A UK company with no establishment in France that sells into France must appoint a representative established in France: that has been the law since 10 July 2026, for every EPR stream. Nothing registered in the UK carries over. UK packaging EPR, UK WEEE and UK batteries registrations cover the UK market, and French marketplaces ask for French identifiers.
This guide is for UK brands and manufacturers selling into France through Amazon.fr, Shopify, ManoMano or direct to French businesses. Our country page for UK sellers sums up the same rules in short form.
Does a UK company need a French EPR representative?#
Yes, when it has no establishment in France and 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.
One representative and one written mandate cover all your French streams. Each stream keeps its own eco-organisation membership, its own unique identifier (IDU) and its own declarations.
What did Brexit change, and what did it not?#
Brexit changed the trade and customs position. The UK left the EU on 31 January 2020 and the transition period ended on 31 December 2020: since then, goods shipped from Great Britain to France cross a customs border, and UK and EU product rules develop separately.
For French EPR, the July 2026 law matters more than Brexit. The French test is establishment in France, not EU membership. An Irish, German or Dutch company with no French entity needs a French representative exactly like a UK company. Leaving the EU therefore did not create the French obligation; it simply means that nothing on the UK side can stand in for it.
Need a French EPR representative for your business?
We are EPR France specialists for foreign sellers. Fixed annual fee per stream, from €190/year excl. VAT, confirmed in a written quote within one business day. IDU in days, not weeks.
Do UK registrations cover France?#
No. Each of these is a UK regime with no effect in France:
- UK packaging EPR (pEPR) and the Packaging Recovery Notes system cover packaging placed on the UK market.
- UK WEEE and UK batteries producer registrations cover electrical equipment and batteries placed on the UK market.
- The UK Plastic Packaging Tax is a UK tax on plastic packaging with less than 30% recycled content. It is not an EPR scheme in France or anywhere else.
- UKCA marking concerns product conformity, not end-of-life waste.
- EORI and customs registration concern customs clearance. Keep the company name and identifiers on your French EPR file identical to those on your customs paperwork, so the same producer appears everywhere.
- A French VAT number, including a fiscal representative under Article 289 A of the Code général des impôts, does not create an establishment in France for EPR.
French EPR is satisfied in France, with French eco-organisations, through a representative established in France.
Is selling on Amazon.co.uk enough to trigger French EPR?#
No. Orders on Amazon.co.uk delivered to UK customers are UK sales. Amazon.co.uk and Amazon.fr are separate stores, and French EPR starts when you sell on Amazon.fr, or when any channel delivers your products to a French customer.
On Amazon.fr, a UK seller is checked against the French rules like any other seller. French marketplaces must verify their sellers' registration (Article L. 541-10-9 of the French Environmental Code). If a marketplace takes on the EPR obligation for your products under Article L. 541-10-9 of the French Environmental Code (as Amazon offers to do in France), the obligation is deemed met for those products only, and only while you are not registered yourself. Anything sold outside that scheme, or once you register, remains your obligation.
Who is the producer when a UK brand uses an EU warehouse or a French distributor?#
The seller to the French customer. If your UK company invoices the French customer and is the seller of record, it is the producer for France, even when the parcel leaves a warehouse in the Netherlands, Belgium or Ireland. A 3PL that stores and ships for you never becomes the producer.
The answer changes only when a French buyer takes title: a French distributor or retailer that buys the goods and imports them in its own name is the producer for what it resells. Many UK brands have both flows at once, so the scope is mapped channel by channel.
Which French EPR streams does a UK seller usually trigger?#
It depends on the product mix. A UK fashion brand typically triggers textile (Refashion) and household packaging (Citeo or Léko). A UK electronics seller triggers electrical and electronic equipment (Ecosystem or Ecologic), batteries (Ecosystem or Batribox) and household packaging. A UK home goods brand may add furniture (Ecomaison) or DIY and garden products. A UK industrial exporter selling to French businesses may trigger professional packaging (Citeo Pro, Léko Pro or Twiice), where registration is open now and eco-contributions start on 1 January 2027.
The full list of the 19 French streams is on our services page.
What does the PPWR change for a UK seller?#
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.
The PPWR is an EU Regulation and applies country by country in the EU member states. A UK seller active in France, Germany and Spain therefore needs an authorised representative for packaging in each of those countries, not one for the whole EU. We act in France only, for all French streams; other EU countries need a representative established there. Our PPWR Article 45 guide sets out the article.
What does a UK seller need to do?#
The work breaks down into four steps:
- Stream scoping. List the products you ship to French customers and map them against the 19 French EPR streams.
- Representative appointment. Sign a written mandate with a representative established in France, based on Article L. 541-10-9-1 of the Code de l'environnement, signed electronically, in English or French.
- Registration. We file your membership within two business days of receiving the signed mandate, the first invoice payment and the deposit. The identifier then depends on the eco-organisation: Citeo issues it about seven business days after the membership is validated, Léko about five business days after its initial invoice is paid (payable within five business days, otherwise the membership is cancelled), Refashion after membership, the signed contract and your first declaration and payment, then about ten business days, and Ecosystem after your first declaration has been filed and paid.
