Pay on Behalf was Amazon paying French eco-contributions to the eco-organismes for sellers who had no EPR number, then charging the seller. It satisfied Amazon's own liability under article L. 541-10-9, not yours: you were never registered, never received an IDU and were never covered on Cdiscount, ManoMano, Fnac or your own store. Since July 2026 Amazon tells sellers that Pay on Behalf is not a substitute for registration and asks for an IDU per stream. The replacement for a foreign seller is a French mandataire who joins the eco-organismes in your name.
Where Pay on Behalf came from
France made marketplaces co-liable for their sellers' EPR in 2022 (article L. 541-10-9 of the Environmental Code, from the AGEC law). A marketplace must check that each seller holds a valid IDU per stream, and if the seller has none, pay the eco-contributions itself. Amazon's answer was a programme: for sellers without a number, Amazon pays the eco-organismes and deducts an "EPR fee" from the seller. It is Amazon protecting Amazon. From the seller's side it looked like compliance, and for three years nobody pushed back.
What it never did
- No registration. The eco-organisme contract is between Amazon and the eco-organisme. Your company does not appear in SYDEREP.
- No IDU. Only a registered producer gets an IDU. You cannot put "Amazon pays for me" in your terms of sale, which article R. 541-173 says must display the IDU.
- No other channel. Your Shopify orders, Cdiscount listings and wholesale shipments were never covered.
- No Triman. The sorting-information marking on your packaging remained your job.
Why it stopped being enough in 2026
Two things. On 10 July 2026, law n° 2026-602 created article L. 541-10-9-1: a producer not established in France must appoint a France-based representative for its EPR obligations. Then on 12 August 2026 the EU packaging regulation required every producer to be registered in every member state of sale. Amazon's Seller Central notices since summer 2026 say the same thing: provide your own IDU per stream; Pay on Behalf is not a registration.
What replaces it
- Appoint a French mandataire by written mandate.
- The mandataire joins the eco-organismes for each stream (household packaging, plus EEE, batteries, textiles, toys, furniture as relevant) in your name.
- The eco-organisme registers you; ADEME issues one IDU per stream.
- Enter the IDUs in Account Health, your terms of sale and your website; declarations follow from your sales data.
Eco-contributions are the same tariff you would pay directly, without the marketplace mark-up. The mandataire fee is fixed per year. The Free EPR Calculator shows both sides for your volumes.
If you paid Amazon for years
Those payments are not lost: Amazon did pay the eco-organismes for those units, so there is nothing to catch up on for the past. There is nothing to migrate either; you start a fresh membership through the mandataire, and Amazon stops charging the fee once your IDU is verified.
Frequently asked questions
Was Pay on Behalf illegal?
No. It was Amazon meeting its own obligation as a marketplace. It just never met yours as a producer.
Can I keep Pay on Behalf and also get my own IDU?
Once your IDU is verified in Account Health, Amazon stops charging the EPR fee for that stream. Paying twice makes no sense.
I only sell on Amazon.fr. Do I still need a mandataire?
If your company is not established in France, yes. The registration and IDU are per producer, not per channel.
Sources
- Légifrance — Code de l'environnement
- Ministère de la Transition écologique — filières REP
- ADEME — French EPR schemes, PROs and IDU register
- EUR-Lex — Regulation (EU) 2025/40 (PPWR)
- Commission estimate of the representative-services market (€1–2 bn/yr), reported Aug 2026
Founder of EPR France Rep, the France-based EPR authorised representative for companies selling into France.
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