Printed Graphic Paper: When Do Catalogs and Manuals Require EPR Registration?

The graphic paper EPR stream is the least known of the major French EPR streams, and the most overlooked by non-EU producers. It covers printed catalogs, magazines, advertising mailings and free-standing brochures distributed in France. Like every other EPR stream, it is in scope for any producer placing such material on the French market.

What the stream covers

Graphic paper EPR applies to printed paper products distributed in France:

• Catalogs: product catalogs mailed to consumers or distributed at retail.
• Magazines: editorial publications, brand magazines.
• Advertising mailings: direct-mail flyers, promotional inserts.
• Free-standing brochures: trade-show takeaways, product brochures distributed separately from the product.
• Telephone directories: where still produced.

What is not in scope: printed material that is integral to a product (instruction manuals shipped inside the box, warranty cards, ingredient labels). These are treated as packaging components.

Why non-EU brands hit this stream

Three common patterns:

Trade-show distribution. A non-EU brand exhibits at a French trade show and distributes branded catalogs. Catalogs left in France are in scope.

Direct-mail campaigns. Mailing printed flyers to French consumer addresses (sourced from a French database or supplied by a local partner) places printed material on the French market.

Brand magazines. Issuing a printed brand magazine to French subscribers or distributing it via retailers.

For typical non-EU D2C brands, the volumes are modest and the eco-contribution is small. The registration itself is the operational obligation.

Who operates the stream

The graphic paper stream is operated by Citeo and Léko (the same eco-organisms that operate the household packaging stream). Most non-EU producers who already file Citeo for packaging can extend the same dossier to cover graphic paper — administratively cleaner than splitting between providers.

Filing and cost

Same flow as other streams:

1. Authorized representative engaged.
2. Declared graphic paper volume estimated (kilograms distributed annually in France).
3. Dossier filed with Citeo or Léko (extension of existing packaging dossier).
4. IDU issued, published to SYDEREP within 2-3 weeks.

Cost for an extension to an existing packaging dossier:

• Representative fee: €249/month for the additional stream (€2,988/year billed annually in advance — see /pricing).
• Eco-organism membership: typically bundled into the existing packaging membership.
• Eco-contribution: €0.05-€0.10 per kg of graphic paper distributed. Modest for typical volumes.

Common operational issues

Confusing graphic paper with packaging. The boxes you ship products in are packaging. The catalog you mail separately is graphic paper. Different stream, different declaration.

Missing trade-show takeaways. Brands sometimes track marketing print spend but not destination geography. Trade-show distributions in France should be tracked separately for the declaration.

Treating manuals as graphic paper. Manuals shipped inside the product packaging are typically considered packaging components, not graphic paper. Verify with your representative for borderline cases.

FAQ

Does the printed manual that ships with my product count?

Generally no, if it is integral to the product (installation guide, warranty card). It is treated as part of the product packaging. Free-standing printed material distributed separately (catalogs mailed to consumers, brochures, flyers) is in scope under the graphic paper stream.

What about printed material distributed at trade shows in France?

Yes, in scope. Brochures, catalogs and printed material left at French trade shows are placed on the French market and trigger graphic paper EPR. Trade-show takeaways are one of the more common producer situations where the graphic paper stream applies to non-EU exporters.

How big is the eco-contribution for graphic paper?

Modest. Eco-contribution for graphic paper is typically €0.05-€0.10 per kilogram, far lower than plastic-based packaging. For a producer distributing 1,000 kg of catalogs to France annually, the contribution is around €60-€100. The registration matters more than the contribution amount.

Add graphic paper to your existing packaging mandate

If you already have a packaging file in place, extending to graphic paper is straightforward. Flat €249/month for the additional stream — /pricing. Send your annual print volume estimate to /contact for a written quote in 24 hours.