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Home / Use cases
Use case · Pan-EU FBA

My FBA stock is in Germany. Do I still need French EPR?

Yes.

Free EPR Calculator →Do I need a representative?
Razvan TomaBy Razvan Toma · Founder
Last updated 15 September 2026Sources linked below
Quick answer

Yes. Producer status is decided per country by who first makes the product available there, not by where the warehouse is. When Amazon ships your goods from a German fulfilment centre to a French consumer, you are the producer in France: you need household packaging membership, the product streams that apply, one IDU per stream, and, since 10 July 2026, a French EPR representative if you are not established in France. Your German LUCID registration does nothing for France.

Why the warehouse location does not matter

EPR follows the market where the product reaches the end user. Under the French Environmental Code and the EU packaging regulation, the producer is whoever first places the packaged product on the French market. With Pan-EU FBA that is you, the seller of record, whichever country Amazon stores the stock in.

What applies

  • Germany: LUCID registration, dual system contract, and since 12 August 2026 a German authorised representative if you sell directly to German end users without an establishment there.
  • France: household packaging membership (Citeo, Léko or Adelphe), product streams for what you sell, one IDU per stream, and a French representative (article L. 541-10-9-1).
  • Italy, Spain, Netherlands: separate registrations if Amazon serves those markets from your stock.

Common mistake

Entering the German LUCID number in the French field of Account Health. Amazon validates the number against ADEME's register; a foreign number fails and the listing is deactivated.

What we do

We act as your French representative, join the French eco-organismes in your name, deliver the IDUs for Account Health, and file the French declarations from your Amazon sales reports. Germany stays with your dual system.

Frequently asked questions

Amazon ships from Germany. Isn't Amazon the producer in France?

No. Amazon is the logistics provider; you are the seller of record and the one placing the product on the French market.

Can one representative cover Germany and France?

No. Each country needs a representative established there. We cover France; your German dual system or a German representative covers Germany.

I only sell a few hundred units a year in France. Does it still apply?

Yes. There is no minimum for packaging in France. Small volumes usually fall under flat-rate regimes with low eco-contributions, but registration is still required.

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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