From 1 Jan 2026, Amazon is simplifying its EPR Pay on Behalf fees and shifting to fixed annual costs per category…
This new, less complex fee structure for the Extended Producer Responsibility (EPR) Pay on Behalf service is good news for brands across the UK and Europe – but first, a quick recap.
What is the EPR Pay on Behalf Scheme?
If you use Amazon’s EPR Pay on Behalf service, it means that Amazon handles your EPR obligations; registering, reporting and paying your environmental fees for you.
And until now, the cost has included:
- A fixed annual fee per category, and
- In some countries, an additional 3% variable fee.
What’s changing?
From 2026, the variable element disappears – Amazon is moving to one fixed annual fee per EPR category, with no percentage-based charges.
The new fee structure is:
United Kingdom
- £20 per EPR category/per year
Belgium, France, Italy, Spain
- €25 per EPR category/per year
In some markets, it does mean a tiny increase (€0.01) – but the 3% variable fee that previously applied in Spain and France will be gone.
If you’re in the scheme, you don’t need to do anything unless you choose to opt out of Pay on Behalf.
Why it’s good news
EPR compliance isn’t optional, and the consequences for non-compliance are heavy – from de-listing and suppressed listings to blocked shipments.
By shifting to fixed, predictable fees, brands will have a clearer control over their environmental compliance costs, especially for multi-category catalogues, and it also removes the variability that has made cost forecasts harder in some EU markets.
For brands with complex portfolios, this is an opportunity to build cleaner, more accurate cost models for 2026 and understand exactly how EPR influences margins per ASIN, landed costs and the profitability of your catalogue as a whole.
Some things to consider…
Fixing the fees makes things simpler for brands, but the overall commercial picture is still complex.
Brands still need to understand:
- How many EPR categories their catalogue covers
- The real margin impact for them across UK + EU markets
- Whether Amazon Pay on Behalf or self-management is more cost-effective
- And how and where their EPR fees intersect with pricing, contribution margin and Net PPM
This is particularly relevant for brands operating across packaging-heavy categories or with products that span spanning multiple EPR classifications.
Here’s a quick “do now” checklist:
- Audit your EPR category footprint so you know which products fall under which category; packaging, WEEE, batteries, textiles etc.
- Model the impact on your margins at a category-level, so you can build the fixed fees into your forecasts.
- Decide whether to stay on Amazon Pay on Behalf. If you prefer to self-manage, you’ll need to opt out and provide valid ERNs.
- Review your international expansion strategies, because EPR remains a barrier to EU scaling.
- Strengthen your internal compliance governance, ensuring ownership for EPR reporting, cost monitoring and product classifications.
How to opt out of the EPR Pay on Behalf Scheme
If you want to manage EPR yourself?
Submit your EPR Registration Number (ERN) through:
- Account Health → Manage your Compliance → Submit compliance information.
The Bottom Line
Amazon’s EPR changes make costs more predictable, but it’s still a complex landscape for brands that calls for clear governance, accurate category mapping and strong financial modelling.
If you need support? Our Amazon experts can help you build strategies that help you expand internationally while protecting your margins – get in touch today.