A significant portion of EPR compliance confusion for e-commerce sellers comes from a misreading of what marketplaces actually do. Amazon, Zalando, eBay, and others have built EPR compliance infrastructure — they collect registration numbers, validate them against national registries, and in some cases take on a "deemed importer" role for certain obligations. This is real and useful. But it is also partial, conditional, and frequently misunderstood as covering more than it does.
The result is that thousands of marketplace sellers believe they are compliant because their Amazon dashboard shows a green tick next to their EPR registration number — while actually being non-compliant for their D2C sales, for countries where Amazon does not act as deemed importer, and for obligations that Amazon never handles regardless.
This article maps exactly what each major EU marketplace does and does not handle for EPR, so you can identify the gaps that remain your responsibility.
The conceptual distinction: registration versus declaration
To understand what marketplaces do and do not handle, you need to understand the difference between the two core EPR obligations:
- Registration is the one-time (or annual renewal) process of registering as a packaging producer with the national PRO or packaging register. It produces a registration number. This is always your obligation. No marketplace registers on your behalf. They ask for your registration number, verify it is valid, and require you to provide it as a condition of selling.
- Declaration and payment is the periodic (usually annual) process of reporting how much packaging you placed on the market and paying the corresponding EPR fees. In some countries and for some channels, marketplaces take on a "deemed importer" or "responsible party" role and handle the declaration and payment for their platform's sales. In most countries and for most channels, they do not.
The short version: you always register yourself. Marketplaces sometimes (not always, not everywhere) handle declaration and payment for your sales through their platform.
Amazon: the most advanced EPR infrastructure
Amazon has built the most comprehensive EPR compliance infrastructure of any EU marketplace. Here is what they actually do, country by country:
Germany
Amazon requires all sellers who list packaged products on Amazon.de to provide a valid LUCID registration number. Amazon validates this number in real time against the Zentrale Stelle LUCID database. If your number is not found or is invalid, Amazon suppresses affected listings.
For sellers using Fulfilment by Amazon (FBA) in Germany, Amazon acts as a "Bevollmächtigter" (authorized representative) for certain packaging declaration purposes. In practice, this means Amazon reports and pays EPR fees for packaging that passes through their fulfilment network on your behalf. However: you must still be registered in LUCID yourself, you must provide your LUCID number to Amazon, and the coverage relates specifically to FBA order packaging handled by Amazon — not to your own D2C packaging or packaging from other channels.
France
Amazon requires French EPR registration numbers from sellers with sales to France. Amazon France has taken on deemed importer status for certain packaging categories under the AGEC legislation, meaning they assume declaration and fee obligations for some categories of packaging sold through their platform. The scope of this varies by packaging category and product type. You must still hold a valid CITEO or Leko registration and provide it to Amazon.
Spain
Amazon.es requires sellers to provide their ECOEMBES registration number. The deemed importer coverage for Spain is more limited than in Germany and France. Most sellers on Amazon.es are responsible for their own ECOEMBES declarations and fee payments, with Amazon's role being primarily to collect and validate the registration number.
Austria
Amazon.de extends to Austrian sales for many sellers. Austria requires separate EPR registration (with ARA or another licensed PRO). Amazon requires Austrian registration numbers for sellers with Austrian sales. The coverage model is similar to Germany.
For a full breakdown of the Amazon-specific compliance workflow, see our dedicated article on Amazon sellers and EPR compliance.
Platform-by-platform comparison
| Platform | Collects registration numbers | Validates against PRO database | Acts as deemed importer (declaration/fees) | Countries covered |
|---|---|---|---|---|
| Amazon | Yes | Yes (automated in DE, FR) | Partial — FBA in DE, FR; limited in ES, AT; expanding | DE, FR, ES, AT, IT (expanding) |
| eBay | Yes | Yes (DE, FR) | No | DE, FR, IT (expanding) |
| Zalando | Yes (partner brands) | Manual verification | No — Zalando treats partner brands as responsible parties | All EU markets where Zalando operates |
| Etsy | Yes (limited markets) | Limited | No | DE, FR (expanding) |
| Cdiscount | Yes (FR) | Yes (FR) | Partial (FR only) | FR |
| OTTO | Yes (DE) | Yes (DE) | No | DE |
| Kaufland.de | Yes (DE) | Yes (DE) | No | DE, CZ, SK |
| Shopify (hosted store) | No — seller's own responsibility entirely | N/A | No | N/A |
What no marketplace handles for you
Regardless of the marketplace and regardless of any deemed importer arrangements, there are obligations that remain entirely with you as the seller:
Registration in every country
You must register yourself with the PRO in every EU country where your products reach consumers. No marketplace does this for you. Amazon requires your LUCID number for Germany — they do not give you a LUCID number. You must register separately.
Your own D2C sales
If you run a Shopify or WooCommerce store alongside your marketplace channels, every order shipped from your own store is entirely your EPR responsibility. Amazon's deemed importer coverage applies only to sales through Amazon, not to your direct sales. The same applies to all other marketplace arrangements.
