Citeo Membership vs French Authorized Representative: What Is the Difference?

If you sell packaged goods in France and you are not established here, you will hear two terms thrown around as if they were the same choice: joining Citeo and appointing an authorized representative (mandataire). They are not alternatives. Citeo is the eco-organism you pay to fund recycling; an authorized representative is the France-established entity that signs you up to Citeo, gets your Identifiant Unique, and files your annual declaration in your name. A non-established producer needs a representative in order to register with Citeo. This article clears up the confusion in one read.

Two different layers, not two options

French Extended Producer Responsibility (EPR) has two distinct moving parts, and people conflate them constantly.

• The eco-organism (Citeo, Léko, Adelphe for packaging). This is a State-accredited body that pools the money producers pay and uses it to finance collection and recycling. You "adhere" to it and pay an eco-contribution that scales with how much and what kind of packaging you put on the market. This is where the recycling actually gets funded.
• The authorized representative (mandataire). This is a company established in France that acts for a producer not established in France. It registers you, obtains your IDU (Identifiant Unique) from ADEME, adheres to the eco-organism on your behalf, and submits your annual declaration. It does not fund recycling; it is the legal and administrative bridge that lets a foreign producer meet a French obligation.

Think of it this way: Citeo is the toll you pay to use the road; the authorized representative is the licensed agent who is allowed to sign the paperwork in your name because you do not have a French entity to do it yourself.

Why a non-established producer cannot just "join Citeo"

The underlying rule is in Article L. 541-10 of the Code de l'environnement, reinforced by the AGEC law n° 2020-105 of 10 February 2020. The producer is whoever first places the product on the French market. If that producer is not established in France, French law requires it to designate a France-established representative to carry out its obligations.

For packaging specifically, this is now hard law at EU level: Regulation (EU) 2025/40 (PPWR), Article 45, applicable from 12 August 2026, makes the France-established authorized representative mandatory for any producer not established in France. So the foreign producer does not adhere to Citeo directly; the representative adheres to Citeo on its behalf, in the producer's name.

French national law is in fact ahead of PPWR here. Since 10 July 2026, Article L. 541-10-9-1 of the Code de l'environnement (law n° 2026-602 of 8 July 2026) requires any person with no establishment in France to designate a France-established representative, for every EPR stream and not only packaging, and subrogates that representative into the EPR obligations for which it accepts the mandate. In plain terms: the representative does not only do the filing, it carries the obligations inside the mandate. You remain the producer, you answer for the accuracy of the data you provide and for the period before the mandate took effect, and the eco-contribution is still yours to fund. That is why the two roles stay separate: one is the body that finances recycling, the other is the entity that carries your registration and declaration obligations in France.

Side-by-side: Citeo vs authorized representative

If you want to see how the representative service fee is structured for your product mix, the pricing page explains the two cost layers, and a written quote fixes your exact figure within one business day.

Citeo only covers packaging and graphic paper

A common trap: assuming Citeo handles "all of EPR." It does not. Citeo (and the competing eco-organisms Léko and Adelphe) is accredited for household packaging and graphic paper only. Professional packaging goes to Citeo Pro (with Léko Pro and Twiice also accredited). Every other stream has its own eco-organism:

• WEEE/DEEE (electricals): Ecosystem, Ecologic
• Batteries: Ecosystem (which absorbed Corepile in 2025) and Batribox (ex-Screlec)
• Furniture (DEA): Ecomaison (household) and Valdelia (professional)
• Textiles: Refashion
• Toys and sports/DIY: Ecomaison
• Construction products (PMCB): Valobat, Ecominéro

So if you sell, say, a packaged electronic device, you have two obligations: packaging (Citeo or a competitor) and WEEE (Ecosystem or Ecologic). You adhere to two eco-organisms, but one authorized representative can handle both registrations and both declarations under a single mandate. This is the practical reason the representative layer exists separately from any single eco-organism.

What this means for your budget

Two cost lines, not one:

1. The eco-contribution. Variable, set by Citeo (or the relevant eco-organism) on its published barème, and rising with your declared tonnage. Neither we nor any representative can reduce it, and none of it is ours: our fee is never a percentage of it and we take no margin on it.
2. The representative service fee. Ours starts from €190/year excl. VAT for a stream under an eco-organism flat-rate regime; everything else is fixed in a written quote within one business day, driven by the declaration regime and the number of product references, not by your sales volume. A one-off setup per stream and a refundable guarantee deposit are itemised in the quote.

Confusing the two is how people end up either thinking EPR is "free once I have adhered to Citeo" or "expensive because the representative charges the eco-contribution too." Both are wrong. They are separate layers with separate prices.

If you are still untangling who pays whom in your channel, our guide on whether you need a representative when a distributor imports and our explainer on the Identifiant Unique go deeper.

One representative, French streams only

We are a France-established mandataire. We register and declare your French streams: we adhere you to Citeo (and any other eco-organism you need), obtain your IDU per stream, and file your 28 February declaration in your name. We do not operate a partner network and do not refer you abroad. If you also sell in other EU Member States, each of those countries requires its own authorized representative established there, which the producer arranges separately; that is outside our scope. You can start your French registration here.

Not sure whether you need a representative at all, or only the eco-organism? Book a free 15-minute compliance diagnostic via our registration form and we will tell you exactly which layers apply to your setup.

Sources

• Article L. 541-10 du Code de l'environnement (Légifrance)
• Loi n° 2020-105 du 10 février 2020 (AGEC), Légifrance
• LOI n° 2026-602 du 8 juillet 2026, article 5, 2°, creating Article L. 541-10-9-1 du Code de l'environnement (JO of 9 July 2026, NOR TECX2407166L), in force 10 July 2026
• Conseil d'Etat, 10 November 2023, n° 449213 (EcoDDS)
• Regulation (EU) 2025/40 (PPWR), EUR-Lex
• Citeo, the household packaging and paper eco-organism