France has 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. After the surprise sine-die postponement of 26 June 2026, producers finally have a date they can plan against, and a published implementation path to get there.
This article is the operational answer to the question every B2B shipper is now asking: what does the calendar to 1 January 2027 actually look like, what should you do now, and what should you wait for? It is written for producers, EU and non-EU alike, that ship packaged goods to French businesses.
What changed, in one paragraph
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, without a new date, a move the trade press described as unprecedented for a French EPR stream. On 28 July 2026 the ministry closed the loop with an official press release: the start is now 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 does more than set a date; it publishes the path to it:
- the ministry asks the accredited eco-organisms to publish their 2027 barèmes from September 2026, and the minister says he will be very vigilant that they match the financial projections in the accreditation applications;
- the administration will lift all remaining uncertainties on who is obligated by September 2026 at the latest;
- the minister's stated objective: every obligated operator should have joined an eco-organism by the end of 2026, for a fully operational scheme on 1 January 2027.
What does not change
Four things were true before the announcement and remain true:
- 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, not the existence of the stream.
- 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.
- The rates are published. All three per-tonne schedules are out. They are 2026 grids, with the 2027 barèmes due from September 2026; until then they are the best available basis for comparing eco-organisms on your mix.
- No retroactivity. Nothing is owed for the period before the start date.
And one adjacent date is entirely unaffected: PPWR Article 45 still makes a packaging authorized representative mandatory in every Member State where you sell without an establishment from 12 August 2026. The EPRO postponement does not postpone that.
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The working calendar to 1 January 2027
| When | What happens | Status |
|---|---|---|
| Now | Adhesion open at all three eco-organisms; Citeo Pro advertises a sign-up in a few clicks, with no KBIS or bank details required upfront | Confirmed |
| At adhesion | Provisional declaration of placements, based on your latest full-year volumes (2025 tonnages per Citeo Pro's adhesion memo) | Confirmed mechanics; reference year to re-confirm |
| Second half of 2026 | Compare the schedules on your real material mix and pick your eco-organism; producers without a French establishment appoint their French representative | Recommended window |
| September 2026 | Eco-organisms publish their 2027 barèmes (ministry request; Citeo Pro's standard contract already provides for rate publication three months before a new rate applies); the administration lifts the remaining scope uncertainties | Announced, press release of 28 July 2026 |
| End of 2026 | Every obligated operator has joined an eco-organism, per the minister's stated objective | Announced objective |
| 1 January 2027 | Eco-contributions start; the food-service (restauration) stream folds into EPRO | Confirmed |
| Early 2027 | First invoicing cycles on the provisional basis, per your eco-organism's contract terms | To be confirmed by eco-organisms |
| Early 2028 | First declaration of actual 2027 volumes (before 1 March 2028 under Citeo Pro's current contract terms), then settlement against the provisional amounts | Expected; detailed schedule to be republished |
One honesty note on the last rows: the detailed timetable in Citeo Pro's June 2026 adhesion memo (provisional 2026 declaration on 2025 tonnages, a prorated provisional invoice, then the actual declaration of second-half 2026 tonnages in early 2027 followed by a settlement) was built for a 1 July 2026 start. With the start moved to 1 January 2027, those milestones mechanically shift, and the eco-organisms are due to republish their documents with the 2027 barèmes from September 2026. Treat intermediate milestones as indicative until your eco-organism confirms them; the start date itself and the no-retroactivity principle are the fixed points.
The three eco-organisms, and how to choose
The choice is contractual, not legal: all three run the same regulatory scheme under the same cahier des charges. What differs is the barème 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. Publishes a standard contract and an adhesion memo on its site.
- Léko Pro: the challenger's B2B offering, positioned on competitive per-tonne rates.
- Twiice: the only operator 100% dedicated to professional packaging, with a plastics and reuse focus.
On the heaviest B2B materials the schedules are close (plastics around €218/t, paper-cardboard around €35/t); the spread is on metals and residual categories, where the per-tonne difference can be several-fold. The right answer depends entirely on your material mix: our EPRO rates comparator runs your tonnages across all three published schedules and returns the annual euro figure per eco-organism.
Inside the Citeo Pro standard contract: what you actually sign
We have read Citeo Pro's standard contract (general terms applicable from 1 July 2026) and its adhesion memo of June 2026 in full. The practical points producers ask about:
- What you need to join: the SIRET of your legal entity's head office (not a secondary establishment), your main packaging materials, your main activity sector, and a designated signatory. No KBIS, no bank details upfront. Existing Citeo group clients keep a single client number.
- Validation and IDU: Citeo Pro confirms registration by email within 8 working days, then obtains your unique identifier (IDU) from ADEME and forwards it within 8 working days of validation. The IDU is visible in the client portal, with the registration certificate.
