EPR Compliance in France: The Complete Guide for Foreign Sellers in 2026

Any company selling physical goods into France without a French establishment, whether from the US, the UK, China or another EU country, must register for French EPR from its first sale. Since 10 July 2026 it must also appoint a France-established representative by written mandate under Article L. 541-10-9-1 of the French Environmental Code. One mandate covers every stream.

This guide covers the 2026 regime in full: who is in scope, what registration looks like, what it really costs, why the rules on the mandataire changed in November 2023 and again on 10 July 2026, and what PPWR adds since 12 August 2026.

What does EPR mean for a foreign seller?#

Whoever first places a product on the French market finances its end-of-life management. The legal anchor is Article L. 541-10 of the Code de l'environnement, reshaped by the AGEC law of 10 February 2020.

The "producer" is not the factory. It is the legal person that first makes the finished product available to a French customer. For a US Shopify brand selling direct, that is the US company. For a Chinese seller using Amazon FBA in France, that is the Chinese company. For a UK retailer dropshipping from a German 3PL, that is the UK company. What matters is who legally makes the first French sale.

This is why marketplaces care. Under Article L. 541-10-9 of the Code de l'environnement, platforms such as Amazon, ManoMano, Cdiscount, Fnac Marketplace and TikTok Shop must verify that each third-party seller is registered. Where the seller is not, the platform is treated as the producer and owes the contributions, so platforms block listings without a valid identifier.

Which EPR streams matter most for foreign sellers?#

France has 19 EPR streams; a foreign e-commerce seller usually meets two to four of the eleven below. Each stream has one or more approved eco-organisations and needs its own membership and identifier, all under the one mandate.

• Household packaging (cartons, plastic films, paper, glass): Citeo, Léko, Adelphe
• Professional packaging (packaging of products used only by professionals; contributions and identifiers start on 1 January 2027, the 1 July 2026 launch having been postponed sine die on 26 June 2026, then fixed by ministerial announcement): Citeo Pro, Léko Pro, Twiice
• Electrical and electronic equipment (WEEE): Ecosystem, Ecologic
• Batteries and accumulators: Ecosystem (the one we recommend), Batribox
• Textiles, household linen and footwear: Refashion
• Furniture (household and professional): Ecomaison, Valdelia, Valobat
• Toys: Ecomaison
• Sports and leisure articles: Ecologic
• DIY and garden articles: Ecomaison, Valobat, Ecologic
• Graphic paper: Citeo, Léko
• Construction products: Valobat, Ecominéro

A seller of Bluetooth speakers in retail packaging needs WEEE + batteries + household packaging. A Chinese fashion brand on Shopify needs textile + household packaging. A US toy seller on Amazon France needs toys + household packaging.

Each registration gives you an identifier called an IDU, issued through ADEME's SYDEREP service. Marketplaces verify it. Without it, you are exposed to the fines of Article L. 541-9-5: up to EUR 7,500 per unit or tonne for a legal entity, and up to EUR 30,000 for failing to register or to obtain an identifier.

Why can a foreign seller not register on its own?#

Because the law now requires a representative. A written mandate under Article L. 541-10-9-1 of the French Environmental Code, created by Law No. 2026-602 of 8 July 2026. Since 10 July 2026, any producer not established in France and subject to EPR must appoint a representative established in France, for every stream. For packaging, Article 45 of Regulation (EU) 2025/40 (PPWR) adds the same requirement at EU level.

The representative (in French, mandataire) registers you with the eco-organisations, obtains your IDU, files your declarations and is the interface with eco-organisations and platforms. You remain the producer. Under the written mandate required by Article L. 541-10-9-1 of the French Environmental Code, we take charge of and answer for your registration, your identifier, your declarations, the exchanges with the eco-organisation and audits, and the archiving of your files. Your eco-contributions stay invoiced to you and paid by you directly to the eco-organisation.

This role is often confused with two others: the EU Authorised Representative or Responsible Person for product safety, and the VAT fiscal representative. They are different mandates; see EPR representative vs EU authorised representative.

What changed in November 2023 and in July 2026?#

In November 2023 a court struck down the old decree-based transfer of obligations; in July 2026 a law made the representative compulsory for every producer without a French establishment.

Until November 2023, Article R. 541-174 of the Code de l'environnement transferred the producer's EPR obligations to the mandataire it designated. On 10 November 2023, in case n° 449213 (the EcoDDS ruling), the Conseil d'État annulled that provision: changing who answers for substantive obligations belongs to the legislator, not to a decree. That ruling now only concerns producers established in France: they have no obligation to appoint anyone and declare in their own name.

For producers with no establishment in France, the rule since 10 July 2026 is Article L. 541-10-9-1, created by Law No. 2026-602 of 8 July 2026. The mandate covers the streams and the period it names, so check its scope, its duration and the tasks it lists before you sign.

What does an authorized representative actually do?#

Five things: memberships, identifiers, declarations, eco-contribution follow-up, and answers to eco-organisations and platforms. The producer supplies the data; the representative turns it into compliant filings.

1. Memberships. The membership contracts with each eco-organisation are signed in your name, identifying you as the producer and the representative as its contact.

