If you sell on Amazon in Europe, you've probably already encountered EPR requirements. Amazon.de asks for your LUCID number. Amazon.fr asks for your CITEO identifiant unique. Amazon.es wants your ECOEMBES registration. You entered those numbers into Seller Central, the warnings went away, and you moved on.
But having a registration number is just the beginning. Amazon doesn't file your packaging declarations for you. It doesn't calculate how many kilograms of cardboard and plastic your orders generated in each country. It doesn't pay your EPR fees. Those are your responsibilities, and ignoring them doesn't make them disappear — it makes them accumulate until a PRO audit or a marketplace suspension forces the issue.
What Amazon does for EPR
Amazon has built an "Extended Producer Responsibility" compliance program into Seller Central. The program requires sellers to provide EPR registration numbers for each marketplace where they sell. Since July 2022, Amazon Germany has required LUCID numbers. Amazon France requires CITEO or Leko registration. Amazon Spain requires ECOEMBES. Amazon Italy checks CONAI registration. Amazon Austria requires proof of compliance with the Austrian Packaging Ordinance.
Amazon validates these numbers against national registries. On Amazon.de, for example, your LUCID number is checked against the Zentrale Stelle Verpackungsregister database in near-real time. If the number is invalid, expired, or doesn't match your company details, Amazon suppresses your listings. No warning period, no grace window. Listings go down until the number checks out.
That enforcement is effective. It gets sellers registered.
What Amazon does not do:
- Track the weight or material composition of your packaging
- File periodic declarations with PROs on your behalf
- Calculate or pay your EPR fees
- Maintain your packaging Bills of Materials
- Ensure you're compliant beyond having a valid registration number
Registration is step one of a multi-step obligation. Amazon handles step one. Steps two through six — declaration, fee payment, documentation, minimization, substance compliance — are entirely on you.
FBA vs. FBM: who declares what?
The fulfillment model you use affects which packaging is your responsibility to declare. This is where sellers get confused, and honestly, the rules aren't as clean as they should be.
FBA (Fulfillment by Amazon)
With FBA, you send inventory to Amazon's warehouses. Amazon stores it, picks it, packs it in an Amazon-branded shipping box with Amazon air pillows or paper fill, and ships it to the customer.
You are still responsible for declaring the packaging that reaches the consumer. That includes:
- Primary packaging — the packaging directly around your product (the bottle, the bag, the blister pack)
- Secondary packaging — any product box or branded packaging around the primary package
- Shipping packaging — and this is where it gets complicated
Amazon's shipping packaging — the brown box, the air pillows, the tape — is packaging that reaches the consumer. Who declares it?
In Germany, Amazon declares its own FBA shipping packaging under Amazon's own LUCID registration. This is explicitly stated in Amazon's terms. You declare only your product packaging (primary and secondary).
In France, the situation is murkier. Amazon has its own CITEO registration, but the allocation of shipping packaging responsibility between Amazon and the seller isn't as clearly documented. The safest approach: confirm directly with CITEO whether Amazon's FBA shipments to French consumers are covered by Amazon's declaration or yours.
In Spain, similar ambiguity exists. ECOEMBES guidance suggests the "putter on the market" is responsible, which for FBA orders could be interpreted as Amazon (since Amazon is the entity that places the shipping packaging around the product). But interpretations vary.
The practical rule: always declare your product packaging (primary + secondary). For FBA shipping packaging, check each country's current rules. When in doubt, declare it. Overdeclaring costs you a few extra euros in fees. Underdeclaring costs you a potential audit finding.
FBM (Fulfillment by Merchant)
With FBM, you handle everything yourself — or through your own 3PL. There's no ambiguity here. Every piece of packaging that reaches the customer is your responsibility: the product packaging, the shipping box, the void fill, the tape, the poly bag, the thank-you card insert. All of it goes into your declaration.
FBM sellers have the same obligations as any D2C brand shipping from their own warehouse. The only difference is that the orders originate on Amazon instead of your own website.
The data extraction challenge
To file EPR declarations, you need to know what you sold, where you shipped it, and what packaging each product used. Amazon provides the first two. You have to supply the third.
What Amazon gives you
Through Seller Central reports and the SP-API (Selling Partner API), Amazon provides order-level data including:
- ASIN and SKU
- Quantity sold
- Marketplace (Amazon.de, .fr, .es, .it, .nl, etc.)
