Final report

Producer responsibility of third-country producers in e-commerce

In order to enforce producer responsibility under waste law against producers of electrical and electronic equipment, batteries and packaging from countries outside the EU, so-called third countries, a new study recommends adding two new actors into the law and create a compulsory verification for them. Producers from third countries mostly sell their products in Europe via electronic marketplaces and have them stored and shipped by fulfilment service providers. The operators of the electronic marketplaces and the fulfilment service providers have so far not met any obligations from the ElektroG, BattG and VerpackG, as they are neither producers nor distributors. However, they are the first players on European soil who make a significant contribution to placing products from third countries onto the market in Europe. It is therefore necessary to provide them with the obligation to check whether the producers of these products are fulfilling their producer responsibility and, for example, are correctly registered according to the ElektroG.