Save over€1,000

a year in textile eco-contributions with Plus*

Calculate your saving →

*Example: 2,000 women's T-shirts a year, at Refashion's published 2026 rates. Your saving depends on your products and volumes.

French EPR representative rule in effect since 10 July 2026 · day 91Check if it applies to you →
Since 10 Jul 2026 · Check if it applies to you →
Home / Answers

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

Only for what you sell on Amazon.fr.

Last updated 8 October 2026Sources linked below
Quick answer

Only for what you sell on Amazon.fr. Pay on Behalf is Amazon's fallback for sellers who have not given it a valid French EPR number for a category. Amazon reports your Amazon.fr sales to an eco-organisme, pays the eco-contributions and recovers them from your seller account, plus a service fee of €25 per EPR category a year since 1 January 2026. It does not register you: there is no eco-organisme membership and no IDU in your name, so your own website, other marketplaces and direct B2B sales into France are not covered.

Backed by data: Marketplace requirements (dataset)

What Pay on Behalf does

  • Enrolment is automatic. Amazon enrols you, category by category, if you have not submitted a valid EPR number before the end of the reporting cycle.
  • Amazon declares and pays. It reports your Amazon.fr sales in each category to the eco-organismes it works with, pays the eco-contributions and recovers them from your seller account.
  • The service fee is €25 per EPR category a year in France since 1 January 2026, on top of the eco-contributions. Until the end of 2025 it was €24.99 plus 3% of the eco-contributions.
  • Under the policy in force since 27 August 2025, Amazon may hold amounts in reserve and charge outside the normal reporting cycle.

What it does not do

  • It does not make you a member of an eco-organisme and does not give you an IDU. There is nothing in your name to print on your terms of sale or to give another marketplace.
  • It covers Amazon.fr sales only. Your own website, Cdiscount, ManoMano, Fnac, Zalando and direct B2B sales into France are outside it.
  • It does not appoint a representative. A producer not established in France still needs a French mandataire for the products it sells through any other channel.

When it is enough

Your situationIs Pay on Behalf enough?
You sell into France only through Amazon.frYes, for those sales, and it is the cheapest route
Amazon.fr plus your own website shipping to FranceNo: the website sales need your own registration
Amazon.fr plus other marketplacesNo: they ask for your own IDU
Sales to French businessesNo

One channel outside Amazon is enough to need your own registration. Once you have an IDU for a category, you enter it in Account Health, under Manage your compliance, and Amazon stops paying on your behalf for that category.

Moving to your own registration

You get an IDU by joining an eco-organisme for each stream: see how to get a French IDU. A representative does this in your name; see pricing. For the legal side of marketplaces, see Amazon says it handles EPR. Am I covered?

Frequently asked questions

Does Pay on Behalf give me an IDU?

No. Amazon pays the eco-contributions on your Amazon.fr sales, but no eco-organisme membership and no IDU is created in your name.

Is Pay on Behalf cheaper than my own registration?

If you sell into France only on Amazon.fr, yes: the service fee is €25 per EPR category a year, and the eco-contributions are owed either way. As soon as you sell into France through another channel, you need your own registration as well.

How do I leave Pay on Behalf?

Submit a valid French EPR number for the category in Account Health, under Manage your compliance. Amazon then stops paying on your behalf for that category.

Sources

Razvan Toma
Written byRazvan Toma

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

Connect on LinkedIn →
Keep reading

Related reading

EPRO

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.

Read →
EPRO

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.

Read →
EPRO

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 →
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 →

Question not answered here?

Ask it and we will answer in writing — and add it to this page if others are asking it too.