Navigating Amazon’s EPR Pay‑on‑Behalf Scheme: Key Insights for 2025

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August 18, 2025 France Flag France
Richard Kupce

Richard Kupce - August 18, 2025

Richard Kupce is the CEO and Co-Founder of Safari Star, driving the company’s global expansion and strategic direction. On this blog, he shares insights on scaling businesses, navigating regulations, and seizing international opportunities.

Amazon has updated the Extended Producer Responsibility (EPR) Pay on Behalf policy affecting sellers in the UK, Spain, and France. These changes are essential for businesses selling packaged goods on Amazon’s platforms, as they redefine compliance expectations and cost structures.

 

What You Need to Know About the EPR Pay on Behalf Update

 

Policy Consolidation (Effective 27 August 2025)
Amazon will merge its country-specific EPR policies for the UK, Spain, and France into a unified framework. This makes it easier for sellers to access consistent compliance information and manage obligations across all regions.

EPR Fee Reserves & Flexible Billing
Amazon may hold eco-contribution and service fees in reserve to ensure they can meet payment obligations to environmental bodies. They may also charge additional fees at various times—even outside regular reporting periods—if regulatory recalculations arise.

Data Sharing Requirements
Amazon will share necessary product and sales data with environmental organizations to meet legal transparency and reporting requirements.

 

Where POB Schemes Apply and What They Cost

 

Eligible Countries

  • UK: Pay on Behalf is active for undeclared sellers in packaging categories sold on Amazon UK. Automatically enrolled if you have no valid EPR registration.
  • Spain & France: POB applies to sellers of packaging goods without valid producer registration numbers. In Spain it complements Royal Decree 293/2018; in France it aligns with AGEC. Marketplaces must ensure compliance by enrolling sellers or registering them automatically. 

 

Fee Structure

  • Spain & France: Annual service fee of €24.99 per category plus 3% of the eco-contributions paid.
  • UK: Annual service fee of £20 per EPR category, on top of eco-contribution fees, for sellers outside the UK.

 

Pros and Cons of Using Amazon’s POB Service

 

Advantages

  • Simplified compliance managed by the platform
  • Automated calculation and payment of eco fees through Amazon’s system.

 

Drawbacks

  • Less control over fee calculations and reporting
  • Dependence on Amazon’s accuracy and process
  • Ambiguity around fault if compliance issues arise

User feedback also highlights surprise enrollment and unexpected fees, especially for small sellers with limited sales in affected markets.

 

Action Steps for Sellers

 

  1. Submit a valid EPR registration number where possible to opt out of Automatic POB enrollment.
  2. Review your service fees—categorize products correctly and understand charge cycles.
  3. Track EPR communications and policy updates from Amazon to avoid unexpected billing or regulatory exposure.
  4. Evaluate independent registration in applicable markets if you prefer greater control over compliance.

 

Stay Compliant & Confident with Safari Star

 

Safari Star helps e-commerce businesses understand and manage EPR requirements—including the Pay on Behalf scheme—in Europe. From registration strategies to compliance monitoring, our team ensures your operations remain safe and uninterrupted.

Reach out to Safari Star today for expert guidance on EPR compliance and Amazon marketplace readiness.

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