Amazon Sellers Face New EPR Reserve Rules in France Spain

New Amazon EPR regulations for France and Spain will take effect in November 2025, introducing an account-level reserve mechanism to cover environmental fees. Sellers should pay close attention to the initial and subsequent monthly reserve rules, accurately estimate funding requirements, optimize product categorization, and set up account reminders to ensure compliant operations. This proactive approach helps avoid unnecessary fines and potential store risks associated with non-compliance. Understanding and adapting to these changes are crucial for continued success on Amazon's European marketplaces.
Amazon Sellers Face New EPR Reserve Rules in France Spain

Amazon is introducing significant changes to its Extended Producer Responsibility (EPR) compliance system for sellers operating in France and Spain. Starting November 2025, the platform will implement a new "reserve fund" mechanism designed to streamline environmental fee payments and ensure compliance. While this system may temporarily affect sellers' available balances, it aims to prevent penalties and simplify the compliance process.

Account-Level Reserve Funds: Amazon's Compliance Solution

The new system will automatically freeze a portion of sellers' account balances as dedicated funds for EPR environmental fees. This approach eliminates manual payment processes while ensuring timely compliance with French and Spanish environmental regulations.

  • Benefits: Automated fee processing with no additional service charges
  • Impact: Temporary reduction in immediately withdrawable balances

Reserve Calculation: A Two-Phase Approach

Amazon has established a transparent calculation method across two distinct phases:

Initial Reserve (November 2025):

The first reserve amount will combine three components:

Initial Reserve = €24.99 annual fee + (Pending environmental fees × 3% service charge) + Total pending environmental fees

Example: For a seller with €120 in pending French packaging fees, the initial reserve would be €24.99 + (€120 × 3%) + €120 = €148.59

Monthly Reserves (Subsequent Periods):

Following the initial phase, reserves will only reflect environmental fees generated by that month's sales. For instance, €45 in Spanish electronics fees generated during November would result in a €45 December reserve.

Reserve Fund Mechanics: Frozen but Not Deducted

The reserve system operates with notable flexibility:

  • Funds remain seller property but become temporarily non-withdrawable
  • Automatic deductions occur at payment deadlines
  • Excess reserves return to available balances
  • Shortfalls draw from available funds without requiring manual intervention

Critical Timeline for Implementation

  • November 2025: Initial reserve covering full-year environmental fees
  • January 2026: Monthly deduction cycle begins
  • Ongoing: Monthly reserves reflect previous month's sales

Amazon will notify affected sellers via email 1-2 days before implementation.

Monitoring Reserve Funds

Sellers can track reserves through:

  1. Seller Central → Payment Reports → Settlement Overview → Account-Level Reserve section
  2. Reports → Manage Your Extended Producer Responsibility Compliance Tasks
  3. Payment Service → Ecological Fees by Category (downloadable reports for France/Spain)

Strategic Recommendations for Sellers

  1. Project reserve requirements using 2025 sales data
  2. Enable account balance change notifications
  3. Optimize product categories to minimize unnecessary environmental fees
  4. Integrate reserve transactions into financial tracking systems

While temporarily reducing liquidity, this system aims to prevent compliance violations and associated penalties. Proactive preparation can help sellers maintain operational stability during the transition period.