Pay on Behalf and the French IDU: two different things
Direct answer: A marketplace Pay on Behalf service is a payment arrangement between the marketplace and the producer responsibility organisations. The French unique identification number (IDU, called the EPR number or UIN by marketplaces) is an identifier issued by a producer responsibility organisation to a company registered in a given scheme. Amazon's own published wording says that where compliance cannot be proven, it pays the fees on the seller's behalf and recovers them from the seller — so it is a mechanism that starts when the number is missing, not a replacement for it. This page sets out where each one sits, with its sources. It does not tell you whether your company is a producer under the regulation: that determination is yours, from the text of the law.
1 · The two words do not name the same thing
Pay on Behalf is a payment arrangement between a selling platform and the producer responsibility organisations: the platform pays eco-contributions for certain schemes and recovers them from the seller. The French unique identification number (IDU) is the identifier a producer responsibility organisation issues once a company is registered in a scheme — identifiant unique in French, UIN on Amazon's help pages, "EPR number" in common marketplace usage, in the form FRxxxxxx_xx.
One is how the money moves. The other is whether the registration exists. Both can exist; so can only one.
2 · What the marketplaces write themselves
Amazon's seller announcement (sellercentral-europe.amazon.com seller forums, read 22 October 2026):
« Effective January 1, 2022, if you cannot prove your compliance with EPR in France, we will pay the corresponding EPR fees to the qualified Producer Responsibility Organizations Schemes on your behalf and recover the fees from you. »
Note the shape of that sentence: the trigger is failure to prove compliance, the action is paying on behalf, and the ending is recovering the fees from the seller. It describes a route that opens when the number is missing, and the cost still lands on the seller.
The same company's official page states (sell.amazon.fr, read 22 October 2026, no update date shown on the page):
« you will need to obtain your unique identification numbers (UINs) for the products you sell on Amazon. These will need to be submitted on the Compliance Information for Extended Producer Responsibility page »
« You'll also need to report and pay eco-contributions to a Producer Responsibility Organisation (PRO) »
TikTok Shop's seller university page for its EPR Pay on Behalf service states that a seller listing an item subject to EPR obligations is enrolled in that service automatically unless it provides information showing that it already complies (seller-ie.tiktok.com, official page; read on 22 October 2026 through a search index — the page is rendered by JavaScript and could not be read directly that day. The limitation is stated here rather than hidden).
On Temu and SHEIN: as at 22 October 2026 we could not read an official page from either on French EPR numbers. This page therefore makes no statement about their requirements. Chinese-language media reported on the subject on 31 May and 23 June 2026, but a media report is not a platform's published text, and we do not use it as a source.
3 · Which side the law is on
Article L. 541-10-9-1 of the French Environment Code applies from 10 July 2026, under article 5 of the law of 8 July 2026 (no. 2026-602). Its text has a company holding no establishment in France, and falling under extended producer responsibility, appoint in writing someone established in France whose task is to see that its obligations are kept; that appointee is subrogated in every extended producer responsibility obligation whose mandate it takes on. The same article carries an exception: the obligation is deemed satisfied where a person referred to in Article L. 541-10-9 established in France ensures that those obligations are met (Légifrance, read 22 October 2026).
The law speaks of obligations and of a representative. It neither describes a marketplace payment arrangement as a way of meeting them, nor excludes it. Whether your company is a producer in a given scheme is your determination, from the text of the law and from what you place on the market; this page gives the references, it does not decide for you.
4 · What a number looks like in the public register
ADEME publishes a daily open dataset (rep-producteurs-idu) in which each row is one unique identifier, with its scheme, company name, country of registration and approved categories. When we read it on 22 October 2026 it held 310,841 rows. A payment arrangement creates no row there: the register records registrations, not payments.
How to look for yourself: see checking a number in the ADEME public register.
5 · Sources
- Légifrance, Environment Code art. L. 541-10-9-1 (applicable from 10 July 2026; article 5 of the law of 8 July 2026, no. 2026-602) — read 22 October 2026.
- sell.amazon.fr, Extended Producer Responsibility compliance page (no update date) — read 22 October 2026.
- sellercentral-europe.amazon.com, seller forums announcement on the French EPR compliance portal — read 22 October 2026.
- seller-ie.tiktok.com, EPR Pay on Behalf service page — read 22 October 2026 through a search index, not re-read directly.
- data.ademe.fr, open dataset
rep-producteurs-idu— read 22 October 2026.
What each marketplace publishes (October 2026) → What a written mandate contains → Back to how it works
FAQ
If the marketplace pays the contributions, is a number still needed?
Amazon's seller announcement reads: « Effective January 1, 2022, if you cannot prove your compliance with EPR in France, we will pay the corresponding EPR fees to the qualified Producer Responsibility Organizations Schemes on your behalf and recover the fees from you. » (sellercentral-europe.amazon.com seller forums, read on 22 October 2026). The same company's official page states that unique identification numbers must be obtained and submitted (sell.amazon.fr, read on 22 October 2026). The two are not in conflict: paying on behalf is what happens when proof is missing, and the cost still reaches the seller.
What does the law itself say?
Article L. 541-10-9-1 of the French Environment Code, applicable from 10 July 2026, under article 5 of the law of 8 July 2026 (no. 2026-602), has it that where a company holds no establishment in France and falls under extended producer responsibility, it appoints in writing someone established in France whose task is to see that those obligations are kept. The same article provides that the obligation is deemed satisfied where a person referred to in Article L. 541-10-9 established in France ensures that those obligations are met (Légifrance, read on 22 October 2026). The law speaks of obligations and of a representative; it does not describe a marketplace payment arrangement.
Why do marketplaces still ask for the number?
Because the number is the proof of registration, and a payment arrangement is not. Producer responsibility organisations issue the identifier per scheme, in the form FRxxxxxx_xx; Amazon's own instructions say to « Repeat these steps for each applicable product category » (same announcement). A payment arrangement creates no entry for you in the public register.
One number per scheme?
Yes. The identifier is issued per scheme: one registered scheme, one number. In the public register, one row is one identifier (ADEME open data rep-producteurs-idu, read on 22 October 2026). The number check page explains the format and how to read the register.