2. Identifiers. You are registered in the national producer register run by ADEME under Article L. 541-10-13. The IDU is attached to your legal person, not the representative's, and stays with you if you change representative.

3. Declarations. Most streams are declared once a year. Exceptions: Ecomaison declares quarterly by default (annual on option below 15 t, 1,000 pieces and EUR 2 million of turnover in the stream), Valdelia quarterly, Ecominéro monthly, and Ecosystem electrical equipment quarterly unless contributions are paid by SEPA direct debit.

4. Eco-contributions. Each eco-organisation sets them on its published schedule from the volumes and materials declared. Your eco-contributions stay invoiced to you and paid by you directly to the eco-organisation. The representative's fee is never a percentage of them and carries no margin on them.

5. Requests and audits. When eco-organisations send notices or audit your declarations, or a marketplace asks for proof, the representative answers, in French, and archives your file.

What does French EPR cost a foreign seller in 2026?#

Two separate costs that should never be confused: the representative's service fee, and the eco-contributions set by each eco-organisation.

The representative's fee. French providers split into two models:

• Quote-only providers, often traditional environmental consultancies, quote case by case: typically €3,500 to €10,000 or more per stream per year.
• Fixed-fee providers such as EPR Representative commit to a fixed written figure before you sign. Our fee is a fixed annual amount per EPR stream, from €190/year excl. VAT for streams under the eco-organism flat-fee regime, confirmed in a written quote within one business day. Your annual fee is a fixed amount per stream and per calendar year, independent of your eco-contributions. It depends on the declaration regime and frequency, the number of references and, above EUR 1,000 of eco-contribution per stream, its size. It is fixed in writing for the year and can only change for the following year, notified in writing by 15 September, or during the year if your scope changes, for example a new stream or a change of declaration regime. A one-time setup per stream is stated in the quote, together with the deposit: a refundable security deposit equal to one year of your estimated eco-contributions, at least the eco-organisation's minimum billing, paid once by separate transfer to a dedicated account, never invoiced. It covers sums left unpaid under the mandate and is returned within sixty days of the end of the mandate, once the last contributions are paid.

For three streams (an Amazon FBA seller of electronics with batteries in retail packaging), one written quote covers packaging + WEEE + batteries. Compare the totals and the escalation clauses of any quotes before signing.

Eco-contributions. These depend on stream, material, weight or unit, and each eco-organisation's 2026 barème. Examples from the published grids:

• Household packaging (Citeo, Léko): €0.02 to €2.80/kg depending on material in the 2027 grids, with a Citeo flat fee of €110 a year below 10,000 units
• WEEE (Ecosystem): €0.04 for a USB charger, €2.44 for a smartphone, €3.58 for a laptop
• Batteries (Ecosystem): €0.374/kg for alkaline batteries, €0.453/kg for Li-ion accumulators
• Textile (Refashion): €0.0323 for an adult T-shirt on the detailed scale, about €0.58 per clothing item on the simplified regime
• Toys (Ecomaison): €0.08 for a 0.3 kg plush toy, €0.22 for a 1.5 kg board game

Eco-organisation membership itself runs from €0 to €450 a year depending on the stream. Every stream is on the 2026 barèmes hub. We never mark eco-contributions up.

Which dates should every foreign seller know?#

Three: your declaration calendar, 1 January 2027 for professional packaging, and 12 August 2026 for PPWR Article 45.

• Declarations: most streams once a year, with the exceptions listed above.
• Professional packaging (1 January 2027): packaging of products used only by professionals. A package also sold to households stays household packaging, even when a business buys it. The 1 July 2026 launch was postponed sine die on 26 June 2026, then set for 1 January 2027. Register now; contributions and identifiers start on 1 January 2027 (Citeo Pro, Léko Pro or Twiice).
• 12 August 2026: Article 45 of Regulation (EU) 2025/40 requires a producer that makes packaging available in a member state where it is not established, including from another EU country, to appoint an authorised representative for extended producer responsibility in that member state. It is directly applicable EU law.

PPWR matters beyond France: it puts the same packaging requirement in every member state where you sell without being established.

What should you do, and in what order?#

Map, appoint, register, publish, organise your data, watch the rules. The identifier timing depends on each eco-organisation, about seven business days after the membership is validated at Citeo.

1. Map your portfolio against the 19 streams. A "fashion brand" usually triggers textile + packaging + sometimes graphic paper for printed inserts. An "electronics seller" triggers WEEE + packaging + batteries.

2. Appoint a representative. Look for a public entry price and a fixed written quote, a mandate built on Article L. 541-10-9-1 (explicit scope, duration and tasks), and written support in a language you work in (English or French with us). Avoid any fee charged as a percentage of your eco-contributions.

3. Sign the mandate and get registered. It depends on the eco-organisation. Citeo issues the identifier about seven business days after the membership is validated. Léko issues it about five business days after its initial invoice is paid; that invoice must be paid within five business days, otherwise the membership is cancelled. Refashion issues it after membership, the signed contract and your first declaration and payment, then about ten business days. Ecosystem issues it after your first declaration has been filed and paid. Professional packaging (EPRO): registration is open now, eco-contributions from 1 January 2027. We file your membership within two business days of receiving the signed mandate, the first invoice payment and the deposit.

