France's EPR Rules on Amazon: UINs, Eco-Contributions and Pay on Behalf

In brief: in France, sellers of products covered by EPR (extended producer responsibility) must join a producer responsibility organisation (PRO), get a unique identification number (UIN) for each category, declare their sales and pay eco-contributions. Amazon asked sellers to submit valid UINs by 31 December 2022. Anyone who didn't was automatically enrolled in Pay on Behalf: Amazon pays and reports the eco-contributions for your Amazon offers and recovers the cost from your seller account. For 2022 sales, Amazon charged no service fee on top. From 2024, rules for resellers tightened and a service fee applied under Amazon's French EPR policy.

Two ways to comply with Amazon France EPR

Route	What you do	What it costs
Direct	Register with each relevant PRO, submit UINs to Amazon, declare and pay yourself	PRO eco-contributions, billed by the PRO
Pay on Behalf	Nothing — Amazon enrols you if no valid UIN is on file	Eco-contributions deducted by Amazon, plus a service fee (none for 2022 sales)

The 2024 changes

• Resellers need the producer's UIN. If you aren't the producer, you must get the UIN from whoever produces the goods upstream, submit it and tick a box confirming you aren't the producer. The generic distributor number FR000000_00DIST stopped being valid on 5 March 2024.
• Paper merged into Packaging from 1 January 2024. A Paper-only UIN became invalid; the PRO was due to issue a Packaging UIN, to be submitted by 31 December 2024.
• New category for food packaging (household and catering) from 1 January 2024, with UINs due by 31 December 2024.
• December 2022 had already added six categories: toys, sports and leisure items, garden and DIY goods, building materials, tobacco products, and industrial or lubricating oils.

A worked example

A UK seller of toys and garden tools has no French UINs. Amazon enrols them in Pay on Behalf, pays the eco-contributions on their Amazon.fr sales and deducts, say, €900 for the year plus the service fee. Registering directly would mean paying the PROs instead — worth comparing once volumes grow.

What it means for your bookkeeping

• Deductions need a home. Pay on Behalf charges come out of your Amazon account; post them to a compliance or EPR cost account rather than lumping them into selling fees.

• Eco-contributions are a cost of French sales. Tracking them by marketplace shows the real margin in France.

• VAT: take the treatment of eco-contributions and service fees from Amazon's invoice.

• Check your categories. A missing or invalidated UIN silently moves you into Pay on Behalf; review the compliance portal whenever categories change.

• Where it shows up. Pay on Behalf deductions reduce the payout — see reconciling an Amazon settlement and why a payout may not match Xero.

How TrueBooks helps

TrueBooks posts every line of your Amazon settlements to Xero, so deductions show up as their own lines instead of disappearing into the payout. It doesn't register you for EPR or pay eco-contributions. See the Amazon Xero integration.