Three ways to handle packaging EPR as a marketplace seller — and what each actually costs
A marketplace seller has three ways to meet packaging EPR: do it yourself, hire a compliance provider, or let Amazon pay on your behalf. All three parties publish prices for their own route and none compares them. As of 1 January 2026 Amazon's pay-on-behalf fee is a flat €25 per EPR category per year (£20 in the UK) on top of the eco-contributions themselves — and the route only exists in France, Spain, Italy, Belgium and the UK. In Germany, the Netherlands, Poland and Sweden there is no pay-on-behalf: Amazon deactivates non-compliant listings instead.
The three routes, and what they are legally
The EU Packaging and Packaging Waste Regulation (PPWR, Regulation (EU) 2025/40), applying from 12 August 2026, keeps these routes legally distinct — which matters, because they are often sold as interchangeable:
| Route | Legal nature | Basis |
|---|---|---|
| Do it yourself | You are the producer; registration, scheme membership and reporting are your own obligations. Marketplaces must verify your registration number before letting you list (a verification duty, not an assumption of your obligation). | Art 45(1)–(2), 45(4), 45(6) |
| Compliance provider / authorised representative | A commercial service. Where you are established outside the country of sale, several national laws make an authorised representative mandatory — Germany and France both do, including for non-EU sellers — but the representative is someone you appoint and pay; the obligation stays yours. | Art 45(3); VerpackDG §5(2); C. envir. L541-10-9-1 |
| Marketplace pay-on-behalf | Voluntary and mandate-based: the producer's obligations “may, on the basis of written mandate, be met by the provider of the online platform”. The PPWR does not make platforms liable in your place; where a platform must step in by law (France, Spain, UK), that comes from national law, not the PPWR. | Art 45(4) last sentence |
One more piece of the same article explains the pressure sellers feel: fulfilment providers (including FBA warehouses) may not provide warehousing, packaging or dispatch services to an unregistered producer, and must suspend services if registration data proves false and is not corrected — PPWR Art 45(7)–(8). Non-compliance therefore does not stay a paperwork problem; it becomes a listing and fulfilment problem.
Germany and France, side by side
These are the two countries where marketplace demand is strongest, and they sit at opposite ends of the comparison: France has a published statutory-style tariff and offers Amazon pay-on-behalf; Germany has market-priced dual systems and no pay-on-behalf at all.
| Cost block | Do it yourself | Compliance provider | Amazon pay-on-behalf |
|---|---|---|---|
| Germany — packaging | |||
| Registration (LUCID) | €0 — the ZSVR charges nothing, and registration must be done personally; it cannot be delegated even to a provider | €0 — same register, you still register yourself; the provider handles the rest | — |
| Licence fees (dual system) | Market price, no published tariff — public configurators quote small volumes from roughly €39/year (Lizenzero entry price, checked 2026-09-01) | Included in or on top of the service fee, per provider — e.g. Eldris quotes Germany packaging at £240/year with scheme fees included | — |
| Authorised representative | Mandatory from 12 August 2026 if you have no branch in Germany — a commercial fee, quoted per provider | Usually the core of the service | — |
| Marketplace route | — | — | Not offered. Amazon has blocked unregistered sellers' listings in Germany since 2022 rather than paying on their behalf |
| France — household packaging | |||
| Registration (IDU) | Issued through the eco-organisme you join; no separate ADEME fee published | Handled by the mandataire / provider as part of membership | Handled by Amazon under the mandate |
| Eco-contribution | Published tariff — per-kg by material plus a per-unit sector component; under 10,000 consumer sales units a year the whole declaration collapses to a flat €110 (excl. VAT). Rates per material on our France page | Same tariff — a provider does not change what the eco-organisme charges | Same tariff — Amazon pays it and recharges you |
| Mandataire | Mandatory since 10 July 2026 for every producer established outside France, EU or not — commercial fee, quoted per provider | Usually the core of the service | Covered by the mandate while enrolled |
| Service fee | — | Per provider — see the directory for every public price we could verify | Flat €25 per EPR category per year from 1 January 2026 (until 31 December 2025: €24.99 + 3% of eco-contributions) |
Worked examples — the same packaging, three prices
Take a seller shipping a typical e-commerce mix — 70% paper and cardboard, 30% flexible PE film — into France. The weight component of the 2026 eco-contribution uses the published rates €0.2581/kg for paper-cardboard and €0.7701/kg for flexible PE, a blended €0.4117/kg for this mix. On top of the weight component the tariff adds a per-unit sector component (a matrix by business sector and unit count in the tariff guide), which depends on your unit count, not your kilograms — the figures below are therefore the weight component only, and the true eco-contribution is somewhat higher.
