Given the constant changes to EPR regulations EPR France, sellers UIN the Amazon.fr marketplace who do not have UIN must choose between the default Amazon Pay on Behalf program and specialized solutions such as CompliancR. This decision directly impacts their compliance costs and their exposure to regulatory risks.

The key difference between these two approaches lies in how eco-contributions are handled: Amazon applies a uniform calculation to 100% of sales, while CompliancR reporting by distinguishing first-time sellers on the French market. For a seller who purchases 70% of their products from French suppliers, this distinction can result in annual savings of several thousand euros, depending on their sales volume.

Amazon Pay on Behalf: Seemingly Simple, Hidden Costs

The Amazon Pay on Behalf service is automatically applied to French sellers who have not provided their UIN Unique Identifiers) by the end of the reporting cycle. This default enrollment incurs a fee of €24.99 perEPR Scheme ,EPR 3% of the eco-contributions calculated on the seller’s total revenue.

Amazon selects eco-certification bodies based on its own criteria, without consulting the seller, and applies higher per-unit eco-contribution rates than the standard rates. The system automatically debits the seller’s account on a quarterly basis. This standardized approach completely disregards the seller’s French supply chain.

According toArticle L541-10 of the Environmental Code, extended producer responsibility EPR with the first entity to place the product on the French market. However, Amazon makes no distinction between imported products and those purchased from French suppliers that are already compliant.

The Critical Limitations of Amazon Pay on Behalf for the French Ecosystem

The fact that eco-contributions are calculated on 100% of sales is the main flaw in the Amazon system. A seller who purchases products from a French wholesaler ends up paying twice: first through the purchase price (which includes the supplier’s eco-contributions), and then a second time via Amazon Pay on Behalf.

Amazon systematically rejects FrenchUIN and does not incorporate any upstream traceability mechanism. This policy results in the systematic double reporting of the same products, in violation of the "polluter pays" principle established by the AGEC Act.

The lack of transparency regarding the rates applied poses a major risk in the event of an inspection by the DGCCRF or ADEME. The seller has no detailed documentation to support this, contrary to the requirements of the ADEME registry for EPR sectors.

CompliancR Smart Optimization of EPR Obligations

CompliancR offers a radically different approach based on the automatic collection of UIN and the intelligent exclusion of products that have already been reported. The system automatically identifies the first distributors on the French market using their SIRET number.

Unlike Amazon, CompliancR full visibility by product into calculated contributions, applied eco-surcharges, and an exportable history for audits. This transparency is crucial given that EPR non-compliance penalties can reach €15,000 per violation.

In addition, with CompliancR, multi-platform sellers regain control of their annual global declaration by simply providing CompliancR with CompliancR quantity of products placed on the market in the previous year and paying their eco-contributions at the most competitive rate during the first quarter of the following year.

Detailed Comparison: Actual Costs and Features

For a seller generating €100,000 in annual revenue on Amazon, with 70% of their products being French, Amazon charges approximately €500 in additional eco-contributions as a duplicate payment. CompliancR, by excluding these products, limits costs to only the 30% of products that are actually subject to reporting.

The difference in legal risk is even more significant. In the event of an audit, Amazon does not provide any detailed documentation to support the declarations made. CompliancR automatically CompliancR all the necessary supporting documents, in accordance with the requirements forobtaining UIN numbers.

Choose the solution that best fits your seller profile

The choice between Amazon Pay on Behalf and CompliancR mainly on your supply chain and sales volume. Sellers who import all their products and sell exclusively on Amazon may opt for Amazon’s integrated solution, despite its additional costs.

On the other hand, sellers who purchase primarily in France would be well advised to switch to CompliancR. The transition process requires obtaining UIN , but it yields substantial savings starting in the first year. The visible fee on B2B invoices makes this process easier.

EPR schemes (DIY, sports, toys) and the upcoming European PPWR regulation further complicate the regulatory landscape. CompliancR these changes through its partnerships with eco-organizations, while Amazon imposes its decisions without consultation.

Conforama’s recent penalty for non-compliance with AGEC regulations underscores the growing importance of EPR traceability. CompliancR this traceability.

FAQ

Does Amazon Pay on Behalf calculate eco-fees for all my products?

Yes, Amazon calculates eco-contributions based on 100% of your sales, including products purchased from French suppliers who have already reported and paid their EPR obligations. This double reporting artificially inflates your compliance costs.

CompliancR retrieve the UIN my French suppliers?

CompliancR automatically CompliancR your French suppliers using their SIRET numbers and excludes their products from your EPR reports. This approach adheres to the “first-to-market” principle and prevents duplicate payments of eco-contributions.

What types of receipts can I get with Amazon Pay on Behalf?

Amazon does not provide any detailed documentation supporting the reports submitted by Scheme your behalf. In the event of an inspection by the DGCCRF or ADEME, you will have no supporting documentation regarding the reported quantities or the rates applied.

How much does the transition to CompliancR actually cost CompliancR

CompliancR €180 plus 3% of the eco-contributions actually due for a declaration certified by us and submitted toProducer Representative Organisation.

For a retailer with 70% French products, the savings on eco-contributions more than offset these costs each year.

Does Amazon Pay on Behalf comply with French EPR regulations EPR

Technically, yes, Amazon reports your products to environmental agencies. However, calculating based on 100% of sales without distinguishing their origin results in duplicate reporting, which violates the “polluter pays” principle set forth in Article L541-10 of the Environmental Code.

Ready to optimize your EPR management EPR Get started for free on CompliancR and discover your potential savings today.