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~ Go Global Ecommerce ~

don’t miss addressing the environment. The EPR (Extended of the Food Business Operator and the recognition of
Producer Responsibility) directive for packaging waste designations of origin. This is a complex process, not only
involves many countries and aims to limit upstream the because the exit treaty is very long but also because wine is
environmental impact of packaging and disposal. Producer one of the most sold products in the continent and in the
accountability includes both specific and economic United Kingdom. Until now, it was necessary to indicate
obligations aimed at fighting the use of packaging or the on the label a Food Business Operator (FBO) as the person
production of goods difficult to dispose of. As this is a responsible for the marketing of the wine; what changes
directive and not a regulation of the European Union, today is that this figure will have to be based in the UK
the requirement imposed on member states concerns the and that this location will have to be stated on every bottle.
pursuit of the objectives, which are also deferred over However, companies have been given time until September
time, but not the methods and instruments used to achieve 30, 2022, to comply: during this transition period, they will
them. What’s new is that starting from 2022, France and still be allowed to keep using the name and address of the
Germany will extend the responsibility of verifying the importer based in the European Union.
compliance of producers to marketplaces that sell goods
through their platform, also adopting with respect to the Designations of origin are precisely regulated by uniform
ecological issue the theme of accountability for the relations rules throughout the European Union. In the United
with third parties. Fundamentally, marketplaces will have to Kingdom, on the other hand, protection will now only be
ensure that they receive EPR registration details from their temporary: also, in this case, there will be a transition period
customers. to align with the regulations, at the end of which it will be
necessary to register the product not only in the EU but also
Each country has a register of those required to make this in the UK if the designation of origin is not to be lost.
contribution, which varies from state to state. In Italy, in 2022 is characterised by numerous regulatory changes
particular, the body in charge is the Consorzio Nazionale driven by a common intention in favour of consumer
Imballaggi, CONAI. Therefore, those marketplaces that sell protection through the regulation of all activities related
in France and Germany, as of July of this year, will have to to the collection, storage and use of users’ personal data.
make sure that sellers using the services of their platform Also, paying attention to other transparency issues and fair
have actually fulfilled their registration and payment commercial practices. In response to this scenario, more
obligations. If, as a marketplace, you are also involved in and more cross-border e-commerce companies in Europe
shipping and packaging and not just in the provision of are turning to Merchants of Record such as Go Global
digital services and intermediation, then the obligation to Ecommerce to manage the resulting obligations—from
obtain an EPR registration number from the manufacturer tax-related aspects to customer and supplier relations—
is accompanied by another requirement: namely, the intermediary figures who act on behalf of the eshop in order
provision of your own EPR position and the direct payment to simplify financial management, allowing companies to
of the contributions required, in line with state legislation. focus on product development and sales channels without
worrying about the risk of penalties for non-compliance
At the moment, since this is a European directive, each state with new regulations. ••
can adopt different provisions for its own territory, with
the consequent multiplication of EPR regimes that differ
from each other in the type of contributions required and
the subjects who are required to pay them. Therefore, the
utmost attention is requested to those who sell in France
and Germany because, regardless of the producer, they will
inevitably have to face higher control charges.

What is certain is that, starting this year, accountability will
be distributed and shared among the various subjects, also
affecting network choices. It will no longer be possible to
neglect to investigate the working methods of one’s partners,
which could entail, especially in the absence of adequate
support, not only financial risks, in the case of penalties,
but also a greater burden on the management of the various
steps of the supply chain.

Finally, the repercussions of Brexit branch out to touch the
wine market, basically compelling double authorisations
between the EU and the UK, about, in particular, the figure

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