- The IDU goes into your sales terms. The contract requires the client to include the unique identifier in its terms and conditions of sale (or, if it has none, another contractual document). Plan the legal-notice update.
- Declarations: the 2026-specific provisional declaration (2025 tonnages) was due before 15 September 2026 for contracts concluded before 15 August 2026, otherwise within one month of validation; 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 the flat fee. Declarations can be completed in French or English.
- Billing: provisional invoice first, then an annual adjustment (credit note or supplementary invoice) once actual volumes are declared; the invoice never falls below the flat rate. Payment terms: 30 days end of month. A late declaration can carry a surcharge capped at 5% of the contribution.
- Late joiners are backdated. The contract contains an anti-free-rider mechanism: a producer signing in 2027 or 2028 without prior registration sees the contract take effect retroactively (drafted as 1 July 2026 in the pre-postponement text, which should track the new start date), with back declarations due 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 eco-organism contract starting on 1 January. Your 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 (one month in exceptional regulatory circumstances), which is exactly the September 2026 window the ministry has now set for the 2027 barèmes.
Léko Pro and Twiice publish their own contractual terms; the regulatory architecture is identical, the operational details may differ at the margin. Expect all three to republish their documents for the 2027 start.
Why registering now is the cheap move
Waiting until December 2026 is legal. It is also how you end up registering in a rush, under pressure, alongside everyone else. Registering now:
- Costs almost nothing. First-year minimums are around €80 HT at Citeo Pro, and no eco-contribution is due before the start date.
- Answers your customers, and the ministry. French distributors and B2B buyers are already asking suppliers for their EPRO position; marketplaces verify IDUs per stream; and the minister's stated objective is that every obligated operator has joined an eco-organism by the end of 2026. "Registered, contributions start 1 January 2027" is the answer that closes the topic.
- Locks your choice calmly. Comparing three barèmes on your real mix takes days, not hours; doing it in Q4 2026 with everyone else is how mistakes get made.
- Solves the representative step for foreign producers. If you have no French establishment, the registration runs through a France-established authorized representative; setting that mandate up now also covers the PPWR Article 45 obligation that bites on 12 August 2026.
The EPRO pillar guide covers scope and obligations in depth, and the 2026 rates article details the three schedules material by material.
Frequently asked questions
Is 1 January 2027 firm, or could it slip again? It is an official ministry press release of 28 July 2026 resolving the sine-die postponement, and it matches one of the two scenarios the ministry itself floated in June (1 October 2026 or 1 January 2027). It also comes with an implementation plan rather than a bare date: 2027 barèmes from September 2026, scope uncertainties lifted by September, adhesion of all obligated operators targeted for the end of 2026. Nothing is ever beyond a future decree, but this is the government's own chosen date, announced to settle the uncertainty it created. We track the stream continuously and update this page if anything moves.
I already joined an eco-organism before the postponement. Do I need to do anything? No. Your adhesion stands, your provisional declaration stands, and no eco-contribution accrues before 1 January 2027. Watch for your eco-organism's republished declaration calendar.
Do I pay anything at all in 2026? Adhesion-level minimums may apply depending on the eco-organism's terms (around €80 HT first year at Citeo Pro), plus your representative fee if you need one. Eco-contributions on your tonnages start only with the stream, and are billed to you directly by the eco-organism, with zero margin from us.
Does the postponement change which packaging is in scope? No. Sales, grouping, transport and service packaging reaching French professionals stays in scope as defined by décret n° 2025-1081; the exclusions (streams already covered elsewhere, such as chemicals or construction products) are unchanged.
We sell both to French consumers and French businesses. Two registrations? Yes: household packaging and professional packaging are separate filières with separate IDUs and declarations. One mandate with us covers both, with a multi-stream discount on the recurring fee.
Sources & references
The start date and the September 2026 milestones are per the ministry's official press release of 28 July 2026. Contract-level details are from Citeo Pro's standard contract (general terms applicable from 1 July 2026) and its adhesion memo of June 2026, both read in full; those documents predate the postponement and their intermediate dates are flagged as indicative pending republication. Not legal advice. Verified 28 July 2026.
- 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)
- Léko Pro and Léko, la REP des emballages professionnels
- Restauration21, accreditation of Citeo Pro, Léko Pro and Twiice
- Usine Nouvelle, the June 2026 postponement
- Ministry press release: Mathieu Lefèvre announces the operational start of the professional-packaging EPR stream
- franceinfo, "le principe pollueur-payeur repoussé au 1er janvier 2027"
- Déchets Infos, coverage of the 1 January 2027 announcement (late July 2026)
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