екип по съответствиеAmazon Pay on Behalf solves a narrow problem well: it calculates eco-contributions on covered Amazon sales, reports them to a selected producer responsibility organisation and debits the cost from your seller account. It does not solve the whole Spanish producer-compliance problem.
The right comparison is therefore not “cheap Amazon service versus expensive consultant.” It is fee collection versus owning the legal registration.
Choose the route by coverage, not price alone
Channels
List Amazon, own-store and wholesale sales
Evidence
Check whether your company owns an ENV number
Compare
Separate eco-contributions from administration
Transition
Validate the ENV number before disabling Pay on Behalf
| Decision factor | Pay on Behalf | Own registration |
|---|---|---|
| Amazon sales contributions | Covered | Covered |
| ENV number | Not issued by the service itself | Issued to the producer |
| Other channels | Not covered | Can be reconciled in one file |
What Pay on Behalf includes
Amazon's public Spain guidance describes automatic enrolment for sellers subject to EPR who have not submitted a valid registration number. The service:
- uses Amazon sales and product information to calculate eco-contributions;
- submits reports for the categories in which the seller is enrolled;
- pays the corresponding eco-contributions and recovers them from the account;
- adds a service fee.
Amazon's published Spain fee notice states €24.99 per year plus 3% of the eco-contributions, excluding VAT. Current charges should always be confirmed in the seller's Pay on Behalf dashboard.
What it does not give you
Pay on Behalf does not itself create:
- an ENV number in Spain's Registro de Productores de Producto;
- a written appointment of your authorised representative in Spain;
- a packaging declaration covering Shopify, eBay, wholesale or other non-Amazon sales;
- a producer-owned compliance record that can be reused across channels.
This distinction matters because PPWR Article 44 separately obliges producers to register, while Article 45 tells marketplaces to collect their national registration number. Paying an eco-contribution and being registered are connected duties, not interchangeable ones.
Cost comparison with worked examples
The examples below use a typical parcel containing 150 g of cardboard and 10 g of flexible plastic. Eco-contributions use the tariff ranges in our interactive calculator and include scheme minimums.
| Parcels/year | Eco-contribution estimate | Pay on Behalf estimate | Own registration bundle |
|---|---|---|---|
| 500 | €40–€50 | about €65–€80 | about €515–€525 |
| 4,000 | about €90–€130 | about €120–€160 | about €565–€605 |
| 10,000 | about €230–€320 | about €260–€355 | about €705–€795 |
The own-registration column is our €474 annual packaging bundle plus the same recycling fees passed through at cost. A €150 setup fee applies in year one. The Pay on Behalf estimate uses €24.99 plus 3% of eco-contributions and excludes VAT.
Pay on Behalf is cheaper in these examples. The reason to leave it is not a fictional saving: it is to complete the legal file, obtain the number PPWR makes verifiable, cover every sales channel and control the underlying data.
Coverage comparison
| Requirement | Pay on Behalf | Own registration |
|---|---|---|
| Pay eco-contributions for covered Amazon sales | Yes | Yes |
| Spanish ENV producer number | No, not by itself | Yes |
| Authorised representative | No, not by itself | Yes |
| Non-Amazon sales included | No | Yes |
| Producer controls registration evidence | No | Yes |
| Annual national declaration managed | Amazon scope only | Full declared scope |
When does it make sense to move?
Own registration is the stronger route when you sell on more than one channel, want a registration that belongs to your legal entity, need to prepare for PPWR marketplace checks, or want one packaging dataset reconciled across the whole Spanish business.
Do not switch by simply turning Pay on Behalf off. First complete the authorised-representative mandate, scheme onboarding and MITECO registration; then submit the validated number to Amazon and wait for the compliance status to update.
The decision in one sentence
Pay on Behalf can keep eco-contributions moving. Your own registration is what puts the producer itself on the record.
If you are unsure which route your current setup uses, the fastest check is simple: look for an ENV/YEAR/9-DIGIT number issued for your company in Spain. If there is no number, start with the registration checklist.
Final thoughts
Pay on Behalf and producer registration solve different problems. One moves eco-contributions for covered Amazon sales; the other puts the producer on the Spanish record.
The cheaper route is not automatically the complete route. Channel coverage, ownership of the ENV number and the evidence required under PPWR matter alongside price.
Transition in the right order. Validate the representative, scheme and final registration before switching off an existing payment mechanism.