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Answer · Marketplaces
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Amazon still charges me French EPR fees, but I am already with Citeo. Why?

Because Amazon has no validated IDU from you for that category.

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Razvan TomaBy Razvan Toma · Founder
Last updated 29 October 2026Sources linked below
Quick answer

Because Amazon has no validated IDU from you for that category. Pay on Behalf is automatic and works category by category: if Amazon has no valid French EPR number for a category before the end of the reporting cycle, it reports your Amazon.fr sales in that category, pays the eco-contributions and recovers them from your account, plus €25 per category a year. Being a Citeo member does not switch it off; entering your IDU for that category in Account Health does.

What to check

  1. The category. A Citeo IDU covers household packaging only. If Amazon charges for textiles, electrical equipment, furniture or another stream, it needs the IDU for that stream (one IDU per stream).
  2. The number is entered. In Account Health, under Manage your compliance, for each category Amazon lists.
  3. The same legal entity. The IDU is held under the legal name and VAT number given to the eco-organisme. If the seller account belongs to another company in your group, Amazon cannot match them (the details behind an IDU).
  4. The dates. Charges for a period before your number was validated are Pay on Behalf working as designed. Since 27 August 2025 Amazon may also hold amounts in reserve and charge outside the normal reporting cycle.

Charged after your IDU was validated

Gather Amazon's EPR fee statement, your IDU for that category and the date it was validated, and open a case with Seller Support. Whether Amazon refunds a charge is Amazon's decision; nobody can promise it.

Your declaration to the eco-organisme

If Amazon declared and paid for some of your Amazon.fr units through Pay on Behalf, tell your eco-organisme and ask how those units go in your declaration. Do not leave units out of your declaration on your own because Amazon charged for them.

If you are our client

Send us Amazon's EPR fee statement: we check which categories and periods it covers against your IDUs and tell you what to enter or contest. How Pay on Behalf works: is Pay on Behalf enough?

Frequently asked questions

Does my Citeo membership stop Pay on Behalf automatically?

No. Amazon does not look at your membership; it checks whether you have submitted a valid IDU for each category. Enter it in Account Health, under Manage your compliance.

I sell clothing. Is my Citeo IDU enough?

No. Citeo covers the household packaging. The clothing itself falls under the textiles stream, with its own IDU through Refashion.

Will Amazon refund what it charged?

Amazon decides. For charges after your IDU was validated, open a case with Seller Support with the fee statement and the IDU.

Sources

Razvan Toma
Written byRazvan Toma

Founder of EPR France Rep, the France-based EPR authorised representative for companies selling into France.

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Is my packaging household (EMPAP) or professional (EPRO)?

The arrêté of 2 December 2025 decides whether packaging falls under the household stream (EMPAP) or the professional one (EPRO). The three-step test, the automatic lists and the e-commerce exception that catches most online sellers.

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Do I have to do anything about EPRO before 1 January 2027?

ADEME asks producers to join an eco-organisme before 31 December 2026, ahead of the professional packaging scheme starting on 1 January 2027. What that means for a company with no French establishment, and what has to happen in which order.

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Who is the producer for professional packaging in France?

Producer status under EPRO follows the first placing on the French market, not who owns the pallet or who pays the freight. How it lands for a foreign supplier, a French importer, a distributor and a marketplace.

Read →Establishment

Does a French VAT number mean I am established in France?

No. French tax law has a standing category for companies liable for French VAT with no permanent establishment in France. A VAT registration does not remove the EPR representative duty under article L. 541-10-9-1.

Read →Establishment

Does stock in a French warehouse or 3PL make me established in France?

Holding stock in France, using a French 3PL or selling through FBA does not give you a French establishment, and it does not remove the EPR representative duty. It does confirm you are the producer for what you sell from it.

Read →Who is the producer

We sell DDP or DAP into France. Who is the producer?

Incoterms allocate cost and risk between buyer and seller. They do not move producer status under French EPR, which follows who first places the goods on the French market.

Read →Existing registrations

I already have a French IDU. Do I need another one for professional packaging?

Yes. The IDU is issued per EPR stream, so household packaging and professional packaging each have their own. Your existing identifier stays valid and the same representative mandate can cover both.

Read →Who needs one

We are an EU company. Do we really need a French EPR representative?

Yes. Article L. 541-10-9-1 turns on establishment in France, not on nationality or EU membership. A German, Dutch, Italian or Spanish company selling directly to French end users is in the same position as a non-EU one.

Read →EPRO

Which eco-organisme do I join for professional packaging?

Three eco-organismes are approved for French professional packaging — Citeo Pro, Léko Pro and Twiice — plus three approved individual systems, all pallet poolers. How to choose, and what an individual system does and does not cover.

Read →Marketplaces

Amazon says it handles EPR. Am I covered?

A marketplace established in France carries a backstop duty for sellers who have not registered, and the French article treats the obligation as satisfied for those products. It is not a substitute for your own IDU, and it covers only that channel.

Read →Marketplaces

Is Amazon's Pay on Behalf enough for French EPR?

Only for your Amazon.fr sales. Pay on Behalf pays the eco-contributions on what you sell on Amazon.fr, for a service fee of €25 per EPR category a year since 1 January 2026. It gives you no IDU and covers no other channel.

Read →The IDU

How do I get a French IDU?

By joining an eco-organisme for each stream you are caught by. The eco-organisme registers you in SYDEREP and sends you the IDU; you cannot register yourself in a collective scheme.

Read →The IDU

Do I need one IDU or several?

One per EPR stream you are caught by. A single product can fall under several streams, so a smartphone seller can hold three IDUs.

Read →The IDU

What details does a foreign company need to get a French IDU?

An EU company identifies itself with its intra-EU VAT number; a company outside the EU with the registration number from its home tax authority. Plus address and product categories.

Read →The IDU

Where do I have to show my IDU?

In your general terms of sale, on your website, and to any buyer who asks. Articles R. 541-173 and L. 541-10-10 of the Environmental Code.

Read →The IDU

How can I check whether a company has an IDU?

In ADEME's search engine of issued IDUs, or in ADEME's open dataset of producers and IDUs.

Read →The IDU

Can my IDU be withdrawn?

Yes. In a collective scheme the eco-organisme can remove it, and it takes effect if you are not a member of another one.

Read →Existing registrations

I already have a Citeo, Léko or Refashion membership. Do I start again?

No. Your membership and your IDU stay valid. The law adds one step: you appoint a France-established representative by written mandate, and it takes over your obligations.

Read →Costs

Does the €990 a year cover everything?

Yes, for our work: the mandate, memberships, IDUs and declarations for up to three streams, with no setup fee and no other charges from us. Eco-contributions go to the eco-organismes at their published tariff.

Read →Costs

Why is the fee not pro rata, and when do I pay?

Because the mandataire takes over your obligations for the whole calendar year, and your annual declaration covers everything you placed on the French market that year, including the months before the mandate.

Read →

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