Amazon FBA & EU EPR: Who Is Responsible?
FBA describes how orders are fulfilled. It does not, by itself, identify the legally responsible producer for every product and packaging component in every EU country. Assess the supply chain and the applicable rule before deciding who registers or reports.
Separate the product from shipment materials
Create two packaging records: the materials supplied with the product and the materials added for dispatch. Record who supplies, brands, assembles or changes each item and where the order goes. Keep fulfilment statements and packaging specifications alongside your own records. Do not assign all packaging to a party merely because its name appears on the parcel.
Germany shows why the facts matter
Current ZSVR guidance distinguishes branded shipment packaging, unbranded complete packaging and components assembled into a package. It also addresses fulfilment-provider checks. Use that German guidance for German orders; do not apply an older blanket statement about fulfilment responsibility to every EU market.
Keep marketplace requests separate from fulfilment
For each request, save the marketplace, selling account, country, waste stream, requested evidence and deadline. Check whether the request concerns packaging, electronics or batteries. A logistics invoice or FBA enrolment is not the same document as a producer-register confirmation, scheme agreement or specific assumption of obligations.
Build a responsibility matrix before filing
List each country and stream, the entity assessed as responsible, the supporting facts, the registration or scheme route, and who supplies reporting data. For Belgium, start with the packaging route and assess equipment or batteries separately. Agree the PPWR representation scope in writing; GPSR is separate and not included in EPR services.