- Ship-to country
- Order date
- Fulfillment method (FBA or FBM)
You can export this data through Seller Central under Reports > Fulfillment Reports (for FBA) or Reports > Order Reports (for FBM). The "Amazon Fulfilled Shipments" report is particularly useful for FBA because it includes the actual ship-to address and country.
What Amazon doesn't give you
Packaging composition. Packaging weights. Material types. None of this exists in Amazon's order data. Amazon knows your product's ASIN, its dimensions, and its weight (for shipping cost calculations), but it doesn't know that your product ships in a 45g cardboard box with a 12g PP cap and a 3g paper label.
You need to bridge this gap by creating packaging BOMs for your products and then multiplying by your Amazon sales quantities per country. The process is the same as with Shopify or WooCommerce — except the order export comes from Seller Central instead of your store admin.
Multi-marketplace complexity
This is where Amazon sellers face a challenge that single-store brands don't.
Selling on Amazon.de, Amazon.fr, and Amazon.es means three separate EPR obligations. Three registrations. Three sets of declarations. Three fee payments. Even if you operate from a single Amazon seller account, each marketplace maps to a different national EPR regime. See the multi-country EPR strategy guide for how to structure registrations and declarations efficiently across markets.
Country of delivery, not country of shipment
The EPR obligation is based on where the product is delivered, not where it ships from. Amazon can ship your FBA inventory from a warehouse in Germany to a customer in France. That order counts toward your French EPR obligation, not your German one.
This matters more than you might think.
Pan-European FBA
If you use Pan-European FBA, Amazon can move your inventory between warehouses in Germany, France, Spain, Italy, Poland, the Czech Republic, and the Netherlands. You may not know — and it doesn't matter — which warehouse a particular unit shipped from. What matters is where it was delivered.
Pan-European FBA can actually simplify your EPR data in one way: the "Amazon Fulfilled Shipments" report shows the actual ship-to country for each order. Use that field, not the warehouse location, when allocating orders to country-level declarations.
European Fulfillment Network (EFN)
Under EFN, your inventory stays in one country (say, Germany) and Amazon ships cross-border from that single warehouse. A German warehouse shipping to a Spanish customer still creates a Spanish EPR obligation for you. The physical origin of the shipment is irrelevant to the packaging regulation.
EFN sellers sometimes assume their entire EPR obligation falls under Germany because that's where the inventory sits. Wrong. Every country of delivery is a separate obligation.
Amazon's EPR dashboard and packaging estimates
Amazon provides an "EPR Compliance" section in Seller Central where you upload and manage your registration numbers per marketplace. This dashboard has improved over time and now includes a "Packaging Waste" reporting feature for some marketplaces.
The Packaging Waste feature provides estimated packaging weights for your products. Amazon calculates these estimates based on product dimensions, weight category, and typical packaging configurations. The idea is to give sellers an approximation of their packaging footprint.
Do not use these estimates for your official PRO declarations.
Here's why: Amazon's estimates are generic. They don't know that your product uses a glass jar instead of a plastic bottle, or that your secondary packaging is a rigid gift box instead of a folding carton. The estimates might be off by 30–50% for individual products. Across a large catalog, the errors might average out somewhat, but "somewhat accurate on average" is not a defensible position in an audit.
Use Amazon's estimates as a sanity check. If their estimate says 150g of packaging and your BOM says 380g, investigate the discrepancy. But your official declarations should be based on your actual BOMs with measured weights, not Amazon's approximations.
What to do: step by step
If you're an Amazon seller who has the registration numbers in place but hasn't been filing declarations, here is the remediation path.
Step 1: Register with PROs in every country where you sell.
Check your Amazon order data for the past 12 months. Every country that shows up as a delivery destination needs a PRO registration. Germany needs a LUCID number and a dual system contract. France needs CITEO or Leko. Spain needs ECOEMBES. Italy needs CONAI. Don't skip smaller markets like the Netherlands (Afvalfonds), Belgium (Fost Plus), or Austria (ARA).
Step 2: Export your Amazon order data by marketplace.
In Seller Central, go to Reports. For FBA orders, use the "Amazon Fulfilled Shipments" report. For FBM orders, use the "All Orders" report. Export for the declaration period your PROs require — typically quarterly or annually. Make sure the export includes the ship-to country. Filter out non-EU destinations.
Step 3: Create packaging BOMs for your products.
