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.
Since the Conseil d'Etat EcoDDS ruling of 10 November 2023 (n° 449213), the mandataire acts under an ordinary civil mandate (Articles 1984 et seq. of the Code civil), in the producer's name and without subrogation. In plain terms: the representative does the filing, but the legal responsibility remains the producer's. That is exactly why the two roles are separate.
Need a French EPR representative for your business?
We are EPR France specialists for non-EU sellers. Published volume-tier pricing per stream (Light from €49/mo, Standard from €199/mo, Volume from €349/mo, Enterprise on quote), post-EcoDDS contract, IDU in 2 to 3 weeks.
Side-by-side: Citeo vs authorized representative
| Eco-organism (Citeo / Léko / Adelphe) | Authorized representative (mandataire) | |
|---|---|---|
| What it is | State-accredited body that funds recycling | France-established company acting for a foreign producer |
| What it does | Collects eco-contributions, manages recycling | Registers you, obtains the IDU, files your declaration |
| What you pay | Variable eco-contribution (by tonnage) + small membership fee | Service fee (published volume tiers) |
| Who needs it | Every producer with packaging or paper on the French market | Only producers not established in France |
| Covers which streams | Packaging and graphic paper only | All streams that apply to you, via the right eco-organisms |
| Legal status | Not your legal representative | Your mandatary under the Code civil |
If you want to see how the representative service fee is structured for your product mix, our cost calculator maps your streams and gives a figure in about a minute.
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 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:
- The eco-contribution you pay to Citeo (or the relevant eco-organism). This is variable, set by published baremes, and rises with your declared tonnage. Neither we nor any representative can reduce it; it is set by the eco-organism.
- The representative service fee. Ours is published as volume tiers, not a flat fee: Light from €49/month, Standard from €199/month, Volume from €349/month per stream, with a one-off setup from €290 to €1,290 depending on the stream and tier. Multi-stream producers get a discount on the monthly fee (the setup is never discounted).
Confusing the two is how people end up either thinking EPR is "free if I just pay 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.
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