12 August 2026 is live law
The PPWR applies from 12 August 2026. Packaging EPR remains administered through Member-State producer registers and national systems rather than one EU-wide registration number.
Legal + Amazon policy review17 September 2026
AMAZON EU · PACKAGING EPR · PPWR 2026
Amazon needs the right country EPR record. It does not replace the record.
Since the PPWR became applicable on 12 August 2026, Amazon’s EU packaging-EPR workflow is increasingly country-specific. Separate three questions: who is the Producer, where is the consumer located, and what evidence does Seller Central currently require?
Direct answer
There is no single Amazon or EU-wide packaging EPR number. If you are the Producer, you generally need the applicable national registration for each Member State where you first make packaging or packaged products available. Amazon then verifies the relevant country evidence. FBA does not remove responsibility for product packaging, and Pay on Behalf does not remove the ERN requirement.
Country-specific ERNFBA ≠ exemptionPay on Behalf ≠ registrationSeller Central evidence
What changed in 2026
Amazon’s packaging-EPR workflow now sits on top of the PPWR country-register architecture.
The legal obligation and the Amazon interface are separate layers. A Seller Central field can lag behind national law, and an Amazon Approved status does not by itself prove that reporting, financing or representation duties are complete.
Amazon asks for ERNs country by country
Amazon’s current EU help page directs sellers to submit packaging EPR registration numbers through Account Health → Regulatory Compliance → Submit compliance information for each relevant country.
Consumer destination matters
Amazon states that country-specific registration can also matter for cross-border sales into non-store countries and that Pan-EU availability can create a registration need where the consumer is located.
Amazon is a verification layer
PPWR Article 45 requires relevant online platforms to obtain registration information and producer self-certification and to make best efforts to assess completeness and reliability. The underlying EPR duties remain separate.
Seller Central
How Amazon currently tells sellers to submit a packaging ERN
Use the live Account Health workflow, but fix the national source record first. Amazon warns that a newly issued number can be rejected if it has not yet appeared in the public register.
- 01
Select the relevant country
Choose the country from the selector near the Seller Central logo. Amazon treats the submission as country-specific.
- 02
Open Account Health
Go to Regulatory Compliance and then Submit compliance information under Manage your compliance.
- 03
Submit the correct ERN
Use the identifier for the correct Producer and Member State. Use supplier evidence only where the legal Producer analysis and Amazon country flow support non-producer status.
- 04
Wait for register visibility where relevant
Amazon says a newly issued number may take up to 72 hours to appear in a public register; premature submission can be marked invalid.
- 05
Check Approved or Rejected
Where public-registry validation is available, Amazon says a decision can follow within five working days. Common rejection reasons include number not found, expired number and producer-name mismatch.
- 06
Continue after approval
Keep national registration, PRO/system participation, reporting, payments, representation and evidence current. Amazon approval is not the end of the EPR cycle.
Amazon country reference map
Amazon currently points sellers to nine EU packaging systems — with Austria on a separate Amazon EPR route.
This is an Amazon operating map, not a substitute for national legal analysis. Register, PRO, reporting, representation and packaging scope can still differ by country.