| Annual volume | Do it yourself | Compliance provider | Amazon pay-on-behalf |
|---|---|---|---|
| 100 kg (small seller, under 10,000 units) | €110 flat simplified declaration — it replaces the per-kg calculation entirely — plus your mandataire fee if established outside France | €110 flat + provider service fee (e.g. Lovat reporting from €190/year; registration quoted separately) | Eco-contribution as billed + €25 for the packaging category |
| 500 kg | ≈ €206 weight component (500 × €0.4117) + unit component + mandataire fee | ≈ €206 + unit component + provider service fee | ≈ €206 + unit component + €25 |
| 2 t | ≈ €823 weight component (2,000 × €0.4117) + unit component + mandataire fee | ≈ €823 + unit component + provider service fee | ≈ €823 + unit component + €25 |
The eco-contribution itself is identical on all three routes — no route makes the tariff cheaper. What varies is who files, and what you pay them for filing: a mandataire quote, a provider subscription, or Amazon's €25. Mandataire fees are quoted per provider and rarely published, which is why that column cannot be a single number.
The same exercise in Germany has no published per-kg column at all: dual system prices are market prices, so the honest comparison is your configurator quote (from roughly €39/year for small volumes at the entry end) against a provider's package price — and no Amazon column, because the route does not exist there. Our German registration guide links the public configurators.
Where Amazon pays on behalf — country by country
Amazon's own fee and policy pages largely sit behind a Seller Central login, so this table uses Amazon's public fee notice where one exists and cross-checks the rest across several compliance providers; each row says which. “Enforcement only” means Amazon verifies your EPR registration number and deactivates listings without one, but does not offer to pay on your behalf.
| Country | Pay-on-behalf | Fee (from 2026-01-01) | Categories | Source basis |
|---|---|---|---|---|
| France | Yes — auto-enrolment since end 2022 | €25 / category / year (2022–2025: €24.99 + 3% of eco-contributions, per Amazon's public fee notice) | Packaging, WEEE, batteries, textiles, furniture, toys, sports goods | Amazon public fee notice + provider cross-checks · high confidence |
| Spain | Yes — auto-enrolment | €25 / category / year (previously €24.99 + 3%, same notice as France) | Packaging (household and commercial), WEEE, batteries | Amazon public fee notice + provider cross-checks · high confidence |
| United Kingdom | Yes — for sellers not established in the UK | £20 / category / year (free during 2024; fee since April 2025) | Packaging under the UK data-reporting regulations; WEEE and batteries handled separately | Provider cross-checks (2+ sources) · high confidence |
| Italy | Yes — added for 2026 (enrolment deadlines Dec 2025 / Mar 2026) | €25 / category / year | WEEE, batteries, packaging (non-established sellers), polyethylene, oils, tyres | Amazon seller-forum announcement + provider cross-checks · fee high, category detail medium confidence |
| Belgium | Yes — added in the 2026 fee policy | €25 / category / year | Packaging confirmed; full category list not published in any source we could read — unverified | Provider cross-checks only · fee medium, categories low confidence |
| Germany | Enforcement only | — | Listing blocks for packaging since mid-2022; WEEE delistings 2023; battery offers deactivated August 2025 | Provider cross-checks (3 sources) · high confidence |
| Netherlands · Poland · Sweden | Enforcement only | — | Named alongside Germany as listing-deactivation countries; battery enforcement August 2025 | Provider cross-checks · high confidence |
| Austria | Enforcement only | — | Strict verification with listing blocks reported from mid-2026 | Single provider source · medium confidence |
| Other EU countries | Not published | — | From 12 August 2026 Amazon verifies packaging EPR numbers EU-wide under the PPWR; whether a country gets pay-on-behalf or deactivation has not been published — we do not extrapolate the €25 fee to countries not listed above | — |
How to choose
The honest split, by situation rather than by what anyone is selling:
- You sell small volumes into France (under 10,000 consumer units a year). The whole declaration is a €110 flat form; if you are established in France there is nothing left to outsource, and paying a provider more than the declaration costs makes little sense. If you are established outside France you still need a mandataire — compare that quote against Amazon's €25-per-category route before signing anything annual. See the French registration guide.
- You are established in Germany and sell only in Germany. You do not need a provider: LUCID registration is free and personal, a dual system contract is a normal commercial contract via a public configurator, and volume reports are a short form. See the step-by-step guide.
- You are established outside the EU and sell in Germany or France. A representative is mandatory in both countries (Germany from 12 August 2026, France since 10 July 2026) — the real question is not whether to pay someone but whether you buy a bare representative and do the rest yourself, or a full-service package. Get the representative quote first; it is the one block you cannot avoid.
- You sell in one of the five pay-on-behalf countries and your time is worth more than the paperwork. €25 per category per year plus the eco-contributions you would owe anyway is, at current prices, cheaper than most provider subscriptions — the trade-off is that it only covers Amazon sales: your own shop, eBay or Etsy sales in the same country still need one of the other two routes.