- Marketplace and operational update. Add your identifiers to Amazon Seller Central (and ManoMano or Cdiscount as applicable), update your French-facing terms and invoices, and set up the data you will need for the declarations.
What the mandate does: 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. You answer for the accuracy of the data you provide, and declarations, contributions and breaches from before the mandate took effect stay with you.
Does the July 2026 law change an existing UK mandate?#
If you signed a French mandataire contract before July 2026, it was written for a regime that no longer applies to you. The Conseil d'État ruling of 10 November 2023 (case n° 449213, EcoDDS), on which many older templates rely, now only concerns producers established in France.
- Review the contract. If it does not reference Article L. 541-10-9-1, its legal basis is out of date, although it stays valid for its administrative scope.
- Ask for a version that names the article and states which streams and products it covers, and from which date.
- Your identifiers and memberships are not affected: updating the mandate is a file update, not a re-registration.
What does it cost a UK seller?#
Two separate amounts. Our fee is a fixed annual amount per stream, from €190/year excl. VAT, confirmed with the one-time setup and the refundable security deposit in a written quote within one business day: see pricing. The eco-contributions are set by each eco-organisation on its published schedule and your declared volumes; they stay invoiced to you and paid by you directly to the eco-organisation, and we take no percentage on them.
What is the penalty if a UK seller does nothing?#
French administrative fines under Article L. 541-9-5 of the Code de l'environnement (checked on Légifrance on 6 October 2026): up to EUR 7,500 per unit or tonne for a legal entity, and up to EUR 30,000 for failing to register or to obtain an identifier. On marketplaces, a missing French identifier blocks the listing, which usually bites first.
Frequently asked questions#
Does a UK company need a French representative to sell into France?#
Yes, if it has 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. A UK company selling on Amazon.fr, from its own store or to French buyers that do not import the goods is in that position.
Does UK packaging EPR, UK WEEE or the UK Plastic Packaging Tax satisfy any French obligation?#
No. UK packaging EPR (pEPR), the UK WEEE and batteries regimes and the UK Plastic Packaging Tax cover the UK market only and have no equivalence under French law. French EPR is satisfied separately, through memberships with French eco-organisations and, since 10 July 2026, a representative established in France.
Does a French VAT number make a UK company established in France?#
No. A French VAT registration, or a fiscal representative appointed for VAT, does not create an establishment in France for EPR purposes. The UK company still needs a representative established in France. VAT and EPR are separate regimes, and we handle EPR only.
Does opening a Dutch or Irish subsidiary remove a UK seller's need for a French representative?#
No, unless that subsidiary is French. The French criterion is establishment in France, not EU membership, so a Dutch or Irish entity with no French establishment still needs a representative established in France under Article L. 541-10-9-1. Only a French entity that itself places the products on the market removes the representative requirement.
My French mandataire contract predates July 2026. Is it still valid for a UK seller?#
It remains valid for its administrative scope, but it was written for an earlier regime. A UK seller should ask for a contract that names Article L. 541-10-9-1 of the French Environmental Code and states the streams, products and start date it covers.
How fast can a UK seller get its French identifiers?#
We file your membership within two business days of receiving the signed mandate, the first invoice payment and the deposit. The identifier then depends on the eco-organisation: Citeo issues it about seven business days after the membership is validated, Léko about five business days after its initial invoice is paid (payable within five business days, otherwise the membership is cancelled), Refashion after membership, the signed contract and your first declaration and payment, then about ten business days, and Ecosystem after your first declaration has been filed and paid.
Next step#
Request a written quote: send your product list and channels, receive a fixed written quote within one business day, sign the mandate. We work in writing, in English or French. If you are unsure whether you need an EPR representative or a product-compliance representative, see EPR representative or EU authorised representative.
Sources & references#
All legal and regulatory claims in this article trace back to the following primary sources (Légifrance, EUR-Lex, ADEME and equivalents). Verified 31 July 2026; penalties checked 6 October 2026.
- Loi n° 2026-602 du 8 juillet 2026, article 5, 2°, creating Article L. 541-10-9-1 du Code de l’environnement (JO of 9 July 2026), Légifrance, in force 10 July 2026. Mandatory representative for producers not established in France.
- Article L. 541-9-5 du Code de l’environnement (sanctions REP), Légifrance
- Loi n° 2020-105 du 10 février 2020 (AGEC), Légifrance
- Conseil d’État, 10 novembre 2023, n° 449213 (EcoDDS), Actu-Environnement
- Regulation (EU) 2025/40 (PPWR), EUR-Lex
- SYDEREP, registre public des producteurs (ADEME)
- Citeo, éco-organisme emballages ménagers
- Léko, éco-organisme emballages
- Ecosystem, éco-organisme DEEE
- Ecologic, éco-organisme DEEE
- Refashion, éco-organisme textile, linge, chaussures (TLC)
- Ecomaison, éco-organisme meuble, jouets, bricolage et jardin
- Batribox, éco-organisme piles et accumulateurs
- ADEME, Agence de la transition écologique
- Amazon EU Seller Central, EPR France requirements
- Cadre général des filières REP, Ministère de la Transition écologique
Ready to start your French EPR registration?
Three-minute application form. Written quote within one business day. IDU in days, not weeks.