| Country | Amazon reference | Seller action | Critical note |
|---|---|---|---|
| DEGermany | ZSVR / LUCID | Register the correct Producer, keep LUCID current and submit German packaging registration evidence to Amazon. | Since 12 August 2026, ZSVR states that a foreign company without a German branch selling packaged goods directly to end users in Germany must appoint a German EPR authorised representative. LUCID registration itself remains the producer’s personal duty. |
| FRFrance | French REP / approved PRO route | Obtain the applicable packaging ERN/identifier and submit it in Seller Central. Eligible sellers can use Pay on Behalf for supported reporting and eco-contribution activity. | Pay on Behalf does not eliminate the ERN requirement in Amazon’s current PPWR packaging workflow. |
| ESSpain | MITECO producer register | Complete the applicable Spanish producer-registration route and submit the country identifier to Amazon. | Pay on Behalf may support eligible reporting/payment activity, but Producer status, registration and representation remain separate questions. |
| BEBelgium | Fost Plus / Valipac | Distinguish household from professional packaging, establish the correct route and submit the relevant evidence to Amazon. | Do not collapse Fost Plus and Valipac into a generic Belgium number; the packaging stream matters. |
| ITItaly | CONAI / evolving national-register route | Follow the current Italian Producer/CONAI route and the live Seller Central compliance task. | Amazon’s current help page states that the new national packaging register is not yet available and that sellers registered with CONAI report on their own rather than through packaging Pay on Behalf. |
| NLNetherlands | Verpact | Resolve Dutch Producer status and registration where Dutch consumers are in scope, then submit the relevant country evidence when requested. | Amazon uses the Netherlands as an example of Pan-EU destination-country registration. Separately, Pan-EU FBA has required an active Netherlands offer since 3 September 2026. |
| IEIreland | Repak / applicable Irish route | Establish the applicable Irish registration and scheme relationship and provide the requested Amazon evidence. | The Amazon field is a verification endpoint; Irish reporting and financing remain separate. |
| PLPoland | BDO | Determine the correct BDO packaging registration and maintain the underlying Polish compliance record before submitting evidence to Amazon. | BDO registration, ongoing EPR fulfilment and Amazon verification are related but separate layers. |
| SESweden | Naturvårdsverket + applicable PRO | Complete the applicable Swedish Producer registration/system route and submit the requested registration evidence in Seller Central. | Keep authority registration and PRO relationship distinguishable in the evidence file. |
| ATAustria | VKS packaging number / separate Amazon route | Submit a valid Austrian packaging EPR number or use Amazon’s separate EPR-registration option where eligible. | Amazon states that registration and authorised-representative services in this route are provided by ERP Austria GmbH under that provider’s terms; Amazon itself does not provide EPR advisory services. |
Producer before ERN
Do not decide which number to upload until you know whether you are the Producer.
The PPWR Producer test follows the actual first-making-available chain in the destination Member State. Amazon offers a non-producer workflow in several countries, but the checkbox does not change the legal role.
If you are the Producer
- Producer registration in the relevant Member State
- PRO/system participation where applicable
- EPR authorised representative where required
- Packaging data, reporting and eco-contribution payments
- Amazon ERN submission tied to the same legal entity
If you are genuinely not the Producer
- Identify the upstream Producer for the destination transaction
- Confirm its registration covers the packaging and Member State
- Obtain the correct ERN and supporting evidence
- Use Amazon’s non-producer option only where the country flow provides it
- Retain the supplier statement in the marketplace evidence file
FBA · FBM · Pan-EU
Fulfilment changes the packaging flow. It does not create a blanket EPR exemption.
Separate product packaging from shipment packaging added later, then apply Producer status and destination-country rules.
| Model | Seller analysis | Packaging point | Amazon verification |
|---|---|---|---|
| FBA | Producer status, destination countries, product-packaging quantities, national registrations and AR where applicable. | Amazon says the seller remains responsible for product packaging that reaches the fulfilment centre; Amazon handles EPR for transport packaging Amazon adds when fulfilling FBA orders. | Yes. Amazon says packaging EPR verification applies to FBA sellers. |
| FBM | Producer status plus packaging introduced by the seller or fulfilment chain. | Seller-filled shipment packaging can form part of the seller’s reportable packaging position. | Yes. Amazon says the requirements apply whether orders are merchant-fulfilled or Amazon-fulfilled. |
| Pan-European FBA | Consumer destinations, not only stock-storage countries or storefronts. | Inventory and VAT geography are not substitutes for the packaging-EPR Producer test. | Amazon says a destination such as the Netherlands can require its own ERN. Since 3 September 2026 Pan-EU also has a separate active-offer requirement for the Netherlands; Belgium follows on 26 February 2027. |
| Cross-border non-store sale | Destination Member State and actual Producer chain. | A customer in an EU country without a dedicated Amazon store can still create a packaging-EPR destination issue. | Amazon is activating additional compliance-portal locations; absence of a field is not proof that the legal duty does not exist. |
Amazon EPR Pay on Behalf
Useful administration where offered. Not a substitute for registration.
