Amazon streamlines EPR Pay on Behalf policy across UK, Spain and France 

Amazon has recently confirmed, in an official Seller Central announcement, that effective 27 August 2025, its Extended Producer Responsibility (EPR) Pay‑on‑Behalf service policy for the UK, Spain and France will be unified into a single cross‑market policy.  

This change alters how eco‑contributions and service fees are applied to sellers across those jurisdictions. Let’s see what’s changed, why it matters, and what actions you can take to stay compliant. 

What’s changed with the policy?

Until now, Amazon operated three separate EPR Pay on Behalf policies: 

• In France and Spain, non‑compliant sellers were automatically enrolled and charged a €24.99 annual service fee plus 3% of eco‑contributions, per category. 

• In the UK, Pay on Behalf covered non‑UK established sellers under the Packaging Waste (Data Reporting) Regulations 2023, with no service fee in 2024 but from 1 April 2025 adding an annual £20 fee per EPR category alongside eco‑contribution charges. 

From 27 August 2025, these will be replaced by a single unified policy covering all three countries. This includes: 

• One consolidated policy document rather than three separate national rules. 

• EPR fee reserves that allow Amazon to set aside funds to meet legal payment obligations. 

• Flexible billing that can be triggered outside regular cycles if recalculations are needed. 

• Data sharing with environmental authorities and Producer Responsibility Organisations (PROs) as required under law. 

What’s staying the same?

Amazon will continue to: 

• Automatically enrol sellers without valid UINs in each relevant country and category if they haven’t submitted a valid EPR number before the end of the applicable reporting cycle. 

• Pay eco‑contributions to PROs on behalf of sellers, then recover these costs. 

• Require ongoing product, packaging and sales reporting. 

3 reasons why this change to Amazon EPR policy matters for sellers 

This consolidation matters for three key reasons: 

1. Simplification: One unified policy will help sellers forecast costs and understand obligations across multiple EU and UK marketplaces. 

2. Financial impact: Reserve capabilities and flexible billing mean sellers may see charges applied at different times – and should monitor their accounts closely. 

3. Regulatory focus: The inclusion of data‑sharing provisions reinforces the importance of accurate product and sales data. 

Learn more about whether Pay on Behalf is right for your business. 

At a glance: the Pay on Behalf policy before and after 27 August 2025

✅ Immediate action points for sellers

If you sell into or from the UK, Spain or France, now’s the time to: 

• Check your EPR compliance status and confirm whether your UINs are valid in each market. 

• Estimate your annual and per‑category fees under the new policy. 

• Set internal alerts for unexpected deductions or new reserve requirements. 

• Brief your finance and compliance teams to adjust forecasting models. 

How AVASK can support your EPR compliance 

AVASK helps sellers do more than just react to Amazon’s compliance requirements. Our environmental and EPR compliance services are designed to give businesses the confidence to sell across borders while staying ahead of regulatory changes. 

We provide: 

• EPR registration and UIN acquisition in the UK, France, Spain and across the EU. 

• Eco‑contribution calculation and reporting tailored to your product portfolio. 

• Strategic compliance planning to minimise costs and avoid last‑minute enrolment in Pay‑on‑Behalf schemes. 

• Packaging, WEEE and batteries compliance services to meet all relevant environmental obligations. 

For Amazon sellers, working with AVASK means you can: 

• Avoid unnecessary Pay‑on‑Behalf fees by securing your own valid registrations. 

• Control your compliance strategy rather than having it dictated by marketplace defaults. 

• Gain clarity on your cost exposure in multiple jurisdictions. 

Understand more about EPR and EU-wide packaging rules.

Whether you are a UK SME branching into France or Spain, or an international brand selling into the UK and EU, our team of specialists ensures your compliance is proactive, accurate and aligned with your growth plans. 

♻️ Quick guide: EPR rules and Amazon fees across the UK, France and Spain

Looking ahead 

Amazon’s move to a unified EPR Pay‑on‑Behalf policy is a positive step towards simplification, but it is still a compliance‑driven system where the marketplace – not the seller – sets the terms.  

Businesses that take ownership of their EPR obligations will retain greater control over costs, avoid unexpected charges and present a stronger compliance profile to regulators. 

Don’t wait for Amazon to decide your compliance path. Contact AVASK today to take control of your EPR obligations.