- You sell across many countries. This is where providers earn their fee: one contact for many registers. Compare multi-country packages (see the directory) against the sum of doing each country yourself, and check what a package actually includes — software access, reporting, and representation are priced very differently.
Provider directory — every public price we could verify
All providers we have researched are listed, whether or not they publish prices. We have no commercial relationship with any provider, marketplace or scheme named on this page and take no referral fees. Prices as displayed on 2026-09-01, excluding VAT unless the provider states otherwise.
| Provider | Offer | Public price |
|---|---|---|
| ecosistant | EPR self-service software, 30 countries (packaging); per-country plans; extra waste streams as add-ons | From €399 first year (all-Europe package; renewal from €299); country plan from €24.90/country/year; Germany plan €0 |
| Eldris | Per-country EPR service, scheme fees included | Germany packaging (LUCID) £240/year; WEEE first country £790/year; batteries £470/country; additional categories £335/category/country |
| Lovat | EPR reporting subscription (registration quoted separately) | €190/year (up to 1 t, 4 jurisdictions) · €220/year (up to 4 t, 8 jurisdictions) · €620/year (up to 100 t, 12 jurisdictions) |
| EcoComply | EPR registration and reporting; EU/UK authorised representation priced separately (EU AR €1,500/year, UK AR €900/year) | EPR service quote-only (a ~€1,000/country/year figure we recorded earlier in 2026 is no longer displayed) |
| Lizenzero (Interzero) | German dual-system licence shop (this is the scheme's own shop, not an agency); EU-wide licensing via a separate portal | From €39/year, exact price via public configurator |
| Deutsche Recycling | Germany/EU EPR full service | Quote-only — no public price |
| AVASK | EPR registration and authorised representation; advertises free transfer from Amazon EPR services | Quote-only — no public price on its own pages |
| Repax | EPR compliance software | Quote-only — no public per-country price we could verify |
A price in this table is what the provider displays publicly, not a like-for-like unit: some include scheme fees (Eldris), some are software only (ecosistant), some exclude registration (Lovat). Read what each includes before comparing.
Sources
Every link opened logged out on 2026-09-01. Amazon's Seller Central policy pages require a login and are deliberately not cited; where no official public page exists a figure rests on cross-checked provider sources and the table above says so.
- PPWR — Regulation (EU) 2025/40, full text (Art 45: platforms, mandates, fulfilment providers) ↗ eur-lex.europa.eu
- Amazon — public fee notice for EPR pay-on-behalf in France and Spain (€24.99 + 3%, pre-2026 structure) ↗ go.amazonsellerservices.com
- Amazon — seller education page on extended producer responsibility ↗ sell.amazon.de
- Adelphe (Citeo group) — 2026 household packaging tariff guide (PDF) ↗ adelphe.fr
- Citeo — the simplified declaration for small producers (mechanism) ↗ citeo.com
- La Micro by Flo — packaging EPR for micro-businesses (cross-check for the €110 flat simplified declaration) ↗ lamicrobyflo.fr
- AVASK — Amazon EPR pay-on-behalf in the UK, Spain and France ↗ avask.com
- AVASK — EPR compliance guide 2026 (enforcement timeline by country) ↗ avask.com
- ChannelX — Amazon simplifies EPR pay-on-behalf fees from 1 January 2026 ↗ channelx.world
- ChannelX — Amazon combines EPR pay-on-behalf policy for UK, Spain and France ↗ channelx.world
- Venture Forge — EPR fees are changing in 2026 ↗ venture-forge.com
- ecosistant — EPR registration numbers for Amazon sellers (enforcement cross-check) ↗ ecosistant.eu
- Eldris — Amazon EPR requirements (enforcement cross-check) ↗ epr.eldris.ai
- ecosistant — EPR self-service pricing ↗ ecosistant.eu
- Eldris — per-country EPR pricing ↗ epr.eldris.ai
- Lovat — EPR reporting subscription pricing ↗ vatcompliance.co
- EcoComply — pricing page ↗ ecocomply.ai
- Lizenzero (Interzero) — German dual-system licence shop ↗ lizenzero.de
- Deutsche Recycling — EPR full service (quote-only) ↗ deutsche-recycling.com
- AVASK — EPR services (quote-only) ↗ avask.com
How to cite
EPR Rates (2026). Three routes to packaging EPR compliance, compared. https://eprrates.com/compare/epr-paths/ · Retrieved 2026-09-04. CC BY 4.0.
@misc{eprratescompareeprpaths,
title = {Three routes to packaging EPR compliance, compared},
author = {{EPR Rates}},
year = {2026},
url = {https://eprrates.com/compare/epr-paths/},
note = {Retrieved 2026-09-04. CC BY 4.0}
}
Rate figures are extracted from the official publications listed under Sources; those source documents remain under their publishers' terms.