4. Publish your IDUs on your seller accounts, your invoices and your terms of sale.

5. Set up the declaration data flow. Decide who collects volumes (units, weights, materials) and how they reach your representative before each deadline.

6. Watch the rules. PPWR implementing acts on recyclability, labelling and eco-modulation keep arriving through 2027 and 2028.

Will Amazon really block listings without an IDU?#

Yes. Because Article L. 541-10-9 makes the platform answer for unregistered sellers, Amazon France asks for the IDU of each applicable stream and removes listings without one; ManoMano, Cdiscount, Fnac and TikTok Shop run similar checks. Recovery starts with a published IDU for each stream concerned.

Frequently asked questions#

What does French EPR require of a foreign seller in 2026?#

Three things. Appoint a representative established in France by written mandate (Article L. 541-10-9-1 of the French Environmental Code, in force 10 July 2026), join an approved eco-organisation and obtain an identifier (IDU) for each stream you fall under, then declare your volumes, usually once a year. There is no volume threshold, and fines reach EUR 7,500 per unit or tonne.

Is there a minimum sales volume below which French EPR does not apply to a foreign seller?#

No. Registration is due from the first sale in France. Under Article L. 541-9-5 of the Code de l'environnement, a legal entity faces up to EUR 7,500 per unit or tonne, and up to EUR 30,000 for failing to register or to obtain an identifier, whatever its French volume.

Can a foreign company register directly with a French eco-organisation?#

Not on its own since 10 July 2026. Article L. 541-10-9-1 requires any producer not established in France and subject to EPR to appoint a representative established in France, by written mandate, for every stream. The memberships are then signed in the producer's name through that representative.

What exactly does the French EPR mandataire answer for?#

You remain the producer. Under the written mandate required by Article L. 541-10-9-1 of the French Environmental Code, we take charge of and answer for your registration, your identifier, your declarations, the exchanges with the eco-organisation and audits, and the archiving of your files. Your eco-contributions stay invoiced to you and paid by you directly to the eco-organisation.

Is the French EPR representative the same as an EU Authorised Representative?#

No. The EU Authorised Representative or Responsible Person answers for product safety and conformity, and a fiscal representative for VAT. The French EPR representative registers you with eco-organisations, obtains your identifiers and files your declarations. Each role needs its own contract.

Does a French subsidiary remove the need for an authorized representative?#

Yes, if that French entity is the one first placing the product on the market: it registers in its own name. The requirement of Article L. 541-10-9-1 applies only where the producer itself has no establishment in France, whatever its nationality and whether or not it is in the EU.

Can a single French representative cover other EU countries?#

No. Since 12 August 2026, PPWR Article 45 requires a packaging representative in each member state where you are not established, and other streams follow each country's rules. We act in France only.

Where to go from here#

French EPR is a recurring process for as long as you sell to French customers. The decisive step is choosing the representative before a marketplace forces the timing.

For a written quote on your portfolio within one business day, start with the short application wizard. We are EPR France specialists for producers without a French establishment, with a public entry price and a mandate written for the regime in force since 10 July 2026.

Sources & references#

All legal and regulatory claims in this article trace back to the following primary sources (Légifrance, EUR-Lex, ADEME and equivalents). Verified 31 July 2026; eco-contribution examples from the 2026 barèmes of each eco-organisation.

• LOI n° 2026-602 du 8 juillet 2026, Légifrance, 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. Mandatory representative for producers not established in France.
• Article L. 541-9-5 du Code de l’environnement (sanctions REP), Légifrance
• Article L. 541-10-9 du Code de l’environnement (responsabilité marketplaces), Légifrance
• Article L. 541-10 du Code de l’environnement (cadre général REP), Légifrance
• Loi n° 2020-105 du 10 février 2020 (AGEC), Légifrance
• Conseil d’État, 10 novembre 2023, n° 449213 (EcoDDS), Actu-Environnement
• Regulation (EU) 2025/40 (PPWR), EUR-Lex
• SYDEREP, registre public des producteurs (ADEME)
• Citeo, éco-organisme emballages ménagers
• Léko, éco-organisme emballages
• Adelphe, éco-organisme emballages (filiale Citeo)
• Ecosystem, éco-organisme DEEE
• Ecologic, éco-organisme DEEE
• Refashion, éco-organisme textile, linge, chaussures (TLC)
• Ecomaison, éco-organisme meuble, jouets, bricolage et jardin
• Valdelia, éco-organisme mobilier professionnel
• Batribox (ex-Screlec), éco-organisme piles et accumulateurs
• Valobat, éco-organisme produits et matériaux de construction (PMCB)
• Ecominéro, éco-organisme matériaux inertes du bâtiment
• ADEME, Agence de la transition écologique
• DGCCRF, Direction générale de la concurrence, de la consommation et de la répression des fraudes
• Amazon EU Seller Central, EPR France requirements
• Cadre général des filières REP, Ministère de la Transition écologique