The market is experiencing a phase of very important regulatory evolution that concerns those who sell certain product categories both through Amazon and other channels.
The changes to the rules on extended producer responsibility, in fact, are a structural change in the way companies must manage the life cycle of their products, with particular attention to environmental impact and disposal.
For sellers operating on Amazon, the new provisions are also an opportunity to align their business with more sustainable standards. And, in addition, to operate with greater transparency in the market.
Let’s share some reflections on this topic together and what its impact is on sellers.
Which products are affected by the new rules
The scope of the new rules involves a wide range of product categories, each with its own specificities. WEEE, waste electrical and electronic equipment, are however probably the most relevant category for many Amazon sellers, considering the technological nature of a large part of products sold online.
Another critical area consists of batteries, given their presence in countless everyday products. Packaging also falls into the categories subject to regulation, although with some exemptions for micro-enterprises, which we will explore further. Tires, oils, and polyethylene complete the regulatory framework, affecting relevant sectors for those operating in online commerce with a diversified range of products.
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Which deadlines must be respected
December 31, 2025 is the first appointment for those marketing electrical and electronic equipment. By this date, it will in fact be necessary to have completed both the registration and reporting of WEEE sales made during the year.
The second date to mark on the calendar is March 30, 2026, which concerns a wider group of product categories. Batteries, packaging, tires, oils, and polyethylene must be subject to registration and reporting by this deadline.
The times are therefore quite tight, especially regarding WEEE.
The need to focus on WEEE with maximum priority
Also by virtue of the early deadlines for WEEE, it emerges how the legislator intended to place maximum attention on this category. On the other hand, when a seller places electrical or electronic equipment on the market, they automatically assume responsibility for its end of life. They also contribute financially to collection and recycling systems. The principle in some ways overturns the traditional logic according to which waste management was exclusively a public problem or one for the final consumer.
For those selling on Amazon, understanding if a product falls under WEEE means therefore carefully analyzing their catalog. Contrary to some superficial analysis, in fact, not only computers or smartphones fall into this area. Products that are apparently harmless like small LED devices, chargers, digital watches, or electronic toys are also attributable to this category.
The definition is therefore very broad and includes practically everything that needs electric current or batteries to function, making catalog verification a potentially complex operation for those marketing hundreds or thousands of ASINs.
How to adapt to the new provisions
Adaptation to EPR standards requires as a first step a detailed analysis of one’s business. The initial step consists in fact in examining category by category which products of one’s inventory are subject to extended responsibility obligations. An internal audit phase that is fundamental, because it determines the extent of subsequent fulfillments and may reveal areas of the business not previously considered from an environmental regulatory profile.
Once the relevant categories have been identified, the next step is registration with the organizations in charge of managing producer responsibility systems. Every category has its reference bodies and obtaining the EPR registration number becomes a mandatory step to continue operating legally on the Italian market. For mineral oils, for example, the procedure goes directly through CONOU, while for other categories there are various consortia and collective systems to choose from.
Reporting sales and paying environmental contributions are a recurring activity that must be integrated into company processes. Contributions are not taxes in the strict sense of the term, but are a portion that every producer pays to finance collection and recycling systems. The calculation of contributions depends on the type and volume of marketed products. A sales tracking system by product category and geographic destination thus becomes necessary.
The authorized representative for non-EU sellers
For sellers who do not have a physical headquarters in Italy, the legislation provides for the possibility of appointing an authorized representative. The figure assumes a central role because they become the interface between the seller and the Italian authorities. They manage administrative fulfillments and guarantee compliance with local regulations.
Consider that the appointment of a representative is not always mandatory, but becomes particularly important for those operating from abroad and who do not have the structure or skills to navigate the Italian regulatory system autonomously.
Moreover, the authorized representative does not limit themselves to acting as a bureaucratic intermediary. Instead, they can provide specialized advice:
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on the correct classification of products
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on the choice of the most suitable consortia
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on the optimization of reporting processes.
In general, for many international Amazon sellers serving the Italian market, relying on a local representative is the most efficient solution to ensure compliance without having to internally develop specific skills on the EPR system.
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The exemption for micro-enterprises in the packaging sector
As anticipated, there is an important exception that specifically concerns packaging. Micro-enterprises that:
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employ fewer than ten employees
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record a turnover or balance sheet total of less than two million euros
can in fact benefit from an exemption from packaging obligations. A provision aimed at streamlining the activities of smaller entrepreneurial entities. Entities for which the burdens linked to packaging management could be disproportionate to the size of the business.
However, it is fundamental to carefully verify if one actually falls within the exemption parameters. The criteria are in fact cumulative. That is, both the limit on the number of employees and that on turnover or balance sheet must be satisfied simultaneously. Furthermore, the exemption exclusively concerns packaging. It does not extend therefore to other product categories like WEEE, batteries, or oils. For these, the obligations remain regardless of company size.
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What implications for seller business on Amazon
The introduction of these new EPR obligations evidently fits into a context of progressive tightening of environmental regulations. Those who sell on Amazon must interpret these changes certainly not as an obstacle. Rather, as part of a transition towards more sustainable business models. Models that, in the medium-long term, are a clear competitive advantage. Consumers are in fact increasingly attentive to the environmental impact of their purchases. The ability to demonstrate compliance and environmental responsibility can therefore transform into an element of differentiation in the market.
Let us also recall how timely compliance with EPR obligations can prevent much more serious problems than economic sanctions. Amazon itself increasingly requests evidence of seller regulatory compliance. Therefore, failure to register for EPR could lead to the suspension of the ability to sell certain product categories. Investing time and resources in adaptation today is therefore a useful recipe to protect the continuity of one’s business tomorrow. Thus, operational interruptions that could have significant impacts on revenues can be avoided.
