Many Amazon sellers assume that Amazon handles their EPR obligations through the Pay on Behalf program. That’s partially true — but with the arrival of the PPWR, this is fundamentally changing. From 12 August 2026, sellers are required to have their own valid EPR registration number. If you wait too long, you risk extra costs, less control, and potentially blocked listings.
What is Amazon Pay on Behalf?
Pay on Behalf is a service through which Amazon calculates, reports, and pays your packaging EPR contributions to the relevant organisations across Europe. You pay the environmental contribution yourself, plus a service fee that Amazon charges on top.
Sellers who do not provide a valid EPR registration number are automatically enrolled in this programme by Amazon. It is not a choice — it is a fallback.
What changes under the PPWR?
The PPWR (Packaging and Packaging Waste Regulation) is a European regulation that takes effect on 12 August 2026. It replaces the existing packaging directive and applies directly across all 27 EU member states, without national interpretation. For more on what the PPWR entails, read our earlier article: What is PPWR and what does it mean for e-commerce entrepreneurs?
One of the most important consequences for Amazon sellers: under the PPWR, marketplaces like Amazon are required to verify that their sellers hold valid EPR registrations in every EU country where they are active. Amazon is already anticipating this and has set 12 August 2026 as its internal enforcement date.
This means Pay on Behalf loses its role as a “compliance solution”. The programme will continue to exist as a financial stopgap, but it does not relieve you of the obligation to hold your own registration number.
What are the risks if you do nothing?
If you do not have a valid EPR registration number before the deadline, there are three concrete consequences:
Your listings may be blocked. Amazon has shown before that it does not wait for national enforcement. When the LUCID registration requirement was introduced in Germany in 2022, Amazon blocked listings of sellers who were not compliant in time — sometimes before official enforcement had even begun.
You pay more. Pay on Behalf is more expensive than registering yourself, because Amazon adds a service surcharge on top of the environmental contribution. You also have less control over the reporting data and the default values used.
You still bear the responsibility. Even if Amazon handles the payment on your behalf, the legal obligation remains with you as the seller. Pay on Behalf does not cover everything the PPWR requires, such as declarations of conformity and packaging requirements.
Which countries does this apply to?
The obligation applies to every EU country where you sell packaged products. Think of Germany, France, Italy, Spain, the Netherlands, Belgium, Poland, Sweden, and Ireland. If you use Amazon FBA with Pan-European distribution, your products may be active in more countries than you realise. Check in Seller Central which countries Amazon distributes your inventory to.
What should you do now?
The deadline of 12 August 2026 is six weeks away. Registrations across multiple EU countries take time. These are the steps you need to take now:
Check in Amazon Seller Central which EU countries your products are sold or distributed in. Apply for EPR registration numbers for packaging (and, where applicable, electronics or batteries) in each relevant country. Enter the registration numbers in Seller Central via Account Health, before the end of the current reporting cycle.
Do you have questions about which registrations apply to your situation? Our EPR specialist Juul is happy to help. You can find more information about EPR registrations on our EPR page.
