Amazon.fr asks every third-party seller for a French EPR registration number (IDU) per product category, because French law makes the marketplace liable for sellers who have none. Pay on Behalf only pays eco-contributions; it does not give you an IDU or make you compliant. If your company is not established in France, you get your IDUs through a French EPR representative, who joins the eco-organismes in your name; ADEME then issues one IDU per stream, usually within one to three weeks.
What Amazon is actually asking for
Since 2022 French law (article L. 541-10-9 of the Environmental Code) obliges marketplaces to check that each seller holds a valid IDU for every EPR stream its products fall under, and to pay the eco-contributions themselves if the seller has none. Amazon enforces this through Account Health: one IDU per category (household packaging at minimum, plus electronics, textiles, furniture, toys and so on where they apply), checked against ADEME's public register. Listings without a valid number are deactivated in enforcement waves; reactivation follows within a few days of a valid IDU being entered.
Why Pay on Behalf no longer protects you
Pay on Behalf was a stopgap: Amazon paid the eco-contributions for sellers without a number and charged them back. Since 12 August 2026 the EU packaging regulation requires every producer to be registered in each country of sale, and since 10 July 2026 French law requires producers not established in France to act through a French representative. Amazon has told sellers that Pay on Behalf does not replace their own registration, and is asking for the numbers. Paying through Amazon also never gave you an IDU for Cdiscount, ManoMano, Fnac or your own store.
How a foreign seller gets the IDU
- Confirm the streams: household packaging always applies; add product streams for what you sell.
- Appoint a French EPR representative by written mandate (mandatory if you have no French establishment).
- The representative joins the eco-organisme for each stream in your name and prepays the estimated eco-contributions.
- The eco-organisme registers you in SYDEREP; ADEME issues one IDU per stream, typically in one to three weeks.
- Enter each IDU in Account Health and in your terms of sale; declarations follow yearly or quarterly.
Timing
If listings are already deactivated, the order matters: representative mandate first (same day), eco-organisme membership (days), IDU (weeks). Amazon reactivates once the number validates. If you are still live, start now: the eco-organismes are processing a backlog of foreign producers since July.
Frequently asked questions
Can I keep using Amazon Pay on Behalf instead of registering?
No. Amazon itself asks for your own registration numbers. Pay on Behalf paid fees but never gave you an IDU, and since July 2026 a producer not established in France must act through a French representative.
Do I need one IDU or several?
One per EPR stream. A seller of packaged electronics needs at least two: household packaging and electrical equipment; batteries would be a third.
How long until Amazon reactivates my listings?
Once a valid IDU is entered in Account Health, reactivation typically follows within a few business days. Getting the IDU takes one to three weeks from membership.
Is the IDU the same as my German LUCID number?
No. Each country has its own register. LUCID covers Germany; the IDU covers France.
Sources
Founder of EPR France Rep, the France-based EPR authorised representative for companies selling into France.
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