Amazon’s current PPWR help page says sellers must obtain and provide the EPR registration number even when they use Pay on Behalf. Article 45(2) can allow a platform to fulfil certain financial obligations under written mandate, but that does not automatically transfer the rest of the Producer’s duties.
✓
- Calculate eligible Amazon sales for the supported EPR stream
- Submit supported reports to selected PROs or environmental organisations
- Pay eco-contributions on the seller’s behalf
- Debit regulatory amounts and applicable service fees
- Reduce manual administration for the Amazon sales stream it covers
—
- Remove the ERN requirement
- Determine Producer status for every supply chain
- Cover non-Amazon sales automatically
- Provide a universal EU EPR authorised representative
- Prove every national report, payment and renewal is complete
- Replace PPWR technical packaging conformity work
Germany after 12 August 2026
Germany now has a separate representation issue for foreign direct sellers — and LUCID remains personal.
- A company based abroad, without a German branch, selling packaged products directly to German end users must appoint an authorised representative.
- The representative assumes German EPR obligations except the producer’s own LUCID registration.
- The representative must be entered in LUCID; ZSVR says registration cannot be completed without the required representative information.
- Existing foreign registrations should be reviewed for the post-12-August-2026 regime.
- Do not confuse Amazon ERN approval with completion of LUCID, system participation, reporting and representation.
Amazon rejection clinic
Fix the national record before repeatedly resubmitting the same ERN.
| Amazon status | Likely cause | Check | Do not |
|---|---|---|---|
| Number not found | Registry publication delay, wrong identifier, wrong country or non-public record. | Confirm the identifier in the competent source; if newly issued, allow register propagation. | Do not change formatting randomly or use another entity’s number. |
| Producer name mismatch | Seller Central legal entity and national register entity differ. | Compare exact legal name and registered Producer identity. | Do not swap the legal entity for a trading name just to pass the screen. |
| Expired / invalid | Underlying registration is no longer valid. | Renew or correct the national record first. | Do not rely on an old Amazon approval screenshot. |
| No country field visible | Amazon portal activation is not yet available for that account/location. | Keep national compliance current and monitor Regulatory Compliance. | Do not infer Amazon does not ask = the law does not apply. |
| Pay on Behalf active but ERN warning remains | The PPWR workflow still requires the registration number. | Obtain the correct ERN and submit it to the country task. | Do not treat Pay on Behalf as registration. |
Marketplace evidence file
Build evidence that survives both Amazon review and a national audit.
Producer identity
Legal entity, establishment, tax identifiers and evidence supporting the Producer conclusion.
National registration
Current ERN/registration evidence, register extract and effective dates.
PRO / system evidence
Membership or system-participation evidence where required.
EPR AR mandate
Written mandate and representative evidence where applicable.
Packaging master
SKU → packaging component → material → unit weight → effective-date data used for reports.
Amazon submission record
Country, submitted ERN, status, date, rejection history and correspondence.
Reporting + payments
Declarations, regulatory invoices, payment evidence and reconciliations.
Supplier evidence
Where claiming non-producer status, retain the upstream Producer statement and registration evidence.
Beyond the ERN screen
Packaging EPR is only one part of PPWR compliance.
EPR record
Producer registration, PRO/system relationship, reporting, financing and evidence under the Member-State EPR architecture.
Packaging technical file
Applicable PPWR design, composition, minimisation, information, technical-documentation and conformity requirements are a separate layer.
EU Declaration of Conformity
Where applicable, the PPWR EU Declaration of Conformity belongs to the manufacturer technical-conformity chain. It is not the same as an Amazon EPR submission.
Multi-channel ledger
National EPR reporting can extend beyond Amazon sales. Reconcile total reportable packaging across channels.
Legislative watch · Article 45(3)
The proposed suspension of the cross-border EPR-authorised-representative rule is still not enacted law.
