Pay on Behalf used to be a way out. Now it's an add-on.
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Amazon’s Pay on Behalf service still exists. What changed is what it does for you.
Until this year, POB was a complete answer to packaging EPR in France and Spain: Amazon registered the quantities with the national schemes, paid the eco-contributions, and invoiced you. You did not need your own registration number. In spring 2026 Amazon notified sellers that continuing in POB requires you to hold your own EPR registration numbers and enter them in Seller Central.
That is a change of role, not a withdrawal. POB stopped being an alternative to registering and became something layered on top of registering. If you were using it as your EPR solution, as of 12 August 2026 you do not have one.
What changed, and when
The trigger is the Packaging and Packaging Waste Regulation, Regulation (EU) 2025/40, which applies from 12 August 2026. Among other things it requires online marketplaces to verify that sellers using them hold valid packaging EPR registration in the markets they sell into.
A marketplace cannot satisfy a verification duty by pointing at its own payment service. Verification requires a registration number in the seller’s name, which is why the number became a condition of staying in POB rather than an alternative to it.
What Pay on Behalf actually was, and where it never existed
This is the part most coverage gets wrong, and it matters because it determines whether any of this applies to you.
In the EU, Pay on Behalf existed only for France and Spain. The UK had a parallel arrangement under its own post-Brexit packaging regime. Amazon unified the three in August 2025, which is the source of a good deal of confusion, because a single announcement covering three countries reads as though the programme is broad.
It was never available for Germany, Italy, Poland, the Netherlands, Belgium, Sweden or Ireland.
Germany is the clearest case. German packaging law requires the producer to register in the LUCID register directly, before the first sale, with no volume threshold and no mechanism for a marketplace to do it for you. Any seller shipping to Germany has needed their own number all along. If you have been selling into Germany without one, POB was never covering you, and 12 August is not when your problem started.
The fee was never the cost
The POB service fee was €24.99 per year per EPR category, plus 3% of the eco-contributions. Amazon removed the 3% component in January 2026, leaving roughly €25 per category per year.
A few categories in two countries lands under €100 a year. At that price almost nobody examined the arrangement closely, and that was a reasonable judgement.
But the service fee and the eco-contribution are two different things, and only the first was ever what POB charged for. Eco-contributions are calculated on the packaging you actually place on the market — material by material, by weight, by quantity sold. For a seller with real volume they run into the thousands of euros a year, and Amazon billed them straight through to you.
So POB never saved you the money. It saved you the paperwork: the registration, the scheme contract, the periodic declarations, and the job of understanding a different system in each country. That is what has been handed back.
Last time, the deadline resolved itself
This is worth saying plainly, because it explains why some sellers are calm right now.
In summer 2025, Amazon notified sellers that they needed EPR registration numbers for France and Spain or their listings would be deactivated. In the accounts I work with, the deadline passed without deactivation. Sellers without numbers were automatically enrolled into Pay on Behalf. No action was required, and nothing was switched off.
If you lived through that, the reasonable conclusion was that these deadlines have a soft landing built in, and that the cost of ignoring one is a small automatic fee.
Why that cannot happen again
The soft landing in 2025 was Pay on Behalf. Sellers without numbers fell into it, and it absorbed the problem.
The change in 2026 is that the same mechanism now requires the thing it used to substitute for. Falling into POB without a registration number no longer resolves anything, because POB itself presupposes the number. The escape hatch and the obligation have been welded together.
That is the whole story of this change, and it is why “Amazon will probably sort it out again” is a worse bet this year than it was last year.
Why nobody dealt with this sooner
It would be easy to frame this as sellers ignoring their obligations. That is not what happened, and the real reason is more useful.
Amazon offered to carry the administrative burden for under €100 a year. The alternative was learning how packaging EPR works across several countries, each with its own register, its own scheme operators, its own reporting cycle and its own language. Set against that, taking the €25 a category was the correct call for almost everyone.
This is not only a small-seller problem. Even in large manufacturing businesses there is frequently nobody on the payroll whose job this is. Compliance sits somewhere between logistics, finance and legal, none of whom own it, and the question of which agency to even approach in a given country has no obvious internal answer. Work spanning that many jurisdictions tends to sit still until a deadline forces it to move.
What changed is not that the obligation appeared. It is that the option to pay a small fee and not think about it has been withdrawn, and the work has come back onto your desk — with the same number of hours in the week as before.
Where this stands right now
As of 2 August 2026, ten days before the deadline.
What happens to a seller holding no registration number on 13 August is genuinely unsettled. Published sources disagree: some describe automatic enrolment into Pay on Behalf with a service fee as the consequence of non-compliance, which is what happened in 2025; others describe POB continuing only as a payment mechanism for sellers who are already registered, with listing blocks for everyone else. Both cannot be true after 12 August, and anyone stating either with confidence today is guessing.
Registrations I am involved with are in progress and not complete, so I cannot tell you from experience either. I will report what actually happens rather than what was announced.
If you have no registrations and you sell into France or Spain, ten days is not enough. Lead times run from several weeks to several months depending on the country, and no provider can compress a national register’s queue. What ten days is enough for:
- Find out what you already have. Numbers may exist from an earlier registration, or through a brand owner or importer, and simply not be entered in Seller Central. Entering an existing number takes five minutes.
- Separate the countries. Germany was never covered by POB and is a different problem from France and Spain. Treat them as separate tasks, not one project.
- Start the registrations anyway. A registration in progress on 13 August is a materially better position than one not started, whether or not Amazon ends up distinguishing between them.
- Watch your own Seller Central notices, not summaries of them. Any phased or country-specific treatment will appear there first, and the list of countries Amazon verifies changes.
Sources
Primary sources only. Vendor pages are not cited as authority.