Packaging for products you sell through non-covered marketplaces
Most smaller EU marketplaces have no deemed importer infrastructure. If you sell through a regional marketplace in Poland, the Czech Republic, or any smaller market, assume full responsibility for all EPR obligations in those countries.
Accuracy of your declarations
Even where Amazon handles declaration and payment, you are responsible for the accuracy of the underlying data you provide. If your packaging BOMs are wrong, or if you have undisclosed product categories, the declaration Amazon files on your behalf will be incorrect — and the legal risk ultimately flows back to you as the registered producer.
Multi-country coverage beyond the big markets
Amazon's EPR coverage extends to a limited number of countries. Poland, the Netherlands, Belgium, Sweden, and most smaller EU markets are not covered by Amazon's deemed importer arrangements. If you ship orders to those countries, you are responsible for the full EPR workflow there.
The Zalando model: a different approach
Zalando is worth addressing separately because its model differs from Amazon's in a way that surprises many fashion brands. Zalando operates primarily as a retailer (buying inventory) or as a connected retail partner (brands manage their own stock but sell through Zalando's platform). In both cases, Zalando treats the brand as the responsible party for EPR, not itself.
Zalando requires partner brands to demonstrate EPR compliance in each country where Zalando operates — currently 25 EU and European markets. Brands must provide registration numbers and, in many cases, sign compliance declarations as part of the partner onboarding and annual renewal process. Zalando's compliance team reviews this documentation and can suspend brands that cannot demonstrate valid registrations.
For fashion brands selling on Zalando across 15+ EU markets, this creates a significant multi-country compliance burden. Zalando does not file your declarations or pay your fees — it simply requires that you do so and verifies you have done it. The operational challenge this creates is exactly what the multi-country EPR strategy article is designed to address.
The practical compliance checklist for marketplace sellers
For a seller operating across multiple EU marketplaces, the compliance checklist is:
- Register with the PRO in every EU country where at least one order shipped — regardless of channel.
- Provide valid registration numbers to every marketplace that requests them. Keep these numbers updated when registrations renew.
- Identify which countries and channels are covered by marketplace deemed importer arrangements. For everything not covered, handle your own declarations.
- Build and maintain packaging BOMs for every SKU. Accurate BOM data is the foundation whether you file declarations yourself or provide data to a marketplace that files on your behalf.
- Track your D2C sales separately from marketplace sales. Your D2C declaration is always your own regardless of what any marketplace covers.
- Set calendar reminders for declaration deadlines in every country, regardless of whether a marketplace handles part of your obligation there. You are still responsible for submitting your own declaration for the volumes the marketplace does not cover.
If you use multiple channels across multiple countries, the volume of compliance work compounds quickly. Understanding the full scope of EPR compliance for e-commerce and the PPWR compliance checklist provides the broader framework within which marketplace-specific rules sit. The Shopify EPR compliance guide covers the D2C channel that marketplace coverage never reaches.
Frequently asked questions
Does Amazon filing my packaging declaration on my behalf mean I am fully compliant?
No. Amazon's deemed importer role covers specific obligations in specific countries for your Amazon channel sales only. It does not cover your D2C website sales, your other marketplace sales, or all EU countries. You are still responsible for registering with each national PRO, ensuring your registration numbers are valid and up to date, and declaring packaging volumes from all channels. Amazon's coverage is a partial offset, not a complete compliance solution.
What happens if I provide an invalid or expired EPR registration number to Amazon?
Amazon validates registration numbers against national registries in real time or on a regular cadence. If your registration number is invalid, expired, or not found in the registry, Amazon will suppress your listings for that country. In Germany, Amazon checks LUCID numbers against the Zentrale Stelle database. In France, it validates against CITEO or Leko databases. Listing suppression is immediate when a verification fails, so keeping registrations current and renewal dates in your calendar is essential.
If I sell exclusively through Amazon FBA, do I still need to register with PROs myself?
Yes. Even for countries where Amazon acts as deemed importer for packaging obligations on your Amazon sales, you still need your own registration. Amazon requires you to provide a valid registration number — they do not register on your behalf. The deemed importer arrangement means Amazon takes on some declaration and payment obligations for your Amazon channel, but you must be registered and must provide Amazon with your registration number. Without a registration number, your listings will be suppressed.
I sell on both Amazon and my own Shopify store. How does EPR work across channels?
You need to treat each sales channel separately for EPR purposes. Your Amazon sales may be partially covered by Amazon's deemed importer arrangements in certain countries. Your Shopify sales are entirely your own responsibility in every country. You register once per country (one registration covers all your channels), but your declarations must include packaging from all channels. Do not assume Amazon's coverage of your Amazon sales extends to your direct sales — it does not.
Do smaller marketplaces like Etsy or eBay have the same EPR requirements as Amazon?
eBay has implemented EPR registration number requirements in Germany and some other markets, following Amazon's lead. Etsy has begun collecting EPR information from sellers in certain EU markets. However, the scope and enforcement rigor varies significantly by platform. Smaller platforms are generally less advanced in their EPR enforcement infrastructure. Regardless of whether a marketplace asks for your registration number, the legal obligation to register and declare exists independently of the platform's requirements.