You are. The manufacturer in China never places the product on the French market; you do, as importer and brand owner. That makes you the producer for household packaging and for every product stream your goods fall under, one IDU each. Being "not the manufacturer" changes nothing. Amazon's option to enter a supplier's number applies only when a French or EU company upstream already holds French IDUs for those products, which a Chinese factory never does.
Why "not the manufacturer" does not help
Article L. 541-10 defines the producer as the person who first makes the product available on the French market, whether it manufactures, imports or sells under its brand. A UK or German company buying finished goods in China and selling them to French consumers is the importer and the first to place them in France. The factory's compliance in China is irrelevant.
Amazon's "not the producer" box
Account Health lets a seller enter its supplier's registration numbers and declare it is not the producer. That is meant for resellers buying from a French or EU brand that already holds IDUs for those exact products. If your supplier is a factory outside the EU, or a brand with no French IDU, ticking that box leaves you non-compliant; Amazon validates the numbers against ADEME's register.
What applies
- Household packaging for every unit shipped to a consumer.
- Product streams for what you sell: electronics and batteries, toys, textiles, furniture, sports, DIY.
- Since 10 July 2026, a French representative if your company has no French establishment.
Cost reality
Low volumes fall under flat-rate regimes, so eco-contributions per country are small; the fixed cost is the representative and the setup. If you sell in six EU countries at low volume, the honest exercise is to rank them by margin and register where it pays. France is usually near the top of that list.
Frequently asked questions
Our Chinese supplier says it has EPR registration. Does that cover us?
Only if the supplier itself holds a French IDU for those products and is the one placing them on the French market. A factory shipping to you does neither.
We sell the same product in six EU countries. One representative for all?
No, one per country. We cover France; other countries need their own. Compare each market's margin against its fixed EPR cost.
Is there an exemption under 10 kg of packaging a year?
Not in France. Some countries (Ireland, for example) have tonnage thresholds; France has none.
Sources
Founder of EPR France Rep, the France-based EPR authorised representative for companies selling into France.
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