Packaging EPR for Amazon sellers delivering to France

Confirm whether you deliver packaged products to consumers in France, including from another Amazon storefront. Gather your company’s establishment country, whether the products reach private consumers in packaging, and whether you first make them available in France. Those are the questions behind the ComplyShelf packaging check.

Household packaging falls under EMPAP, the household packaging and graphic papers scheme. For a producer in scope, the collective-scheme route starts with a producer responsibility organisation (PRO).

• Join a PRO for household packaging to obtain your IDU. The PRO registers you in SYDEREP and sends the identifier. ADEME cannot generate an IDU for a collective-scheme member; contact your PRO if it has not arrived.
• Keep the IDU tied to its scheme. ADEME’s unique identification number (IDU, or UIN in its English guidance) is issued per EPR scheme. Foreign companies are identified by an EU VAT number or the tax registration number from their country of residence.
• Publish your IDU in your terms of sale and on your website. Keep evidence of where it appears.
• Get Triman and sorting information from your PRO. Place the information supplied at joining on the product or packaging and retain it with your scheme records.

A distance seller established in another EU Member State that first makes packaged products available directly to end users in France needs a French EPR authorised representative, appointed by written mandate (PPWR Article 45(3)).

France’s representative rule for sellers established outside the EU is not confirmed in this source review. ComplyShelf routes these cases to expert review. It also sends sellers established in France to expert review because the France pilot covers sellers established outside France.

Regulation (EU) 2025/40 (PPWR) applies since 12 August 2026 (Article 71). Article 3(1)(15)(d) includes foreign distance sellers first making packaged products available directly to end users in another Member State within the producer definition.

Article 44 provides for producer registration in each Member State where packaging or packaged products are first made available. Member States have 18 months from the first implementing act to set up the register, so do not assume every Article 44 register is already operating. Check the national arrangements for each destination.

Under Article 45(4), online marketplaces must obtain the producer’s registration and registration number for the Member State where the consumer is located, plus a self-declaration that EPR obligations are met there, before allowing sales to those consumers. How Amazon implements this in Seller Central is unconfirmed here.

ADEME explains that a marketplace is the producer for quantities it places on the market for third parties unless it holds proof of the seller’s IDU for the scheme concerned. Keep your packaging IDU evidence available; this does not establish which Seller Central screen or document Amazon currently requests.

• Check the storefront, delivery country and packaging scheme named in the request.
• Check which business entity, number or evidence Amazon asks you to supply.
• Keep the request, your submission and Amazon’s resulting status as separate records.

For an in-scope EU-established distance seller, the France pack groups missing IDU registration, PRO membership and French representative evidence into country actions. Its setup checklists cover joining a PRO, publishing and recording the IDU, placing the supplied sorting information and recording the written mandate.

Missing answers stay unresolved. If you say the products do not reach consumers in packaging, or that another business first makes them available in the destination, the pack sends the case to expert review. Supplier coverage is not a resolution path in this pilot.

Record existing evidence, follow the country setup checklist or seek expert review. Steps requiring evidence stay incomplete without it. The pilot covers packaging only in Germany, Austria, France, Italy and Spain. Saved numbers are not independently verified; Amazon status is recorded separately from country evidence readiness.

You can also record a whole storefront × destination market exit after applying the restriction yourself and confirming its scope, effective date and reason. See how Country Market Access works. ComplyShelf does not register your business, appoint a representative or change Amazon settings.

Read the packaging EPR guides for Italy, Spain and Germany and Austria. Use Country Market Access to keep country evidence and next actions together.

• France: ADEME on the unique identifier (IDU) — scheme-specific identifiers, collective-scheme registration, foreign-company identification and marketplace responsibility; L541-10-13 and L541-10-9 as quoted by ADEME.
• France: ADEME FAQ — §§ 3–4, IDU publication and Triman / sorting information.
• EU: Regulation (EU) 2025/40 (PPWR) — Articles 3(1)(15)(d), 44, 45(3)–(4) and 71.

This is a practical starting checklist. Resolve questions about your role and packaging scope with the relevant authority or a qualified adviser.

ComplyShelf is built and run by Denys Holda, an individual business established in Italy and registered with the Camera di Commercio Monte Rosa Laghi Alto Piemonte under REA BI-325108. It is a small operation, not a compliance agency, and you can reach a person at hello@complyshelf.com.

• Your files stay in your workspace. They are stored privately and are not shared with other customers. Administrative access is restricted, but it exists — support cannot honestly promise nobody can ever look at a file, so it does not. How the data is protected.
• Nothing becomes public because you uploaded it. A product safety page is published only when you choose to publish one, through a link that can be revoked afterwards. Public pages and revocable links.
• You can ask for your data to be deleted. Write to the address above. Your rights and what is kept and for how long.
• Never send credentials. ComplyShelf holds no Seller Central login and never needs one. If anything asks you for one, it is not us.