Nineteen product categories fall under EPR in France. Here is the list, how to obtain your unique identifiers, and where to enter them in Seller Central.
Extended producer responsibility makes the producer accountable for a product's whole life cycle, from design through to the collection and recycling of the waste it becomes. It started in Sweden and Germany in the 1990s and has become a pillar of EU waste policy. Each member state implements it differently, and France goes furthest: nineteen product categories sold on Amazon.fr were in scope in 2023, and the list keeps growing.
Are you a “producer”?
The producer is whoever first places an in-scope product on a national market. That means you qualify in three situations: you manufacture a product and sell it on your domestic market; you import a product into the country where you are established; or you sell a product into a country where you are not physically established.
The third case catches most sellers out. It covers the majority of cross-border accounts, including sellers who resell wholesale stock or dropship. If your supplier is already registered for the category in question, their identifier can serve as proof — provided they are willing to hand it over, which is far from guaranteed.
The categories in scope in France
Amazon listed nineteen EPR product categories on its French marketplace:
- Electrical and electronic equipment (EEE)
- Batteries and accumulators
- Packaged products and graphic paper
- Commercial packaging
- Furniture and furnishings
- Clothing textiles, household linen and footwear
- Single-use sanitary textiles
- Tyres
- Toys
- Sports and leisure goods
- DIY and garden goods
- Building products and construction materials
- Chemical products
- Lubricating and industrial oils, mineral or synthetic
- Sharps-type medical devices
- Tobacco and accessories
- Non-biodegradable synthetic chewing gum
- Fishing gear containing plastic
Packaging and graphic paper are declared as a single category: one identifier covers both. That is the only shortcut in the system — everywhere else, one category means one registration.
Almost every seller is caught by at least one category, if only the box the parcel ships in. A seller of headphones stacks up three: packaging, EEE and batteries.
Obtaining and then declaring your identifiers
- Join a producer responsibility organisation for each category you sell.
- Obtain the unique identifier issued once you are a member.
- Declare the volumes placed on the market and pay the corresponding eco-contributions.
- Enter each identifier on the EPR compliance information page in Seller Central.
Step four is what unblocks your listings, but step three is what keeps you compliant over time. Plenty of the files we take over have valid identifiers and no tonnage declaration for two years.
The German case
Two categories are policed in Germany. For packaging, proof takes the form of a thirteen-digit registration number issued by the LUCID register, which you submit through Amazon's compliance portal. For electrical and electronic equipment, the ElektroG law requires registration with Stiftung EAR, the competent authority, plus an obligation to have your products collected at end of life.
Three duties, not one
EPR is not only about paying. As a producer you generally carry three separate obligations:
- Financial: contributions paid to the scheme based on the volumes you sell, plus, in some countries, a chargeable registration with the authorities.
- Take-back: in some countries, an obligation to offer customers collection of their old product on request.
- Information: telling buyers how to recycle, carrying certain wording on invoices, filing reports with the authorities, and providing proof of compliance to Amazon.
What you are risking
Amazon is legally exposed if its sellers are non-compliant, which explains how firmly it enforces. Without a valid identifier the platform can deactivate the affected listings, or comply on your behalf: in that case the eco-fee is taken out of your sales at a rate you did not negotiate. On the regulatory side, schemes ask for past declarations and national authorities can impose penalties.
What we recommend
Start by establishing your real categories, product by product, before registering anything. Registering in a category that does not apply costs an annual membership for nothing; a forgotten category costs you a suppressed listing at the worst possible moment. That mapping is exactly what the first call is for.