax software or consulting with tax professionals can help ensure accurate collection, reporting, and remittance of sales tax.

VAT registration and VAT filing service in EU

FZCO Accountants — Fri, 07 Jul 2023 23:48:52 +0000

In the European Union (EU), businesses that meet certain criteria are required to register for Value Added Tax (VAT) and file periodic VAT returns. VAT registration and filing services are available to assist businesses with these obligations.
Here's an overview of VAT registration and filing services in the EU.

VAT Registration:

Eligibility

Businesses are typically required to register for VAT if they exceed the VAT registration threshold in the country where they have a taxable presence or if they make taxable supplies of goods or services in another EU member state.

Registration Process

The specific process for VAT registration varies by country. Generally, businesses need to complete an application form and provide relevant information about their business, including legal entity details, contact information, and estimated turnover.

Assistance

VAT registration services, including accountants, tax advisors, or specialized firms, can help businesses navigate the registration process, ensure compliance with local requirements, and submit the necessary documentation to the tax authorities.

VAT Filing:

VAT Returns
VAT-registered businesses are typically required to file periodic VAT returns, providing details of their taxable sales, input VAT (VAT paid on purchases), and the resulting VAT liability or refund.

Filing Deadlines

Each EU member state has its own specific deadlines for filing VAT returns, which can range from monthly to quarterly, or annually depending on the turnover and other factors.

Compliance Support

VAT filing services can assist businesses in calculating VAT liabilities, preparing VAT returns, reconciling transactions, and ensuring compliance with the applicable regulations.

Electronic Filing

Many EU countries have implemented electronic filing systems, allowing businesses to submit VAT returns electronically through online portals or designated software. VAT filing services can help businesses navigate these electronic systems.

It's important to note that VAT regulations and procedures can vary among EU member states. Therefore, businesses should seek professional advice or consult with local tax authorities to ensure compliance with the specific VAT registration and filing requirements in each country where they have obligations.

VAT understanding for Amazon sellers

FZCO Accountants — Thu, 16 Sep 2021 17:13:23 +0000

Amazon Sellers can be a hard path to navigate. I get a lot of queries about VAT and Amazon. This post to cover to give you as much information as you need. This post will cover UK VAT, distance selling to the EU and Pan European FBA VAT.

If you are an overseas business and you are not based in the EU, then you will need to register for VAT. You have to make a plan to start making sales in the UK. It does not matter what your turnover is? You must register for VAT immediately if you are planning on selling on Amazon in the UK.

If you are considering expanding your Amazon operations into the European market, you have probably heard of Amazon sellers VAT calculation. You would be confused and concerned over VAT and how it will affect your bottom line. VAT may seem a little complicated to newcomers in these markets. They really are not as complex as you think and should not stand between you and your opportunities for growth!

A Few Thoughts on Amazon Seller VAT

Before we get started, here are a few thoughts to keep in mind when you are exploring expanding your Amazon business into the European market:

VAT is a legal requirement when selling in Europe. You cannot avoid or ignore it.
Start smaller, sell in only one country, to familiarize yourself with VAT.
You will need to do a little extra administrative work when selling to European customers.
Amazon tools, such as FZCO Accountants are available to help and can save you a lot of headaches, time, and errors.

Selling in the EU on Amazon – Distance Selling Rules

Distance selling rules are for those who sell from the UK to another EU country. So, if you sell on Amazon and sell from the UK and do not store your goods in the EU then you will be covered by the distance selling rules.

They have separate thresholds for each EU country. This can be come complicated as you need to monitor your sales to each country over a calendar year. Registering for VAT in a different country can be difficult due to the language and complexity. You normally need to get a professional to help.

Place of supply (Location of goods)

VAT rules are built around where the goods are stored. So, if you are an Amazon Seller from the UK and send the item from the UK, then they are UK sales. If you are based in the UK and sell using FBA, your good may be stored in Germany. If your goods are stored in Germany, then you are subject to German VAT rules (not the distance selling threshold).

Amazon have been stopping people using FBA if they do not give a valid VAT certificate for each country, they store goods in. If you store goods in another country other than your home country then you need to register for VAT in that country. This should put a lot of people off the pan-European amazon fulfilment program. The cost of registering in several countries can be quite high and unless your business will scale quickly you may want to hold off.

Registering and Filing for VAT as an Amazon Seller

The two biggest things to remember about registering for VAT is that you will need a separate registration for each company and that you will need to file VAT returns routinely.

‍

Amazon VAT Registration

When you register for a VAT you will need to present the necessary paperwork, including a passport, business documents, and administrative paperwork. While it can take two months to receive your government issued VAT number, you can begin selling your products right away using your validity date.‍

Amazon VAT Returns

VAT returns are due during different time frames, depending on the country. Germany, for instance, requires monthly returns, while the UK is quarterly. You generally have two weeks to pay before penalties will be assessed. Once you submit the VAT return, you will receive confirmation and pay the bill using a bank transfer.
Even though VAT registrations and returns are not complicated. It still may be advisable to leave the process to professionals to save time, paperwork, and costly errors.

If you think you need to register for VAT in the UK, EU or elsewhere please get in touch with us. We are expert Ecommerce Accountants and understand all aspects of selling on Amazon. Either send us an email or book a free consultation here: Contact us or find out more about us as Amazon Accountant.