France vs. Germany EPR: The Main Differences for Cross-Border Sellers

If you ship to both France and Germany, you have to run two parallel EPR files. Same logic, different rules, different costs, different registries. The good news: convergence is happening, mostly thanks to PPWR. The bad news: only since 12 August 2026, and only for packaging. This article maps the practical differences for cross-border sellers active in both markets.

What does each country regulate?#

France (AGEC law, 2020) runs nineteen official EPR streams: household packaging, professional packaging (EPRO), WEEE, textile (TLC), furniture (DEA), batteries, toys, sports/DIY/garden, graphic paper, construction (PMCB), and several smaller ones.

Germany (VerpackG plus stream-specific laws) runs roughly six streams: packaging (VerpackG), WEEE (ElektroG), batteries (BattG2), textile (under PPWR transition rules), single-use plastics, and a few smaller categories. The packaging law (VerpackG) is the most comparable to French AGEC.

For a single-category seller (only packaging, only WEEE), the regulatory burden is similar in both countries. For a multi-category seller, France covers more streams and therefore has more obligations.

How do the central registers, SYDEREP and LUCID, differ?#

Both countries operate central registers, but they work slightly differently.

SYDEREP (France), public registry run by ADEME. Searchable by name, IDU, stream. Marketplaces query it. Producers register through eco-organisms (Citeo, Refashion, etc.) which submit dossiers to ADEME for IDU issuance.

LUCID (Germany), central register run by ZSVR (Zentrale Stelle Verpackungsregister). Producers must register directly with LUCID first, before contracting with a licensing scheme (Duales System, equivalent of eco-organism). The LUCID number is what marketplaces query.

The architectural difference: in France, the eco-organism is upstream of the registry. In Germany, the LUCID registration is upstream of the licensing scheme.

Who runs the schemes: eco-organisms or licensing schemes?#

In France, each stream has accredited eco-organisms with State-set tariffs:

• Packaging: Citeo (largest), Léko, Adelphe.
• WEEE: Ecosystem, Ecologic.
• Textile: Refashion.
• Furniture: Ecomaison, Valdelia.
• Batteries: Ecosystem (the one we recommend), Batribox.
• Toys: Ecomaison.
• Sports and leisure articles: Ecologic.
• DIY and garden articles: Ecomaison, Valobat, Ecologic.

In Germany, the packaging stream is operated by dual systems (Duale Systeme), historically dominated by Der Grüne Punkt but now competitive with multiple licensors (Belland Vision, EKO-PUNKT, Interseroh+, Reclay, Veolia, Zentek). Each licensor sets its own packaging tariffs; producers can shop between them.

This makes the German packaging market more competitive on price but adds the complexity of choosing the right licensor. France is simpler in that respect, fewer choices, set tariffs.

How do costs compare? (packaging only, indicative)#

For a foreign seller shipping €500,000/year of packaged consumer goods to each country:

Costs are close. Germany tends to win on packaging tariff slightly. On the French side, 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. See our pricing page for how the fee is built.

Who actually checks what?#

Both countries enforce via marketplaces + administrative channels, but with different rhythms.

France runs aggressive marketplace enforcement (Amazon.fr, Cdiscount, ManoMano, Fnac, TikTok Shop) plus periodic ADEME / DGCCRF audits. Listings deactivate within days of detected non-compliance. The administrative penalty grid is steep, Article L. 541-9-5 of the Code de l’environnement, applied after a formal notice from the administration: up to €30,000, plus up to €1,500 for an individual or €7,500 for a company per unit or per tonne of non-compliant product. See our penalties guide.

Germany runs equally aggressive marketplace enforcement (Amazon.de, Otto, eBay, etc.) plus DPRC (Datenbank Produktverantwortliche Registrierungs-Center) checks. Listings deactivate quickly. Administrative penalties under VerpackG can reach €200,000 per breach but are typically applied per producer rather than per SKU.

In practice, marketplace enforcement is the dominant channel in both countries.

