Navigating French EPR for Swiss, Norwegian, and Non-EU European Companies

A Swiss, Norwegian, Icelandic or Liechtenstein company with no establishment in France must appoint a representative established in France to sell products subject to EPR into France. EFTA membership, the European Economic Area and the EU-Swiss bilateral agreements do not change that: French law asks one question, whether the producer is established in France.

Who has to appoint a French representative?#

Any producer not established in France that places products subject to EPR on the French market. 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 rule draws one line, between producers established in France and all others. A Swiss or Norwegian company sits on the same side of that line as a German, American or Japanese one. One representative and one written mandate cover all of a producer's French streams.

Does Swiss status change anything?#

No. Switzerland is a member of EFTA but not of the EU or the EEA, and its relations with the EU rest on bilateral agreements. None of them makes a Swiss company established in France.

A Swiss company selling to French consumers from a Swiss website or warehouse is the producer for France: the order is placed in Switzerland and the parcel clears customs at the border, but the product is placed on the French market by the Swiss seller. Only when a French buyer imports the goods and takes title before resale does the French buyer become the producer.

Swiss recycling-fee systems, for example for electrical equipment or batteries, cover products sold in Switzerland. They have no effect in France. Our page for Swiss companies sums up the Swiss case.

Does EEA membership change anything for Norway, Iceland and Liechtenstein?#

No. Norway, Iceland and Liechtenstein are in the EEA with the 27 EU member states, which gives them access to the single market. EPR, however, is organised country by country: each country runs its own schemes, with its own eco-organisations and identifiers. A Norwegian company with no French entity is a producer not established in France, and its Norwegian scheme memberships cover Norway only.

What about the United Kingdom?#

The UK is neither in the EU nor in EFTA, and the French test applies in the same way: a UK company with no French establishment needs a representative established in France. Our guide for UK sellers covers UK packaging EPR, Amazon.co.uk and Amazon.fr, and PPWR Article 45.

Which streams do Swiss and Norwegian producers usually trigger?#

It follows the products, not the country. Typical profiles (illustrative):

• A Swiss watch brand selling to French consumers from its own website. Household packaging for boxes and mailers; electrical and electronic equipment and batteries for connected models.
• A Norwegian outdoor apparel brand selling to French customers. Household packaging, and textile (Refashion) for clothing and shoes.
• A Swiss instrument maker selling to French laboratories. Professional electrical and electronic equipment, and professional packaging (Citeo Pro, Léko Pro or Twiice), where registration is open now and eco-contributions start on 1 January 2027.
• A Norwegian food brand selling packaged products to French consumers. Household packaging (Citeo or Léko).

In each case the cost is the same structure: a fixed annual fee per stream in a written quote, plus the eco-contributions set by each eco-organisation on its published schedule.

How does registration work?#

1. Sign a written mandate with a representative established in France.
2. We file a membership with the eco-organisation of each applicable stream.
3. Each eco-organisation issues an identifier (IDU) per stream. 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. Add the identifiers to French marketplaces and give them to French business customers that ask for them.
5. File the 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.

EFTA or EEA status makes no difference to this sequence.

What does PPWR Article 45 add?#

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.

For a Swiss or Norwegian producer selling packaged goods in several EU countries, that means one authorised representative per EU member state where it makes packaging available, not one for the whole EU. We act in France only, for all French streams. See our PPWR Article 45 guide.

Frequently asked questions#

Do Swiss and Norwegian companies need a French representative to sell into France?#

Yes, when they have no establishment in France. Since 10 July 2026, Article L. 541-10-9-1 of the French Environmental Code requires any producer not established in France and subject to EPR to appoint a representative established in France, for every stream. Membership of EFTA or the EEA, or the EU-Swiss bilateral agreements, change nothing: the only test is establishment in France.

Switzerland has bilateral agreements with the EU. Does that exempt a Swiss producer from French EPR?#

No. Switzerland is in EFTA but not in the EU or the EEA, and its bilateral agreements with the EU do not create an establishment in France. A Swiss company with no French entity that sells to French customers is the producer for France and needs a representative established in France.

Norway is in the EEA. Does EEA membership help with French EPR?#

No. EEA membership gives Norway, Iceland and Liechtenstein access to the single market, but French EPR asks whether the producer is established in France. A Norwegian company with no French entity needs a representative established in France, like any other producer outside France, and its Norwegian scheme memberships cover Norway only.

Does PPWR Article 45 apply to Swiss and Norwegian producers selling into the EU?#

For each EU member state where they make packaging available without being established there, yes. Since 12 August 2026, Article 45 of Regulation (EU) 2025/40 requires such a producer to appoint an authorised representative for extended producer responsibility in that member state. A Swiss producer selling in France and Germany needs one in each.

What does French EPR cost a Swiss or Norwegian company?#

Two separate amounts. Our fee is a fixed annual amount per stream, stated with the one-time setup and the refundable deposit in a written quote within one business day. The eco-contributions are set by each eco-organisation on its published schedule and your declared volumes, and stay invoiced to you and paid by you directly to the eco-organisation.

Getting set up#

Send your product list and channels through our onboarding form and receive a fixed written quote within one business day. We work in writing, in English or French. Our fee starts from €190/year excl. VAT per stream; see pricing.

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; legal basis updated for law n° 2026-602.

• Article L. 541-10 du Code de l’environnement (cadre général REP), Légifrance
• Loi n° 2026-602 du 8 juillet 2026 (article L. 541-10-9-1 du Code de l’environnement), Légifrance
• Loi n° 2020-105 du 10 février 2020 (AGEC), Légifrance
• Regulation (EU) 2025/40 (PPWR), EUR-Lex
• SYDEREP, registre public des producteurs (ADEME)
• Cadre général des filières REP, Ministère de la Transition écologique