Regulation (EU) 2025/40 currently contains Article 45(3). For certain cross-border Producer profiles it requires a written EPR-authorised-representative mandate in each relevant Member State other than the Producer’s state of establishment; for third-country Producers, Member States may impose a national appointment requirement.
COM(2025) 982 proposes suspending application of Article 45(3) until 1 January 2035. EUR-Lex still lists procedure 2025/0395(COD) as ongoing on this review date.
For Amazon sellers, do not use a pending EU proposal as a reason to skip a representation requirement that currently applies in the destination country.
Open the EUR-Lex legislative procedure ↗Do the work
Move from Amazon warning to a country-ready compliance file.
Amazon EPR ChecklistRun the practical Amazon sequence.→Producer Status CheckerDetermine who is the packaging Producer for the destination transaction.→EU Country Obligation CheckerMap which Member States require an operating file.→EPR AR CheckerCheck representation separately from Amazon’s ERN screen.→Marketplace Evidence PackBuild the file supporting Seller Central submissions.→Packaging Data Readiness ChecklistPrepare weights, materials and SKU packaging data.→
FAQ
Amazon EPR & PPWR questions sellers actually need answered
Do I need one Amazon EPR number for the whole EU?
No. Amazon’s current PPWR packaging guidance is country-specific. There is no single EU-wide Amazon ERN.
Does FBA mean Amazon is responsible for all packaging EPR?
No. Amazon says FBA sellers remain responsible for product packaging that reaches the fulfilment centre; Amazon handles EPR for transport packaging Amazon itself adds to fulfil FBA orders.
Does Pay on Behalf remove the ERN requirement?
No. Amazon’s current EU packaging help page says sellers must obtain and provide the EPR registration number even if they use Pay on Behalf.
Can I submit my supplier’s EPR number?
Only where you are genuinely not the Producer and the Amazon country workflow supports a non-producer submission. Amazon currently lists Spain, France, Netherlands, Belgium, Sweden, Poland, Italy and Ireland for that route.
What happens if Amazon rejects my ERN?
Amazon lists number not found, expired number and producer-name mismatch among common reasons. Correct the national source record or allow register propagation before resubmitting.
Does Amazon Approved prove full EPR compliance?
No. National registration, reporting, eco-contribution payments, representation, renewals and recordkeeping remain separate.
Do Pan-EU sellers need to look at non-store countries?
Yes. Amazon says registration follows where consumers are located and that cross-border sales into non-store countries can require a distinct country registration.
Is Article 45(3) postponed to 2035?
Not as of this review. COM(2025) 982 proposes a suspension, but EUR-Lex still shows procedure 2025/0395(COD) as ongoing.
Is the UK covered by the PPWR Amazon workflow?
No. Amazon expressly notes that the United Kingdom is not subject to Regulation (EU) 2025/40.
Primary sources
What this Amazon guide is based on
Regulatory claims use EUR-Lex, Commission and competent-authority material; Amazon-operational claims use Amazon’s own seller documentation.
Amazon Seller Central — New EU Packaging Waste RegulationAmazon packaging EPR workflow, country references, ERN submission, FBA/FBM and Pan-EU FAQs.↗Regulation (EU) 2025/40Binding PPWR text including Articles 44–45.↗European Commission PPWR Guidance C(2026) 3702Commission interpretation of Producer status, online sales and establishment.↗ZSVR — Appointing an authorised representativeGermany’s post-12-August-2026 representation and LUCID guidance.↗Amazon France — Environmental Compliance / Pay on BehalfSupported reporting and eco-contribution administration.↗Amazon — Austria EPR policy routeAustrian VKS/GLN requirements and separate registration option through ERP Austria GmbH.↗Amazon — Pan-EU Netherlands/Belgium updateNetherlands offer requirement from 3 September 2026 and Belgium from 26 February 2027.↗EUR-Lex 2025/0395(COD)Ongoing proposal concerning suspension of PPWR Article 45(3).↗
Amazon EU operating file