A frequent and costly misunderstanding: fulfilling through Amazon (FBA) does not make Amazon the producer for packaging EPR. The seller placing the goods on the market remains responsible. What has changed is that marketplaces are now legally required to verify that sellers hold valid EPR registrations — so a missing number increasingly means blocked listings, not just regulatory risk.
What an FBA seller needs, per country
An EPR registration number for each market you sell into — e.g. a LUCID number for Germany, an ADEME unique identifier (IDU) for France, and equivalents for Italy, Spain and others. These go into Seller Central, which checks them.
Scheme membership — a dual system / eco-organisation contract in each country (Germany requires this in addition to the LUCID number).
An authorised representative where the country requires a locally-established party (common for non-EU sellers).
Packaging design and data
Know your packaging — you must be able to declare the materials and weights of the primary, secondary and transport packaging you ship. This is the same data your suppliers should provide on a spec sheet before the order.
Meet PPWR design rules — recyclability, recycled content and the empty-space/minimisation limits apply to your packaging as they phase in; over-boxed FBA shipments are exactly what the minimisation rule targets.
Label correctly — harmonised EU marks as they arrive, plus any national marks (France's Triman/Info-tri, Italy's environmental labelling) still in force.
Amazon's own country help pages list the exact registrations they check — treat this as an orientation, and confirm each country's requirement against its official register.