What changed on 12 August 2026 with PPWR?#

PPWR (Regulation (EU) 2025/40) has applied directly since 12 August 2026. For the packaging stream, it harmonises minimum requirements across both countries:

• Per-Member-State representative obligation becomes EU law (was already national law in France and Germany). 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.
• Recyclability classes A/B/C phase in from 2030, eventually aligning eco-modulation grids.
• Reusable packaging targets phase in 2027 onwards.

For a seller already French-compliant on packaging and German-compliant on packaging, PPWR adds zero short-term obligation. For a seller shipping packaging to other EU Member States without local representation (Italy, Spain, Belgium, Netherlands), PPWR adds the same obligation in each of those markets. Full detail in our PPWR Article 45 deep dive.

What should cross-border sellers do?#

The pragmatic approach for a non-EU brand shipping to both France and Germany:

• Run separate representatives in each country for the foreseeable future. Quality of execution per market matters more than the appeal of a single contact.
• Choose providers that give a fixed written quote before engagement wherever possible. Both markets have fixed-fee and open-ended providers; a fixed written fee gives you better budget visibility.
• Synchronise 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. German LUCID declarations align with the calendar year. Block every deadline in your compliance calendar.
• Cover PPWR in your other markets. If you ship packaging to Italy, Spain, Belgium or other EU markets where you are not established, PPWR has required a representative there since 12 August 2026.

We act as your authorized representative in France only. For other EU Member States, including Germany, a separate authorized representative established in each country is required, that is outside our scope. Send your situation through our onboarding form and we will return a written quote within one business day.

FAQ#

Can I use the same authorized representative for France and Germany?#

No. France requires a France-established representative; Germany requires a Germany-established one. They are separate legal mandates under separate national EPR laws. Many providers offer EU-wide service bundles that coordinate both, but the underlying mandates are separate and the fees are separate. PPWR Article 45 generalises this per-Member-State rule for packaging from August 2026.

Is German EPR more or less expensive than French EPR?#

For packaging only, Germany tends to be marginally cheaper because the eco-contribution rates are slightly lower and the eco-organism (Der Grüne Punkt and competitors) sets less aggressive bonus-malus. However, France covers more streams (19 official vs roughly 6 in Germany), so a multi-category seller pays more in France in total. For an FBA seller with packaging + WEEE + batteries, France and Germany combined add up to roughly €6,000 to €10,000 per year all-in.

Does VerpackG require a German representative for foreign sellers?#

Since 12 August 2026, Article 45 of the PPWR requires a packaging producer not established in Germany to appoint an authorised representative there; before that date, German packaging law (VerpackG) allowed such a representative but did not require one. Registration is done via the LUCID central register run by ZSVR (Zentrale Stelle Verpackungsregister). 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.

Cross-border? Start with France#

We are a France-established authorized representative. 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. We act as your authorized representative in France only. For other EU Member States, including Germany, a separate authorized representative established in each country is required, that is outside our scope. Request a written quote. French pricing details at /pricing. In German: Bevollmächtigter EPR Frankreich, Verpackungsregistrierung in Frankreich and IDU für Amazon.fr.

Sources & references#

All legal and regulatory claims in this article trace back to the following primary sources (Légifrance, EUR-Lex, ADEME and equivalents). Verified 24 May 2026.

• Article L. 541-9-5 du Code de l’environnement (sanctions REP), Légifrance
• Article L. 541-9-4 du Code de l’environnement (sanction de l’Info-tri), Légifrance
• Loi n° 2020-105 du 10 février 2020 (AGEC), Légifrance
• Regulation (EU) 2025/40 (PPWR), EUR-Lex
• SYDEREP, registre public des producteurs (ADEME)
• Citeo, éco-organisme emballages ménagers
• Léko, éco-organisme emballages (concurrent de Citeo)
• Adelphe, éco-organisme vin, spiritueux, pharma (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
• 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
• VerpackG, Verpackungsgesetz (allemand), Gesetze im Internet
• LUCID, Verpackungsregister (Stiftung Zentrale Stelle Verpackungsregister, Allemagne)
• Cadre général des filières REP, Ministère de la Transition écologique