Every ASIN in your catalog needs a packaging BOM listing each component, its material, and its weight. If you have 200 ASINs but only 15 unique packaging configurations, you need 15 BOMs assigned across 200 products. See the BOM guide for the full walkthrough.
Step 4: Multiply and aggregate.
For each order line: quantity sold x packaging weight per component = total packaging weight. Aggregate by country and by material type. The result is your declaration data: "In Q1 2026, we placed 245 kg of cardboard, 38 kg of LDPE plastic, and 12 kg of glass on the French market."
Step 5: Generate and submit declarations to each PRO.
Each PRO has its own declaration format. ECOEMBES uses a specific CSV structure. CITEO has its own online portal with defined categories. LUCID declarations go through your chosen dual system (Interseroh, Reclay, Der Grne Punkt, etc.). Format your data accordingly and submit before the deadline.
Step 6: Pay the invoiced fees.
After your declaration is processed, the PRO invoices you based on the quantities and materials declared. Fees range from a few euros for small sellers to thousands for high-volume operations. Pay on time. Late payment can trigger compliance flags.
Step 7: Repeat.
This isn't a one-time task. Declarations are periodic — quarterly for most PROs, annually for some. Set calendar reminders. Build the process into your operations so it becomes routine rather than a quarterly fire drill.
Reconciling Amazon and direct sales
If you sell the same products on Amazon and through your own Shopify or WooCommerce store, you need to combine the data for a single EPR declaration per country. The PRO wants to know your total packaging placed on their market — not split by sales channel.
This means your declaration process looks like:
- Export Amazon order data (by country)
- Export Shopify/WooCommerce order data (by country)
- Apply the same BOMs to both datasets
- Combine the packaging totals per country per material
- Submit one declaration per country covering all channels
Common mistakes in multi-channel reconciliation:
- Double-counting: Submitting separate declarations for Amazon and Shopify to the same PRO, effectively reporting twice
- Missing a channel: Declaring only Amazon sales and forgetting your direct store, or vice versa
- Using different BOMs: If the same product ships in different packaging from Amazon FBA vs. your own warehouse, you need separate BOMs per channel for that product. A product that ships in your branded mailer from Shopify has different shipping packaging than the same product shipped in an Amazon brown box from FBA.
The PRO doesn't care which platform generated the sale. They care about the total kilograms of each material that entered their country's waste stream because of your products.
Amazon-specific gotchas
Prep center packaging
If you use an Amazon prep center that repackages your products before sending them to FBA warehouses — adding poly bags, suffocation warning stickers, FNSKU labels, bubble wrap — that packaging reaches the consumer. It's part of your declaration. Make sure your BOMs include prep center packaging, not just your own branded packaging.
Multi-packs and bundles
If you sell a bundle (3-pack of soap bars, variety pack of teas), the ASIN for the bundle needs its own BOM. The bundle packaging — the shrink wrap or the bundle box — is additional packaging on top of each individual product's primary packaging.
Removed inventory
If Amazon returns unsold inventory to you (removal orders), those units weren't delivered to consumers. They shouldn't count toward your EPR declaration. Use the "Amazon Fulfilled Shipments" report (which tracks actual customer deliveries) rather than the "Inventory Event Detail" report to avoid counting removed or disposed inventory.
Marketplace-specific thresholds
Some smaller EU marketplaces (Amazon.nl, Amazon.pl, Amazon.se) have EPR requirements that are less enforced but still legally binding. If your Pan-European FBA program delivers to customers in these countries, you have EPR obligations there too. Check whether you need to register even if Amazon hasn't explicitly flagged it in your account health.
Putting it together
Amazon sellers face the same EPR obligations as any brand selling in the EU, plus the added complexity of multi-marketplace operations, FBA packaging ambiguity, and the need to reconcile Amazon data with other sales channels.
The registration part is solved — Amazon forces it. The declaration and fee payment part is where most sellers fall behind. And with the PPWR harmonizing enforcement across all EU countries from August 2026, the window for "we'll deal with it later" is closing.
Pack Declare supports Amazon data import alongside Shopify and WooCommerce, consolidating all channels into a single EPR declaration per country. If you're selling across multiple Amazon marketplaces and direct channels, having a single system of record for packaging data across all of them saves significant time at each declaration cycle.
For more on platform-specific compliance, see the Shopify EPR compliance guide, the WooCommerce EPR guide, and EPR compliance for marketplace sellers. For country-specific registration details, start with LUCID (Germany) and CITEO (France).