The "I am not the producer" option in Account Health is for resellers: you buy goods from a French or EU company that has already placed them on the French market and holds French IDUs for them, and you enter that company's numbers. It works only if the supplier genuinely is the producer in France and its IDUs cover the streams and products you sell. It does not work when your supplier is a factory outside the EU, a brand without French IDUs, or when you own the brand: in all those cases you are the producer and need your own numbers.
What the option is for
French law puts EPR on the first person to place a product on the French market (article L. 541-10). A French distributor buying from a French brand is not that person; the brand is. Amazon's form lets such a seller say so and enter the brand's IDUs, which Amazon checks against the ADEME register. This is a legitimate and common situation for retailers of established brands.
The test, in three questions
- Is the supplier established in the EU and did it place the goods on the French market before you? A French or EU wholesaler who sold you goods already in free circulation in France: yes. A factory in China shipping to you: no, you are the importer.
- Does the supplier hold French IDUs, per stream, for these products? Ask for them. A German brand with only a LUCID number does not have French IDUs; a French brand registered with Citeo and ecosystem does.
- Is the brand theirs, not yours? Private label makes you the producer even if the physical product is identical to a supplier's.
Three yes answers: enter the supplier's IDUs. Any no: you need your own registration.
Where sellers get caught
- Non-EU supplier. The most common case. The Chinese, Turkish or Indian factory may have "EPR" for its own direct sales, or claim to. Its numbers cover nothing you import.
- EU brand without French numbers. A German or Italian brand that only sells to you, not to France, is not the producer in France. You are.
- Dropshipping from abroad. The goods never pass through a French company; the shipper is the producer for the packaging.
- Numbers for the wrong stream. A supplier's packaging IDU does not cover the EEE or battery stream of the product.
Amazon verifies the numbers against the register. A wrong or unrelated IDU is treated as no IDU, and the listing is deactivated.
If you are the producer
A company not established in France registers through a French mandataire, one IDU per stream. Small volumes fall under flat-rate regimes. The Free EPR Calculator shows the streams and eco-contributions for your catalogue; the scope check confirms whether you are the producer.
Frequently asked questions
My supplier is a French wholesaler. Can I use its IDUs?
If it placed the goods on the French market before you and its IDUs cover the streams you sell, yes. Ask for the numbers and keep the invoices.
My supplier gave me an 'EPR certificate'. Is that enough?
Only if it is a French IDU per stream for the products you sell, and the supplier is the one placing them on the French market. A certificate from a non-EU factory is not.
We are both: we resell a French brand and sell our own private label. What do we do?
Enter the brand's IDUs for the brand's products and your own IDUs for your private label. Registration is per producer, not per seller.
Can our French distributor's IDU cover our direct Amazon.fr sales?
No. Its IDU covers what it places on the market. Your direct sales are yours.
Sources
- Légifrance — Code de l'environnement
- ADEME — French EPR schemes, PROs and IDU register
- Commission estimate of the representative-services market (€1–2 bn/yr), reported Aug 2026
- Citeo — Déclarer (98,000 clients)
Founder of EPR France Rep, the France-based EPR authorised representative for companies selling into France.
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