Pay on Behalf pays your EPR fees. It does not register you.
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Amazon can be paying your eco-contributions and warning you about the same country at the same time. That is not a mistake, and you have not fallen through a crack.
Two separate things are running on your account.
Amazon pays in France, Spain, Belgium, Italy and the UK. It does this automatically whenever you have no registration number, and it has done so for years. 12 August changed nothing about it.
Amazon asks for your number in more countries than that — Germany, Poland and Sweden among them. Since 12 August it has to hold that number to let you keep selling.
The bill and the warning are not connected. Being enrolled never protected a listing. Getting a number stops the warning, and it is not what stops the bill.
Why you can be paid up and still non-compliant
Pay on Behalf does one job. It works out what you owe the national scheme, pays it, and bills you plus a service fee.
That is a real service and for a lot of sellers it was a relief. The fees got paid, nobody had to learn what Citeo was, and the notices went quiet.
None of it has been withdrawn. What changed is what Amazon has to check, and that is the registration — not the payment.
So the sellers most exposed now are not the ones who ignored EPR. They are the ones who were enrolled, had a quiet account for a year, and reasonably assumed they were covered.
What you actually need, country by country
Two things, in most countries: a registration number, and a representative if you have no company there. Who does which changes.
Germany. Registration in LUCID is free and you have to do it yourself — nobody can hold it for you, not a representative and not Amazon. If you have no German company you also need an authorised representative, in place before you put packaging on the market. There is no Pay on Behalf here, so nothing is being paid for you either.
Spain. The opposite arrangement. You appoint a representative first, and the representative then does the registration and the reporting in its own name. Nothing else can start until that appointment is done.
Belgium. Worth knowing before you buy anything: a seller trading only through a marketplace that pays on its sellers’ behalf reports to the platform and needs no representative of its own. That stops being true the day you open a second sales channel. The Belgian producer register is also still being built, so a number cannot currently be obtained.
France and Italy. Amazon pays here, so the money is handled while you are unregistered. The registration is still yours.
Poland and Sweden. Amazon asks for a number and offers nothing. Nobody is paying anything for you in these countries, which makes them the quieter risk.
Three things Pay on Behalf does not do
- It does not cover your other sales channels. Amazon’s FAQ is explicit: it only pays for sales made on Amazon. Your own website, eBay and any other marketplace are yours to declare.
- It does not stop the day you register. Enrolment ends when the reporting cycle turns, which for an annual category can be months away.
- It does not refund an overlap. Amazon’s terms say it will not reimburse contributions it has already paid, even where you and Amazon both paid for the same products. Budget for paying twice in the year you switch over.
What to do this week
- Check which countries and streams are actually open against you. Amazon raises an issue per stream and does not raise them all at once, so no notice is not proof you owe nothing.
- Look for numbers you already hold through a brand owner, importer or an old registration that were never entered in Seller Central. Five minutes, and sometimes it ends the problem.
- Do Germany yourself if it is on your list, and start the representative appointment alongside it.
- Start with the representative in Spain, because the registration cannot begin without it.
- Read the right screen. Account Health carries the deadline list. The EPR submission page carries whether a number is actually valid. On 12 August, in an account I watched, Account Health showed France red and past due while the submission page showed the same registration valid. When they disagree, the submission page is the one about your status.
Dates differ per country and per stream — there is no single EU-wide deadline. If this turns into a deactivation, what is running is a 30-day clock on your FBA stock. And what Pay on Behalf is, how you got into it and what it costs, is the companion article.
Sources
Primary sources only. Vendor pages are not cited as authority.