EPRO: the professional packaging calendar to 1 January 2027, and what to do now

France ended a month of uncertainty on its newest EPR stream: by an official press release of the ministry for ecological transition dated 28 July 2026, the professional packaging (EPRO) eco-contribution start is fixed for 1 January 2027. Since then, the 2026 scales were withdrawn and the three eco-organisms published their 2027 scales in October 2026. Register now; contributions and identifiers start on 1 January 2027.

This article is the operational answer to the question every B2B shipper asks: what does the calendar to 1 January 2027 look like, what should you do now, and what can wait? It is written for producers, EU and non-EU alike, that place professional packaging on the French market.

What changed in 2026?#

The AGEC law originally scheduled the professional packaging stream for 1 January 2025. It slipped to 1 January 2026 (the date the legal framework, décret n° 2025-1081 of 17 November 2025, entered into force), then the operational start was set for 1 July 2026. On 26 June 2026, days before launch, the minister announced a sine-die postponement. On 28 July 2026 the ministry set the start at 1 January 2027. In the words of Mathieu Lefèvre, minister for ecological transition: "La mise en œuvre opérationnelle de la filière REP pour les emballages professionnels au 1er janvier 2027 permettra de réunir les conditions nécessaires à un démarrage efficient" (the 1 January 2027 operational start will bring together the conditions for an efficient launch). The stated reasons for the June postponement: the population of contributors was not fully identified (the European Commission's packaging guidance arrived late, in June 2026) and the eco-organisms' rates had only just been published.

The press release also set out the path to the start date:

• the accredited eco-organisms were asked to publish their 2027 scales from September 2026, the minister saying he would be very vigilant that they match the financial projections in the accreditation applications; the 2027 scales were published in October 2026;
• the administration was to lift the remaining uncertainties on who is obligated by September 2026;
• the minister's stated objective: every obligated operator should have joined an eco-organism by the end of 2026.

What did not change?#

• The obligation already exists. The framework has been in force since 1 January 2026. What starts on 1 January 2027 is the payment of eco-contributions and the activation of identifiers.
• The three eco-organisms are accredited: Citeo Pro, Léko Pro and Twiice, by arrêtés of 3 June 2026, published in the Journal officiel on 24 June 2026.
• Nothing is owed for 2026. Per the ministry, eco-contributions start on 1 January 2027. The postponement arrêté is not yet published in the Journal officiel (as of 2 November 2026), and Citeo Pro's general terms applicable from 1 July 2026, which predate the postponement, have not been updated yet.
• PPWR Article 45 is unaffected. Since 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.

What counts as professional packaging?#

Professional packaging is any packaging that is not household packaging. Under the arrêté of 2 December 2025, pallets and palletisation items are always professional; transport packaging is professional, except for products sold online to households; grouped packaging is professional, except multipacks split at the point of sale; sales packaging is professional only when the product is designed exclusively for professionals and nobody sells it to households. Typical examples: drums, jerricans, crates, cases, pallets, stretch film, dunnage, big bags and intermediate bulk containers. Packaging of oils, hazardous chemicals, construction products and agricultural supplies is excluded, because other schemes cover it.

What is the working calendar to 1 January 2027?#

These dates come from the pages and contracts published by the three eco-organisms, read on 2 November 2026: Citeo Pro's "Déclarer ses emballages professionnels" page, Léko Pro's 2027 scale and Annex 2 of Twiice's membership contract. The declaration guides and import templates announced by all three are not yet published.

How do you choose between the three eco-organisms?#

The choice is contractual, not legal: all three run the same scheme under the same cahier des charges. What differs is the scale per material and the operational focus:

• Citeo Pro: the B2B arm of the historic household-packaging eco-organism, already running the food-service stream that merges into EPRO.
• Léko Pro: the challenger's B2B offering.
• Twiice: the only operator fully dedicated to professional packaging, with a plastics and reuse focus.

The 2026 professional packaging scales were withdrawn when contributions moved to 2027. Citeo Pro, Léko Pro and Twiice published their 2027 scales in October 2026 (Twiice on 15 October; Citeo Pro and Léko Pro may still change). Compare them on our comparator. We register clients with all three eco-organisms.

Small producers: under 4 tonnes a year, each offers an annual flat fee: EUR 240 excl. VAT at Citeo Pro, EUR 220 at Léko Pro (also its minimum invoice) and EUR 200 at Twiice, whose FAQ adds a 2,000-unit ceiling.

What does the Citeo Pro standard contract say?#

We read Citeo Pro's standard contract (general terms applicable from 1 July 2026) and its adhesion memo of June 2026 in full. Both predate the postponement; Citeo Pro has since published its 2027 timetable, shown in the table above. The practical points producers ask about:

• The identifier goes into your sales terms. The contract requires the client to include the unique identifier in its terms and conditions of sale (or another contractual document if it has none). Professional packaging (EPRO): registration is open now, eco-contributions from 1 January 2027.
• Declarations: a provisional declaration of 2027 placements in January-February 2027, on estimates; in steady state, the annual declaration of the previous year's placements is due before 1 March. Small producers under an annual threshold can opt for a flat fee. Declarations can be completed in French or English.
• Billing: advance invoices in April, July and October 2027 on the provisional basis, then a settlement once actual volumes are declared. Payment terms: 30 days end of month. A late declaration can carry a surcharge capped at 5% of the contribution. Your eco-contributions stay invoiced to you and paid by you directly to the eco-organisation.
• Late joiners owe the earlier placements. The contract contains an anti-free-rider mechanism: a producer signing late without prior registration declares its earlier placements within six months of signing, invoiced at each year's rates.
• Switching eco-organism: termination by registered letter with acknowledgement of receipt no later than 31 October, effective 31 December, with the new contract starting on 1 January. Declaration and payment obligations for packaging already placed survive termination.
• Rate changes: the rate guide is published annually and Citeo Pro must notify rate changes at least three months before they apply.

