The single most common EPR misconception among Amazon sellers is this: "Amazon ships my goods, so Amazon is the producer." It is not. Here is exactly who registers, who pays, and what Amazon verifies when you sell through Fulfillment by Amazon (FBA).
TL;DR — Under the PPWR, the FBA seller — not Amazon — is the producer. You register for EPR in each country of sale, appoint an authorised representative if you are not established there, and pay the eco-fees. Amazon only verifies your registration numbers.
FBA does not make Amazon your producer
Fulfillment by Amazon stores and ships your inventory; it does not place your product on the market for you. Under the PPWR, the producer is the entity that first makes a packaged product available on a national market — and that is you, the seller of record. Amazon is a fulfillment service provider, a different role with different obligations.
What that means in practice
- You register in the national packaging register of each country where your FBA inventory goes live — not Amazon.
- You appoint an authorised representative in each member state where you are not established.
- You join the producer responsibility organisation and pay the eco-fees, based on the weight and material of your packaging.
- You hold the registration numbers that Amazon asks for before your inventory can list.
What Amazon actually verifies
Amazon is not doing your compliance for you — it is checking it. Under Article 45(4), marketplaces must verify that sellers hold valid EPR registration numbers before allowing them to list. When Amazon asks for your LUCID number for Germany or your Fost Plus number for Belgium, it is confirming that you are registered, not registering you.
The FBA enforcement pattern
Amazon has enforced EPR deadlines on schedule every time — LUCID in 2022, WEEE in 2023, batteries in 2025. The PPWR extends the same pattern EU-wide. A missing registration number does not get you a warning; it gets your ASIN suppressed in that country, and FBA inventory sitting in an EU warehouse becomes unlistable.
The practical takeaway: treat FBA as a logistics convenience, not a compliance shield. You remain the producer, and your registration numbers are what keep your FBA inventory sellable.
Sources: PPWR (EU) 2025/40, Article 45(4).
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