Amazon is paying your EPR bill. Here's what that does not cover.

By Jarmo Habakuk · 2 August 2026 · Updated 29 August 2026

✓ Last verified against primary sources: 29 August 2026

If Amazon is billing you eco-contributions for a country you never registered in, that is Pay on Behalf. You did not sign up for it. Amazon enrolled you because you have no registration number there.

Amazon prices it for France, Spain, Belgium and Italy at €25 a year per category, and for the UK at £20. It does not run in Germany or Poland.

It is narrower than being enrolled makes it feel, and Amazon says so in its own terms. It pays for your Amazon sales and nothing else. It may cost you more than registering yourself. And it does not stop when you register — it stops when the reporting cycle turns.

Corrections. 17 August 2026: the original version said the outcome of 12 August was unsettled. It settled the undramatic way — sellers without numbers are automatically enrolled, not locked out. 29 August 2026: the original also said you need your own registration numbers to remain in Pay on Behalf. That is backwards, and this article has been rewritten. The number you needed by 12 August is the one that keeps you selling.

You did not opt in. You fell in.

Amazon’s compliance pages for France and Spain both say it plainly: it enrols you automatically if you sell products subject to EPR obligations and have not submitted a valid registration number.

The missing number is the trigger. There is no subscription and no button you pressed.

It works one country and one category at a time. Packaging is only one category. Amazon’s French page runs quarterly cycles for WEEE, furniture and toys, semi-annual for sport and leisure, and annual for the rest. So you can be enrolled in one category and registered in another, in the same country, on the same day.

That is why the dashboard has a tab per country and a row per category. Read it as a list of the places you have no number.

Why Amazon offers this in some countries and not others

Pay on Behalf tracks the countries whose own law makes the marketplace liable for its sellers.

France says so directly. Under Article L541-10-9 of the Code de l’environnement, a marketplace facilitating sales of EPR products must contribute — unless it holds proof that the seller already complied. Your registration number is that proof, by name.

Spain gets there differently. Under Royal Decree 1055/2022, if a foreign producer has not appointed an authorised representative, the platform acts subsidiariamente as producer.

So Amazon is not doing you a favour. It has a liability of its own in those countries, and Pay on Behalf is how it discharges it.

That is the best available explanation of the map, not a proven rule. I have read the French and Spanish provisions at source. I have not proved that Germany and Poland lack an equivalent one — absence is harder to establish than presence, and I have not established it.

Two cautions on the list itself. It moves without notice, as Italy proved this month. And Amazon’s own documents disagree with each other: the service page named five countries in August, while a separate coverage table also listed Ireland and Austria. Check your own dashboard rather than any list, including this one.

Nor is France a clean either/or. Amazon has posted that in France non-compliant listings will be suspended and that it will recover the cost of your eco-contributions. Being billed is not the same as being safe.

Three things Amazon’s own terms say it does not do

This is the part worth reading twice, because none of it appears on a vendor page.

It covers Amazon sales and nothing else. Amazon’s FAQ: “No, Amazon only pays eco-contribution for sales made on Amazon.” Sell the same packaged goods through your own site, eBay or a local marketplace, and none of that volume is declared or paid for you. Being enrolled reads as being covered. For anyone selling on more than one channel, it is not.

It may cost you more than doing it yourself. Also Amazon’s own wording: it “may be unable to apply eco-modulation”, and “accordingly, you may pay higher eco-contributions by using the EPR Pay on Behalf service” than if you register and meet the obligations yourself. France is where this bites hardest, because the eco-modulation discounts only come with the detailed declaration.

If you both pay, you do not get it back. Amazon reserves the right not to reimburse contributions it has paid on your behalf “in any circumstance, including if, for any reason, both you and Amazon pay Eco-Contributions in respect of the same products.”

Put the third one next to the reporting cycle below and paying twice in the year you switch over is the design, not an accident.

You leave when the cycle turns, not when you register

This is the mechanism nobody explains, and it is the one that costs money.

Amazon’s FAQ says you are auto-enrolled if you have not submitted a valid number for the category before the last day of the reporting cycle. It stops declaring and paying from that reporting cycle onwards.

So the unit of un-enrolment is the cycle, not the day your number clears. Hand over a valid number in August for an annual category and you stay enrolled until the year turns. A quarterly category turns over four times faster, for exactly the same reason.

Which means the dashboard can show three true things at once: your number is valid, Amazon has told you it will un-enrol you, and the category still reads Enrolled. Nothing is broken. Amazon’s clock is not your clock.

One thing still open, as at 29 August 2026. In an account I watch, a French packaging number was valid by 12 August. Amazon confirmed in writing three days later that the account was de-enrolled for that category, retroactively to 1 January, and that the reserved amount would come back within seven days. That is a better outcome than the policy above describes. Two weeks past the promised date, the money has not appeared in the transaction log. One account, and I will update this when it resolves either way.

Check your dates before you argue any of this. Amazon’s appeal windows run from the charge date, not from when you noticed. Enrolment errors — a missing or invalid number — get 90 days. Wrong classification or measurement gets 12 months. Late appeals are refused outright.

What to do this week

• Open the Pay on Behalf dashboard and read it as a gap list. Every country tab and every category row is a place you hold no validated number.
• Add up your non-Amazon sales in those countries. That volume is not covered by anything, and nobody will invoice you for it until someone does.
• Submit numbers you already have. They may exist from an earlier registration, or through a brand owner or importer, and simply never have been entered.
• Do not assume the exit is available. In Belgium the producer register is still being built, and a seller asking for a Belgian number today cannot get one. Italy has the same shape of problem and I have not resolved it.
• Treat Germany as its own job. It was never in Pay on Behalf, so 12 August is not when that problem started. Registering in LUCID is still free and still yours to do — but a seller with no German establishment must now also appoint an authorised representative, and that is not free.
• Do not read enrolment as compliance. Under the PPWR a marketplace can meet your financial obligations by written mandate, and only those. Registration and the authorised representative stay yours, which is the companion article on what Pay on Behalf does not do.