How to manage EPR for Amazon sellers in 2026 (FBA included)

Getting your EPR numbers is a one-off. Keeping them good is the job that never ends, and EPR for Amazon sellers can go wrong in two separate places at once.

By the end of this guide you will have a routine that keeps your listings live in every Amazon store you sell in. It is written for sellers who are already registered somewhere and now have to hold it together across stores, categories and an FBA account that ships packaging you never chose.

What to open before you change anything

Almost none of this is guesswork. Four things in your own Seller Central account already describe your obligations, so pull them up before you decide anything.

1. Every store you are switched on in. Not the ones you meant to sell in, the ones with active listings today.
2. The categories you list in. Packaging is rarely the only one. A gadget in a box is electrical equipment as well as packaging, and anything with a cell in it is a battery too.
3. The numbers already on file. The compliance portal shows what Amazon holds for you, store by store and category by category.
4. Whether Fulfilment by Amazon (FBA) is switched on, and where. FBA brings a second set of duties and a second set of packaging.

Keep your most recent filing for each register open next to that. It is the only way to see whether what you told the register and what Amazon holds still say the same thing.

If you do not have the numbers yet, start with our guide to getting EPR numbers for selling on Amazon and come back here once they exist.

The two checks Amazon runs on you

Since 12 August 2026 the EU Packaging and Packaging Waste Regulation (PPWR) has given online platforms one set of duties and fulfilment services another. Amazon does both jobs for a seller on FBA, so you get checked twice.

Both checks sit under the same set of online marketplace obligations, and Amazon publishes its own EPR compliance page for each store it gates.

Two things follow, and they shape the whole routine. The test is where your customer is, not where your company sits and not where your stock sits. And the two gates close independently, so clearing one does not clear the other.

How to keep your Amazon EPR in order step by step

Run these six once to build the routine, then run the last one again every time something changes. Each closes a different way this quietly falls over.

1. Work out which countries your customers are actually in

Start from the customer, not the warehouse. You owe a packaging registration in every EU country where you are the first to make packaging available there, and the listing check asks for your number in the country the buyer is in. So the list you need is the list of countries your orders land in.

Two things move that list without a decision from you. Pan-European FBA stores inventory in France, Germany, Italy, Spain, Poland and the Netherlands, and makes your offers available across nine European stores.

Amazon's own page for the programme warns about the extra VAT reporting that comes with holding stock abroad, and says nothing about EPR.

Storing stock in a country is not what creates the packaging duty. Selling to a customer there is. But a programme that widens where you sell also widens where you owe, which is why this belongs at step one rather than in a review later.

Mapping it once looks like this.

2. Make the numbers Amazon holds match the register

Amazon does not read the national register and act on what it finds. It holds a copy of your number, and that copy has to keep matching the source.

Two features of the law make a mismatch findable. Every national register list has to be public, free and machine readable, and a country may run automated reconciliation against it to verify what a platform was given.

So a number that was right when you typed it, and wrong after your company moved address, is a number that can be checked and found wrong.

So go through the compliance portal store by store and category by category, and compare each entry against your current register record. Where the two disagree, correct the register first and the portal second, because the register is the side that gets checked.

3. Give the same information to the warehouse side

If you use FBA, the fulfilment side needs the same registration number and self-certification, and it needs them from the moment the fulfilment contract is in place. The regulation puts the accuracy of that information on you rather than on the provider.

What happens after that is worth knowing before it happens rather than during. If the provider has reason to believe your information is inaccurate, incomplete or out of date, it has to ask you to put it right.

If you do not, it has to suspend the service for EU customers until you have, and tell you why. You can challenge that decision in court in the country where the provider is established.

The practical consequence is that a stalled registration is not only a listing problem. It can strand stock you have already shipped into a warehouse, which is a slower and more expensive thing to unwind.

Both gates are worth picturing as separate doors.

4. Count the packaging Amazon puts around your orders

Your own packaging is only part of what reaches the customer. When Amazon ships an FBA order it adds its own box, envelope or filling, and in Germany that shipping packaging counts in your report.

Amazon says so plainly and hands you the figures. Its guidance for German FBA sellers has been in place since 1 July 2022.

It tells sellers to include secondary shipment packaging volumes in their packaging reports and forecasts, and states that Amazon cannot declare the packaging it used to ship your products through FBA.

The weights sit in the Extended Producer Responsibility reports in Seller Central. Filter the marketplace column to amazon.de, filter the category column to secondary packaging, and read the paper and plastic figures in kilograms.

Those weights get added to what you already report. They are not a separate filing.

Here is where they come from and where they go.

5. Put every filing date on one calendar

Registrations rarely lapse on purpose. They lapse because two registers wanted different things in different months and only one of those months was written down anywhere. Our guide to EPR reporting covers what goes into each filing.