Léko Pro and Twiice publish their own contractual terms; the regulatory architecture is identical, the operational details may differ at the margin.

Why is registering now the cheap move?#

Waiting until December 2026 is legal. It is also how you end up registering in a rush alongside everyone else. Registering now:

1. Costs no eco-contribution before the start date. Nothing accrues on 2026 placements.
2. Answers your customers, and the ministry. French distributors and B2B buyers already ask suppliers for their professional packaging position, and the ministry's objective is that every obligated operator has joined by the end of 2026. "Registered, contributions start 1 January 2027" closes the topic.
3. Lets you choose calmly. Comparing the 2027 scales on your real mix takes days; doing it in late December is how mistakes get made.
4. Solves the representative step for foreign producers. If you have no French establishment, the registration runs through a France-established representative, and the same mandate covers the PPWR Article 45 requirement.

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.

The professional packaging page covers scope and obligations in depth, and the professional packaging rates article explains how the scales work. Request a written quote: we reply within one business day.

Frequently asked questions#

When does the French professional packaging EPR (EPRO) actually start?#

Eco-contributions and identifiers start on 1 January 2027, per the ministry's official press release of 28 July 2026, after the 1 July 2026 launch was postponed sine die on 26 June 2026. The 2026 scales were withdrawn and Citeo Pro, Léko Pro and Twiice published their 2027 scales in October 2026 (Twiice on 15 October; Citeo Pro and Léko Pro may still change). The registration obligation already exists: register now.

What does professional packaging cover?#

Professional packaging is any packaging that is not household packaging. Under the arrêté of 2 December 2025, pallets and palletisation items are always professional; transport packaging is professional, except for products sold online to households; grouped packaging is professional, except multipacks split at the point of sale; sales packaging is professional only when the product is designed exclusively for professionals and nobody sells it to households. Drums, crates, cases, pallets, stretch film, big bags and intermediate bulk containers typically fall in scope; packaging of oils, hazardous chemicals, construction products and agricultural supplies is excluded because other schemes cover it.

What did the ministry's 28 July 2026 press release commit to, beyond the date?#

Three things. The accredited eco-organisms were asked to publish their 2027 scales from September 2026 (they were published in October 2026), with the minister saying he would be very vigilant that they match the financial projections in the accreditation applications. The administration was to lift the remaining uncertainties on who is obligated by September 2026. And the stated objective is that every obligated operator has joined an eco-organism by the end of 2026.

Is joining an eco-organism already possible, and should I do it now?#

Yes. Citeo Pro, Léko Pro and Twiice were accredited by arrêtés of 3 June 2026 (Journal officiel of 24 June 2026) and their adhesion journeys are open. Joining now triggers no eco-contribution before 1 January 2027 and settles the questions your French distributors and B2B customers are already asking. Register now; contributions and identifiers start on 1 January 2027. A producer without a French establishment registers through a France-established representative.

What do I have to declare, and when?#

The provisional declaration covers your estimated 2027 placements, not your past volumes. At Léko Pro you submit it at adhesion; at Citeo Pro and Twiice you file it in January-February 2027, with estimates and averages accepted. The declaration of actual 2027 volumes follows in January-February 2028, before 1 March, then a settlement against the provisional amounts. Start collecting your tonnage per material now (plastic, paper-board, wood, steel, aluminium, other), pallets and reusable packaging included.

Are the EPRO rates known?#

Yes, for 2027. The 2026 professional packaging scales were withdrawn when contributions moved to 2027. Citeo Pro, Léko Pro and Twiice published their 2027 scales in October 2026 (Twiice on 15 October; Citeo Pro and Léko Pro may still change). Read the 2027 scale on your eco-organism's site, or send us your material mix and we compare the three in your written quote.

What happens to the food-service (restauration) packaging stream?#

It folds into the professional packaging stream at the start date, 1 January 2027. Producers contributing under the food-service scheme (historically with Citeo Pro) move to the professional packaging framework at that point; the eco-organisms handle the mechanics of the merger.

I am an EU or non-EU producer with no French establishment. What does this change for me?#

Since 10 July 2026, any producer not established in France and subject to EPR must appoint a representative established in France, for every stream (Article L. 541-10-9-1 of the French Environmental Code). For packaging, Article 45 of Regulation (EU) 2025/40 (PPWR) adds the same requirement at EU level, including for a producer established in another EU country. The 1 January 2027 start gives you a clean runway: register in 2026 and enter 2027 compliant.

Sources & references#

The start date is per the ministry's official press release of 28 July 2026. The 2027 timetable comes from the three eco-organisms' pages, scales and contracts, read on 2 November 2026. Citeo Pro contract details are from its standard contract (general terms applicable from 1 July 2026) and its adhesion memo of June 2026, both read in full and both predating the postponement. Not legal advice.

• Ministry press release: Mathieu Lefèvre announces the operational start of the professional-packaging EPR stream
• Ministère de la Transition écologique, page Emballages professionnels
• ADEME, filière EPRO
• Citeo Pro, adhesion page, its adhesion memo of 2 June 2026 (PDF) and standard contract (PDF)
• Citeo Pro, Déclarer ses emballages professionnels
• Léko Pro and its 2027 scale
• Twiice and its 2026 membership contract (PDF)
• Restauration21, accreditation of Citeo Pro, Léko Pro and Twiice
• franceinfo, "le principe pollueur-payeur repoussé au 1er janvier 2027"