With the constant changes in EPR regulation in France, Amazon.fr marketplace sellers without an EPR unique identification number (UIN) must choose between the default Amazon Pay on Behalf programme and specialised solutions such as CompliancR. This decision directly affects their compliance costs and their exposure to regulatory risk.

The key difference between these two approaches lies in how eco-contributions are managed: Amazon applies a uniform calculation on 100% of sales, while CompliancR optimises declarations by distinguishing the first producers to place products on the French market. For a seller buying 70% of its products from French suppliers, this distinction can generate several thousand euros in annual savings depending on sales volumes.

Amazon Pay on Behalf: apparent simplicity, hidden costs

The Amazon Pay on Behalf service automatically applies to French sellers who have not provided their UIN before the end of the declaration cycle. This default enrolment charges €24.99 per EPR scheme plus 3% of eco-contributions calculated on the seller's entire turnover.

Amazon selects producer responsibility organisations (PROs) according to its own criteria, without consulting the seller, and applies higher unit eco-contribution rates than the standard rates. The system automatically debits the seller's account quarterly. This standardised approach completely ignores the seller's French supply chain.

Under Article L541-10 of the French Environmental Code, EPR responsibility falls to the first producer to place a product on the French market. Yet Amazon makes no distinction between imported products and those bought from French suppliers already in compliance.

The critical limits of Amazon Pay on Behalf for the French ecosystem

Calculating eco-contributions on 100% of sales is the main flaw of Amazon's system. A seller buying products from a French wholesaler thus pays twice: once through the purchase price (including the supplier's eco-contributions), then again through Amazon Pay on Behalf.

Amazon systematically refuses French supplier UINs and includes no upstream traceability mechanism. This policy creates a systematic double declaration for the same products, in breach of the "polluter pays" principle set out in the AGEC law.

The lack of visibility on the fee scales applied poses a major risk in the event of a DGCCRF or ADEME (the French environment agency) inspection. The seller has no detailed supporting documents, contrary to the requirements of the ADEME EPR scheme register.

CompliancR: smart optimisation of EPR obligations

CompliancR offers a fundamentally different approach based on automatically acquiring supplier UINs and intelligently excluding already declared products. The system automatically identifies the first producers to place products on the French market via their SIRET number.

Unlike Amazon, CompliancR provides full product-by-product visibility on the contributions calculated, the eco-modulations applied, and an exportable history for audits. This transparency proves crucial given the EPR non-compliance sanctions, which can reach €15,000 per breach.

In addition, with CompliancR, multi-platform sellers regain control of their overall annual declaration by simply telling CompliancR the quantity of products placed on the market the previous year, and pay their eco-contributions at the fairest price during the first quarter of the following year.

Detailed comparison: actual costs and features

For a seller with €100,000 in annual turnover on Amazon and 70% French products, Amazon charges around €500 in additional eco-contributions as duplicate payment. CompliancR, by excluding these products, limits costs to just the 30% of products actually subject to declaration.

The difference in legal risk is even more significant. In the event of an inspection, Amazon provides no detailed documents to justify the declarations made. CompliancR automatically generates all the necessary supporting documents, in line with the requirements for obtaining UINs.

Choosing the right solution for your seller profile

The choice between Amazon Pay on Behalf and CompliancR mainly depends on your supply chain and your business volume. Sellers who import all their products and sell only on Amazon can choose Amazon's integrated solution, despite its extra costs.

Sellers who buy mostly in France, on the other hand, have every reason to switch to CompliancR. The transition process requires acquiring supplier UINs, but generates substantial savings from the first year. The visible fee on B2B invoices makes this process easier.

New recent EPR schemes (DIY, sport, toys) and the upcoming European PPWR regulation are making the regulatory landscape even more complex. CompliancR anticipates these changes through its partnerships with PROs, while Amazon imposes its choices without consultation.

The recent sanction against Conforama for AGEC non-compliance illustrates the growing importance of EPR traceability. CompliancR provides this traceability.

FAQ

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

Yes, Amazon calculates eco-contributions on 100% of your sales, including products bought from French suppliers who have already declared and paid their EPR obligations. This double declaration artificially increases your compliance costs.

Can CompliancR retrieve my French suppliers' UINs?

CompliancR automatically identifies your French suppliers via their SIRET number and excludes their products from your EPR declarations. This approach respects the principle of the first producer to place a product on the market and avoids duplicate eco-contribution payments.

What supporting documents can I obtain with Amazon Pay on Behalf?

Amazon provides no detailed supporting documents for the declarations made on your behalf by scheme. In the event of a DGCCRF or ADEME inspection, you have no evidence of the quantities declared or the fee scales applied.

How much does switching to CompliancR actually cost?

CompliancR charges €180 plus 3% of the eco-contributions actually due, for a declaration certified by us and submitted to the PRO.

For a seller with 70% French products, eco-contribution savings largely offset these fees each year.

Does Amazon Pay on Behalf comply with French EPR regulation?

Technically, yes: Amazon declares your products to the PROs. However, calculating on 100% of sales without distinguishing origin creates double declarations that breach the polluter pays principle set out in Article L541-10 of the French Environmental Code.

Ready to optimise your EPR management? Start for free on CompliancR and discover your potential savings today.