Three rhythms show how far apart they sit:

1. The EU packaging register works to 1 June. You report the preceding full calendar year by 1 June. Under 10 tonnes a year you file a smaller set of data on the same date, which is a lighter report and not an exemption from registering.
2. A country may ask for it quarterly. A Member State is allowed to require quarterly submission where it needs the data for budget reasons.
3. Germany runs on two dates. The planned volume report for next year can only be filed up to 31 December this year, and the actual volumes only up to 15 May. Miss 15 May and it goes in as a supplementary report instead.

Germany adds one more date for larger volumes. Three thresholds decide it, measured on last year's volumes: 80,000 kg of glass, 50,000 kg of paper, paperboard and cardboard, or 30,000 kg of the metals, plastics, beverage cartons and composites group taken together.

Reach any one of them and you also owe a declaration of completeness by 15 May, audited by an auditor registered with LUCID.

One year on one calendar makes the clashes obvious.

6. Re-run the whole thing whenever the business changes

Your registration describes the business at one moment. When that description stops being true you have to tell the register without undue delay, and the same change usually has to reach Amazon as well.

The triggers are ordinary commercial events:

1. A new store goes live. New country, new register, new number, following the same route as any other EPR registration in Europe. A registration number can take up to twelve weeks to issue once the authority has everything it asked for, so plan a new market a quarter ahead rather than as a switch you flip.
2. A new kind of product. A battery or an electrical part brings its own stream and its own registration on top of packaging.
3. A packaging change. A different material or weight changes what you report, and in several markets what you pay. Our guide to calculating EPR fees covers how that flows through.
4. A company change. A new address, legal name or contact person is exactly what makes your register record and your Seller Central entry disagree.

Tie this review to the calendar from step five so it happens alongside a filing, rather than sitting as a separate task nobody owns.

Where Repax fits around the numbers Amazon checks

All of the above is data work with deadlines attached. Repax is built for that half of the job, and it is worth being exact about which half.

• Repax Core is live and does the data groundwork. Spec each product and its packaging once, with materials, weights and components, and Core turns that into the figures each register asks for. Pricing is public, with a free tier at €0 a month and paid plans from €29 a month.
• Core prepares the filing, it does not submit it. Enrolling with a producer responsibility organisation and submitting to a national register still happen outside it.
• There is no Amazon connector today. Core's named integrations are Shopify, WooCommerce, PrestaShop, Magento, CSV or Excel, Dinero, e-conomic and a REST API, so an Amazon seller brings volumes in through the Seller Central report export or the API. Better to know that before you plan around it.
• Repax Comply handles the filing side, registering you and filing across EU markets, with an authorised representative where one is required. German packaging is the exception, because the LUCID entry stays personal to you.
• Repax Declare covers the packaging Declaration of Conformity where the PPWR asks you for one.

Repax does not make you compliant on its own and it does not enter numbers into Seller Central for you. It keeps the product and packaging data behind every one of those numbers straight, which is the part that goes wrong without anyone noticing.

If you are still choosing tools, our best EPR software rundown lines up the options, and there is a version for ecommerce sellers as well.

How a compliant seller quietly drifts out of compliance

None of these look like mistakes at the time. They are the six ways a seller who did everything right in January is exposed by autumn.

1. A new store is treated as a growth decision. Marketing switches on Italy, nobody registers in Italy, and the listings hold right up until the check runs.
2. Pan-European FBA is treated as logistics. It changes where your goods sell, so it changes where you owe. The paperwork does not follow the pallets on its own.
3. The FBA shipping packaging is never counted. Your own packaging goes into the German report, Amazon's box does not, and the report is short every single year.
4. The register and Seller Central drift apart. A change of address updates one of them, usually the one your accountant touched.
5. A product picks up a battery. The listing changes, the packaging registration stays, and the battery stream is never registered at all.
6. Pay-on-behalf is treated as a fix. A marketplace can cover your financial contributions under a written mandate, and that is what the offer to comply on your behalf rests on. It cannot register for you and it cannot report for you, and German registration cannot be handed to anyone at all.

For the wider version of this beyond Amazon, our guide to managing EPR for ecommerce sellers covers the same discipline across your own store and other marketplaces.

Frequently asked questions about managing EPR on Amazon

Short answers to what Amazon sellers ask once the numbers are already in place.

How long does managing EPR on Amazon take each year?

Once the registrations exist it is a few hours per market per year, plus the data work behind them. The pressure is not volume, it is dates. Germany alone has filing windows closing on 31 December and on 15 May.

Does Amazon report my packaging to the register for me?

No. Amazon gives German FBA sellers the weight of the shipping packaging it used, inside the Extended Producer Responsibility reports, and states that it cannot declare that packaging for you. Adding those weights to your own report is your job.

What happens if my fulfilment gets suspended over EPR?

The provider has to tell you why, and has to lift the suspension once you have corrected or completed the information it asked for. You also have the right to challenge the decision in court in the country where the provider is established.

Do I need a separate registration for every Amazon store?

You need one per country you sell into and per waste stream, not one per store. Two stores selling into the same country share a registration, while one store selling packaged electronics needs both a packaging and an electricals registration.